Last July, commercial broadcasters jumped through hoops to file the new biennial ownership reports (the Form 323) with the Federal Communications Commission.  Now the FCC has published the results of the information collected in those reports.  The public may review the ownership information for broadcasters based on ownership structure, ownership relationships, ownership interests, ownership groups and other categories in downloadable files. 

The ownership reports filed last July (reporting broadcast ownership as of November 1, 2009) are the first in a series of “snapshots” of broadcast ownership data.  The new reports break down the ownership information into categories to provide for analysis on many levels.  With ownership reports to be filed biennially and by the same date, the FCC hopes to provide a reliable basis for analyzing ownership trends in the broadcast industry, including ownership by minorities and females. 

The problem with this approach is the FCC’s collection of ownership information is incomplete.  The FCC is not collecting the same ownership information for noncommercial stations and low power FM stations. The most recent broadcast totals indicate that 22.83% of the full power broadcast and LPFM stations are noncommercial.  These stations were not included in the broadcast information filed with the FCC last July.  A further 11.65% of the full power broadcast stations did not file ownership reports last July.  Eliminating these categories of stations from any ownership analysis removes a substantial number of stations from consideration, thereby all but guaranteeing that any analysis will be flawed. 

The FCC has pending a proceeding to consider similar collection of ownership data for noncommercial broadcast stations.  Until the noncommercial stations and the commercial stations that did not file ownership reports last July are included in any snapshot of the ownership makeup of the broadcast industry, any analysis will be of no use to the FCC in moving forward with any changes in media ownership involving underrepresented groups.