ACA on Double TV Station Reach Discount: It's Doubly Wrong

The American Cable Association, which represents small and midsized cable operators, has a response to broadcasters' proposals to double their audience reach: No way. The ACA told the Federal Communications Commission that the proposal is both ill-conceived and unlawful. The National Association of Broadcasters wants the FCC to extend the UHF discount to VHF stations, which means all broadcast groups could effectively double their audience reach cap from 39% to 78% of the national audience. Affiliate associations want the same thing, except they want to maintain the 39% limit for network-owned stations. "Both proposals for an 'Everybody Discount' are ill-conceived as a matter of policy and impermissible as a matter of law," the ACA told the FCC. As ACA points out, doubling the discount is equivalent to raising the cap, a solution broadcasters "presumably seek only because significant questions remain as to the Commission’s authority to raise or eliminate the cap itself."