The NAB has entered the FCC’s ongoing competition proceeding with a data-heavy argument for structural reform and a warning that “the competitive viability of many local broadcast stations is now in peril” in a marketplace now ruled by unregulated Big Tech.
NAB’s comments were submitted ahead of the FCC’s biennial Competition in the Marketplace report to Congress.
The filing marshals data from Edison Research, BIA Advisory Services, and Borrell Associates to make the case. Edison’s Q4 2025 Share of Ear survey, cited in the filing, shows AM/FM radio’s share of all audio listening time dropped from 53% in 2014 to 32% by the end of last year. Among listeners ages 13 to 34, AM/FM now accounts for only 19% of listening time.
The in-car dashboard, long radio’s most defensible ground, is giving way on the same trajectory.
The filing notes that 41% of in-car listening time now goes to streaming, SiriusXM, YouTube, and podcasts combined. Among drivers with Apple CarPlay or Android Auto in their primary vehicle, AM/FM captures only 47% of in-car listening time, compared to 62% among those without either system.
The revenue picture is equally stark, as BIA data in the filing shows radio stations’ total ad revenue fell 30.1% between 2007 and 2025 on a nominal basis. Borrell’s 2026 annual report projects local digital advertising will account for 76% of all local ad spending by 2029, with roughly 84% of that digital spend flowing to “fierce and formidable” players like Google, Meta, and national listing platforms rather than to local broadcasters.
Current caps, NAB argues, prevent broadcasters from achieving the scale economies available to every major competitor, driving up per-station costs and accelerating revenue decline. A 2019 BIA study cited in the filing modeled cash flow benefits from combinations currently blocked by local radio caps and found the gains would be largest in small markets, where fixed operating costs are hardest to cover.
The filing also renews NAB’s push to expedite the ATSC 3.0 transition and cites the Broadcast Positioning System’s national security applications as additional grounds for relief, arguing that broadcasters face multi-year FCC approval processes for technology upgrades that wireless carriers implement without Commission permission.
