By Placing Its Thumb on the Scale of Competition, the Commission by This
....@-- by placing its thumb on the scale of competition, the Commission by this Rule has distorted and restricted competition in other ways affecting pro gram producers, syndicators, independent stations, new networks, and network affiliates. The Rule has come to be seen largely as a measure to promote the fortunes of independent and UHF stations. The evidence shows that today many independent stations are more profitable than affiliates. Further, UHF affil iates of ABC, CBS and NBC are victims of the Rule, yet on average are fi nancially weaker than UHF independents, intended beneficiaries of the Rule. Furthermore, any "handicapII affecting independent UHF stations in the past has been reduced or eliminated, due to forces other than PTAR. The economic costs, penalties, restrictions and consumer harms caused by PTAR cannot be justified by an increase in diversity, because PTAR has not increased diversity. The number of outlets for local broadcast programming is unchanged by the Rule. The number of sources of programming avail able to those outlets is reduced by the terms of the Rule. There is no basis to believe that the Rule enhances the diversity of prime-time broadcast program content (or the variety of viewpoints), and there are some reasons to believe that diversity has been reduced. In any event, the flowering of new media alternatives makes irrelevant whatever marginal change in broadcast network affiliate content diversity, if any, can be attributed to the Rule. ECONOMISTS INCORPORATED - 65- Appendix A Data tables Table A-I
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