STATEMENT OF
COMMISSIONER ROBERT M. McDOWELL
Re: Promoting Diversification of Ownership in the Broadcasting Services, MB Docket No. 07-294.
Over the years, an array of groups from across the political spectrum have criticized the 
Commission’s systems and methodologies for collecting and maintaining broadcast ownership data.  
Debates over policy, and the important subsequent decisions that often emerge, should be firmly 
grounded not only in law but in solid facts as well.  Rendering rules on an unsure factual foundation is 
akin to building a house on quicksand.  Today, the FCC attempts to improve our fact-gathering as we 
pursue our obligation to improve our understanding of diversity of ownership in the traditional media 
marketplace.  As the expert government agency, we should provide both policymakers and the public 
with station ownership statistics that are more precise and reliable.  
I look forward to receiving comment on proposals to make our data more comprehensive as well, 
including recommended approaches to account for ownership of noncommercial stations, which have 
considerable variation in their licensees’ organizational structures.
What today’s action does not do, however, is change our existing broadcast attribution rules.  To 
do so now, in the midst of such economic uncertainty, would be foolhardy.  As I continue to advocate for 
a regulatory environment that is more attractive to private investment, I am interested in hearing from 
commenters as to whether the changes to Form 323 would impose any inadvertent negative effects.  
In sum, although I do not entirely agree with every word in the item, I support this action and I 
look forward to reviewing the information that it will yield.