Subj: Peer Review of Fcc Media Ownership Study (#3)

The study examines the effect of several television ownership attributes on the fraction of prime-time broadcast television minutes devoted to different programming types, as well as the effect of these ownership attributes on prime-time broadcast advertising minutes and rates. Overall, the study considers an interesting question with appropriate data and methods and should ultimately prove useful for policy purposes. I have three general comments related to the robustness of analytic results, the relationship between empirical estimates and conclusions, and theoretical assumptions about advertising. I outline my general comments below, following the guidelines described in your memo. I also attach a list of specific comments designed to improve the clarity and accuracy of the study.