When considering what to discuss in this column, I’m inclined to occasionally pontificate. You may not agree with my thoughts and that’s fine, but sometimes, we should consider issues that aren’t often discussed. There are “hidden corners” of the audience measurement world, and Nielsen, that most people don’t know (and perhaps don’t care), but I find them interesting.
Last June, I wrote a column taking Nielsen corporate to task for some of their pronouncements on LinkedIn (and perhaps elsewhere) with respect to whether certain identity groups were properly represented in media. My purpose wasn’t to take a stand for or against the viewpoint, but rather to point out that Nielsen is the impartial arbiter of audience size and composition and the “inclusion role” should belong to others. I don’t know if anyone at Nielsen cares about my views, but recent Nielsen pieces in LinkedIn focus on the company’s areas of expertise (who’s watching, streaming use, etc.).
Within Nielsen Audio, there is a policy with a similar bend that bothers me and seems unfair. Back in the “old days” (sorry, but we must start somewhere), Arbitron used to list all commercial radio stations that made MRS (Minimum Reporting Standards) regardless of their subscriber status. Non-commercial stations were not reported “in the book” but could be found in Maximi$er (remember that software?) and third-party software packages.
When PPM debuted, non-commercial stations were added to “the book” and this extended to the diary service as well over time. All well and good.
Like any company, Arbitron/Nielsen was always looking for more revenue and there was a reasonable perception that non-subscribing stations were getting a “free ride”. Their estimates appeared everywhere, agencies could easily buy them, but you could take the position that their success was being subsidized by subscribing companies. Of course, if any of the non-subscribing stations tried to use the data and were caught, the penalties for “piracy” (copyright infringement in this case) were and continue to be severe.
In late 2020, Nielsen Audio announced that effective with the January 2021 reports, stations owned by Black, Hispanic, female-owned, etc. and non-profit stations would be listed if they have at least one mention (PPM or diary). Here’s the actual policy taken from the Spring 2024 Nielsen Audio Description of Methodology:
‘Exempt’ Stations
An AM or FM radio station that is a minority-owned small business may request ‘exempt’ station status. Exempt stations are also eligible to be reported in the Summary Data set. To qualify for an exemption, the broadcaster must:
• Attest to African-American, Asian-American, Hispanic, or Native-American on the station’s FCC biennial ownership report (i.e., FCC Form 323); and
• On that same form, attest that the station’s minority owner has a voting / equity stake of at least 50.1%; and
• The total gross revenue for all stations owned by the broadcaster making the request is no more than 10 million USD from all sources (according to BIA for the most recent available reporting year).
An AM or FM radio station that is a female-owned small business may request ‘exempt’ station status. Exempt stations are also eligible to be reported in the Summary Data set. To qualify for an exemption:
• The total gross revenue for all stations owned by the broadcaster making the request is no more than 10 million USD from all sources (according to BIA for the most recent available reporting year).
• Attest to 51% Female ownership on the station’s FCC biennial ownership report (i.e., FCC Form 323), and
• Be at least 51% controlled by women and have women manage day-to-day operations who also make long-term decisions.
o Broadcasters may satisfy the third eligibility criteria by either: (i) obtaining certification (free) as a WOSB under the SBA program; or (ii) submitting a written statement to Nielsen certifying that such station is “at least 51% controlled by women with women managing the day-to-day operations who also make long-term decisions” signed by the broadcaster’s Chief Legal Officer or Chief Financial Officer. If the latter option is chosen, Nielsen may publish such station’s ratings with a notation that such station has self-certified that it meets the WOSB’ requirements that women control and manage such station.
o Nielsen reserves the right to deny or revoke a reporting exemption in any instance where the broadcaster has violated our rating distortion guidelines, falsely represented itself in self-certification, or has otherwise not acted in good faith in matters relating to this policy.
Non-profit 501(c)(3) tax exempt radio stations are also eligible to be classified as exempt.
The reporting policy exemption is not available to any station with a foreign ownership stake greater than 49.0% as declared on FCC Form 323. In this context, ‘Foreign’ indicates a person that is not a US Citizen, Permanent Resident, or DACA recipient. The final decision on whether to grant a particular broadcaster a reporting exemption lies solely with Nielsen.
A reporting policy exemption is void should the broadcaster sell, transfer, or otherwise divest the station or if the status of the station’s ownership or Nielsen policy changes so that the station no longer qualifies for the exemption.
Did you fully comprehend that policy? Did it make any sense to you? Further, does it feel “right?”
Unlike the policy, my take is simple. Why discriminate by identity groups? Radio in 2024, especially for small operators whatever their race, gender, ethnicity, or other background, is a tough business. The big companies pay for and can (more or less) afford Nielsen’s charges. Nielsen should devise a simple formula that says small owners or those with just a few stations that have revenue below a specific threshold will be included in the summary data set, assuming they have any listening occasions. Any large or medium sized broadcaster that wants to avoid paying for Nielsen services will still face exclusion but will do so by choice.
The policy’s “exempt status” doesn’t mean that you get data access. Stations that meet the current policy threshold or my proposed revision still have the option to work out a deal with Nielsen for access if they see value in the data. Regardless, while the current policy doesn’t change how Nielsen measures the radio/audio audience, it has the patina of putting a “thumb on the scale” in terms of which ownerships Nielsen favors. As the neutral reporter, Nielsen should change or scrap this policy now.
Let’s meet again next week.
