Sunday, April 01, 2007

C3SR - Have They Sought Your Opinion?

April 1, 2007

Here is how C3SR describes themselves:

"To counter the potentially dim prospects facing subscribers of satellite radio under a monopoly provider, a group of concerned Sirius and XM subscribers have formed the Consumer Coalition for Competition in Satellite Radio ("C3SR"). Through the participation and support of subscribers and volunteers, C3SR -the only consumer group in existence today solely dedicated to advocating on behalf of satellite radio subscribers- is committed to opposing the creation of a monopoly in satellite radio, and ensure continued consumer choice and competition."

This begs a few questions:

1. C3SR has had this same self description since their first day of operation. How is it that they can claim to advocate on behalf of consumers when they seem to have a preconceived agenda of fighting the merger?

2. C3SR offers nothing regarding their platform in what they see as the desires of the satellite radio consumer. Where is the data that suggests that consumers are against a merger?

3. How large is this "group of concerned Sirius and XM subscribers"? Can other people join? Do other people get to voice their opinions? Does C3SR use the voice of the people? How many consumers did C3SR get the opinion of prior to selecting the anti-merger platform?

4. If an organization was an advocate for satellite radio consumers, shouldn't they have contingency plans in place? What is the platform of C3SR if a merger is approved? Wouldn't it be wise to express the consumers desires to Sirius and XM prior to a merger decision being made?

5. Why were funds spent on the Criterion Economics report, authored by Sidak, instead of conducting a survey to find out the sentiments of subscribers?

6. If a survey were to be conducted that shows a majority of subscribers were to be in favor of the merger, would C3SR change policy to reflect that?

To be clear, I think representing consumer concerns is a noble task, so long as it is the consumer concerns that are being addressed. I have yet to see anything from C3SR to illustrate that they are indeed advocating on behalf of the consumer. What I have seen is that the National Association of Broadcasters supports C3SR. I have yet to see C3SR identify how strong their membership is, and how many consumers have joined the group.

If you have been surveyed for your opinion by C3SR please comment to this article

Labels: c3sr

4/01/2007 10:09:00 AM

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Friday, March 30, 2007

C3SR And Satellite Radio Consumers Survey

March 30, 2007

Labels: c3sr, merger, satcos survey

3/30/2007 10:52:00 AM

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Sidak - 23,000 Hours of Content

March 30, 2007

More for the C3SR file.

In his Criterion Economics report Sidak states the following:

"In 2006, Sirius announced it's acquisition of the rights to 23,000 hours of Stern programming, which it intends to air unedited"

Mr. Sidak........Why did you neglect to tell where that programming was from? Why did you neglect to state that the VAST MAJORITY of that programming could air on terrestrial radio TODAY. The fact is that that 23,000 hours of programming represents the terrestrial radio days of Howard Stern. Do these facts not suit your stance?

Today some of that content was on the air, and there was nothing in that show that couldn't have been broadcast on terrestrial radio.

The facts are this. Terrestrial radio could not air the content without the consent of Stern. Stern was not going to allow that to happen, considering that he was being sued by CBS at the time. Sirius bought the rights to the content for $2,000,000. CBS could have stuck to their guns had they found the content so compelling. They did not, and sold their rights for $2,000,000.

Labels: c3sr, criterion economics, sidak, stern

3/30/2007 10:15:00 AM

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Sidak Makes Yet Another Blunder

March 30, 2007

Mr. Sidak, the author of the Criterion Economics (supported by C3SR and the NAB)report against the Sirius and XM merger makes yet another error.

In the report Sidak states:

"Playboy radio, which requires subscribers to opt-in, reportedly drew 1,000,000 customers to Sirius over a three month period."

Mr. Sidak......once again I guess you need to be corrected. Perhaps you are unaware, and did not do the research, or perhaps you are simply trying to be misleading, but here are the facts:

1. Playboy radio did not draw 1,000,000 customers to Sirius. The bulk of those that opted-in were ALREADY subscribers to Sirius. If that was the case, we would already have a Penthouse channel, a Hustler channel, etc.

2. The opt-in is FREE. Consumers tend to take anything that is given to them free. By example, I opted into the FREE Playboy Radio channel. I have listened to the stream for about 15 to 30 minutes when it first launched, and have not tuned in since.

3. There are perhaps a few people who cite specifically Playboy Radio as their reason for subscribing, but I would venture to say that the number is very small. In fact, most studies indicate that consumers cite commercial free music as their reason for subscribing......IMAGINE THAT

Mr. Sidak.....are we having fun yet?????

Labels: c3sr, criterion report, merger, sidak

3/30/2007 10:03:00 AM

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C3SR Criterion Report - Opie and Anthony

March 30, 2007

Wow, the Criterion Economics report is a goldmine for debate. Sidak, the author of the report, seems to have holes in nearly every page.

we all know that there are two sides to every debate, and I am not professing that my viewpoint is the final solution. I am simply pointing out other factors that those reading the report should consider.

In yet another section of the report Sidak states:

"Broadcast radio has also faced sizable fines as recently as April 8, 2004, including a $495,000 NAL against Clear Channel Communications for an episode of the Howard stern Show, a $755,000 NAL against Clear Channel for a broadcast by radio host "Bubba The Love Sponge", and $357,000 in liability against Infinity Broadcasting for an episode of the Opie and Anthony Show. Notably, all of these controversial radio hosts are now offered on satellite radio"

SSG Comments:

Mr. Sidak........please correct me if I am wrong, but isn't Opie and Anthony available of terrestrial radio????? I could swear that I have heard that duo on Boston radio station WBCN. In fact Mr. Sidak, you have offices in Cambridge Massachusetts, so perhaps you have heard them. They were on the air this morning in fact. I also have seen WBC Billboards featuring this duo on FM radio stations. HMMMMMM. You have an office in Washington if I am not mistaken......Seems they are on terrestrial radio there as well. In case you missed it Mr. Sidak, here is a list of terrestrial radio stations offering Opie and Anthony:

New York City: 92.3 FreeFM WFNY (online stream available)
Philadelphia: 94.1 FreeFM WYSP (online stream available)
Dallas: 105.3 FM KLLI (online stream available)
Boston: 104.1 FM WBCN
Pittsburgh: 93.7 FM WRKZ
Cleveland: 92.3 Fm WXRK (show airs from 3pm - 6pm)
West Palm Beach: 103.1 FM WPBZ
Detroit: 97.1 FreeFM WKRK (show airs from 6am - 9am)
Columbus: 107.1 FM WAZU (show airs from 3pm - 6pm)
Rochester: 94.1 FM WZNE (show airs from 2pm - 5pm)
Washington, DC: 106.7 FreeFM WJFK (show airs from 10am - 1pm)
Chicago, IL - 105.9 Free FM WCKG (online stream available)
San Francisco, CA - 106.9 Free FM KIFR (show airs from 10am - 1pm) (online stream available)
Providence, RI - WSKO 790 AM and 99.7 FM
New London, CT - WMOS 104.7 FM
Grand Rapids, MI - WKLQ 107.3 FM
Albuquerque, NM - KBZU 96.3 FM (show airs from 4pm - 7pm)
Portland, ME - WCYY 93.9FM & 94.3FM
Buffalo, NY - WEDG 103.3 FM
Baton Rouge, LA - KRDJ 93.7 FM
Tucson, AZ - 107.5 FM KHYT (online stream available)
Cape Cod, MA - 102.9 FM WPXC Pixy 103
Las Vegas, NV - 107.5 FM KXTE XTXREME ROCK RADIO (show airs from 10am - 1pm)
Flint, MI - 1330 AM WTRX Sports Xtra (show airs from 6am - 9am)
Syracuse, NY - 95.7 FM WAQX 95X (online stream available)

Wow, that is an impressive listing. So the question is this......Are Opie and Anthony indecent, and therefore excluded from terrestrial radio, or are they able to broadcast over the air in all of these markets? I know the answer.....The question is whether you know the answer.

Mr. Sidak, Please forgive my obvious sarcasm, but frankly I tend to get sarcastic when I am being fed a line of BS.

Labels: c3sr, criterion report, merger, sidak

3/30/2007 09:32:00 AM

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C3SR Criterion Report - Mores Holes Exposed

March 30, 2007

More on the C3SR/NAB sponsored Criterion Economics report.

In the report, authored by Sidak, he states:

"As I demonstrate below, the marquee content offered by SDARS is generally prohibited on broadcast terrestrial radio due to indecency standards. The demand for indecent content is widely considered to be inelastic. For example, evidence indicates the demand for adult oriented content is highly price inelastic. Pay-Per-View adult entertainment on cable systems, for instance, garners some of the highest profit margins of any programming. Some analysts claim the margins for cable or direct broadcast satellite operators of up to 80% on each purchase. Other studies show price inelastic demand for indecent content on the internet. This inelastic demand means that most current consumers of indecent content are "inframarginal" consumers who will tolerate a price increase. Although such content may compete weakly against playboy magazine and other indecent content consumed in the privacy of one's home, indecent content over radio is distinguishable because it can be consumed in the car, while driving, and in remote geographical locations."

SSG Comments:

Nice outline of your point, but are you neglecting to remember that consumers have access to a wide variety of content delivery systems????? Did you forget about I-Pods, MP3 Players and CD's? What you term as indecent content can be delivered via those methods as well. Why did you leave these important categories out of your report in this section? Is it that you are slanting this report to terrestrial radio and failing to consider the other competition that consumers have access to?

How does the profit margin of Pay-Per-View television equate to the current model of satellite radio? Do you really want us to believe that if Sirius charged $2.00 for Howard Stern that $1.60 of that money would translate to the bottom line for Sirius????? Come now Mr. Sidak....surely you know the cost of the Howard Stern deal.

Ever see a George Carlin CD? Ever see other CD with warning labels on them? Can those CD's with indecent content be played in the car? Ever see the kinds of programming that can be downloaded to an I-Pod? Do you want us to believe that out of the 90,000,000 I-Pods sold that no one is using them in their car?

Another note......Local content. Why is it that your clients want terrestrial radio to have the monopoly on local content??????? Does that provide an advantage to terrestrial radio?

Mr. Sidak.......your report is generating many questions. Surely someone with your experience and background can provide answers.

Labels: c3sr, criterion report, sidak

3/30/2007 09:07:00 AM

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Thursday, March 29, 2007

Sidak Research Incomplete On Conversion Rates

March 29, 2007

The more I read this Criterion Economics report the more I find holes in it. This one report alone is 91 pages, and the number of inaccuracies will provide for a long series of articles tied to this subject.

In yet another section of the report, Sidak states:

"In addition to low churn rates another indication for inelastic demand for SDARS is the high conversion rate. The conversion rate is defined as the percentage of customers who sign a contract with an SDARS provider after sampling the service for three months free of charge. During 2003 XM was able able to convert nearly three quarters of all customers who were on a three month free trial. During 2004 through 2005, the conversion rate decreased to 60 percent, yet was still impressive. The high conversion rate suggests that SDARS customers would not substitute toward another radio service in response to a small price increase for SDARS"

Mr. Sidak........where is the most current conversion rate data????? Was that data missing or just conveniently omitted from the report??????

2003 conversion was reported at a bit over 70%. What you fail to state is that subsequent to that report XM corrected several parts of their billing system and weeded out bad accounts and people receiving free service beyond the three month period. It was then that the rate dropped to 60%......then 55%.....and the LATEST DATA is at about 52%.

Yes a 52% take rate is decent. However, consider the amount of money invested into those consumers. This is money that the terrestrial radio stations need not invest.

I apologize, but I must ask again......WHAT IS THE REASON YOU NEGLECTED TO PROVIDE THE LATEST DATA????????

Labels: c3sr, criterion economics, merger

3/29/2007 09:32:00 PM

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Comments on Criterion Report Part 3

March 29, 2006

Comments on the study conducted by Criterion Economics against the merger.

SSG is looking over the study conducted by Criterion Economics and commenting on various aspects of the study. Bear in mind that we are not professional economists, but we can offer insight and opinion that we feel the author of the report has overlooked. This analysis will happen over a series of articles.

Article series links below:

Article #1 - Comments on The Criterion Report

Article #2 - CS3R and NAB

This segment concentrates on the comparison to the satellite television merger that was attempted and failed in 2002. SSG Comments in RED

The author of the report states:

"The merger proponents suggest implausibly that this merger bears no resemblance to the proposed DBS merger that was abandoned in the face of FCC skepticism in 2002. But similarities are striking, and they have been detected by many respected industry observers. In the proposed DBS merger, most MVPD customers would have experienced a reduction in the number of suppliers from three (the incumbent cable operator, Direct TV, and Echostar), to two, and five million DBS customers in areas not passed by cable television systems would have experienced a reduction in the number of suppliers from two to one. Assuming generously that terrestrial radio serves the same role of the incumbent cable operator here, most radio customers would experience a reduction in the number radio suppliers from two to one, and those 22 million age 12 and over who receive 5 or fewer stations would experience a reduction in the number of radio suppliers from two to one. For the same reason that the FCC was skeptical of the proposed satellite television merger, the proposed satellite radio merger should be rejected."

Interesting thesis, but lacking in very real terms:

1. Radio stations can not be compared to cable operators. Cable operators are the sole source of cable television and the cable company collects all of the revenue associated with cable subscribers. To insinuate that the many radio stations in a market are collectively a single entity is very very very very wrong. Terrestrial radio stations compete aggressively with each other and other media on a day in and day out basis. Have you ever seen the ratings books????? Pick any town in the U.S with a single cable operator and tell me what their share is of the cable market.......That's right 100%. Radio stations do not have that luxury.

2. The assertion that 5 million customers in ares without cable would have been relegated to one choice is correct, but lets put that in realistic terms. those 5 million customers represent less than 5% of the population of this country.

3. How is it in one statement the author can go from lumping all radio stations together as a single entity to then speaking about markets with 5 or fewer stations? For the purposes of your argument are they lumped together or separate???? Pick a stance and stick to it. This statement seems like it is likely a Direct quote from David Rehr of the NAB. He is good at flip-flopping.

Sorry Mr. Sidak, but you seem to be trying to compare apples to oranges. And, if anyone takes the time to read your footnotes, the supporting argument for the comparisons of these mergers does not reflect at all the sentiment you state in the paragraph above

Labels: c3sr, criterion economics, nab

3/29/2007 08:56:00 PM

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C3SR and The NAB

March 29, 2007

The Consumer Coalition for Competition in satellite Radio, C3SR, is a consumer group that is lobbying against the Sirius and XM merger. They have taken a stance that the merger is bad rather than a stance, such as Public Knowledge that could use their influence to shape the merger into a company with the desired impacts for the consumer.

The NAB has lobbied against the merger from the start, and in our opinion has demonstrated a very shallow argument.

It appears that the NAB is the dollars behind C3SR.

The Criterion Economics study issued to the FCC and DOJ, and authored by J. Gregory Sidak has an interesting note:

"The Consumer Coalition for Competition in Satellite Radio is a consumer group of Sirius and XM subscribers. It is supported by the National association of Broadcasters."

So, is C3SR doing the bidding of consumers, or the bidding of the National Association of Broadcasters?

What is C3SR's position on the consolidation in terrestrial radio that the NAB is seeking?

Sidak, as indicated in this report is regularly in the employ of the NAB. Why is it that the C3SR sponsored this report rather than the NAB?

Did the money that paid for this report come from the NAB?

How many members does C3SR have? To date, information on the C3SR site has been sparse, and there does not seem to be much in way of participation from individuals.

With the release of this report, there now seems to be more questions than answers surrounding the relationship between C3SR and the NAB

Labels: c3sr, merger, nab