Even before the Federal Communications Commission invited public comment on Friday on the proposed XM/Sirius satellite radio merger, the Hispanic Federation weighed in.

Although the advocacy group "takes concerns relating to media concentration and mergers seriously," in this case it would make an exception.

"For the most part, the mainstream media companies offer very limited music and entertainment programming targeted to the Hispanic community," federation President Lillian Rodriguez-Lopez wrote to the FCC on June 5th. "Satellite radio, by contrast, does provide sought after programming, such as CNN en Espanol, ESPN Deportes, and Mexico Canta."

Ditto for the National Black Chamber of Commerce (NBCC), the League of United Latin American Citizens (LULAC), the Latino Coalition, and the League of Rural Voters. They all support the merger; they all fear that without it, satellite radio will fail.

"Satellite radio is critical to the programming needs of African Americans," NBCC president Harry Alford wrote to the Commission on May 21. "Both companies offer dozens of channels that are targeted to African American entrepreneurs, entertainers, and consumers."

All these organizations touch on the same theme in their filings: the consolidation of traditional free radio has left minorities out of the programming loop. Out in the hinterland, there isn't even much of a loop to speak of.

"In many rural areas throughout America, commercial radio reception can be extremely limited," Rural Voter League executive director Niel Ritchie wrote in a May 31st statement.

Consolidation "has left much of rural America behind in recent years," Ritchie concluded, "as locally-owned stations are replaced with corporate conglomerates producing homogenized content with so-called local news and weather delivered from offices hundreds of miles away."

It isn't clear to what extent these filings are part of an orchestrated effort by merger applicants XM and Sirius to win over FCC Chair Kevin Martin, who says agency rules forbid a union of the nation's only two satellite pay-radio companies. The two services fowarded most of these statements to the FCC on June 4th.

But nobody's forcing these groups to support the merger. And as the public comment cycle continues, XM and Sirius will face plenty of opposition from organizations who don't think that the solution to media consolidation is more media consolidation.

That would include the American Anti-Trust Institute (AATI), a Washington think tank whose June 5th FCC filing is quick to point out that when the FCC launched its Digital Audio Satellite Radio Service (DARS) in 1997, the agency expressly forbade a satellite radio monopoly. AATI cites the Commission's own language in its 31 page argument:

"Even after DARS licenses are granted, one licensee will not be permitted to acquire control of the other remaining satellite DARS license," the agency's 1997 Order declared. "This prohibition on transfer of control will help assure sufficient continuing competition in the provision of satellite DARS service."

AATI filers Albert A. Foer and Richard M. Brunell contend that that pretty much settles the issue. They aren't impressed with claims that the merger will boost diversity either.

"Indeed, until the merged company adopts a single system, the diversity of programming available to the public will be reduced because the Applicants [XM ann Sirius] promise to use existing channel capacity to provide the 'best of both' services on each service," Foer and Brunnel charge. "This means that the opportunities for niche programmers will be reduced over the foreseeable future."

All these comments arrived at the FCC's door even before the Commission announced a proceeding on Friday, June 8th. The public can file statements with the Commission until July 9th and responses to statements until July 24.