October 4, 2021
Thursday, September 30, Sue Wilson and Media Action Center filed a Comment in the 2018 FCC Quadrennial Review (yes, you read that date correctly.) The FCC will use comments from this review to establish future rules for TV and radio broadcasters.
You will find the entire document here.
What follows is my opening statement, Final Summary, and a list of recommendations for the FCC to consider.
Comments of Sue Wilson, Media Action Center
The events of January 6, 2021 were entirely foreseeable and, and for those of us watching media policy, predictable. In the arena of public opinion, current Federal Communications Commission rules to govern broadcast radio licensees have been rewarding far-right authoritarian ideologies for a generation, and in practice, preventing any real debate over the air to counter politically motivated lies and disinformation. This problem is compounded by too few radio licensees in any one market, restricting local competition. Looking forward, new FCC rules could well allow one politically motivated TV station group to control all the local news content in TV and radio stations and newspapers in single towns all over the country. With our national debate now pivoting to preventing disinformation, we all realize that FCC media rules really do matter to the very foundation of our country. The FCC has an opportunity now to consider the true impact its rules have on the competition of ideas and information, and rise to this occasion to protect not only industry profits, but also Democracy principles. This paper seeks to provide relevant history, data, and a road map to a better tomorrow.
1. Restore the opportunity to respond to both personal and political attacks on our publicly owned airwaves. If a radio or TV broadcaster attacks someone personally, that person must have the right to respond, to defend himself or herself on the same program where they have been attacked. If a radio or TV show spends hours promoting one political viewpoint, a competitor of opposing views should have the right to respond in that same time slot. This common sense rule change ensures fair competition not only between business competitors but also in the debate so crucial to Democracy.
2. Using proceeds from the $48 million Sinclair fine, reinstate a 21st Century version of the “FCC Office of Plans and Policy's Working Paper Series.” As we have learned, the Federal Communications Commission abandoned its former practice of supporting data driven studies. The agency now relies on underfunded non-profit organizations and independent journalists to counter studies funded by the well-heeled broadcast industry. This creates an anti-competitive advantage for industry. Industry has the further benefit of obtaining actual data from the FCC for its reports – because the industry is providing its own data – which is largely unavailable to the public. Is the data industry is providing to the Commission even correct? Armchair studies suggest it is not, but well-funded studies will provide the facts so crucial to preserving our Democracy in these tenuous times.
3. Get a current snapshot of Local TV industry operations Study individual TV markets to determine how many station groups are currently operating within a single community. Determine how many Network stations within that market each group currently controls, how many non-network stations each group controls. Determine whether station groups are operating within the guidelines established by law or whether they are creating shell operations to hide the control of more than their allotted share of licenses to broadcast in every community.
4. Ensure competition for Local News Determine on a market by market basis whether station groups are providing different local news stories on each of their TV stations in a single community, or whether they are merely duplicating local news stories on their multiple TV stations. Collaborate with willing local level groups to monitor the airwaves in their own communities across the USA. Using this data, develop guidelines so every community has competition in the realm of news and information.
5. Rewrite Radio licensee ownership caps Limit the total numbers of radio licenses to a single radio group to four in a single market, thereby creating opportunities for more station groups to compete. Balance the scale of station Size so each station can have at least one high wattage station.
6. Expand the number of five FCC Commissioners to seven to include two Public Interest Commissioners. These public interest Commissioners will provide the Commission needed insight from real communities outside the Beltway to better serve the public in the Commission’s decision-making process.
As the Commission considers “competition,” please consider the real-life impact of the broadcast industry cornering the market on ideas and rhetoric. The unintended consequence of current FCC rules has over a generation grown from hot topics to fanning flames into a real life insurrection, now recognized as an attempted coup.
So do the FCC’s “media ownership rules remain ‘necessary in the public interest as the result of competition’?”
Absolutely. We need the FCC to make rules, as they are crucial to the public interest and to industry. But the FCC’s current rules provide no competition for the give and take of ideas and information necessary to our Democracy and the future of our nation.
The need for true competition should not be framed as a Republican v Democrat issue. Given the immense power the radio and TV airwaves had, have and will continue to have in the future, the decisions must be framed as a crucial Democracy issue.
Good Commissioners, you are the only ones who can right these wrongs and repair America.
We the People are counting on you.