2002 Media Ownership Proceeding
Media Ownership Limits Facing Repeal at the FCC
- Comprehensive 2002 Media Ownership Proceeding in the FCC
- Newspaper Broadcast Ownership Rule
- Local Radio Ownership Rule
- Local Television Ownership Rule
- Dual Networks Rule
Comprehensive 2002 Media Ownership Proceeding in the FCC
On September 12, 2002, the FCC started a proceeding to review all the media ownership rules currently in law. The FCC completed this proceeding in a vote that took place on June 2, 2003.
Read background on June 2nd decision. Read MAP’s press release on the June 2nd decision.
The FCC released the full text of the FCC’s decision on July 2nd. This proposal was a tremendous blow to democracy and civic discourse. For an explanation of the importantace of these rules, see Cheryl Leanza and Harold Feld’s article “More than a Toaster with Pictures: Defending Media Ownership Limits,“ in Fall 2003 issue of Communications Lawyer.
The wave of public protest that was engendered around the country against the FCC’s rules continued after the decision was issued. Congress is considering overturning all or part of the decision. For legislative updates, see Consumers Union, Common Cause, and Free Press.
Table of Contents:
- Background
- FCC Order and Commissioner Statements
- FCC NPRM and Commissioner Statements
- FCC Media Ownership Working Group Studies and Access to Study Data
- Public Interest Response to FCC Proceeding
This proceeding combined previous FCC proceedings and directives from several court decisions. This review process is required by law resulting from a provision of the 1996 Telecommunications Act, Section 202(h), that requires the FCC to review its media ownership rules every 2 years. This spring in a case called Fox Television v. FCC, the U.S. Court of Appeals for the D.C. Circuit ruled that in every review the FCC must re-justify every major ownership rule or strike it from the books.
The FCC proceeding will consider the following existing rules (some of which were already under consideration in other proceedings):
- National Broadcast Ownership Cap – limits the ability of any entity to have an ownership interest in broadcast licensees covering more than 35% of the country (remanded by the D.C. Circuit in Fox Television v. FCC).
- Dual Network Rule – Prevents major broadcast networks (ABC, NBC, CBS, Fox) from owning interests in each other.
- Newspaper Broadcast Cross-ownership – Prevents an entity from owning a broadcast station and a daily newspaper in the same market.
- “Duopoly” Rule — limits the number of broadcast stations an entity can own in any given market (remanded by D.C. Cir. in Sinclair v. FCC).
- Local radio competition limits — examines the number of radio stations an entity may own in a local area.
FCC Order and Commissioner Statements:
FCC Releases Text of Report and Order Setting Limits on Media Concentration
- Report & Order
- Erratum 7/14/03
- Attachment
- Chairman Powell Statement
- Commissioner Abernathy Statement
- Commissioner Copps Statement
- Commissioner Martin Statement
- Commissioner Adelstein Statement
- Commissioner Adelstein 7-2-03 News Release
- News Release & Statements Issued After Commission Meeting June 2nd.
FCC Notice of Proposed Rulemaking and Commissioner Statements:
- Read the Commission’s press release on this proceeding.
- Commissioner Copps’ separate statement.
- Commissioner Martin’s separate statement.
After the FCC released its studies (see below), it asked for comment on the studies and the NPRM by December 2, 2002 and reply comments by January 2,2003. After repeated requests for additional time, this deadline was extended by 30 days but no more. The new deadlines were: comments due January 2; reply comments due February 3.
- FCC Order granting 30 day extension
- Commissioner Copps’ dissent arguing a longer extension is warranted.
- For information about the public interest community’s response, see below.
FCC Media Ownership Working Group Studies and Access to Data
On October 1, 2002, the FCC released a series of studies and analyses that would provide a basis for its media ownership proceeding.
- Titles, Authors, and Links to all 12 Studies
- FCC Public Notice Seeking Comment on Studies
- FCC Press Release On Studies
- Read the full text of the NPRM.
Getting Public Access to the Data
The FCC did not grant access to the underlying data in the studies. MAP asked the FCC to grant the public access to the data. On November 5, 2002, the FCC granted a 30 day extension and granted the public access to all the underlying data, with significant limits, in the 2002 Biennial Review proceeding.
Terms of Public Access to Data
- The public will have access, and will be able to manipulate the data.
- The data can only be accessed on site at the FCC and it must stay on site.
- Any results produced from manipulating the data must also stay on site.
- The FCC also is making the authors of the studies available to help members of the public use the software and understand their analysis.
- To access the data, a person was required to sign a protective order agreeing to keep the data secret, and then go to the FCC’s public reference room and use their computer to look at and manipulate the data.
FCC Material on Granting Access to Data
- FCC public notice explaining actions.
- Protective order that individuals must sign if they want to access data.
Public Interest Responses to FCC Proceeding
Here are MAP’s materials and other selected materials.
- On December 4, 2002, Children Now lead a coalition of children’s experts criticizing the FCC for ignoring the impact of media ownership on children, and demanding a meeting with Chairman Powell.
- On December 16, 2002, MAP ally Consumer Federation of America releases comprehensive analysis supporting media ownership limits.
- On December 18, 2002, a large number of major media unions issued a critique of the FCC’s 12 media ownership studies.
- On January 2, 2003, CFA and other allies including MAP submitted comprehensive comments to the FCC. (Complete comments are 296 pages, 837 KB). Read the executive summary.
- Read CFA and CU’s detailed reply comments filed on February 3, 2003.
- AFL-CIO Executive Council Statement, Media Monopolies: A Threat to American Democracy, February 26, 2003 .
- On May 2, 2003 MAP cosigned a letter with Consumers Union and other public interest groups in support of the resolution. (The letter uses an older reference number, H. Res. 212. This was changed when Hinchey introduced a new version of the resolution. The correct number for the pending resolution is Resolution 218).
- On May 6, 2003, Rep. Hinchey (D-NY) introduced a resolution, H. Res. 218, calling upon the FCC to delay any action on the media ownership rules until the American people are fully informed of the possible impact of any such action and until the FCC conducts a more careful study. MAP fully supports this resolution. Those interested in supporting the resolution should take the opportunity to write their Representative asking them to support H.Res. 218 and should circulate this notice to other interested parties. Please redistribute the text of this resolution to any relevant mailing lists.
- May 29, MAP filed a detailed letter explaining why the UHF discount is no longer justified.
- On June 2, the FCC announces its changes to media ownership rules. MAP Press Release.
MAP Press Background. - Common Cause Action Kit opposing FCC decision
Hearings and Fora Around the Country on Media Ownership
Commissioner Michael Copps asked Chairman Powell to discuss the media ownership issue in fora or hearings around the country. The Chairman initially refused, and eventually relented and held one official hearing. Public interest groups around the country held their own hearings and invited FCC Commissioners.
- Columbia Law School announces a forum on Media Ownership to be held January 16, 2003.
- USC Annenberg schedule of hearings.
- FCC Commissioners Copps and Adelstein announced more details about the Seattle hearing to be held March 7, 2003. University of Washington Shilder Center for Law, Commerce, and Technology will host.
- The Benton Foundation convened a hearing in Arizona, at which MAP’s Andrew Jay Schwartzman spoke.
- The FCC hosted one official hearing in Richmond, VA, at which MAP’s Andrew Jay Schwartzman testified. (02/27/03)
The “Newspaper-Broadcast Ownership” Rule
The newspaper broadcast cross ownership rule prohibits a newspaper from owning a broadcast station in the same local area and vice versa. The FCC adopted this rule in 1975. The Supreme Court upheld the rule against constitutional attack in a case called NCCB v. FCC.. At the time the FCC adopted the rule, it allowed many existing newspaper-broadcast combinations to keep their combinations. Many of these “grandfathered” combinations continue to exist today.
In September 2001, the FCC initiated a proceeding to relax or eliminate the rule. (See FCC’s Press Release describing the proceeding and the text of FCC’s Notice of Proposed Rulemaking).
Media Access Project and other public interest organizations filed at the FCC in favor of preserving the rule:
- Executive Summary of 2001 Comments by Media Access Project and other public interest organizations (7 pages).
- 2001 Comments of Media Access Project and other public interest organizations.
- 2002 Reply Comments of Media Access Project and other public interest organizations.
- April 2002 Supplemental Filing Report by Professor Andrew Calabrese of University of Colorado analyzing industry studies. April 17, 2002
Other Comments in support of rule:
- AFL-CIO 2001 Comments
- AFL-CIO 2002 Reply Comments
- Attachment to AFL-CIO Reply Comments, An Analysis of the Newspaper Broadcast Cross Ownership Rule, by Prof. Douglas Gomery (alternate link to Prof. Gomery’s paper).
- United Church of Christ 2001 Comments (represented by IPR).
- United Church of Christ 2002 Reply Comments (represented by IPR).
Other resources on the Newspaper Broadcast rule:
- AFL-CIO supports Newspaper Broadcast Rule, sponsors forum.
- Newspaper Guild believes the Newspaper Broadcast Rule helps journalistic quality.
- Seattle Times Owner Frank Blethen supports the newspaper broadcast rule. A Voice In the Wilderness, Editor & Publisher, March 18, 2002
In 1997 the FCC considered relaxing or repealing the rule, but it determined the rule should remain in place.
- FCC’s Inquiry on cross-ownership restrictions between newspapers and radio stations. (also in WordPerfect Format)
1997 FCC Filings in Support of the Newspaper Broadcast Rule:
- Black Citizens for Fair Media 1997 Comments. BCFM 1997 Comments part 2.
- Black Citizens for Fair Media 1997 Reply Comments
- Minority and Media Telecommunications Council 1997 Filing
- Benton Foundation 1997 Newspaper Broadcast Comments, and Part 2
The local radio ownership rule allows ownership of up to 8 radio stations (on a sliding scale) in a local market, depending on total number of stations in market. Congress repealed the national radio ownership cap in 1996, thus, this is the last significant rule promoting diverse national radio ownership, with the exception of the new low power radio service.
In November 2001, the FCC initiated a proceeding to reconsider its local radio ownership limits. (See FCC Local Radio Ownership Press Release and Full text of FCC Notice of Proposed Rulemaking).
- The Georgetown University Law Center student law clinic filed
comments on behalf of the United Church of Christ in this proceeding on May 8, 2002. - MAP filed comments on May 9, 2002 showing that diversity is decreasing in radio.
Additional resources on radio consolidation:
- “Mega Hurts: Clear Channel’s Big Radio Ways Are Getting a Lot of Static These Days” by Paul Farhi Washington Post, May 29, 2002, p. C1
Local Television Ownership Rules
This rule limits ownership to two television stations in same market only if that market has 8 independent voices, and, one of the two stations is not among the top four stations in that market. Sometimes this rule is referred to as the “duopoly” rule.
In August 1999 the FCC adopted the present rule. In the past, no owner was allowed to possess more than one local television station. (See August 1999 FCC Order .) The 1999 decision took an important step with respect to “LMAs” or local marketing agreements. LMAs, prior to 1999, were a method used by television station owners to control a station but avoid the FCC’s ownership limits. After 1999, LMAs will be considered attributable (see above for more information about attribution rules). At the same time the FCC closed this loophole in the local TV rules, it also adopted the present rule, which increases the number of television stations a single owner can control in a local market.
This rule was challenged in court. See MAP’s court proceedings page.
Filings on local television ownership rule and similar rules:
- 1997 Comments of MAP, et al., on these ownership notices, filed by MAP and the Institute for Public Representation (summary of comments). Second Round of Comments of MAP, et al. (summary)
- Comments of Black Citizens for a Fair Media, et al., on the proposal, in these ownership notices, to repeal the radio-television cross-ownership limits. Filed by the Institute for Public Representation and MAP.
Since the earliest days of broadcasting, FCC rules in effect prohibited a single entity from operating two broadcast networks. In the 1996 Telecommunications Act, Congress relaxed this rule to allow major networks (such as ABC, CBS, NBC and Fox) to create new networks. In 2001, the FCC further relaxed the rule by allowing a major network to purchase or merge with an emerging network (such as WB or UPN). The major networks are still prohibited from merging with one another.
- October 2000 Reply Comments filed by MAP supporting retention of the rule.
- FCC May 2001 Order amending rule to allow one of the major television networks (ABC, CBS, NBC and FOX) to own one of the emerging television networks (WB and UPN). This change allowed CBS to purchase Viacom, which operates UPN.
