SUMMARY
Serving local communities "localism" is a fundamental goal of American broadcast policy. Localism means providing residents of local communities with diverse cultural programming, opportunities for self-expression, and access to the solid, in-depth public affairs programming about local and national affairs that is essential to democracy. Congress has repeatedly asserted the importance of localism in promoting the goals of the First Amendment for the electronic media, and the courts have steadfastly upheld efforts to promote localism.
While the national networks and media chains see localism as quaint and outdated, the Congressional support for and Supreme Court acceptance of policies that promote localism is deeply embedded in our federalist political system. "All politics are local," because in our federal system all elections are state and local. Governors, senators and Electoral College members are chosen on a statewide basis, while members of the House of Representatives are chosen on the basis of single member districts. We pride ourselves on a structure that allows policies affecting education, public health and safety, and community development to be set at the local level.
The importance of localism rests on practical sociological and psychological grounds as well. Local communities promote social trust and shared values, help form individual identities, and preserve cultural diversity. Mobilization of the public to participate in decision-making is best accomplished through local efforts to "get out the vote." The convergence of political decision-making and processes of civic participation at the local level should be celebrated as a strength of our political system. In this sense, localism in the media and the diversity inherent in thousands of units of local government remain critical to a vibrant democracy.
The immensely important role of television in democratic discourse reinforces the need for public policies to promote localism and diversity. Television is the primary source of news and information for the public, especially in local elections. Television is also the primary means of influencing the public through advertising. The news process deeply affects the pattern of political dialogue.
Yet, from the beginning of federal broadcast regulation, there has been a tension between this policy goal of localism and the profit-maximizing ethic of media corporations that became the primary beneficiaries of the licensing system. Requiring commercial media corporations to fulfill public interest obligations to provide diverse political and educational programming in exchange for their valuable license to exploit the commonly owned airwaves has long been the assumed solution to this problem. But imposing such obligations has always been a tense and difficult business, and at best has resulted in only short-lived and marginal improvements. Requirements have been minimal and inconsistent over time, and even so, licensees have often been reluctant to comply.
This tension has reached crisis proportions. Responding to a philosophy of "deregulation" over the past few decades, the Commission has relaxed broadcast companies' public interest obligations. At the same time, the apparent goal of promoting efficiency has led the FCC and other agencies to allow a wave of mergers that have concentrated local media markets, consolidated outlets into regional chains, and conglomerated different types of media under one roof. These trends have combined to weaken localism and diminish diversity in radio and television content. Hypercommercialism in the media has swamped civic discourse. Among the ill effects are that racial and ethnic minority groups are underserved, while community-based nonprofit voices struggle for access to the major media of mass communication.
The time has come for a major shift in broadcast policy. While the longstanding concerns about excessive concentration of media ownership (outlet diversity) and the promotion of public interest programming in the commercial mass media (program diversity) should continue, the Commission should use this fresh look at the issue of localism to promote three additional, and critical, forms of diversity and localism in the media source diversity, institutional diversity, and viewpoint diversity. A balance must be sought between the civic and the commercial in the broadcast media by promoting independent sources of media content and noncommercial outlets for diverse points of view.
The groups joining in these Comments media reform advocates, other public interest organizations, and nonprofit community media producers urge the Commission to initiate the following basic structural changes:
(A) Assign more broadcast licenses to nonprofit, independent media that serve the needs and interests of diverse social, economic, ethnic, and racial groups within local communities. This should include, but not be limited to, more licenses for low power broadcasting, and more spectrum availability for unlicensed community broadcasting. Simultaneously, deny license renewals to commercial broadcasters that are not serving the public interest in localism and diversity, and prevent commercial broadcasters from continuing to expand their geographic coverage areas.
(B) Develop a system of community access or channel leasing whereby commercial broadcasters are required to provide airtime and facilities to nonprofit independent media.
(C) Establish mechanisms for strengthening and supporting nonprofit, independent media, so that they can become meaningful alternatives to commercial broadcasters. This would include a "localism and diversity" fund created with proceeds of spectrum auctions and licensing fees.
The Commission has both the power and, given present circumstances, the obligation to move now toward a new system in which for-profit broadcasting, driven by advertising, beholden to its giant corporate owners, and dominated by commercial entertainment, is balanced by smaller, community-based nonprofits that will provide the cultural and viewpoint diversity so 4 lacking in our current mass media environment, and that will have a genuine commitment to serving local needs.
To view the full comments, please see the PDF file linked below.
