New American Foundation, Free Press, and Media Access Project et al. respectfully submit these comments in the FCC’s inquiry into the Future of Media.  This proceeding represents an ambitious, yet critical undertaking to examine the news and information needs of communities in light of economic and technological shifts in the media industry.  These comments encompass four broad areas for the Commission’s consideration:

1. The information needs of communities and whether they are being met
2. The trends and challenges in the provision of news and information
3. FCC-specific policy recommendations to increase transparency and accountability of media, as well as to promote access to diverse sources of information
4. Policy recommendations that fall outside the FCC’s regulatory jurisdiction, but that are nonetheless an important component of a holistic approach to the crisis in media

Information Needs of Communities

While it is true that most people now have access to more information than at any previous time in human history, it also unfortunately remains the case that race, gender, income, education, geography, age, disability, and sexual orientation all continue to unjustly shape Americans’ opportunities.  Many communities, both of identity and geography, have never been well-served by existing media outlets and infrastructure.  Communities of color, native and rural areas have often been excluded from access to robust infrastructure and emerging technologies, and the issues affecting them have too often been unexplored by professional journalists.  New technologies are creating opportunities to address that, but technological change alone will not create equitable representation or access.
We determine that despite the proliferation of new technologies that have the potential to enhance access to information, by and large the information needs are not being met.  In particular, the unevenly distributed nature of the "digital revolution" and the lack of local information equality have a negative impact on both health and economic well being of communities.

Trends and Challenges in the Provision of News and Information

The digital revolution has upset old business models – particularly those of the advertising-reliant variety.  As a consequence, there exists a looming – though not certain – market failure in the production and circulation of publicly relevant news, especially at the local level. Traditional media are scrambling to maintain balance in the new environment, but have been slow to adapt.  However, while there is much cause for concern about the ability of the new media environment to meet the needs of a democratic society, there are also innovations currently underway in newsrooms.  While many are in their infancy, they hold the promise for enhancing both production of information as well as engaging communities and individuals in creative new media endeavors.

Additionally, new journalistic and civic engagement ecosystems are sprouting up in local news markets across the country, but these systems are emerging in a halting and uneven fashion. As has been widely noted, many of the newest digital media outlets do little or no original reporting. What’s worse, practices of “digital redlining” and the consequences of the migration of legacy news organizations to suburban markets have the potential to replicate patterns of clustered “information paucity” that existed in the pre-digital era.

FCC policies can enhance the availability and diversity of information

The FCC has a legitimate interest and important to role to play in promoting a vibrant Fourth Estate.  Historically, the FCC has sought to foster, not only a substantial quantity of information, but also quality of, as well as access to information by promoting competition, diversity, and localism.  We suggest a number of FCC actions, many on existing proceedings that would preserve or enhance the production and availability of news and information.  Moreover, none of these policy recommendations involve any foray by the FCC into content regulation.  In particular we recommend that the FCC:

• Maintain local media ownership limits, and prevent any contractual circumvention of the FCC’s media ownership rules.
• Protect the open nature of the Internet
• Increase transparency and accountability of local media through reformation of the sponsorship identification rules, and implementation of enhanced reporting requirements and online public file requirements for local broadcasters
• Act on a still extant Petition for Inquiry into the use of misinformation and hate speech in media
• Conduct additional information collection and analyses on broadband  and media ownership data
• Support policies that encourage provision of and access to public and government access channels

The Government's Role in Development of a Healthy Media Ecosystem

FCC policies alone cannot save journalism.  In some cases, important potential solutions will fall outside the FCC’s regulatory ambit.  Thus, we also discuss broader policy shifts that could support a healthy information ecosystem, including:

• The government's role in supporting public and noncommercial media outlets and infrastructure, including new funding models for public media
• Incentives to encourage private sector production of media
• Ways to enhance public engagement with information
• Encouraging anchor institutions, such as schools, universities, and libraries, to support community information flows and provide media training
• The importance of media literacy training in preparing citizens to use media in democratic life.

For a copy of the full comments click here or see the pdf on the right hand side of the page.

[Note: The comments are as corrected and resubmitted to the FCC on July 20th 2010]