The FCC has taken a step in the wrong direction in trying to use strictly quantitative measures in assessing the needs for media-ownership caps. I know this is true because my research, which is quantitatively based, is one of the 12 studies that the FCC is using to revise its ownership rules. Quantitative research has value, but it must be evaluated within a broader framework. Because of the FCC's myopic view of quantitative methodology, I am concerned that my research is being interpreted out of context.
While the research suggests that consolidation does not contribute to a decrease in diversity of entertainment programming, it does not say anything about news. Given the current state of world affairs, one can only wonder where we would be if our citizenry were better informed or at least given a breadth of opinions upon which to make its decisions.
Second, the research was meant to open discussion about the ownership rules and their underlying assumptions—specifically, that diversity is an important policy goal for a body that regulates communications. Given that the FCC has never defined diversity and no one seems to know quite what it is, I would suggest that, as a concept, diversity is at best outdated and at worst fundamentally flawed. Unless and until the FCC, Congress, industry, academics or the White House can define diversity, we will never know when we have achieved it. That being said, we cannot know whether deregulating ownership will be beneficial so why let the horse out of the barn when it is unlikely that we will be able to get it back in once we do? Better to err on the side of caution.
More, not less, regulation of the five media giants that dominate the communications landscape is called for. With the $70 billion giveaway that was the 1996 Telecommunications Act, it is time for the networks to give back. I do not know anyone who believes that the networks will return the analog spectrum to the government—that is, to the people—because the country will never achieve 85% digital penetration. With all that spectrum space available to them, the networks should be required to support independent voices on some of that space. This is not a new suggestion. The Gore Commission raised just this issue five years ago.
With all due respect to the FCC, quantitative measures should not be seen as the be all and end all in determining whether to ease the media-ownership rules. Much of the statistical information in front of the commission is provided by the industry, a decidedly biased group. While my work is not biased (though I have been accused otherwise), I implore the commission to examine it within its appropriate context. It is meant as a work that blames advertising for many of our current woes, not as a means to put even more power into the hands of a select few. I would like to see this research used as it was meant to be used: as a means to stimulate wider discussion on media ownership, media diversity and the underlying economics that guide media content. The FCC says it will decide by June 2. That's simply too soon, given the lack of broad public debate.