Letter to Senate Regarding FCC Notice of Proposed Rule-Making

United States Senate
Washington, DC 20510
April 9, 2003

Dear Senator,

The Federal Communications Commission is expected within the next month to begin final deliberations on proposals to substantially deregulate current restrictions on media cross-ownership. These and other related rules have prevented the rise of media monopolies in the news, entertainment, and information marketplace. The consolidated rule-making that is now reaching its final stages, has been described by Chairman Michael Powell as among the most sweeping regulatory actions in FCC history. In the final analysis, what the agency does could radically reshape the nation’s media landscape with potential adverse consequences for large and small media markets throughout the country.

For this reason, the undersigned organizations seek your assistance in urging the FCC to issue a new Notice of Proposed Rule-Making (NPRM) on any new rule regarding media ownership, as suggested by Senators Allard, Snowe and Collins in their March 19th letter to FCC Chairman Powell.

In today’s already highly concentrated media marketplace, our organizations–which collectively represent over one half million media professionals, artists, technicians and blue collar workers who are involved in all phases of news and entertainment programming–have continued to be advocates for robust competition and ownership diversity.

In the news and information business, these precepts help preserve localism in news coverage, enhance the quality and comprehensiveness of news content, and assure that a multiplicity of voices are heard from a variety of independent sources.

Most importantly, competition and diversity in news and information expands the public’s informed participation in our democracy–a bedrock of our free and open society.

In entertainment, competition and diversity are the economic imperatives that stimulate the kinds of creativity and variety in programming that the American public has come to expect but which has been drastically reduced due to the abolition of the financial interest-syndication rules that resulted in a severe contraction in the number of independent program production owners.

In short, regardless of the number of available media outlets, ownership matters, as does the FCC’s regulatory regimen that protects and advances these important public interest objectives. The repeal of the rules now under review by the FCC or their substantial diminution will have a profound impact upon this nation’s news, entertainment, information, communications and advertising industries.

Given this likely scenario, it is incumbent upon the Commission to assure that its regulatory review process is open, fair, and comprehensive. To that end we applaud the bipartisan leadership of Senators McCain, Hollings, Dorgan, Inouye, Kohl and DeWine and others who have expressed concerns about the FCC’s regulatory undertaking. As noted, most recently Senators Allard, Snowe and Collins wrote to Chairman Powell urging him “not proceed with a final rule until the Commission provides both a full description of all proposed changes and the empirical foundation for the changes as well as provide for an ample public comment period so that members of the public and Congress will have an opportunity to evaluate the new rules’ potential impact.”

We fully endorse the position taken by these Senators. When the FCC issued its initial NPRM the Commission solicited general public comment on the existing rules but not on any specific new set of standards. In our view, the FCC should issue a new NPRM on any new proposed rule before adopting any final new rule.

We, the undersigned 15 national organizations hope that you too share this concern and that you will communicate to FCC Chairman Michael Powell that the Commission should go the extra mile to assure focused public input on the specifics of their proposed final rule.

Thank you for your consideration of this request. Should you or your staff need additional information, please contact Mike Gildea, Executive Director of the AFL-CIO Department for Professional Employees at 202-638-0320.


Actors’ Equity Association Patrick Quinn, President
American Federation of Television and Radio Artists John Connolly, President
American Federation of Musicians Thomas F. Lee, President
Communications Workers of America Morton Bahr, President
Department for Professional Employees, AFL-CIO Paul E. Almeida, President
Directors Guild of America Martha Coolidge, President
International Brotherhood of Electrical Workers Edwin D. Hill, President
International Alliance of Theatrical and Stage Employees Thomas C. Short, President
National Association of Broadcast Employees and Technicians John S. Clark, President
National Writers Union (UAW 1981) Jonathan Tasini, President
The Newspaper Guild Linda K. Foley, President
Screen Actors Guild Melissa Gilbert, President
The Caucus for Television Producers, Writers and Directors Charles W. Fries, Chair
Writers Guild of America, East Herb Sargent, President
Writers Guild of America, West Victoria Rifkin, President