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Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of )
) MB Docket No. 09-182
2010 Quadrennial Regulatory Review ? Review of )
The Commission?s Broadcast Ownership Rules and )
Other Rules Adopted Pursuant to Section 202 of )
the Telecommunications Act of 1996 )
)
Promoting Diversification of Ownership ) MB Docket No. 07-294
In the Broadcasting Services )
Comments of the Writers Guild of America, East, AFL-CIO
The Writers Guild of America, East, AFL-CIO (the ?WGAE?) respectfully submits these
comments pursuant to the Commission?s Notice of Proposed Rulemaking released on December 22,
2011. We address ourselves in particular to the relationship between cross-ownership and both localism
and viewpoint diversity.
The WGAE represents thousands of members who write feature films, network and cable
television programs, radio broadcasts, and digital media. Our members work for the major television and
radio networks and stations and for public television, where they write, produce, edit, and create graphics
for news and public affairs programs. They write and produce for both network and local newscasts for
CBS and ABC, and for Fox local newscasts. This includes material distributed on television, on radio, on
the internet, and on mobile devices.
We take issue with the assertion made by various media companies that consolidation of
ownership frees up resources to improve news coverage. To the contrary, as a general matter
consolidation undermines news coverage because it enables owners to increase efficiency by
deploying fewer journalistic resources across more outlets. Thus, even if a particular instance of
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cross-ownership might result in a greater number of hours of local news broadcasting, this
simply means that fewer stories are distributed through more channels and platforms. There is
no substitute for spending on trained, experienced journalists, and giving them the time and
resources necessary to investigate, write, and produce material that is well-researched,
thoughtful, and reliable. Simply permitting television, radio, internet, or newspaper outlets to
combine will inevitably result in less substance, in the absence of clearly-defined requirements
that specific levels of resources be devoted to journalism. Nothing in the Notice of Proposed
Rulemaking suggests that the Commission has considered imposing any such requirements.
These requirements are more pertinent than ever because of the same economic realities
that broadcasters and newspapers have cited to the Commission. Media companies assert that
they need more leeway to consolidate outlets in order to withstand downward pressures on
advertising and other revenues. Allowing smaller numbers of large corporations to own more
and more outlets will enhance the bottom lines of those corporations, but will not result in the
investment of additional money in newsgathering and distribution ? unless that is required in
specific, measurable ways.
Policy goals
In the Notice of Proposed Rulemaking, the Commission seeks ?comment on our tentative
conclusion not to adopt any policy goals other than competition, localism, and diversity in this
proceeding?. We respectfully submit that these goals are meaningless without an additional
goal: to increase the resources devoted to diverse, local news programming. This is central to
any discussion of the impact of the Commission?s rules ?on the availability to all Americans of
news and information, including national news and information? and on ?investigative
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journalism?. Permitting additional consolidation would negatively impact the availability of
news and information and would weaken investigative journalism, in the absence of concrete
commitments to devote resources to expanding and deepening coverage.
Local Television Ownership Rule
The Notice of Proposed Rulemaking reports that, ?According to broadcasters, common
ownership can increase viewpoint diversity, as owners of multiple stations seek to capture the
greatest possible audience share by diversifying their news and public interest program offerings
among co-owned properties.? Broadcasters also assert common ownership allows stations to add
newscasts. These assertions confuse quantity with quality. Adding hours of broadcast time per
week, and spreading it over a wider variety of outlets, does not enhance diversity or quality,
unless staff is expanded and given the independence and sufficient means to do the work. Fewer
newswriters, editors, reporters, camera crews, and producers means fewer independent voices;
less time and effort devoted to investigation and production of quality pieces; fewer
opportunities to explore contrary points of few or overlooked facts; and less time and energy to
sharpen questions and make stories more compelling to the viewer.
These are not abstract concerns. Newsrooms around the country have experienced
unprecedented staff reductions, through attrition and layoff. The remaining resources are
deployed across stations. In collective bargaining in 2010 CBS insisted on the right to assign
Writers Guild members to write stories, not only for their own stations, but for all other CBS-
owned stations in the relevant markets. Thus, a newswriter for WCBS-AM might be assigned
pieces to be aired on WCBS-TV; a piece created for WFAN (sports radio) might appear on
WINS-AM (news radio). As discussed below, CBS has consolidated its Internet operations in all
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major local markets. That is, a single website presents Internet content for all CBS-owned
television and radio stations in the market. There is nothing wrong with this, per se, but it
contradicts the notion that consolidation begets diversity.
The Notice of Proposed Rulemaking seeks comment on the effect of the Internet on local
television stations ? in particular, ?whether the development of local and hyperlocal websites
should alter? the analysis that Internet alternatives compete mostly at the national level and not
locally; and whether ?there is evidence that viewers find broadcast television stations to be
interchangeable with new technologies.? We respectfully submit that these questions are related
to those posed in connection with the television/newspaper cross-ownership issues raised by the
Notice of Proposed Rulemaking, including the following point made by Steve Waldman and his
colleagues: ?Although consumers are turning increasingly to the Internet for news and
information generally and seeking new platforms on which to access local news, the websites
most frequently viewed for news and information are affiliated with legacy media.?
However economists might describe the divergence between Internet news sites and
broadcast news, broadcasters themselves believe that the distinction is meaningless. Their view
is that news is increasingly platform-neutral. Our members at CBS and ABC write for both
broadcast and Internet. In some cases, lower-level management of broadcast and Internet
operations is somewhat separate, but that is often not the case, and the actual content flow is
direct and immediate.
As noted above, CBS has consolidated its Internet operations. A single team, augmented
by station newswriters, runs a single website presenting all Internet content for all CBS-owned
stations in a particular market. It appears that the local Internet operations are also coordinated
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by national management. In other words, these important web sites, which consumers rely on for
local news, are completely integrated with broadcast stations, locally, and with networks,
nationally. This has significant implications for localism and diversity.
The Notice of Proposed Rulemaking also asks, ?Is the relevant product market expanding
from a video-only market to one that also contains non-video sources of local news and
information?? The broadcaster-owned websites to which our members contribute content
contain both video and non-video content. In some cases, the non-video content consists mostly
of introductory and wrap-around text, but often the text expands beyond what is presented in the
video clips and streams. The websites are not simply on-line vehicles for distributing stories that
are also broadcast on-air.
Conclusion
Increased consolidation of media outlets continues to undermine localism and reduce the
diversity of voices presenting news and public affairs programming. Combined with downward
economic pressures, consolidation reduces the resources made available to do the investigating,
writing, shooting, editing, and producing necessary to provide useful, informative, reliable news
and public affairs programming to the American public. Unless media consolidations are
accompanied by specific, measurable commitments of additional resources to these tasks, the
public interest will not be served.
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