At 8:23 PM -0700 6/2/03, Scarberry, Mark wrote:
News reports say that one of the restrictions eased by today's FCC decision
has to do with ownership of both a newspaper and a TV station. Regardless of
whether TV broadcasting is entitled to full first amendment protection, it
seems to me that it is a violation of the old-fashioned freedom of the press
to penalize a person for owning/publishing a newspaper by denying that
person any privilege available to others. Thus the rules that (it seems)
conditioned TV station ownership on nonownership of a newspaper were
unconstitutional in my (admittedly not very expert) view.

Comments? Does anyone think there is a compelling interest involved here
that would justify penalizing a person for ownership/publication of a
newspaper?

Mark Scarberry
Pepperdine

The passage below is from the FCC Notice of Proposed Rulemaking, which led to yesterday's action. It recites the original rationale for the cross-ownership rules before turning to whether changed circumstances have undermined that rationale. Importantly, the law has historically conceived of broadcast spectrum as a limited resources, and the broadcast license as a "privilege" that is not generally available, and that is granted selectively in the public interest. From that perspective, the cross-ownership rule does not penalize newspaper owners, but rather recognizes "new entry" in the marketplace of ideas as a license qualification.

14. Diversity. As noted above, the Commission
adopted the newspaper/broadcast crossownership
rule largely to promote and protect a diversity
of viewpoints.46 The Commission has sought to
ensure that the public has access to a diversity of
viewpoints to promote First Amendment values. In the
words of the Supreme Court, "[t]hat Amendment
rests of the assumption that the widest possible
dissemination of information from diverse and
antagonistic sources is essential to the welfare of the public.
. . ."47 The Commission historically has sought to
promote its goal of viewpoint diversity indirectly through
structural regulation, such as ownership rules.48
We note that the Commission goal of diversity of
viewpoint has been particularly important in the context
of newspaper/broadcast cross-ownership, given
the reliance the public has placed on these media
as sources of local news and information.49


45 BIA MasterAccess Database, Mar. 2001.


46 See supra � 2.

47 Associated Press v. United States, 326 U.S. 1, 20 (1945).

48 In the past, the Commission also used direct techniques
of programming regulation to achieve its goal. See
Review of the Commission's Regulations Governing
Television Broadcasting, MM Docket No. 91-221, Further
Notice of Proposed Rulemaking, 10 FCC Rcd 3524,
3547-3549, �� 58-59 (1995) (TV Further Ownership Notice).

49 According to a 1998 survey, 41% of Americans cited
television as their primary source of local news, 17% cited
newspapers, and 11% cited radio stations. See RTNDA,
Americans Rely on Local Television News, Rate It Highly,
and Consider It Fair, available at <www.rtnda.org/issues
/survey.htm#download>. We seek additional and
updated information on the relative importance of various
media to the public in terms of where it turns for local
news and information.

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