Before the FEDERAL TRADE COMMISSION Washington, DC 20580 ) In the Matter of ) ) Project No. P091200 Public Workshops and Roundtables: ) From Town Crier to Bloggers: How Will ) Journalism Survive the Internet Age? ) ) ) ) ) ) ) ) ) JOINT COMMENTS OF ACCESS HUMBOLDT, AFRONETIZEN, APPALSHOP, CENTER FOR COMMUNITY AND DEMOCRACY AT THE UNIVERSITY OF WISCONSIN, CENTER FOR MEDIA JUSTICE, CHICAGO MEDIA ACTION, CENTER FOR RURAL STRATEGIES, DONALD MCGANNON COMMUNICATION RESEARCH CENTER AT FORDHAM, ESPERANZA PEACE AND JUSTICE CENTER, FREE PRESS, MAIN STREET PROJECT, MEDIA ACCESS PROJECT, MEDIA ACTION GRASSROOTS NETWORK, MEDIA ALLIANCE, MEDIA JUSTICE LEAGUE, MEDIA LITERACY PROJECT, MEDIA MOBILIZING PROJECT, MOUNTAIN AREA INFORMATION NETWORK, NATIVE PUBLIC MEDIA, NEW AMERICA FOUNDATION, PEOPLES PRODUCTION HOUSE, PROMETHEUS RADIO PROJECT, PUBLIC ACCESS CORPORATION OF THE DISTRICT OF COLUMBIA, RECLAIM THE MEDIA, August 24, 2010 New America Foundation Free Press Media Access Project 1899 L Street NW 501 3rd Street NW 1625 K Street NW Suite 400 Suite 875 Suite 1000 Washington, DC 20036 Washington, DC 20001 Washington, DC 20006 202 986 2700 202 265 1490 202 232 4300 i SUMMARY New America Foundation, Free Press, and Media Access Project et al. respectfully submit these comments in the FTC’s inquiry into the Future of Journalism. This proceeding represents a critical undertaking to examine the news and information needs of communities in light of economic and technological shifts in the media industry. Many of the joint filers here submitted comments earlier this year in the FCC’s similarly oriented “Future of Media” proceeding. The comments that follow are substantially the same as those we filed in that FCC proceeding. We hereby submit the same analyses and suggestions for the FTC’s consideration, although the bulk of the points discussed below are framed in terms of FCC jurisdiction, responsibility, and precedent. Therefore, these comments encompass four broad areas for the FTC’s consideration, along the same lines as the areas discussed in our FCC comments: (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 may fall outside the FCC’s (and most likely outside of the FTC’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 i 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 of many communities 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 the health and the 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. ii 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 iii • 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. We appreciate the opportunity to submit these comments. We hope that the FTC finds value in our research and perspective as it undertakes the daunting, yet critical task of its inquiry into the future of journalism. iv TABLE OF CONTENTS SUMMARY..................................................................................................................................... i Introduction..................................................................................................................................... 1 I. Measuring and Assessing the Information Needs of Communities.................................... 3 A. Information needs and consumption patterns in low income and minority communities are substantially different from the average across all demographics ................................................................................................................. 5 B. Media continue to fail to take into account the needs of minority communities........................................................................................................................ 7 C. Disasters and public health emergencies highlight the need for truly local media ............................................................................................................... 10 D. The media habits of young people present challenges to monetizing media consumption ........................................................................................ 11 II. Trends and Challenges in Media and Provision of Information....................................... 14 A. The Internet has disrupted the old profit-deriving models that have supported news production for the greater part of the 20th century. However, it has not established itself as a viable alternative to the journalistic functions and resources provided by more traditional media outlets.15 B. The Internet has expanded opportunities for citizens to produce user-generated news content. However the use and utility of these tools is uneven and unclear at this point........................................................................................ 17 C. Legacy journalism institutions are having trouble adapting to and embracing new media, while