Coalition Letter to FCC Chairman on Owner Diversity

December 1, 2011

The Honorable Julius Genachowski


Federal Communications Commission

445 12th Street, SW

Washington, DC 20554

Re: MB Dkt 09-182, 2010 Quadrennial Review - Review of the Commission's Broadcast Ownership Rules and Other Rules Adopted Pursuant to Section 202 of the Telecommunications Act of 1996

Dear Chairman Genachowski:

We, the undersigned organizations, urge the Federal Communications Commission to make diversity a central focus of its upcoming Quadrennial Media Ownership Rule Review. The strength of our country lies in the diversity of our people. Our media system will better serve the public interest when it draws on the diverse backgrounds, perspectives and talents of the population. Unfortunately, ownership of the nation's media outlets consistently fails to reflect this diversity.

Women and people of color historically have been grossly underrepresented in ownership of radio and television stations - media forms that use the public airwaves and rank as our nation's most popular and influential outlets. Women comprise over 51 percent of the population yet hold only 6 percent of radio and TV station licenses. And while people of color make up over 36 percent of the U.S. population, they hold just over 7 percent of radio licenses and 3 percent of TV licenses.[1]

The continued absence of FCC action in the face of deep and intractable ownership disparities is unacceptable. The U.S. Court of Appeals for the Third Circuit recently affirmed that "ownership diversity is an important aspect of the overall media ownership regulatory framework." [2] Yet the FCC has failed to adopt proactive policies to remedy these disparities. Furthermore, it has persistently neglected even to examine or address the impact of existing media market consolidation on broadcast ownership opportunities for women and people of color. The FCC must take care not to repeat the mistakes of prior administrations by "pun[ting] yet again on this important issue." [3]

Most importantly, while the FCC assesses the impact of its media ownership rules and pursues more active measures to address longstanding disparities in broadcast media ownership, it must not undercut the benefits of such measures by allowing greater consolidation of broadcast outlets.

Existing media concentration levels already limit ownership opportunities for historically underrepresented groups. Excess consolidation has crowded out female and minority owners, who tend to be single-station owners who cannot compete with consolidated groups for programming and advertising revenue. Allowing increased consolidation in local media markets would raise station prices and further diminish the already limited number of stations available for purchase. This would leave women and people of color with fewer opportunities to become media owners and promote diverse programming in local communities.

In conclusion, we urge the FCC to do the following:

1. Evaluate the impact of its media ownership rules on ownership opportunities for women

and people of color.

2. Take proactive measures to promote ownership of broadcast stations by underrepresented


3. Guard against further erosion of media ownership among these groups by maintaining

existing media ownership limits.

Absent these measures, ownership levels among underrepresented groups will continue to decline and the promise of a diverse media system that serves the information needs of all people will continue to elude our nation.

Respectfully submitted.

Access Humboldt

Alliance for Community Media

American Association of University Women

Asian American Journalists Association

Bitch Media

Center for Media Justice

Center for Social Inclusion

Common Cause

Digital Sisters

Ella Baker Center for Human Rights

Fairness and Accuracy in Reporting

Feminist Majority Foundation

Free Press

Future of Music Coalition


Institute for Local Self-Reliance

International Museum of Women

Media Access Project

Media Alliance

Media Council Hawai'i

Media Equity Collaborative

Media Literacy Project


National Alliance for Media Art & Culture

National Association of Black Journalists

National Association of Hispanic Journalists

National Council of Negro Women

National Council of Women Media and Technology Task Force

National Council of Women's Organizations

National Hispanic Media Coalition

National Lesbian and Gay Journalists Association

National Organization for Women Foundation

National Women's Law Center

Native American Journalists Association

Native Public Media

New Moon Girls

People TV

People's Production House

Prometheus Radio Project

Rainbow PUSH Coalition

Reclaim the Media!

Reel Grrls

Southern Connecticut State University Sexuality and Gender Equality


Southern Connecticut State University Women's Studies Program

SPARK Movement

Teen Voices Magazine

UNITY: Journalists of Color

Women, Action, & the Media

Women In Media & News

Women's Media Center

Women Who Tech


1 S. Derek Turner, Out of the Picture 2007: Minority & Female TV Station Ownership in the United States, 2007,, and S. Derek Turner, Off the Dial: Female and Minority Radio Station Ownership in the United States, 2007,

2 Prometheus Radio Project v. FCC, 652 F. 3d 431, 472 (3d Cir., 2011)

3 Id. at 471.

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