In two filings today and yesterday, United Church of Christ, OC Inc. was pleased to address several important components of the Federal Communications Commission's proceedings considering media concentration limits. Today, UCC OC Inc. joined The Leadership Conference on Civil and Human Rights comments submitted in response to the Federal Communications Commission's release of the Critical Information Needs Research Design. The comment praised the FCC for releasing the design and highlighted it as an important step to counter the substantial dearth of studies addressing the needs of underserved communities. It noted that the FCC cannot proceed with its proposals to change existing media ownership rules in the pending quadrennial review, explaining the current record is "flawed" because of "its lack of adequate data analyzing media concentration’s impact on people of color and women." The letter described a number of refinements which would improve the research protocol.
Yesterday, UCC OC Inc. filed a detailed pleading analyzing recent study by the Minority and Media Telecommunications Council, also in response to FCC request for comments. The filing, written by Georgetown Law Center's Institute of Public Representation, concluded that the FCC "may not and should not" rely on the MMTC study in the ongoing media ownership and diversity proceedings. Yesterday's filing described the study's flaws. It explained that the study utilized only 14 interviews and lacked any transparency or description of the markets that were studied. Further, while the study claimed that its results provided no reasons to alter the FCC proposal to permit more consolidation, in fact 3 of the 14 interviewees did identify problems with the type of media consolidation in question -- joint ownership of TV stations and newspapers. Finally, the study conflated a lack of evidence with proof that no harm exists--something that responsible research cannot do.
These filings are part of UCC OC Inc.'s on-going efforts to promote a diverse and accountable media.