Comments (PDF)
The American Federation of Television and Radio Artists, AFL-CIO (AFTRA), a national labor organization with a membership of over 70,000 professional employees working in the news and broadcast, entertainment, advertising and sound recordings industries, relies on its members experiences as well as empirical evidence to argue that the FCC should strengthen the remaining broadcast ownership rules in order to protect diversity and localism in the news and information available to the general public, to protect against anti-competitive business practices, and to prevent any further erosion of innovation in media programming. AFTRA focus on the issue of source diversity, meaning independent ownership of media outlets, which they argue is critical to maintain viewpoint diversity. AFTRA says that without source diversity, owners of media seek to achieve economies of scale by recycling, reusing and re-purposing existing content (and the viewpoints contained therein) across all commonly owned platforms and distribution mechanisms. They argue that the FCC's prior assessment that there is an "abundance of diversity" ignores the critical need for source diversity in order to foster viewpoint diversity. AFTRA offers numerous examples of situations where the elimination of source diversity has destroyed viewpoint diversity. AFTRA also uses its expertise to comment on the impact of new technologies and delivery platforms on media consumption and ownership issues. The group points out that many Americans still do not utilize new technologies such as iPods and DVR's. Poor communities, rural communities and certain minority communities continue to rely exclusively on traditional media--newspapers and over-the-air radio and television broadcasting--for their news, information and entertainment. AFTRA also points out that the media consolidation that has resulted in the erosion of independent editorial comments, fewer sources of news and information, and less diversity and competition, occurred in an environment where these new technologies have been wide available for years, and has not stopped these negative outcomes from happening thus far. AFTRA also states that "all available evidence indicates that new and emerging technologies represent limited market shares, and that they cannot be viewed as distinct voices in the marketplace, because they are largely owned and controlled by the same large media conglomerates that control radio, television and newspapers." Finally AFTRA highlights the FCC's failure in the area of Local Marketing Agreements (LMA's), which have allowed many Big Media companies to skirt the Commission's local ownership limits.
The marriage of Comcast and NBC is bad news for consumers. But Washington and Wall Street have already bought into the idea that it's a done deal. That's why Americans need to speak out now and stop the mega-merger!
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