National Citizens Committee for Broadcasting v. Federal Communications Commission

555 F.2d 938, 181 U.S. App. D.C. 1
CourtCourt of Appeals for the D.C. Circuit
DecidedMarch 1, 1977
DocketNos. 75-1064, 75-1152, 75-1289, 75-1379, 75-1386, 75-1387, 75-1388, 75-1567, 75-1614 and 75-1618
StatusPublished
Cited by13 cases

This text of 555 F.2d 938 (National Citizens Committee for Broadcasting v. Federal Communications Commission) is published on Counsel Stack Legal Research, covering Court of Appeals for the D.C. Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
National Citizens Committee for Broadcasting v. Federal Communications Commission, 555 F.2d 938, 181 U.S. App. D.C. 1 (D.C. Cir. 1977).

Opinion

Opinion for the Court filed by Chief Judge BAZELON.

BAZELON, Chief Judge:

At issue are Federal Communications Commission regulations dealing with one aspect of media ownership concentration: newspaper-broadcast station cross-ownership. Second Report and Order (Order), 50 F.C.C.2d 1046 (1974), reconsidered 53 F.C. C.2d 589 (1975).1 In 1970 the Commission proposed rules entirely eliminating newspaper-broadcast affiliation in a common city of operation. Docket 18110, 22 F.C.C.2d 349 (1970). Following a lengthy rulemaking proceeding, the Commission issued the more limited ban challenged here by the National Citizens Committee for Broadcasting, the Justice Department and various media interests.2 In relevant part, the rules:3 [7]*7Under the latter rule, roughly 90% of existing combinations are grandfathered. For the reasons expressed below, we affirm the prospective ban but vacate the rules dealing with existing combinations.

[6]*61) forbid the future formation or transfer of co-located newspaper-broadcast combinations4;
2) preserve existing combinations except those in communities served by only one daily newspaper and one broadcast station encompassing the community with a city grade signal; in the latter cases, one of the interests must be divested within five years.5

[7]*7I. THE RULEMAKING PROCEEDING AND ORDER

A. The Proceeding.

The Commission has long been aware that concentrated ownership threatens the public interest in a diversified mass communications media. The Commission’s first multiple ownership rules, adopted in the 1940’s, prohibited any party from owning or controlling more than one broadcast station in the same broadcast service in the same area.6 As a result of the AM radio rules, divestiture was ordered in 24 cases.7 The rules have since been tightened several times, most recently in the early stages of Docket 18110 to prohibit the common ownership of more than one broadcast station of any type in the same service area.8 The Commission enacted these rules without compiling a substantial record of tangible harm; it rested instead on its belief that “the effects of competition or its absence,” are “not readily susceptible of quantitative ascertainments.” 29 Fed.Reg. 7535, 7537, Docket 14711 (1967). The Commission has always viewed diversification as a factor of central importance in comparative license hearings.9

[8]*8In 1970 the Commission broadened the scope of ongoing rulemaking proceedings, Docket 18110, to consider whether newspaper-broadcasting affiliation was in the public interest.10 22 F.C.C.2d 339. Citing figures indicating the high incidence of newspaper-television affiliation,11 and the popular dependency on these media as information sources, the notice of proposed rule-making stated that, as with two television stations, it is not “desirable that these two organs ... be under the same control in any community.” Id. at 344, 346. The Commission suggested that promotion of media competition and maximum diversification of media viewpoints might require the separation of all co-located newspaper-broadcast combinations. Since the Commission contemplated allowing divestiture to take place over five years under favorable tax treatment,12 it expressed confidence that such a rule would produce no more than minimal economic losses. Id. at 347-48. Comments were invited.

Not surprisingly, the proposed rules generated considerable interest. Nearly 200 parties filed comments. In addition, roughly 25 major studies were lodged, Order at 1090-1094, although as will be explained in Section IV-A infra, the studies were of surprisingly little value.13 In March 1974, the Commission requested additional comments dealing primarily with the central problem of newspaper-television cross-ownership. 45 F.C.C.2d 768. Forty eight parties filed fresh comments.14 Three days of oral argument were held and the Order was released on January 31, 1975.

B. The Order.

After summarizing the comments and studies filed in Docket 18110, the Commission explained its justification for the prospective ban. Although the Commission had at one time encouraged newspaper sponsorship of broadcast stations, it concluded this policy was no longer warranted because broadcast licenses had become attractive to other types of investors. It had come to believe that “any new licensing [9]*9should be expected to add to local diversity,” Order at 1075. Because granting a broadcast license to a local newspaper owner could not be expected “to enhance diversity,” id., the Commission decided to prohibit the creation of future combinations. However, a geographic limit was placed on this ban because “there is no basis in fact or law for finding newspaper owners unqualified as a group for future broadcast ownership.” Id. Recognizing that various limits could be imposed, the Commission chose to employ the pattern used in earlier multiple ownership rules; the ban applies only if the station in question would or does encompass the common city with a city grade signal. Id,15

The Commission then focused on the more difficult question — what to do with existing co-located combinations. Initially, the Commission noted it had not yet paid sufficient consideration to certain possible side-effects of divestiture — reduction of local ownership, disruption of broadcasting continuity and local economic dislocations. Order at 1073. Claiming that stability and continuity of ownership serve the public interest, the Commission concluded that “a mere hoped for gain in diversity” was not adequate cause for disrupting ownership. Divestiture would be ordered “in only the most egregious cases.” Order at 1080. In framing its Order, the Commission chose not to focus, as the Justice Department suggested, on competition for advertising, citing authority that it has discretion to determine the weight to be given antitrust principles in shaping its regulatory policy.16 Instead, the Commission stated that the number of media voices serving a given area was a more important concern.

If our democratic society is to function, nothing can be more important than insuring that there is a free flow of information from as many divergent sources as possible. .

Order at 1079 (emphasis added).

The Commission then explained a combination would be considered an “egregious case” if it had an “effective monopoly in the marketplace of ideas” with respect to local issues. Although the Commission stated it had examined “every” combination “known to us,” Order at 1081, the record contained no evidence suggesting which combinations were monopolies in this sense.

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Cite This Page — Counsel Stack

Bluebook (online)
555 F.2d 938, 181 U.S. App. D.C. 1, Counsel Stack Legal Research, https://law.counselstack.com/opinion/national-citizens-committee-for-broadcasting-v-federal-communications-cadc-1977.