BAZELON, Chief Judge:.
This is an appeal, 47 U.S.C. § 402(b) (6), from a memorandum opinion and order of the Federal Communications Commission renewing without hearing the broadcasting license of Radio Station WREO of Ashtabula, Ohio, over the protest of Retail Store Employees Local 880 (Union).1 We conclude that the Commission has failed to demonstrate adequate consideration of issues of substantial public importance, and accordingly remand the case to the Commission for further proceedings.2
I.
This ease arises out of a labor-management dispute not involving WREO. Hill’s Department Store of Ashtabula, [250] Ohio, (Hill’s Ashtabula) is one of a chain of such stores in northeastern Ohio and southwestern .Pennsylvania operated by the Shoe Corppration of America. In April 1965, appellant Union was certified by the National Labor Relations Board as the bargaining agent for employees of Hill’s Ashtabula.3 Late in that year or early in the next,4 after some months of bargaining, the Union determined to seek its objectives by going on strike. Hill’s Ashtabula was struck, and a boycott beginning there spread to other Hill’s stores in the area, including Youngstown, Warren, and San-dusky, Ohio.
During this period, Hill’s regularly purchased radio air time for advertising. Although no samples of Hill’s advertisements are before us, the parties are agreed that the advertising was standard commercial copy, extolling the virtues of Hill’s stock, bargains, and service, and on that basis urging listeners to patronize the various Hill’s outlets. Seventy such announcements were run by WREO between January 10 and February 22, 1966. Similar copy was carried by stations WFMJ of Youngstown, WHHH of Warren, and WLEC of Sandusky. Beginning in February, 1966, the Union undertook to support its .'boycott by purchasing time for one-minute spot announcements stating that a strike was in progress against Hill’s Ashtabula, and urging listeners to respect the picket lines at that and the other Hill’s Department Stores.5 Three hundred and twenty-two such announcements were carried by WREO between February 16 and April 7, 1966. In addition, WFMJ of Youngstown carried two such spot announcements (both on March 22), and WLEC of Sandusky carried one hundred and seventy such announcements from February 23 through March 28.6 WHHH of Warren, Ohio, although approached by the Union, refused to accept any of the Union’s advertisements upon the advice of its counsel that “no fairness question was presented” 7 and that the station was therefore not compelled to run the proffered advertisements.
As the spring wore on, however, the Union experienced more and more difficulty in purchasing air time for its advertisements. Despite continuing attempts by the Union, through an advertising agency, to purchase further time, by early April of 1966 it could find no station serving the area around Ashta-bula willing to run its advertisements. Apparently the last of the stations to cancel was WREO of Ashtabula, which on April 5 wrote the advertising agencies representing the Union and Hill’s Ash-[251] tabula to inform them that WREO “would accept no further commercial copy from either party concerning the strike between Hill’s and the union.”8 Subsequently, after counsel for the Union informed WREO that he had filed a complaint regarding this action with the FCC, the station on April 22 offered free time to both parties for a single “round table discussion” of the issues presented by the strike.9 This offer was never accepted by either party.
Some time in April, the Union filed complaints with the FCC, charging “various Ohio and Pennsylvania radio stations” 10 (including WREO) with violations of the fairness doctrine. The Commission, in an unreported letter of April 29, 1966, “found no controversial issue of public importance involved in the factual situation and * * * pointed out that a broadcaster is not a common carrier in the sense that he must accept advertising from all comers. * * * ” 11 About the same time, the Union formally charged Hill’s with a violation of the National Labor Relations Act for exerting economic pressure against some of these radio stations to persuade them to cancel the Union’s advertising. This charge was ultimately rejected by the National Labor Relations Board’s Office of Appeals on March 14, 1967.12
In the meantime, WREO continued to broadcast advertisements for Hill’s Ash-tabula. One hundred and twenty-three announcements and six sponsored programs were run during the month of April, and from April 1 to the end of the year, the station broadcast 1,088 spot announcements, 176 sponsored programs, and fourteen sponsored one-third segments of football games on behalf of the store.13 Similarly, it appears that advertising on behalf of Hill’s continued to be broadcast by WFMJ, WHHH, and WLEC.14 Accordingly, on August 9, 1967, the Union filed with the FCC unverified15 petitions to deny renewal of the licenses of stations WFMJ, WHHH, WLEC, and WREO. The petitions alleged that the stations had succumbed to economic pressure from Hill’s and therefore cancelled the Union’s strike advertising ; and that, in any event, refusal to carry advertising by the Union while continuing to carry advertising from Hill’s urging listeners to patronize its stores was a violation of the fairness doctrine. The FCC wrote each of the affected stations inquiring, vnter alia, why Union advertising had been rejected.16 After receiving replies to its inquiry,17 [252] the Commission in a memorandum opinion and order 18 denied the Union’s petitions regarding WFMJ, WHHH, and WLEC. The Commission, apparently relying upon its letter to the Union of April 29, 1966,19 found no fairness question presented. With regard to the Union’s charges of economic pressure, the Commission noted that similar charges had been rejected by the National Labor Relations Board after investigation; 20 that each of the three stations had categorically denied that any such pressure had been exerted against them; and that the Union had provided no specific allegations of particular economic pressure exerted against any of the stations.21 Accordingly, the Commission denied the petitions and granted the stations’ request for renewal.22 No appeal was taken from that decision.
Action on the Union’s petition regarding WREO was deferred pending “further inquiries” by the Commission.23 Subsequently, the Commission wrote the Manager of Hill’s Ashtabula requesting a statement regarding “your part, if any” in the controversy between the Union and WREO, and asking him to state “whether Hill’s, or any of Hill’s employees or agents, at any time during 1966 sought to influence WREO directly or indirectly to cancel spot announcements by Local 880 concerning the Ashtabula strike.” 24 The manager replied that no such efforts had been made by the store.25 In addition, the Commission requested further information from WREO regarding its “policy” decision to cancel the Union’s advertising, and regarding a conversation between the station manager and Hill’s advertising agency at which the agency representative had contended that “some of the ads of Local 880 were possibly illegal.” 26
Shortly thereafter, WREO replied. It categorically denied that any agent of [253] Hill’s at any time during 1966 sought to influence WREO concerning the cancellation of the Union’s advertising. It explained the conversation regarding the “possibly illegal” Union advertisements as an uninfluential, isolated remark made during the course of a normal sales call.27 With regard to the station’s decision to cancel the Union’s advertising, the letter provided the following explanation:
WREO has been operating as an independently owned radio station since 1937. During these years we afforded the public a service compatible with good taste and minimal irritation. We never permitted ourselves to be influenced or coerced in the use of air time.
Our policy also has been to avoid airing private controversies since statements might be made of a possibly damaging nature to persons or businesses, and as a generality such controversies were of a private and not of a public interest.
WREO had carried about 322 of Local 880’s announcements when it became apparent, from complaints of the public, that the continuous repetition of these partisan announcements had become an irritant to WREO’s listening audience. The advertisements concerned a controversy in which the public and WREO were not a part of [sic].
We therefore notified both parties that we would accept no more announcements concerning the strike.
The Union then sent a letter to WREO and stated that the public had a right to have information concerning this private labor dispute.
WREO bent over backwards then to offer the union free time on the air at a WREO sponsored round table to discuss the labor dispute with Hill’s, so if there was any possible public interest the matter could be heard. The union did not accept this opportunity.
This response appeared to satisfy the Commission. On December 2, 1968, it released a Memorandum Opinion and Order 28 in which it found “no unresolved questions of fact remaining,”29 and therefore no necessity for a hearing. It accepted Hill’s and WREO’s denials of improper influence, noting that the Union had come forward with no further factual material to support its allegations. As to the Fairness Doctrine aspect of the Union’s claim, the Commission noted that WREO “has presented the [Union’s] advertisements,” and that after refusing to accept further copy on the subject it nevertheless offered free air time for a roundtable discussion. “In the circumstances,” the Commission concluded, “there is no need to consider further issues under the fairness doctrine.” 30 From this decision the Union appeals.
[254] II.
We have previously had occasion to point out that the Federal Communications Commission was intended by Congress to function as far more than a mere referee between conflicting parties.31 Regardless of the formal status of a party, or the technical merits of a particular petition, the FCC “should not close its eyes to the public interest factors” raised by material in its files.32 We have noted that, as a general matter, the federal regulatory agencies should construe pleadings filed before them so as to raise rather than avoid important questions. They “should not adopt procedures that foreclose full inquiry into broad public interest questions, either patent or latent.” 33
As a rule, “an administrative approval without the benefit of a hearing is to be avoided.”34 As we said in Clarksburg Publishing Co. v. FCC,35
The statute contemplates that, in appropriate cases, the Commission’s inquiry will extend beyond matters alleged in the protest in order to reach any issue which may be relevant in determining the legality of the challeged grant, [36] Clearly, then, the inquiry cannot be limited to the facts alleged in the protest where the Commission has reason to believe, either from the protest or its own files, that a full evidentiary hearing may develop other relevant information not in the possession of the protestant.37
We need not here decide whether the Union’s allegations that im.proper economic pressure had been exerted upon WREO to cause it to cancel Union advertising raises an issue of “such overriding public interest that the Commission would have been bound to consider [it] on its own initiative.”38 We are convinced, however, that on the present record something more than summary treatment of the Union’s allegations was required.39 The Union’s [255] claim that no radio station serving Ash-tabula would carry its advertisements stands undisputed. It can hardly be said that the proffered advertisements were objectionable on their face.40 WREO had, in fact, carried 322 such announcements without any apparent hesitation. Nothing in the record suggests that mere repetition was the basis for discontinuing the advertisements, and the station did not offer to broadcast a more limited number of spot announcements, or suggest to the Union that it change its copy more frequently than had been its practice. Moreover, in the nine months following cancellation WREO broadcast more than a thousand spot announcements for Hill’s Ashtabula, an average of over one hundred per month.
Nor can we or the Commission be oblivious of the attitudes of other stations in the area.41 It strikes us as curious, at least, that the general attitude of enterprises whose very existence was dependent upon advertising revenues appears to have been that the proffered advertising would be rejected unless the public interest compelled its presentation.42
Certainly these circumstances may validly be considered as giving rise to a justifiable suspicion that something might have been amiss. Viewed against this background, we cannot say that the responses of Hill’s Ashtabula43 and WREO44 satisfactorily disposed of the matter. Explaining is decision to cancel the Union’s advertisements, WREO merely stated that it had become “apparent, from complaints of the public, that the continuous repetition of these partisan announcements had become an irritant to WREO’s listening audience.”45 The station never undertook to explain how many complaints it had received, or from whom they came; whether complaints had been received regarding other advertisements carried by the station; whether its general policy was to cancel all advertising that was the subject of some listener complaints; or whether the public’s objections might have been cured by less frequent broadcasting of the announcements, or more frequent changes in the Union’s copy.
In light of these ambiguities in the station’s response, some further investigation was certainly necessary. It may well be that, with proper use of the discovery mechanisms available in such matters,46 an adequate record can be made without the necessity for a full-dress evidentiary hearing.47 We hold only that, on the present record, the undisputed facts raise questions adequately answered neither by the station’s ex[256] planations nor by the Commission’s opinion.48 In these circumstances, we cannot say that the renewal of WREO’s license is properly supported by the record.
III.
We are likewise concerned by the Commission’s summary treatment of the fairness question.49 Since the case is to be remanded in any event, there is no need for a full discussion of the question here. But in light of the inadequacy of the Commission’s opinion on this point, we believe it wise to provide a brief indication of some of the issues the Commission should face in this regard upon remand.50
A. Since its inception, federal regulation of radio and television broadcasting has been premised in large part upon the assumption that physical factors unique to this means of communication make both appropriate and necessary special means of regulation that will take into account the particular characteristics of the medium. The limited number of channels available for broadcast, and the possibility of interference among neighboring stations, of necessity required restrictions upon persons seeking to make use of the airwaves.
These restrictions could, perhaps, have been limited to technical matters : allocation of broadcast frequencies, transmitter power, and the like. This, however, has not been the case. Instead, the Commission has interpreted its statutory mandate to insure that broadcasting serves the “public interest, convenience, and necessity” 51 as authority for at least limited regulation of the content of broadcast material.52 The bulk of this regulation has been subsumed under the Commission’s “fairness doctrine.” Simply stated, the doctrine requires each broadcaster to afford “reasonable opportunity for the presentation of contrasting viewpoints on controversial issues of public importance.” 53
[257] As the doctrine has developed, its central purpose has become increasingly clear. That purpose has been to insure both that the listening public is presented with information regarding controversial issues of public importance,54 and that facts, analysis, and argument supporting all reasonable positions on a given issue are aired by the broadcasters.55 That is, central to the fairness doctrine is the promotion of informed decision-making by the public by insuring that the facts and arguments relevant to decision are made available to the listening audience.
If this were the whole of the doctrine, it might well be that no substantial question would be raised by WREO’s denial of air time to the Union for its advertisements. More than three hundred spot announcements had been broadcast by the station in less than two months. Taking the sample before us 56 as typical, the advertisements merely stated that a strike was in progress, listed the issues in dispute but without giving any indication of the positions of the opposing parties, and urged without giving any reasons that listeners support the Union by boycotting Hill's Department Stores. It is difficult to see how repetition of this or similar copy would add to public knowledge, except perhaps that each repetition of the advertisement would inform the public that the strike was still in progress — information that we may well assume was sufficiently presented by regular broadcasts of local news.
But the Supreme Court,57 this court,58 and the Commission itself have all recognized that the fairness doctrine is not an island whole unto itself. It is merely one aspect of the Commission’s implementation of the requirement that broadcast stations serve the public “interest, convenience, and necessity.” Accordingly, although as a general matter equal time is not required so long as a reasonable opportunity is afforded for the presentation of opposing viewpoints,59 the Commission has upon occasion recognized that time, rather than information, is of the essence. Thus, in regard to broadcast spot announcements soliciting campaign contributions, the Commission has recognized that at least with regard to two major party candidates, “fairness would obviously require that these two be treated roughly the same with respect to the announcements.” 60 Presumably, the additional information presented to the public by repeated announcements would be minimal; the value of repetition would be solely in the additional coverage obtained.61 Similarly, in Times-Mirror62 a station had aired more than 20 broadcasts by commentators favoring one major-party candidate for governor, and 2 broadcasts by commentators favoring his opponent. Summarizing its ruling, [258] the Commission stated that “[t]he continuous, repetitive opportunity afforded for the expression of the commentators’ viewpoints on the gubernatorial campaign, in contrast to the minimal opportunity afforded to opposing viewpoints, violated the right of the public to a fair presentation of views.” 63 Most recently, in the Commission’s landmark ruling on cigarette advertising,64 the Commission stated:
We think that the frequency of the presentation of one side of the controversy is a factor appropriately to be considered in our administration of the Fairness Doctrine. * * * For, while the Fairness Doctrine does not contemplate “equal time”, if the presentation of one side of the issue is on a regular continual basis, fairness and the right of the public adequately to be informed compels the conclusion that there must be some regularity in the presentation of the other side of the issue.65
In the present case, it seems clear to us that the strike and the Union boycott were controversial issues of substantial public importance within Ashtabula, the locality primarily served by WREO. The ultimate issue with regard to the boycott was simple: whether or not the public should patronize Hill’s Ashtabula. From April through December, Hill’s broadcast over WREO more than a thousand spot announcements and more than a hundred sponsored programs explaining why, in its opinion, the public should patronize its store. During that same period, the Union was denied any opportunity beyond a single roundtable broadcast to explain why, in its opinion, the public should not patronize the store. We need not now decide whether, as the Union would have us hold, these facts make out a per se claim of a violation of the fairness doctrine. We do believe, however, that the question deserves fuller analysis than the Commission has seen fit to give it.
B. Central to the Union’s argument on this point is the proposition that, in urging listeners to patronize Hill’s Ash-tabula Department Store, Hill’s advertisements presented one side of a controversial issue of public importance. Hill’s copy, of course, made no mention of the strike or boycott, or of the unresolved issues between the Union and the store. But the advertisements did urge the listening public to take one of the two competing sides on the boycott question —they urged the public to patronize the store, i. e., not to boycott it. It seems to us an inadequate answer to this argument merely to point out that Hill’s copy made no specific mention of the boycott. In dealing with cigarette advertising, the Commission has recognized that a position represented by an advertisement may be implicit rather than explicit66 And although the Commission repeatedly emphasized that its holding in that ease —that stations broadcasting cigarette advertisements must regularly provide free time if necessary for the presentation of arguments opposing cigarette smoking — was limited to cigarette advertising, the reasons advanced by the Commission to support that limitation seem to us not to imply that other advertisements may not carry an implicit as well as an explicit message, but rather that the implicit and explicit messages normally carried by advertising do not concern controversial issues of public importance.67
[259] C. The Commission’s ruling with regard to cigarette advertising relied heavily upon the judgment of other branches of government that, in light of the possible dangers of smoking “to the health of millions of persons,”68 the question whether or not to smoke cigarettes was one of substantial importance to the public.69 In its regulation of. labor-management relations, Congress has indicated substantial concern with equalizing the bargaining power of employees and their employers.70 Stripped to its essentials, this dispute is one facet of the economic warfare that is a recognized part of labor-management relations: the Union, in urging a boycott of Hill’s Department Stores, was seeking to put economic pressure upon management to accede to its demands; management, on the other hand, was seeking to resist the Union’s pressure by continuing profitable operations. Part of the Union’s campaign was publicity for its boycott; part of management’s arsenal was advertising to persuade the public to patronize its stores.
If viewed in this light, it could well be argued that the traditional purposes of the fairness doctrine are not substantially served by presentation of advertisements intended less to inform than to serve merely as a weapon in a labor-management dispute. But the fairness doctrine, as we have pointed out, is only one aspect of the FCC’s implementation of the statutory requirement that broadcast stations operate to serve the public interest.71 The public policy of the United States has been declared by Congress as favoring the equalization of economic bargaining power between workers and their employers.72 It is at the very least a fair question whether a radio station properly serves the public interest by making available to an employer broadcast time for the purpose of urging the public to patronize his store, while denying the employees any remotely comparable opportunity to urge the public to join their side of the strife and boycott the employer. If the Union’s claim is to be rejected, we believe this question should be dealt with by the Commission.
IY.
In summary, we believe that the Union’s evidence of denial of access to radio air time raised questions regarding possible improper influence by Hill’s that were not adequately answered by Hill’s bare denial and the station’s letter of denial and explanation. With regard to the Union’s fairness question, we recognize the primary responsibility, of the FCC in assuring that radio broadcasters operate their stations in the public interest. We have not here attempted a full canvass of the issues raised by even a good-faith denial to the Union of access to broadcast time; we have merely sought to indicate some of the questions that must be answered. We do believe, however, that these issues deserve far more comprehensive treatment than was afforded them by the FCC. Accordingly, we remand the case to the Commission for further proceedings consistent with this opinion.
So ordered.