Report on the January 28, 2005 Media Scholars' Symposium, "Democratic Principles in Media Policy for the 21st Century," and Proposals for Future Research

April 4, 2005

On January 28, 2005, more than 30 media scholars met at Fordham University to discuss two related issues: goals, issues, and strategies for media reform; and research initiatives for the next round of Federal Communications Commission proceedings on media ownership.1 The symposium, entitled "Democratic Principles in Media Policy for the 21st Century," was organized by the Brennan Center for Justice at NYU School of Law and co-sponsored by the Media Access Project and the Donald McGannon Communication Research Center at Fordham.2

This report summarizes the day's discussion, outlines directions for future research, and describes some initiatives for collaborative work that emerged from the symposium.

Morning Session: Goals, Issues, and Research Strategies for Media Reform

Structural Regulation and Scarcity. The most prominent issue that the group addressed was the need to articulate persuasive policy arguments for structural regulation of the mass media, especially in the face of widespread disenchantment with the so-called scarcity rationale.3 Many scholars (and some judges) claim that scarcity no longer exists, given the plethora of information sources now available in addition to broadcast radio and television, and that therefore the justification for treating broadcasting differently from other media is obsolete. However, courts continue to rely on scarcity in applying a lenient standard of First Amendment scrutiny to government regulation of broadcasting.4

Ellen Goodman pointed out that cable and satellite have become the dominant purveyors of television; the role of video gatekeeping is shifting from the broadcast networks to cable and satellite, video on demand menus, search engines, and broadband providers. Therefore, as important as ownership rules for broadcasting still are, policy-oriented scholarship must consider other levers for regulation and subsidies. Leonard Baynes responded that even assuming the eventual demise of analog broadcasting, the airwaves are still a government resource, making them very different from the Internet, and subject to different regulation. There is also clearly scarcity with respect to race: only 2.5% of broadcast outlets are owned by minorities.

Harold Feld said that there is still a need for regulation of the broadcast industry to deal with the FCC"s history of granting licenses overwhelmingly to ever-larger commercial entities. Joel Waldfogel questioned, however, whether media concentration is necessarily a bad thing, given that it is expensive to produce good programming. Monroe Price asked whether policymakers and advocates should stop focusing on broadcast media and the public interest obligations of broadcasters.

Steven Wildman noted that economists argue persuasively that all resources are scarce, and that there is more competition in broadcasting than in most media. Is scarcity a red herring? Perhaps the real question is how to get more resources for more diverse programming.

Regardless of the viability of the underlying rationale for differential treatment of the broadcast industry, it was agreed that the structural problem of media consolidation - vesting increasing power over media content and distribution in fewer and larger companies - is not limited to broadcasting. Cable operators generally have monopoly control in their franchise areas, and even the Internet is increasingly dominated by the websites of large corporations. As Ben Scott argued, it is important to identify where scarcity exists. In theory, we have unlimited channels and websites. But we have a problem of artificial scarcity through gatekeepers. Cable systems are choke points for deciding what television most Americans receive, and they are killing independent channels. All of the incumbents in the media industry are trying to protect their spectrum bands, even while their capacity for carrying much more programming, from more varied and diverse sources, expands.

Mark Lloyd added that there has been a deliberate attempt by libertarians to confuse the notion of scarcity. It is still the case that many more people want to be licensed than the government actually licenses. The focus should be on who is licensed (e.g., not minorities). Thus, the issue is scarcity of licenses, not scarcity of channels. We must talk about why we allow the federal government to give licenses to some people and not others.

The need for both theories and empirical research to support structural reform is evident. Several participants argued for advancing a democratic values approach to media policy, in addition to more quantitative or functional approaches.

Other Media Reform Issues. Other important goals and issues identified during this session included: (1) localism - that is, advancing media coverage of local issues and concerns, both political and cultural; (2) demand and consumption in the context of civil society - that is, what is in the public interest is not necessarily what the public is interested in; (3) racial and ethnic diversity, both in mass media content and in the ownership of mass media outlets; (4) access and "bottleneck" issues such as cable industry control over broadband Internet access; (5) subsidies for nonprofit alternative media; and (6) the connection between media industry structure and intellectual property issues.

Regarding both coverage of local issues and consumption, Lewis Friedland pointed to case studies and quantitative data showing that when media outlets digest political information, people respond to it. The public journalism movement provides abundant evidence of this. What is important is high quality, digested, well-reported local civic information - not just a flood of information. But this costs money. Citizens also understand that they need local democratic communication. What they don't see is a policy strategy that speaks to that understanding. Scholars and advocates need a framing strategy that shifts the terms of the discussion to focus on affirmative democratic needs and values.

Ellen Goodman urged that policymakers and scholars also should not shy away from the issue of improving media quality. Can policy be developed that focuses on subsidies for quality content? Can we look to spectrum auctions as a source of money for subsidies? Most new licensing is by auction; should there be a policy that licenses are not just issued according to financial ability?

Federico Subervi noted that there are no studies systematically being done on the content and quality of local Spanish-language broadcast news, except for one study in California on the preparedness of Spanish-language broadcasters to deal with emergencies. The researchers made recommendations based on an earthquake that struck during the time of the study. Similar content analyses of Spanish-anguage media in other regions and states would be useful. Billions of dollars are spent on research, but nothing on how Spanish-language TV affects children. Finally, ownership of Spanish-language media affects its content. NBC/GE own one large Spanish-language network, whose content is driven by what the owners consider profitable across the board - that is, not local content, but homogeneous content for a mass audience. With more Internet access, some Latinos will tune into the stations and media from their home countries, and potentially delay their adaptation into U.S. society.

Mark Lloyd agreed with the need for content analysis, to critique the arguments of commercial broadcasters that they are providing sufficient news coverage, when much of it is sports and car crashes. How does the content of local news actually serve the information needs of diverse communities? Similarly, conservatives have been successful in describing the media as liberal. Content analysis can address that claim. At the same time, there must be alternative media that can supply information and messages that are not heard from the mainstream press. Eric Klinenberg reiterated the need for documentation of how many journalists are actually doing local news reporting.

Balazs Bodo noted that noncommercial media are a good model, but community broadcasting does not have to be defined in a geographic way. Media policy should serve the needs of linguistic and cultural communities as well. Linda Garcia agreed that when we talk about local content, we often limit it to politics and information, and ignore culture. The geography of culture can be tracked. What does it take to create local cultures? "Local" need not be defined in terms of geography.

Mark Cooper warned against government subsidies for alternative media, arguing that public funding necessarily leads to government control. Instead of looking for public funds, there should be a way to finance truly independent broadcasting. Moreover, quality content does not necessarily need high production values. PBS stations with low production values but rich local content are successful in attracting viewers. Edwin Baker responded that non-publicly funded nonprofit media may not be needed. In most countries, public broadcasting is independent of the government and produces better quality, more independent content than private broadcasting. Eric Klinenberg urged a two-pronged strategy: advocating both for independent media, and for public interest obligations of commercial broadcasters.

Ben Scott identified two related access issues that loom particularly large in view of the predicted demise of broadcasting in 10-15 years. First, how do policymakers assure nondiscriminatory access to fiber and broadband networks, since the large technology and cable companies are already preparing for this transition? Second, there should be First Amendment-based arguments for access to the spectrum. Public access must be part of policy. Research can demonstrate that common carrier and public spectrum access requirements produce better democratic content and a richer democratic society. Stefan Verhulst agreed that research is needed to show where gatekeeping takes place and what it means for public values - an overview of the various chokeholds where decisions get made.

Federico Subervi returned to the issue of minority ownership. He pointed out that much of the Spanish-language media is Anglo-owned. Everett Parker said that the core of the problem is financing: there is systematic discrimination against blacks and women that goes beyond cable companies or broadcasters to financial institutions. Advocates need to reach the bankers - Citigroup, J.P. Morgan, Deutsche Bank, Bank of America. Venture capitalists are investing in experimental websites, but not in minority and women-owned media. Aliza Dichter said that environmental justice activists have been successful at challenging banking and investment practices - a model that media activists might study.

Finally, Ellen Goodman emphasized the relationship between the media reform movement and the movement challenging the current system of intellectual property. There should be more cross-pollination. Theoretical access to the Internet is not enough if digital rights management tools control the ability of the public actually to use information. The Internet thus cuts both ways - there are many more voices, spread over more outlets, but media companies can also exercise more control. Harold Feld said that on the advocacy level, there is tremendous overlap between media policy and IP concerns. Empirical research can make the connections, and a theoretical framework can link the two related policy issues.

Len Baynes summarized: We are talking about reframing the issue, away from scarcity and towards essential communication services, including minorities, culture, and localism.

Afternoon Session: Research for the Next FCC Media Ownership Review

The FCC Media Ownership Review. Harold Feld introduced this session. The Telecommunications Act of 1996 required the FCC to engage in a biennial review of media ownership rules, to assure that they are still in the public interest. The FCC's first biennial review was challenged in the U.S. Court of Appeals for the D.C. Circuit, which perceived a deregulatory bias in the 1996 Act, and accordingly required strong justifications for every media ownership rule. In 2003, the FCC issued new rules, which were challenged in the U.S. Court of Appeals for the Third Circuit last year in the Prometheus case. The Third Circuit did not think the FCC was required to demonstrate a deregulatory bias and eliminate existing rules. This cleared the field to focus on what the actual rules should be, in what are now quadrennial, not biennial, reviews. On remand from the Third Circuit decision, the FCC may decide to break up the proceeding into smaller chunks in order to avoid the visibility and political fallout of its 2003 rules.

Mark Cooper pointed to the many citations to empirical research in the record of the Prometheus case. That was a deliberate strategy over the past five years, to pull together academic research, in particular relating to the FCC's "diversity index." The court of appeals accepted the idea of a diversity index but found every aspect of calculating that index was a disaster. The FCC evaluated all television as the same for purposes of providing diverse content. The notorious example was counting Dutchess County Community College TV the same as Channel 4. The court said that the FCC must weight the media properly. It listed what media do, relying on communications scholarship, and found that the Internet is not relevant in terms of providing local programming or political news that differs from radio, television, and newspapers. But this debate is not over, because the broadcasters will come back with research from the last election, attempting to show that the Internet had a huge influence.

Another critical research question, said Cooper, is that once there is an index, where should the thresholds be set in terms of excess ownership concentration? Does the Communications Act set a higher threshold than antitrust law? How many voices do we need? There is a great deal of survey research to be done, to learn how people use and trust different media. Asking "which media influence your opinions?" instead of "what media do you use?" generates a different answer. Harold Feld noted that the FCC considered both ownership diversity and source diversity - that is, the availability of media content from a variety of producers - but found source diversity irrelevant to the question of consolidated ownership. Joel Waldfogel added: if you have an index, then the question is, what are the right values to put into it? You need evidence plus theory to figure out the desirable outcome.

Mark Lloyd read the Prometheus decision not as an endorsement of the FCC's diversity index, but as an endorsement of the relevance of measuring viewpoint diversity, The court critiqued the FCC for not taking account of how different communities use media. The agency used an antitrust model, and did not draw conclusions about the nexus between ownership and content. The FCC media ownership threshold is subject to major debate. Mostly, it focused on news; less on public affairs; almost not at all on entertainment programming. A number of things might be redone in order to construct a sound review of local viewpoint diversity. This review would combine antitrust analysis, content analysis, and use analysis - measuring how communities are using the media. The end result would be a reform-oriented threshold for media concentration.

In response to Federico Subervi's question whether the FCC's diversity index reflected Spanish language or any other minority language media, Mark Cooper explained that Spanish media shows up as another channel, but the index did not look at the language of the programming. Harold Feld said that research on this in the upcoming proceeding would be useful. In the last round, the FCC refused to treat Spanish language media as a distinct market, but it might be persuaded to include this in a future index; and with good data, the FCC also might consider it in future merger proceedings involving Spanish language media. Even if the FCC continues to consider language irrelevant, the court of appeals might not. Len Baynes added that media concentration may affect minorities even more severely.

Arthur Hayes suggested a research project studying how the content of media targeting people of color changes when the ownership switches to nonminorities. It may be that Anglo owners are letting African American management serve as the gatekeepers and control the content. BET is owned by Time Warner, but may be controlled by African Americans. Thus, ownership may not be necessary to achieve diversity in content.

Edwin Baker asked whether the diversity index is supposed to measure voices or power. There are as many voices as there are people carrying signs, but the question is which outlets have the power to shape opinion. At an earlier time in the history of communications policy, the FCC's approach was that mergers and cross-ownership were presumptively bad. At a principled level, they had it right then. There is always a danger that indices will be badly constructed. Mark Lloyd agreed that it was properly understood 30 years ago that diversity of ownership matters; it is important for civil society. That should still be the primary argument, but since proceedings now turn on quantitative data, and someone is going to create an index, reform advocates need to address it.

Steve Wildman noted that although there is a connection between the Justice Department's antitrust index and the FCC's diversity index, the diversity index is more complex, because there are multiple goals. There is no simple quantifiable measure to accomplish the multiple goals of media policy, as there is with antitrust, where the measure is economic efficiency. We assume substitutability within a particular medium, but not across different media such as newspapers and TV. A diversity index must reflect an understanding of the different roles that different media play.

Harold Feld noted the importance of public involvement. The outpouring of public protest after the FCC released its June 2 2003 rules shocked and amazed the Washington advocacy community. Several hundred thousands comments were submitted in the recent FCC "Notice of Inquiry" on Localism. At FCC hearings around the country, there were lines of 4-5 hours for open microphones for people to talk about the ways in which media corporations are not serving local needs. The industry was overwhelmed in San Antonio, Clear Channel's home town. How can the public outpouring be put in a form that the agency can understand? A study by the Future of Music Coalition summarizing the comments submitted in the media ownership proceeding was very useful.5 People are telling specific stories, and aggregating and slicing that data informs the questions the FCC and the courts say are significant. If someone were able to digest those stories and distill patterns, including Comments submitted in the Localism proceeding, that research would be relevant to the FCC.

Eric Klinenberg said that the industry will be well prepared for the next round of proceedings, with data about serving minorities and localism. Clear Channel will say that they broadcast "Air America" more frequently than any other company. Harold Feld agreed that Clear Channel has learned its lesson about the importance of politics and image, and will be well prepared with data and expert testimony for the next round of ownership proceedings. At a legal level, all that is necessary to uphold the FCC is enough evidence in the record to show that its rulings look rational. Reform advocates will need to be able to critique the industry's testimony on how well it is serving the public.

Data Sources and Research Directions. Joel Waldfogel outlined some of the major policy questions that empirical researchers should address:

r How does regulation of media ownership affect the functioning of society?

r How do ownership regulations affect ownership patterns?

r How do ownership patterns affect the availability and targeting of content?

r How does the availability and targeting of content affect the public's behavior?

r Are people better informed when more media products target them?

r How does the use of information affect social outcomes such as voting?

These overriding questions suggest what data are needed: ownership statistics; analysis of content and how it is targeted, by outlet and medium; viewing and consumption patterns, disaggregated by groups and place; relationships between media content and civic outcomes.

Waldfogel then outlined sources of data. For radio, Arbitron reports on audience by outlet and group. Duncan's American Radio supplies value-added Arbitron data: Arbitron plus ownership, formats, and revenue estimates. BIA Media Access Pro is similar to Duncan's.

For newspapers, the Audit Bureau of Circulations gives circulation by MSA, county, and zip code. Burrelle's Media Directory gives total circulation and staffing (including number of reporters by beat). Editor & Publisher gives ownership information, but is relatively difficult to use because it is not computerized.

Data sources for television include Nielsen, which is expensive. Its rating books are also not in a useful form. BIA Media Access Pro contains some Nielsen data: audience, ownership, and affiliation. Broadcast Cable TV Factbook can be a useful source.

For Internet use, there is Current Population Survey, which is free and downloadable; various computer and Internet use supplements, from 1997 to the present; and the Pew Internet & American Life Project research surveys.6 Data sources for individual media behaviors and demographics include Scarborough Research and Forrester Research. Their data are useful but expensive.

Philip Napoli and Eric Klinenberg mentioned that there are currently scholars doing research on staffing levels and collecting demographic data about TV news reporters. Klinenberg said that reports of massive increases in employees are misleading because they may be working in sales and marketing, but be counted as journalism. Robert Horwitz noted that TV subscription data is also untrustworthy. Federico Subervi agreed: the National Association of Hispanic Publications Directory is useful, but questionable. If companies do not advertise in the directory, they are not included. Some are inaccurately reported to be dailies.

Philip Napoli added that the "Zap To It" website7 is a primary source of information about programming content, with more than 70 data fields, including local news and public affairs programming. The website has a two-week window. Google may also soon provide transcripts of television programs.

Napoli has bought Nielsen data for 20+ local markets that are measured six times per year. This is for a study on who is targeted and who is neglected in political advertising campaigns. Lew Friedland noted that Professor Ken Goldstein at the University of Wisconsin has an archive of both advertising and broadcast news in a large number of markets in multiple states over a number of years. Klinenberg noted that the University of Southern California/Annenberg Center is also analyzing this data.8

The discussion turned to ways of pooling of this data. Agreements under which data sets are purchased are sometimes restrictive, though old data, which are no longer commercially valuable, might be easier to purchase and share. With elevated bargaining power, negotiating multi-year licenses with data set providers might be possible. A project could emerge from this meeting that would to develop a cost estimate for an up-to-date and renewed data repository.

Data that the FCC use, on the other hand, must be publicly available - though in reality, it is also often difficult to access. Mark Cooper recalled that although the FCC will force the industry to make its data available, it is only within the confines of the FCC building.

Another major need that was identified is a central clearinghouse for abstracts, both of current and past research. Linda Garcia emphasized that this should go be beyond strictly communications policy research to include cultural studies, history, and sociology. The FCC only references economics journals. There are different definitions of scarcity in law and economics. Scholars need to bridge the gaps.

Summary: Research Needs

This section summarizes suggestions made during the symposium for future research. Philip Napoli and Nancy Gillis's recent paper on the Prometheus decision and the diversity index helped frame some of the suggestions here.9 In addition, this section incorporates post-conference suggestions made by Toby Miller, as well as suggestions made by the Media Access Project in a memo prepared after the FCC's 2003 ownership decision, and included in the materials for the symposium.

I. Scans of Existing Research

A. Determining what other bibliographies or sources of abstracts exist.

B. Scanning cultural studies, sociology, and history as well as communications and economics journals for relevant research.

II. Media Structure/The Effects of Consolidation

A. Measuring the quantity and quality of media diversity through antitrust, content, and use analysis.

B. Measuring the relationship of ownership concentration to viewpoint diversity in local news and public affairs programming.

C. Measuring the relationship between concentrated ownership and minority ownership.

D. Measuring the relationship between concentration of ownership and the size of local news staffs.

E. Measuring the relationship between concentration of ownership and quality of programming.

F. Measuring the relationship between concentrated ownership and targeting of program content.

G. Measuring the relationship between ownership regulation and ownership patterns.

H. Measuring the relationship between deregulation and the growth of talk radio.

I. Measuring the amount of source diversity - including programming from independent producers - and its relationship to concentration of ownership.

J. Expanding on the Future of Music Coalition study measuring the relationship Between radio consolidation and radio program diversity.

III. Media Content and Effects

A. Analyzing news and public affairs programming:

- content of coverage, including expansion of Annenberg/U. of Wisconsin/Seton Hall research on coverage of local elections;
- relevance of coverage to diverse communities;
- amount of viewpoint diversity.

B. Analyzing content of programming targeted to ethnic and racial minority groups:

- quality in local Spanish language media;
- relationship of Hispanic station ownership to civic outcomes;
- relationship between content of media targeting people of color and change of ownership from minority to Anglo.

C. Analyzing the effect of programming with civic and cultural value, including quality journalism:

- the role of "merit goods" that the public does not necessarily demand;
- the sociological perspective on quality political programming and richer democracy;
- empirical research on the importance of community media to education, health, and other civic concerns.

D. Case studies:

- media response to disasters and emergencies;
- other types of case studies

E. Measuring the use of video modification and insertion in TV reporting.

F. Measuring and analyzing the effects of digital product placement.

G. Measuring how different genres - sport, drama, news, music, current affairs - affect nationalism and internationalism.

H. Analyzing the implications of niche-targeted cable channels for citizenship and democracy, e.g., the relationship of the Food Network to agriculture, labor, poverty, and health policy; relationship of the Weather Channel to environmental policy.

I. Identifying international programming that is not aired in the U.S.

IV. Consumption

A. Measuring local media consumption patterns and analyzing why consumer attention moves as it does.

B. Surveying how people use different media and which sources they trust, e.g., local/national news, TV, talk radio, print, the Internet.

C. Measuring how the availability and targeting of content affects consumer behavior.

D. Measuring how the targeting of content affects knowledge.

E. Analyzing industry data on the extent of copyright infringement or alleged infringement, including claims of lost revenues.

F. Measuring the effects of universal service/e-rate discounts for Internet access.

V. Mediators, Bottlenecks, and Gatekeepers

A. Measuring the relationship of common carrier and spectrum access to democratic content.

B. Measuring the relationship of industry structure to intellectual property policies and conflicts.

C. Identifying where gatekeeping takes place - where are the chokepoints and who are the key intermediaries?

VI. Advocacy

A. Analyzing the testimony at the FCC's 2004 localism hearings.

B. Supplementing the Future of Music Coalition's analysis of Comments submitted in the FCC's ongoing Localism proceeding.

C. Documenting cross-pollination between media reform and copyright/public domain advocacy.

D. Surveying international media reform advocacy and international response to the dominance of U.S. media around the world.

E. Analyzing how international consumers and advocates might be brought into the U.S. policy debate.

F. Measuring what language in place of scarcity would resonate with the U.S. public and Policymakers.

G. Surveying and analyzing alliances and potential alliances of media reform advocates with mainstream religious groups.

H. Surveying and analyzing the situation of workers throughout the media industry, Including working conditions and issues of journalistic ethics.

VII. Subsidies/Independent Media

A. Analyzing different methods for funding noncommercial broadcasting.

B. Analyzing how copyright policy might be used to support noncommercial media.

Future Work

A task force consisting of Joe Karaganis, Phil Napoli, and Marjorie Heins met after the symposium to discuss the development of a clearinghouse of research abstracts, a repository of data sets usable by researchers, and a fellowship program that would place scholars in advocacy organizations and provide rapid research response to advocacy needs. These plans are in the development stage.

A task force on global media policy, spearheaded by Richard Maxwell, Toby Miller, and Michael Botein, is planning a meeting on global media issues, to take place just before the opening of the International Communications Association's annual conference in May 2005.

A task force on racial and ethnic diversity is planned to discuss a possible meeting or conference focusing on research needs in this area of media policy. Those who expressed interest in this task force include Len Baynes, Arthur Hayes, Federico Subervi, Everett Parker, and Marjorie Heins.

The media scholars listserv, housed at NYU and administered by Marjorie Heins at the Brennan Center, will continue to be a forum for the exchange of views, communications about new research, possible collaborations, and links between scholars and advocates.

NOTES

1. In July 2003, the FCC issued a "Report and Order" on Broadcast Ownership which significantly loosened restrictions on mass media consolidation. The Order was challenged and struck down in Prometheus Radio Project v. FCC, 373 F.3d 372 (3rd Cir. 2004), and the court sent the case back to the agency for further consideration.

2. A list of the participants and their institutional affiliations is attached.

3. The Supreme Court has ruled that the government may regulate broadcasting more heavily than other media in part because the public airwaves are a scarce resource with a limited number of frequencies; thus, not everyone who would like to broadcast is able to obtain a license. In return for free use of the public airwaves, broadcasting can be regulated both structurally, in order to promote a diversity of ownership and viewpoints, and substantively, through such requirements as an obligation to cover controversial issues or provide equal time to political candidates. FCC v. National Citizens Committee for Broadcasting, 436 U.S. 775 (1978); Red Lion Broadcasting Co. v. FCC, 395 U.S. 367 (1969); National Broadcasting Co. v. United States, 319 U.S. 190 (1943).

4. E.g., Prometheus Radio Project v. FCC, 373 F.3d 372 (3rd Cir. 2004).

5. See Press release, "Citizens Urge FCC to Retain Current Media Ownership Rules: FCC Public Record Shows Overwhelming Opposition to Relaxing Ownership Caps," May 14, 2003, http://www.futureofmusic.org/news/PRFCCdocket.cfm; Analysis of the FCC Docket 02-277: State-by-State Tallies (FOMC), http://www.futureofmusic.org/research/FCCdockettally.cfm.

6. See http://www.pewinternet.org.

7. http://www.zap2it.com/index.

8. Matthew Hale of Seton Hall University is also part of this research team. See Press release, http://ascweb.usc.edu/asc.php?pageID=388&storyID=61,
and the report, Local News Coverage of the 2004 Campaigns,
http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=
pdf&id_document=6517182040.

9. Reassessing Communications Research's Potential Contribution to Communications Policy: The Case of Media Ownership and the Diversity Index, McCannon Communication Research Center, 2004,
http://www.fordham.edu/images/Undergraduate/communications/Communications%
20Research%20and%20Communications%20Policy.pdf.