POLICY STATEMENT OF THE NATIONAL ORGANIZATION FOR WOMEN on legislation to Rewrite or Amend the Communications Act of 1934

The National Organization for Women (CW) has long recognized that women have a major stake in the establishment of social policy goals in the telecommunications industry. In 1971, NOW called for

the Federal Communications Commission to guarantee fair treatment of women (in image, programming, news coverage and employment) in the broadcasting industry.

NOW continues to believe in the validity of the basic concept encompassed in the Communications Act of 1934--that broadcasters hold a public trust--the airwaves. And, the scarcity of these airwaves have put a special obligation on the industry to broadcast in the public interest and necessity.

Since 1934, our nation has seen the development of television, cable systems, satellite communications and other technological advances. NOW supports the efforts of Congress to review the telecommunications policy of our nation in light of these advances. We support the need for an assessment of the legal and regulatory structure that governs the broadcast and cable industries. NOW welcomes the opportunity to participate in helping to mold these new policies from a feminist perspective. We urge the Congress and federal agencies to make every possible effort to ensure that the views of a wide range of feminist organizations and public interest groups are included in the debate on the future of the telecommunications industry.

However, reforms in this rapidly expanding industry must contain certain basic public rights including the following: --Broadcast licenses must be regulated to provide an affirmative obligation to afford equal employment opportunities regardless of sex, race, color, creed, national crigin or sexual preference;

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--The regulatory agency administering telecommunications policy must be granted the authority to enforce EEO provisions and for effective review of equal employment progress;

--The public trusteeship standard must be maintained as a basis for awarding and evaluating the performance of television and radio licenses;

--Licensees must be required to ascertain the problems, needs and interests of the communities they are licensed to serve. Organizations for and of women must be considered a significant community group during the ascertainment procedures;

--Federal programs should be established to assist women in their ability to purchase and control broadcast stations;

--Licenses must be obliged, first and foremost, to cover all controversial issues of public importance. These issues must continue to be presented in a balanced, fair and accurate manner; --Broadcast licenses must be issued for a fixed term and standards must be developed for reviewing their performance.

--Provisions must be developed for reimbursement of citizen participation in all agency proceedings that relate to telecommunications policies. Compensation for participation is especially necessary to present responsible positions that would not otherwise be present, but for such compensation;

--Candidates for public office must have equal access to radio and television broadcast facilities, whether free or on a paid basis;

--Policies on written agreements between radio and television broadcast stations and citizen groups should be developed by the regulatory agency, if found to be consistent with the public interest standard of broadcasting;

--Congress should support continuing research to determine
the impact of television programming and advertising on sex
discrimination and sex-role stereotyping in the American society;
--Television broadcast networks should be regulated under the
same public interest standards as licensees with respect to program
acquisition, presentation of news and public affairs and
equal employment programs;

--Specific authority must be granted to the regulatory agency
to establish rules governing overall multiple ownership of
broadcast stations and limiting the ownership of such stations
in any market on the basis of ownership interests in other
communications media such as newspapers or cable systems.
Such rules should have the effect of encouraging diversity
of ownership of broadcast stations including the increased
ownership of stations by women and minorities;

--Public broadcasting stations receiving Federal support should
be accountable to the communities they serve through public
advisory boards and through full financial disclosure.

--Public broadcasting provisions must insure that program time
and resources be utilized to support and encourage the diversity of
American talent and creativity. Such provisions must encourage
the equal participation of women and minorities in such public
activities;

--Cable television should be regulated under telecommunications
legislation as an alternative to, and competitor of, commercial
television;

--Ownership of cable systems by diverse groups, including
non-profit, local, minority, feminist, cooperative and
governmental should be promoted.

--Cable systems should be required to provide adequate channels
space for use by public interest groups in the community they
serve;

--Access to facilities of cable television systems should be
on an equal and non-discriminatory basis;

--Owners or operators of cable systems should exercise no controls over program content presented by other persons on the cable system;

--The regulatory agency responsible for enforcing telecommunications
policy should also be granted the authority to require equal
employment rules of communications industries other than
braodcasting whose policies are regulated by the agency.
This includes common carriers, telephone and satellite

operators, cable operators and other telecommunications companies.

STATEMENT REGARDING H.R. 3333

given at Citizens Communications Hearings
June 1, 1979

San Diego, California

Our

I am Sister Monica Clark, Director of Communications for the San Diego County Ecumenical Conference, an organization of more than 100 Orthodox, Roman Catholic, and Protestant churches. concern regarding proposed changes in federal communications legislation goes far beyond any regulations regarding so-called religious programming. We are concerned that the air waves continue to be held as a public trust and used for the good of

all people.

The current proposal of Congressman Lionel Van Deerlin, H.R. 3333, if passed, would destroy the long standing legal tradition that maintains this public trust. It would surrender the air waves to broadcasters with little or no public

accountability, except as it might be reflected through advertising revenue. It would, in effect, render the American masses powerless in the face of a few broadcast owners and managers who in the marketplace are ruled more by consumer ethics than by public

service.

Today I am urging that the public interest standard be maintained in communications law so that the American people's right to be involved on all levels--from review of broadcast licensing to editorial reply--be protected. Specifically, however, I wish to address myself this afternoon to three areas of public involvement--ascertainment, equal time opportunities, and the Fairness Doctrine.