The Leadership Conference Reply Comments for the 2022 Quadrennial Review of Media Ownership Rules

View PDF of comments here.

Re: MB 22-459, 2022 Quadrennial Regulatory Review

Dear Chair Rosenworcel:

On behalf of The Leadership Conference on Civil and Human Rights, a coalition charged by its diverse membership of more than 230 national organizations to promote and protect the rights of all persons in the United States, and the undersigned members of its Media/Telecommunications Task Force, we write in response to the public notice seeking comment for the 2022 Quadrennial Review of Media Ownership Rules.[1] Media diversity has long been a priority for The Leadership Conference and its members because we understand that meaningful protection of civil rights and advancement of key policy objectives rely in great measure on an accurate, diverse, and independent media that serves our constituencies.

I. Broadcast media continues to be a critical source of information for consumers all over the country

Broadcast media continues to play a critical role in our democracy, and local broadcast news affiliates remain the most trusted source of information for consumers looking to get involved in their community and to exercise the right to vote — two areas where consumers uniquely rely on broadcast media.[2] Consumers over 50 prefer to get their news from television rather than digital sources of information, and both television and radio are still important sources of news across demographic groups.[3] Additionally, recent studies have shown that an increasing number of people are returning to local television as their primary source of news.[4]

Given the importance of local news, it is crucial that the owners of these stations reflect the communities they serve. Diverse voices in the media landscape help to ensure that diverse topics and perspectives are presented to counter disinformation and misinformation.[5] Unenforceable pledges by media companies are not enough to ensure diverse voices are present in their newsrooms.[6] The presence of powerful, diverse voices and rules that protect the ability of these voices to maintain a seat at the table in newsrooms are what contribute to an accurate, diverse, and independent media.[7]

II. Media mergers have been steadily increasing, while rates of ownership diversity remain unacceptably low

Between 2019 to 2021, the nation saw a steady increase in media and telecommunications mergers,[8] and the data following these mergers showed women and people of color driven from the ranks of broadcast owners. The FCC released its most recent 323 ownership data, which was collected in 2021, on January 13, 2023 after it sought further comment on the docket. The data continue to show dismal levels of ownership diversity. This includes a decline in female ownership of full power commercial television stations from 5.6 percent to 5.3 percent, and a decline in African-American ownership of commercial FM radio stations from 2 percent to 1.8 percent.[9] Given the current low numbers, the FCC must not take any actions that will harm race and gender ownership diversity. Although the commission has released the most recent data available in a more timely manner than in the past, it has still not released reports that offer explanations for industry trends or other factors responsible for the final numbers. The commission should continue its efforts to ensure the numbers are complete and accurate and take steps to repair the omissions in prior data sets that make longitudinal analysis difficult. Some steps the commission could take include tracking individual filers over time, requiring universal submission of Form 323 data, and studying the impact of its media ownership rules on diversity.

III. The Local Radio Ownership Rule, the Local Television Ownership Rule, and the Dual Network Rule are still vital to the public interest

In spite of these abysmally low numbers, the Local Radio Ownership Rule, the Local Television Ownership Rule, and the Dual Network Rule (collectively known as the Media Ownership Rules)[10] continue to serve the public interest — with respect to competition, localism, and diversity — by ensuring that media ownership diversity is not harmed any further. For this reason, and those stated elsewhere in this comment, we believe that these rules should be maintained and enforced, if not strengthened. In particular, the commission should seek comment on ways to ensure that licensees do not exploit loopholes in the current rules to end-run around the protections that they provide to the public, diversity, and competition.

Finally, the commission’s public interest goals are served when FCC actions create pathways for multiple owners with multiple viewpoints and backgrounds to enter the marketplace, not when they facilitate consolidation and restrict the number of opportunities for historically excluded entrepreneurs to enter the marketplace. The commission must not forget this purpose as it commences the 2022 Quadrennial Review. Specifically, the commission should pick up where the Supreme Court’s opinion left off in Prometheus v. FCC, and conclude that the Communications Act’s public interest standard includes ownership diversity, including race and gender ownership diversity. We have consistently encouraged the FCC to prioritize ownership diversity when assessing the public interest during quadrennial reviews, as we understand the close relationship between ownership diversity and both viewpoint diversity and program diversity.[11] The Supreme Court left the FCC full discretion to implement the public interest standard in 202(h) and the Communications Act.[12] Now, the commission has the opportunity to take meaningful action to reaffirm its goal to promote minority and female ownership of broadcast media by stating unequivocally that broadcast diversity is a critical part of its public interest analysis.

A commitment to promoting diverse media ownership is a fundamental component of our nation’s communications policy. Accordingly, we urge the commission to retain and enforce the existing Local Radio Ownership Rule, Local Television Ownership Rule, and the Dual Network Rule. If you have any questions about the issues raised in this letter, please contact Media/Telecommunications Task Force Co-Chairs Cheryl Leanza, United Church of Christ Media Justice Ministry, at [email protected], and Yosef Getachew, director of the media and democracy program at Common Cause, at [email protected], Anita Banerji, senior director of the media & tech program at The Leadership Conference, at [email protected], or Jonathan Walter, media & tech policy counsel at The Leadership Conference, at [email protected].


The Leadership Conference on Civil and Human Rights
Common Cause
Communications Workers of America
Japanese American Citizens League
National Action Network
National Consumer Law Center, on behalf of its low-income clients
National Fair Housing Alliance
National Hispanic Media Coalition
National Urban League
Sikh American Legal Defense and Education Fund (SALDEF)
Take Creative Control
United Church of Christ Media Justice Ministry


[1] Media Bureau Opens Docket and Seeks Comment for 2022 Quadrennial Review of Media Ownership Rules, MB Docket No. 22-459 (rel. Jan. 17, 2023) (Public Notice).

[2] Sarah Fioroni, “Local News Most Trusted in Keeping Americans Informed About Their Communities,” Knight Foundation (May 19, 2022),

[3] Naomi Forman-Katz and Katerina Eva Matsa, “News Platform Fact Sheet,” Pew Research Center (Sept. 20, 2022),

[4] Tom Butts, “Public Broadcasters Discuss Impact of New Tech to Engage Viewers and Stay Competitive,” TV Technology (Mar. 2, 2023),

[5] “The Abysmal State of Media Ownership Diversity in America,” The Leadership Conference on Civil and Human Rights (Dec. 10, 2020),

[6] The Objective Staff, “Are News Companies Already Putting Diversity Pledges on the Back Burner?,” Nieman Lab (Sept. 17, 2020),

[7] Nicole A. Childers, “The Moral for Diversity in Newsrooms is Also a Business Argument – and You Need Both,” Nieman Lab (Nov. 24, 2020),

[8] Antoinette Siu, “Media Mergers Bounced Back in 2021, Signaling Even More Deals This Year,” Yahoo News (Jan. 24, 2022),

[9] Media Bureau and Office of Economics and Analytics, Sixth Report on Ownership of Broadcast Stations, Federal Communications Commission (Jan. 2023),

[10] Media Bureau Opens Docket and Seeks Comment for 2022 Quadrennial Review of Media Ownership Rules, MB Docket No. 22-459 (rel. Jan. 17, 2023) (Public Notice).

[11] Brief of the Leadership Conference on Civil and Human Rights, The Leadership Education Fund, and 16 Other Public Interest Organizations as Amici Curiae, Supreme Court Docket No. 19-1231, at 26-28 (filed Dec. 23, 2020), 1231/164644/20201223142312855_2020.12.22%20Leadership%20Conference%20Amicus%20Brief%20 Final.pdf.

[12] Federal Communications Commission v. Prometheus Radio Project, 141 S.Ct. 1150, 1160, n.3 (2021).