FCC unveils “Consumer Survey” to be used as basis for latest broadcast ownership review

Paging  Richard Dawson! The FCC may be needing you to come out of retirement soon to deliver the classic Family Feud catchphrase. Why? Because the Commission is looking to unleash its own “Consumer Survey”. The subject? “The impact of local media market structure on consumer satisfaction with available broadcast radio and television service.”

The survey is being undertaken in connection with the Commission’s latest quadrennial inquiry into broadcast ownership. As you doubtless recall, that inquiry got kicked off last May. In June, the Media Bureau issued a number of “Requests for Quotations” (RFQs), seeking proposals for “economic studies to evaluate the current marketplace and the state of the media industry”. One proposal was selected on September 30, apparently – not that the FCC made any formal public announcement of that selection back then (the whole selection process appears somehow to have escaped the FCC’s oft-alluded-to commitment to Transparency). 

In any event, now it’s full speed ahead with the survey. In fact, the Commission’s in such a hurry that, according to a notice published in the Federal Register, it’s asking the Office of Management and Budget to give the draft survey the old “emergency processing” treatment so that OMB can give it the thumbs up in a mere 17 days. (Calendar note: the17-day period in question happens, coincidentally or otherwise, to include three weekends, so it’s really a 10-business-day period if you don’t count the last day, i.e., the day the FCC apparently expects OMB approval to issue.)

Looks like the FCC may be hoping to deploy the survey before the end of the month.

The Federal Register notice doesn’t shed any light on why the Commission might think emergency treatment is warranted here. But it does provide the following description of what the survey is supposed to entail:

The consumer survey will be used in a determination to define a performance metric related to the public interest goals the Commission seeks to promote through its media ownership rules. The Consumer Survey will be used to examine the impact of local media market structure on consumer satisfaction with available broadcast radio and television service. The Consumer Survey will collect information regarding how much time people spend with various media and how people get news and information. The Survey will ask respondents to rate, on a numerical scale, their current satisfaction with the overall local media environment and with components such as broadcast television, broadcast radio, and newspapers. The Survey will also include questions asking respondents to rate their current satisfaction with the local news, local public affairs, and other locally oriented media content. This survey will be distributed via the Internet to a nationwide sample of consumers, and the Commission anticipates approximately 5,000 responses to the survey.

The proposed survey was supposed to be available at the OMB website on November 5. As of 4:00 p.m. on November 5 it wasn’t there, although a very helpful FCC staffmember assured us that the survey (and an accompanying “Supporting Statement”) had been sent to OMB for posting around noon. We don’t doubt her on that, since she also very kindly sent us copies of both. We were going to include our own link to the Survey, but we noticed that its front page bears an ominous copyright notice (claiming ownership by the surveyors, not the FCC), so out of an excess of caution, we’ll hold off on including a link until it shows up on the OMB site. But we will include a copy of the FCC’s Supporting Statement here – to tide you over until OMB catches up. (Remember, you have only 17 days to comment, so every minute counts!)

A quick look-see at the survey suggests that there may be plenty of reason to comment.

For openers, the survey is titled “Choosing information from your media environment: What are the options?” That doesn’t sound like it’s gearing up to measure “consumer satisfaction”, but what the heck – it’s just the title.

Remember how the Commission said in its Federal Register notice (quoted above) that the survey would, among other things, inquire about “satisfaction” with “broadcast television” and “broadcast radio”? Well, it doesn’t really do that, mainly because it makes no serious effort to distinguish between “broadcast” services and NONbroadcast services (such as satellite radio, satellite TV, or cable). And when the survey does allude to such differences, it does not do so in a helpful manner. To wit: “Broadcast TV channels are free, over the air if you have good reception, e.g., ABC or NBC. They are often re-transmitted by the cable or satellite company, but they are still broadcast channels.” All true, sort of.

And even if we could accept that rough-hewn definition of “broadcasting”, it really doesn’t make any difference. That’s because, in what appear to be the pay-off questions seeking comparisons among the various different types of “media”, the survey lists merely “radio” and “TV” as options, without reference to broadcast vs. nonbroadcast. And the ultimate question about “satisfaction” (that would appear to be Question No. 51) doesn’t even distinguish among the different types of media – rather, it asks about the respondent’s level of satisfaction with his/her “overall media environment”.

So how is this survey going to provide any useful information at all about “broadcast ownership”?

There are other problems. For example, the survey doesn’t attempt to define for the respondent’s benefit the concept of “satisfaction” as it is used in the survey. How, then, can we know that one respondent’s definition of “satisfaction” is even remotely equivalent to another’s – much less what, precisely, any particular respondent might mean by “satisfaction”.

And while the survey poses questions about the availability of “localism” and “multiculturalism” in the respondent’s media environment, the definitions of those two terms are interesting, but not particularly useful from a regulatory perspective.

Eschewing any effort to provide, like, real definitions, the survey opts instead for “examples”. For “localism”, the survey refers to “reports on: school sporting results, local council meetings, city/county elections, neighborhood crime, local heroes who give their time to the community, or job layoffs at a local factory.” For multiculturalism, the examples offered are “reports on: the Cinco de Mayo celebration, female wage inequality, or programs that help people with disabilities find a job.” Oh yeah, and “news outlets that, rather than only reporting negative news from African American or Hispanic neighborhoods, such as robberies and shootings, provide a balanced story of ‘what is going on’ in these neighborhoods.”

Those may, of course, be perfectly valid examples of the surveyors’ understanding of “localism” and “multiculturalism”. But remember, this survey is supposed to be used by the FCC to develop FCC policy concerning broadcast ownership. Unless the basic terminology used in the survey correlates with some precision to corresponding FCC terminology, it is difficult to see how the survey could produce any data that the FCC could legitimately use. Needless to say, however the FCC may have conceived of “localism” heretofore, it has not defined it like the survey does. Ditto for “multiculturalism”.

The survey includes an elaborate series of questions in which the respondent is asked to indicate a preference between two different mixes of five variables (i.e., “cost”, “advertising”, “diversity”, “localism”, and “multiculturalism”). Again, it’s not at all clear how these questions will generate any data properly useable in an assessment of broadcast ownership.

Don’t take our word for it. Click on the survey when it shows up on the OMB site and wander through its 25 pages. (Try to do so in 15 minutes, though – that’s the time the surveyors estimate will be needed to complete it. Presumably that time estimate does not include the time necessary to locate all your recent bills for newspaper, satellite radio, cable/satellite TV and/or Internet service – all of which are required to answer a number of the questions. 15 minutes? Good luck with that.)

Over and above the survey itself, the FCC’s submission to OMB sheds no light on precisely how the survey will be administered. We know that the surveyors plan to distribute it to about 5,000 people over the Internet, but who those lucky few are and how they will be chosen is a mystery. (Despite its Internet-based delivery, the survey will be available to folks who don’t have home access to the Internet. That’s because the surveyors plan to provide such folks with “free netbook computers and Internet access”. Other “non-specific survey incentives” will be provided to respondents to “maintain a high degree of panel loyalty”.  Where can we sign up?)

Oh, and by the way, according to the FCC’s Supporting Statement, the survey cost $88,300 to produce. Those would be our tax dollars at work.

Anyone interested in commenting on the survey has until November 22, 2010 to do so. You should bear in mind, though, that the FCC has asked OMB to approve the survey on the 17th day, so it might be a good idea to file comments sooner rather than later. (Of course, if the FCC is already expecting OMB approval on November 22, what are the chances that the opportunity to file comments with OMB is likely to be much more than a charade?)