WASHINGTON D.C. — As U.S. media outlets confront a rapidly changing marketplace, policymakers must resist the impulse to intrude into their workings when attempting to "save the media" and journalism, say Adam Thierer, Berin Szoka, and Ken Ferree of The Progress & Freedom Foundation in comments filed today in the Federal Communication Commission's (FCC) "Future of Media" proceeding. They urge the FCC to "reject Chicken Little-esque calls for extreme media 'reform' solutions," and counsel policymakers to move cautiously so that media reform can be "organic and bottom-up, not driven by heavy-handed, top-down industrial policies for the press."

The 79-page filing covers a wide range of ideas being examined by Washington policymakers to help support struggling media outlets and unemployed journalists. Its main sections explore:

• First Amendment concerns implicated by government subsidies;
• The pitfalls of imposing new "public interest" obligations on media operators;
• How advertising restrictions could harm the provision of media and news;
• Taxes, fees and other regulations to be avoided;
• The limited role in reform that public media subsidies can play; and
• Positive steps government could take.

The authors note that as "many operators [are] struggling to cope with intensifying competition, digitization, declining advertising spending, and audiences fragmenting, some pundits and policymakers are wondering what the 'future of media' entails." The answer, they conclude: "Nobody knows." While this uncertainty has put over-zealous policymakers at the ready to "help," the authors warn that: "There is great danger in rash government intervention." Instead, policymakers should be "careful to not inhibit potentially advantageous marketplace developments, even if some are highly disruptive." Marketplace meddling, or government attempts to tinker with private media business models in the hopes that something new and better can be created, are misguided. Moreover, "Our constitutional traditions warn against it, history suggests it would be unwise, and practical impediments render such meddling largely unworkable, anyway."

The authors address several vexing proposals to use public coffers to prop up the media—such as media vouchers, taxing broadcast spectrum, and expanding postal subsidies, among others. They believe that most of these stand on shaky ground, especially as they relate to press independence; First Amendment values; political strings, pressure and meddling; taxpayer promotion of failed models; and taxpayer-compelled funding of unwanted or offensive content.

The PFF comments also focus on the integral role advertising plays in supporting free media: "Advertising has been the hidden, unappreciated benefactor that has sustained a free press historically and policymakers should understand that an attack on advertising is tantamount to an attack on media itself." Accordingly, if Washington wages a war on advertising, media providers will suffer greatly.

The authors tackle non-commercial media, too. Though limited support can work at the margins, "policymakers should not view public media as a substitute for private media operations." If the government truly wants to help ailing media outlets and journalism, policymakers could relax media ownership regulations; allow non-profit status for media enterprises; and provide far greater transparency into its own affairs.

The authors conclude that the Commission should ignore sky-is-falling rhetoric, which would "destroy the important wall between State and Press." Thus, instead of imposing an industrial policy on the press, they urge policymakers to exercise patience and let creative destruction in the media marketplace play out.

The authors have built up to their FCC filing with a series of essays over the last month, entitled "The Wrong Way to Reinvent Media" (see Parts 1, 2, 3, 4 and 5). On May 20th, the think tank will host an event covering these and competing ideas, called "Can Government Help Save the Press?" That event will be keynoted by the FCC's Ellen Goodman; RSVP here today.

Adam Thierer may be reached for comment. For further information, please contact Mike Wendy at mwendy@pff.org.

The Progress & Freedom Foundation is a market-oriented think tank that studies the digital revolution and its implications for public policy. PFF is a 501(c)(3) research & educational organization.