Libraries and FCC Rules Related to Media Concentration and Localism

Prepared by Nancy Kranich, Chair of the ALA IFC Subcommittee on FCC Rules and Media Ownership, January 30, 2004

America's libraries play a critical role in providing a diversity of ideas and local information to the public. Public libraries are located in almost every community—urban, suburban, and rural—with more than 9,000 systems supporting over 16,000 outlets. At the same time, another 3,500 academic libraries, 94,000 school libraries, and 10,000 armed services, government, and special libraries serve the full spectrum of the public's information needs. Like the media, libraries are charged with providing the public "the widest possible dissemination of information from diverse and antagonistic sources." 1 Their success in fulfilling this mission-at very low cost-provides a model to consider when looking for new ways to address media diversity and localism.

The principles of freedom of expression and diversity of opinion are essential to democracy; theses ideals serve as the bedrock of American librarianship. America's libraries are essential to the collection, preservation, and provision of local information and history to their communities. They help explore, exchange, and understand the unique cultures and viewpoints of local residents. Librarians are committed to ensuring the free flow of information in our society. They excel at identifying, acquiring, organizing, housing, preserving, archiving and assisting in the use of information. They have extensive experience working with community groups in providing essential local information and promoting the public's right to know. Furthermore, libraries serve as local communities' historic, cultural, political and social record. Politically neutral institutions, libraries follow the "common carriage" model of access, thereby maximizing the flow of the largest number of ideas.

Librarians value America's pluralism and strive to reflect that diversity by providing a full spectrum of resources and services to the communities they serve. They also celebrate and preserve democratic society by making available the widest possible range of viewpoints, outlets, programs, and sources from a diversity of providers, in order to ensure that everyone has the opportunity to participate in a 21st-century information society. Over the years, they have developed and endorsed numerous policies that recognize and support the importance of diversity in libraries. These positions are guided by the American Library Association's (ALA) Library Bill of Rights, 2 a statement that affirms that all libraries are forums for information and ideas, that they should "provide materials and information presenting all points of view on current and historical issues," and they should not exclude items "because of the origin, background, or views of those contributing to their creation."

Definitional Recommendations about Media Diversity and Localism
Like mass media, libraries operate in an economic environment. But the values underlying librarianship—values such as intellectual freedom, equity of access, diversity, and literacy—do not fit traditional marketplace models. Instead, these democratic values privilege citizens over consumers, emphasizing discourse and participation over efficiency. The success of libraries in fulfilling their mission of serving all citizens requires that they assume public interest responsibilities beyond the boundaries of the market. This dichotomy between the private and public interest cannot be overlooked when determining options of achieving goals of media diversity and localism.

Research Recommendations
In the digital age, libraries serve as a safety net for the full spectrum of ideas. But librarians can only acquire items that are produced or published. If the mainstream media ignores, under covers, or diminishes essential stories, libraries are unlikely to acquire them. Therefore, we cannot assume that libraries will fill the access gap and ensure the public a source of information beyond the mainstream. As the information revolution changes the way we live, learn, work, and govern, we are not guaranteed access to all the resources and points of view desired. Access to abundance does not ensure access to diversity.

Evidence shows that concentration of media ownership reduces the number of independent voices and decreases the amount of locally produced and locally relevant news and programming. For libraries, such concentration of media ownership and production diminishes their ability to provide a wide range of views and information. Without the production of diverse media resources, libraries cannot fulfill their mission by acquiring materials that present all points of view on current and historical issues.

Librarians are concerned that the new  Federal Communications Commission (FCC) rules that will allow a company to reach more viewers nationally, acquire more stations locally, and own television stations and newspapers in the same market. At the ALA annual conference in June 2003, the ALA Council unanimously passed a  resolution expressing opposition to these changes in media rules. In order to measure the impact of media consolidation, librarians are working together to analyze and assess the performance of both commercial and noncommercial media on issues related to intellectual freedom, diversity of ideas, and freedom of information.

Over the last decade, librarians have studied the impact of changing markets on their collections and users. They have found that the public now has access to more and more of the same ideas, with alternatives marginalized more and more. They have employed a number of methods to measure the costs and diversity of resources as well as the critical thinking skills of library users. These approaches are useful metrics for determining whether the nation's media system actually promotes the diversity of sources, outlets, viewpoints, programs, and owners essential to an informed public and a robust marketplace of ideas, and whether it provides sufficient content and services that address the needs and interests of local communities.

Below are a sampling of methods libraries employ to assess the diversity, relevance, and usability of local library collections:

  1. Collection Development and Assessment: Librarians use a variety of tools to survey collections in order to determine the scope, content and relevance to communities, measure the relative size of holdings, and compare titles to determine overlap and duplication with other collections. They analyze the demographics and interests of their communities so they can build collections of interest. Most libraries work closely with their communities to develop and update Collection Development Policy Statements. These documents present a blueprint for purchases, withdrawals, and retrospective buying. They also offer community members an opportunity to work with the library to ensure it reflects the diversity of needs of local citizens. Libraries also develop and publicize policies and procedures for recommending and challenging their acquisitions, services, and policies. For example, a clear multi-step process is outlined for residents who seek to appeal a selection decision. In this way, the library serves the broad public interest of its local community, remains accountable to its constituents, and ensures a transparent, open and fair review process for all.
  2. Alternative Literature and Multimedia Collections: Librarians work hard to purchase and/or highlight materials outside the mainstream, including the alternative press, government documents, research reports, and materials produced by non-profit groups and ethnic minorities in a variety of languages and formats. They identify and seek out numerous, independently owned and institutionally distinct outlets for materials that are not widely accessible. They also conduct studies about the representation of alternative materials in library collections. 3 Libraries respond to the special needs of community members such as children, senior citizens, people with disabilities, and limited English and literacy skills. They also build extensive collections of electronic, video, audio, graphic, and other materials. In this capacity, they are major markets for materials outside the realm of bestsellers like independent and educational film and video, reference materials, large-print materials, children's resources, poetry, non-fiction, and scholarly materials.
  3. Scholarly Publishing: Academic librarians have employed various techniques to analyze subscriptions and choose monographs more selectively, thanks to skyrocketing costs as a result of mergers in the scholarly publishing industry. To counter the negative effects of monopolies on research and scholarship, librarians have documented the impact of the problem, analyzed economic data, protested mergers to the Antitrust division of the Justice Department, launched  SPARC—an alternative publishing venture, forged coalitions to influence intellectual property policy, and organized a new group, " The Information Access Alliance." These efforts can serve as models for assessing the impact of mergers in the mainstream media.
  4. Content Analysis: Librarians have helped library users harness databases to analyze content, citations, and texts for such purposes as: tenure review to determine importance of faculty contributions; literary research to analyze authorship; and news analysis by groups like  FAIR and  Project Censored to measure the impact of diminishing media diversity.
  5. Copyright Law Impact: Librarians have helped examine the chilling effects of new restrictive copyright regimes on current and downstream uses of information, particularly as they limit the advancement of scholarship and creativity. In order to educate the public and influence policy, ALA, along with other library associations, submitted amicus briefs for such Supreme Court decisions as the Tasini vs. the New York Times and Eldred cases; advocated for fair use, the public domain, and the first sale doctrine; and fought against copyright term extension, restrictive licensing arrangements, technological protection measures including the broadcast flag and filters. Librarians have also documented harm, developed alternative information sharing systems, and forged powerful coalitions to advance to promote a balance.
  6. 21st Century Literacy: Librarians have assessed what skills are needed for citizens to thrive in a 21st-century information society. They now actively promote the teaching of new skills—including information, media, visual, and cultural literacy—that equip the public to make effective use of information in all formats and think critically about content and its delivery across old and new media. Indicators developed to assess these competencies are important measures of the public's ability to recognize the effects of diminished media diversity.

Policy Recommendations
Librarians utilize a number of methods to ensure that libraries respond to the diverse needs of their local communities. They strive to ensure that libraries remain institutions that serve the public interest, and make them accountable by employing open, transparent, and fair methods of engaging their constituents. Like libraries, the nation's media companies could benefit from greater disclosure about their practices related to diversity and localism. If the FCC required more open, transparent review processes when it licenses media companies, the public would be better equipped to determine whether these companies have fulfilled their public interest mission and whether they are likely to serve this role in the future. Such accountability mechanisms are likely to help local communities monitor and assess the success of broadcasters in providing a diversity of sources, viewpoints, programs, and outlets by a variety of providers, as well as services that reflect the needs of their local communities.

Statement prepared for " Media Diversity and Localism: Meaning, Metrics, and the Public Interest " Conference Report, Sponsored by the Ford Foundation, December 15-16, 2003, Fordham University, New York.


1Associated Press v. United States, 326 U.S. 1 (1945), p. 20.

2American Library Association,  Library Bill of Rights , 1948; Amended 1961 and 1980, and Reaffirmed 1996.

3See, for example, Brian Campbell, "Media Concentration and the Role of Libraries in Promoting a Diversity of Voices," Feliciter: Publication of the Canadian Library Association, v. 48, #6 (November/December 2002): 275-7; Nancy Kranich, "A Question of Balance: The Role of Libraries in Providing Alternatives to the Mainstream Media," Collection Building vol.19 #3 (2000): 85-90; Rita Marinko, and K.H. Gerhard, "Representation of the Alternative Press in Academic Library Collections," College and Research Libraries, Vol. 59 No. 4, (July 1998): 363-377; Milton Wolfe and Meredith Bloss. "Without Walls Means Collaboration," Information Technology and Libraries, Vol. 17 No. 4, (December 1998): 212-215.