United States

Catholic Conference

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TELEVISION

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September 10. 1975

Administrative Board

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Statement

on the introduction of the

“Family Viewing” period

during prime-time by the

television networks

Administrative Board

United States Catholic Conference

September 10, 1975

I. Introduction

With the 1975 Fall season the three tele-

vision networks have introduced their new

policy of a "Family Viewing" period during

prime-time programming hours.

In summary, the following guidelines will

be observed by the networks. The first hour

of network entertainment programming in

prime-time and the immediately preceding

hour are to be set aside as a "Family View-

ing" period. Secondly, in the occasional case

when an entertainment program broadcast

during the "Family Viewing" period contains

material which may be unsuitable for viewing

by younger family members, a "viewer ad-

visory" will be broadcast in audio and video

form. Moreover, viewer advisories will also

be employed during the later evening hours

for any program containing material that

might be disturbing to significant portions

of the viewing audience. Finally, broadcast-

ers will endeavor to inform publishers of

television program listings of those programs

that will contain "advisories." A responsible

use of "advisories" in promotional material

is also urged upon broadcasters.

This new network policy on family viewing

is the result of conversations that the Chair-

2



man of the Federal Communications Com-

mission had with network leaders in the early

part of this year. The results of those nego-

tiations were made public by the Commission

in its “Report on the Broadcast of Violent,

Indecent and Obscene Material” on February

19, 1975 (FCC 75-202,30159). The report,

which was in response to Congressional di-

rectives on the subject, addresses the “spe-

cific positive action taken and planned by

the Commission to protect children from

excessive programming of violence and

obscenity.” The acceptance by the Commis-

sion of the “Family Viewing” concept consti-

tutes the major element of this plan.

II. Presuppositions

Before evaluating this “Family Viewing”

policy we wish to outline certain presupposi-

tions which the United States Catholic Con-

ference views as important and relevant to

the question at hand.

(1) In our society today television is the

single most formative influence in shaping

people’s attitudes and values. It is not only

the power the medium itself possesses that

supports this proposition. Of even greater

significance is the cumulative effect upon an

individual of his daily television experiences,

frequently passive and uncritical, from early

childhood until the evening of life. By the

time they have completed high school, most

children have spent more hours before a

television set than they have in the class-

room. The average adult also spends con-

siderable time each day viewing television.

(2) Unquestionably, therefore, the experi-

ence of television is both an ordinary and

integral part of American home life today.

Hence it follows that any evaluation of the

role that television plays in the American

experience must focus on the actualities,

first, of substantial daily viewing by the aver-

3



age American, and secondly, of the home

environment in which the viewing is experi-

enced. We are not dealing then with the

occasional entertainment experience that a

child or adult may have by going out of the

home to see a movie. Much less are we deal-

ing with the even rarer entertainment experi-

ence of a nightclub show.

(3) The Church respects the enormous

potential that television has: for education;

for providing full and accurate information

so essential to enlightened public opinion;

for building understanding and community

among men and nations; for preserving and,

indeed, creating art; for providing entertain-

ment and relaxation that re-create the human

spirit and emotions.

In the face of this enormous potential

broadcasters cannot view themselves as

merely entertainers or technicians. Because

social communications are so central to

modern life the vocation of a broadcaster is

a calling of high honor—and of heavy re-
sponsibility. The broadcaster, more than

others, helps to shape the very ethos of the

world In which we live.

(4) It should be noted as well that Ameri-

can broadcasters’ responsibilities go far be-

yond the frontiers reached by their signats.

They have a global responsibility because

they belong to an industry that has estab-

lished American international leadership in

the technology, the content, and the style of

contemporary mass communications. One

example is enlightening: during 1974, of

1707 film entertainment programs shown on

Brazilian television 1267 programs were of

American origin; only ten were Brazilian pro-

ductions. American broadcasters cannot

therefore take a parochial or narrowly na-

tionalistic view of their responsibilities. They

must be increasingly sensitive to the cul-

tural and moral imperatives of societies

4



other than our own. The American people,

sharing as they do a collective responsibility

in our interdependent world, have every right

and duty to protest whenever broadcasters

may manifest indifference or insensitivity to

the needs of their sisters and brothers across

the world. In a word, the question of the

broadcast of violent, indecent and obscene

material has to be viewed from an inter-

national as well as a domestic perspective.

III. USCC Evaluation of the “Family Viewing"

Policy

At the very outset of our evaluation of the

FCC acceptance of the “Family Viewing”

policy it seems important to state that if our

opinion of the Commission’s recommenda-

tions must be largely negative, it is not be-

cause we have failed to appreciate the most

difficult task of the Commissioners.

The FCC report (page 3) quite rightly ob-

serves that “administrative actions regulat-

ing violent and sexual material must be rec-

onciled with constitutional and statutory

limitations on the Commission’s authority to

regulate program content.” Not only do we

support this observation but we would op-

pose any recommendation that would call for

the direct involvement by government in the

content area of programming. Section 326

of the Communications Act specifically pro-

hibits the Commission from exercising the

power of censorship. This prohibition must

be maintained.

Opposition to direct governmental involve-

ment in program content, however, does not

call in question the role required of the Com-

mission by the same Communications Act,

namely, that it ensure that broadcast licens-

ees operate in a manner consistent with the

public interest. The Red Lion decision of the

Supreme Court explicitly reminded broad-

casters that they are “public trustees” with

5



fiduciary responsibilities to their communi-

ties. We strongly support the Commission’s

policy that program service in the public in-

terest is an essential part of every licensee’s

obligation.

Nor again, by opposing direct involvement

by government, do we intend to cast any

doubt on the obligation that Congress has to

legislate effectively against the broadcast of

violent, obscene or indecent material. Speci-

fically, we support the Commission's legisla-

tive proposal that Congress amend Section

1464 of Title 18, United States Code, in

order to remove the present uncertainty of

the Commission as to whether it has statu-

tory authority to proceed against the video

depiction of obscene or indecent material.

(Report, page 9).

In the light of the constraints placed on It

by the Constitution and Section 326 of the

Communications Act, the Commission under-

standably notes that it “walks a tightrope

between saying too much and saying too

little" when applying the public interest

standard to programming. In the present in-

stance, the Commission decided that “regu-

latory action to limit violent and sexually-

oriented programming which is neither ob-

scene nor indecent is less desirable than

effective self-regulation." (Report, page 3).

Hence the Chairman of the Commission met

with broadcast industry leadership in the

hope that he might “serve as a catalyst for

the achievement of meaningful self-regula-

tory reform."

Although the effort of the Chairman is

commendable, our judgment is that the re-

sults are unacceptable. Our reasons are as

follows:

(1) Self-regulation must be open, ac-

countable and cooperative.

6



The United States Catholic Conference has

been, is and will continue to be firmly com-

mitted to the principle of voluntary self-

regulation for all the communications media.

We therefore share the Commission’s con-

viction that broadcast self-regulation is the

basic solution to the problems at hand. How-

ever, we strongly disagree with the Commis-

sion’s apparent conviction that a few modifi-

cations in the status quo will enable the

networks to achieve “meaningful self-regu-

latory reform’’ in the area of broadcast enter-

tainment.

Self-regulation is not a unilateral activity

performed behind closed doors by a few

powerful individuals at the top. Self-regula-

tion, to deserve the name, is an open, ac-

countable and cooperative process, involv-

ing both broadcasters and the public they

serve.

We are far from convinced that broadcast

management is genuinely open to dialogue

with the public or accountable to it. The very

corporate structure of the networks, for ex-

ample, is such a forbidding and complicated

maze that it appears designed to guarantee

that. Insulated from public scrutiny, top man-

agement may, without fear of challenge or

other encumbrance, pursue the uniquely

important goal of maximizing profits. And

yet, of all the communications media, broad-

casting should be the one most open to

dialogue with the public precisely because

the airwaves belong to the public and broad-

casters are public trustees with fiduciary re-

sponsibilities to their communities. The

polished rhetoric of industry public relations

releases Is not dialogue but self-serving

monologue. In spite of good Intentions, the

series of closed meetings which the Chair-

man of the Commission held with the inner

circle of network top management strikes us

as having little to do with openness to public

7



dialogue or public accountability. Even

worse, it can only serve in effect to strength-

en the claims currently being made by some

broadcasters that the public does not really

own the airwaves.

Neither will the quality of openness and

accountability characterize industry self-

regulation as long as the public is without

ready access to reliable advance information

about broadcast entertainment program-

ming. This need for information is not satis-

fied by industry-generated publicity releases

or advisories. Books, plays, records, movies,

circuses, exhibits of all manner are also the

object of publicity and promotion, but before

buying, the interested consumer has critical

evaluations of the product available to guide

his or her choice. Since, apart from summer

repeats, broadcast entertainment is essen-

tially a one-time presentation, reliable ad-

vance program information would only be

possible were networks and local stations to

adopt and implement a policy of prescreen-

ing all entertainment programs for critical

review. We are aware, of course, that the

“rating-game” approach to television enter-

tainment effectively precludes even the con-

sideration of any prescreening policy that

might, in effect, serve to restrict potential

audiences. Without it the broadcast industry

cannot justly claim to be open and account-

able to the public it claims to serve. One

might have expected that the Chairman of

the Commission would have seen this as an

important question to have posed to network

top management.

Self-regulation is also a cooperative activ-

ity that should involve every local broad-

caster. A frequent complaint of the local

broadcaster is that he is rarely consulted or

otherwise actively involved by the networks

In the decision-making process with regard

to network entertainment programming. To

8



the best of our knowledge top network man-

agement did not invite the prior counsel of

their affiliate stations on the subject of

whether there ought to be a family-viewing

period during prime time. Neither are we

aware that the Commission sought the opin-

ion of the affiliates in the matter. If the deci-

sion has been unilaterally taken by the

networks and accepted by the Commission,

it may be because, were it left to local affili-

ate management, who alone must bear the

ultimate responsibility to the public, many

of them might have rejected the idea on the

grounds that their prime-time audience is a

family audience. At the very least, they might

have demanded stricter and more precise

standards.

Self-regulation also involves cooperation

on the part of the viewing public. No system

will succeed unless it enjoys public confi-

dence and support. Part of our complaint is

that neither the networks nor the Commis-

sion made any effort to consult the public

on whether it was indeed prepared to accept

the introduction of a distinction between

family-type and adult programming and. If

so, under what conditions. We seriously

doubt that the average parent would or

should find it reasonable to insist that older

children be excluded from watching tele-

vision in their own home after certain time

periods. By what mandate or legal title, par-

ents might rightfully demand, can the Com-

mission and the networks unilaterally decide

that henceforth minor children are entitled

to enjoy only a limited access to evening

television entertainment? A more than lurk-

ing suspicion remains that the audience for

prime-time television is after all not the gen-

eral American public but older teenagers,

young adults and the affluent who have the

money to spend on the products advertised.

In short, children, the poor and the aged are

to be disfranchised. How all of this relates to

9



high-sounding network appeals to creativity

and First Amendment guarantees or is to be

reconciled with serving the public interest is

difficult to perceive.

(2) Commercialism—Core Problem
And so we come to what must be acknowl-

edged as the core obstacle to effective self-

regulation in the broadcast industry—its
complete domination by commercial inter-

ests. What American commercial television

is all about is not primarily either informa-

tion or entertainment, neither news nor cul-

ture. Its primary objective is to create a

meeting place for consumers and advertis-

ers. American television is essentially con-

cerned with the sale of consumers to adver-

tisers.

As long as this equation controls program-

ming decisions, especially during prime-time

when network competition is keenest, the

central concern of broadcast management

has to be to air that type of program which

will deliver the greatest possible audience.

And what kind of programming is this? Look

at the record. Do we find serious dramatic

works or programs that might challenge

viewers to confront disturbing social issues

or documentaries that might open American

minds and hearts to understanding and com-

passion for the powerless at home and

abroad? What has the average American

viewer of prime-time entertainment program-

ming learned about the global village, the

interdependent world in which we are said

to live—about Africa, Latin America, Asia,
Oceania? The record will reveal that network

management programming decisions have

much more to do with appealing to the al-

leged lowest common denominator of audi-

ence interest,—smart comedy, crime, vio-
lence and sex. Were the record otherwise,

the Commission would never have been man-

dated by Congress to undertake its study.

10



(3) Lessons Learned From Motion Picture

Code and Rating Program

On page five of the Commission's Re-

port it is stated that “the Chairman raised

the possibility of the adoption of a rating

system similar to that used in the motion

picture industry." We believe that some

sobering conclusions might have emerged

for the members of the Commission had they

reflected on what has happened to American

motion pictures since October 7, 1968, when

the Motion Picture Association of America

(MPAA), first announced the details of its

new and expanded plan of movie-industry

self-regulation.

The MPAA plan bore the title “The Motion

Picture Code and Rating Program." We wish

to emphasize that it was a code as well as a

rating program. At the top of the document

appears a section entitled “Declaration of

Principles of the Code of Self-Regulation of

the Motion Picture Association." A few ex-

cerpts from this section are of interest:

“This Code is designed to keep in close

harmony with the mores, culture, the

moral sense and change in our society.

“The objectives of the Code are:

1. To encourage artistic expression by

expanding creative freedom; and

2. To assure that the freedom which

encourages the artist remains re-

sponsible and sensitive to the stan-

dards of the larger society."

“We believe self-restraint, self-regula-

tion, to be in the American tradition. The

results of self-discipline are always im-

perfect because that is the nature of all

things mortal. But this Code, and its ad-

ministration, will make clear that freedom

of expression does not mean toleration of

license.

11



“The test of self-restraint—the rule of
reason—lies in the treatment of a sub-
ject for the screen.”

Under the second section of the MPAA

document which is entitled “Standards for

Production” there are eleven standards

enunciated which will determine whether a

motion picture will qualify for a Code Seal of

approval. Those standards read as follows:

“—The basic dignity and value of human
life shall be respected and upheld.

Restraint shall be exercised in portray-

ing the taking of life.

—Evil, sin, crime and wrong-doing shall
not be justified.

—Special restraint shall be exercised in
portraying criminal or anti-social ac-

tivities in which minors participate or

are involved.

—Detailed and protracted acts of brutal-
ity, cruelty, physical violence, torture

and abuse shall not be presented.

—Indecent or undue exposure of the
human body shall not be presented.

— Illicit sex relationships shall not be
justified. Intimate sex scenes violating

common standards of decency shall

not be portrayed.

—Restraint and care shall be exercised
in presentations dealing with sex aber-

rations.

—Obscene speech, gestures or move-
ments shall not be presented.

—Undue profanity shall not be per-
mitted.

—Religion shall not be demeaned.
—Words or symbols contemptuous of

racial, religious or national groups

12



shall not be used so as to incite bigot-

ry or hatred.

—Excessive cruelty to animals shall not
be portrayed and animals shall not be

treated inhumanely.”

The Motion Picture Code and Rating Pro-

gram envisioned two distinct questions for

its administration. The first question per-

tained to these Standards for Production; if

the submitted motion picture conformed to

the standards, it would be issued a Code Seal

of Approval. If it did not qualify for a code

seal, it could only be rated (X). For a Code-

approved film a second question was then

to be applied, namely, which of the first three

ratings (G, M, or R) were to be applied.

The United States Catholic Conference

and the National Council of Churches en-

dorsed in principle this MPAA program “as

being consistent with the rights and obliga-

tions of free speech and artistic expression,

as well as with the duty of parents and soci-

ety to safeguard the young in their growth to

responsible adulthood.” The Churches “rely-

ing on the good faith of the industry” gave

“genuine and full support to this plan” and

urged “Its conscientious implementation on

every level of production, distribution, and

exhibition.”

The Churches maintained their support of

the MPAA plan for over two and a half years.

Finally, on May 18, 1971, after a detailed

statement of concern published a year previ-

ously, the Churches, because they could no

longer in good conscience be party to a cha-

rade, withdrew their support.

How could a plan which had been wel-

comed with genuine enthusiasm only two and

a half years previously have failed so miser-

ably? The best of motivation and the highest

good faith could not stand up to the pres-

sures of commercial competition. Within a

13



few short weeks of the introduction of the

Code and Rating Plan, there began to emerge

an attitude on the part of some film pro-

ducers that “now that the kids are protected,

anything goes.” And in no short order, al-

most everything did go—including the stan-
dards for production, which, as noted previ-

ously, were to determine whether films quali-

fied for the Code Seal of Approval. Although

the MPAA has not formally advised the pub-

lic, the Code is officially dead. All that re-

mains is the rating aspect of the original

plan.

One result of all this is that the theatrical

motion picture as such has become a lost

experience for the majority of Americans.

For the industry, in spite of the occasional

box-office successes that keep some of the

Hollywood glitter going, the loss of the gener-

al audience has resulted in serious financial

reverses for many producers and exhibitors

across the industry. Perhaps, the worst con-

sequence of all for American society is that

too many of the creative community of pro-

ducers, writers, directors and actors have

been replaced by hacks whose artistic per-

ception is limited to “exploit-the-audience-

with-sex-and-violence.”

Our purpose in this review is not to focus

on the problems of the motion picture in-

dustry but to raise the question of why a

reasonable person would be expected to ac-

cord greater confidence to effective self-

regulation by the television networks than to

the MPAA. To the credit of the MPAA it has

involved itself in broad consultation with

representatives of the public before introduc-

ing its Code and Rating Program and con-

tinued to collaborate with them in an effort

to make the program work. Again, the film

industry prescreens its product for public

review and takes its chances at the box-

office. As already noted, the broadcast in-

14



dustry’s self-regulation is a closed shop and,

short of the risk of challenge at license re-

newal time, is not otherwise accountable to

the public. In fact, the networks do not even

have to face that risk—except in the narrow
area of their owned and operated stations.

We have no confidence that once the com-

mercial broadcast industry as presently con-

stituted is permitted without challenge to

introduce what is in effect a rating system

for programming, the identical excesses that

have occurred in the motion picture medium

will not be visited upon the American public

—but this time not at the local theater but
In the American home. In making this judg-

ment we are not limiting our concern to the

pressures of commercial competition pres-

ently experienced by the networks. We are

also looking down the road when the net-

works will have to face the added competi-

tion from pay-television, video-cassettes,

video-discs, and whatever else technological

genius may develop.

(4) Greater Handicaps for Parents and

Family Life

We have placed great emphasis upon

television’s role in American family life. We

do not think that it is possible to exaggerate

the centrality and Importance of this role,

especially at a time in our history when the

very structure of family life is seriously

threatened. We, therefore, commend the

Commission when It states (Report, pages

7-8):

“Parents, in our view, have—and should
retain—^the primary responsibility for
their children's well-being. This traditional

and revered principle . . . has been ad-

versely affected by the corrosive processes

of technological and social change in

twentieth-century American life. Neverthe-

less, we believe that it deserves continu-

ing affirmation.”

15



'Television . . . also has some responsi-

bilities in this area. . . . The Commission

has sought to remind broadcasters of their

responsibility to provide some measure of

support to concerned parents."

However, we must also seriously fault the

Commission for then making recommenda-

tions which, in the light of our foregoing

observations, will only serve to create even

greater handicaps for parents as they strug-

gle not only to assure the well-being of their

children, but also to preserve family life

which is so essential to the well-being of this

or any nation.

(5) Specific Criticism of "Family View-

ing" Plan

Although it may seem unnecessary to com-

ment on the specific recommendations that

the FCC Report has proposed for the Fall

1975 television season, we will do so anyway

with the understanding, however, that these

criticisms are secondary to our already

stated core concerns.

(a) Inspection of the report reveals that

the 7:00-9:00 p.m. "Family Viewing" period,

which appears to have been the Initial FCC

objective, will hold only In fact for the East-

ern and Western time zones. For the Midwest

it will mean a 6:00-8:00 p.m. period and for

the Rocky Mountain time zone 5:00-7:00

p.m. Why? The Commission lamely acknowl-

edges that the networks had informed It that

"a standard based on a 9:00 p.m. local time

would require prohibitively expensive sepa-

rate program transmissions to each time

zone." This concession to commercial con-

siderations is incredible. It hardly demon-

strates an honest commitment by the net-

works to American parents.

(b) The use of the so-called "advisory

warnings," the second point in the FCC pro-

posals, is an equally incredible concession.

16



“Viewer advisories," the Report states, “will

be broadcast in audio and video form in the

occasional case when an entertainment pro-

gram broadcast during the "Family View-

ing" period contains material which may be

unsuitable for viewing by younger family

members." (Emphasis added.) Not only does

this “advisory warning" concession open the

door to abuse in order to attract larger audi-

ences; there is something far more disturb-

ing about it. It leads to the obvious conclu-

sion that neither the Commission nor the

networks are single-minded about keeping

the “Family Viewing" period inviolate.

(c) The combination of “viewer advis-

ories" and the “advance notice" to be given

about such advisories clearly implies that a

television rating system, almost as developed

as that of the motion picture industry, is

about to be foisted upon the American public

without, however, it being candidly identified

as a rating system and, of course, without

any previous public debate as to the merits

of same.

(d) Granted the advisory or rating system

proposal, who is going to be making the

necessary judgments as to material “which

may be unsuitable for viewing by younger

family members" or concerning programs,

“in the later evening hours," which “contain

material that might be disturbing to signifi-

cant portions of the viewing audience?" The

Commission report makes much of the “sub-

jectivity" of these matters. But even if artis-

tic and moral considerations were actually

as subjective as the approach of the Commis-

sion would imply, there is no reason to con-

clude, as the Commission does in fact con-

clude, that such decisions must be left to the

networks. This, of course, touches on the

basic issue: despite the fervent rhetoric of

the FCC report, the networks continue to be

answerable to no one but themselves. In

17



some respects the report of the Commission

is an insult to the public’s intelligence and

inescapably lends credence to the suspicion

that the main function of the FCC Is after all

to act as a buffer between the networks and

public accountability.

(e) An integral part of the Commission’s

plan involves the incorporation of the “Fam-

ily Viewing’’ period concept and the advisory

warnings into the Television Code of the

National Association of Broadcasters. It ap-

pears unnecessary to observe that the NAB

as presently constituted has been neither

organized for, nor is It capable of, taking on

any serious representation role for the public

interest. The NAB is a trade organization

whose function is to argue for the interests of

its members before the government and the

public. Moreover, since no more than 60 per-

cent of all stations belong to this voluntary

organization, NAB cannot even speak for the

entire industry. Nor, in fact, can it effectively

discipline Its members who choose not to

abide by its Standards and Practices rules.

Finally, the FCC has not yet secured agree-

ment of the independent television stations

to support the NAB TV Code’s Incorporation

of “Family Viewing’’ despite the fact that the

NAB voted to give independents a waiver on

restrictions against sex and violence until

September, 1977, for any programs under

contract since last April.

IV. Conclusions

For all the reasons set forth in this state-

ment the United States Catholic Conference

finds the proposals contained in the FCC’s

report to be unacceptable. Our principal rea-

son is that those proposals stand or fall upon

effective self-regulation by the broadcast in-

dustry.

Effective self-regulation has to be an open,

accountable, and cooperative process. Our

judgment is that to date the networks have

18



not demonstrated a commitment to such a

process. Moreover, we seriously question

whether such a commitment is even possible

for the networks as long as no industry effort

is undertaken to reduce the impact of com-

mercial pressures upon their program deci-

sion-making.

In this connection, the “rating game"

must be addressed specifically. A basic weak-

ness of commercial broadcasting Is that

management is incapable of exercising re-

sponsible freedom in the program decision-

making process because they are trapped in

a rating thralldom.

If ratings objectively identified the needs

of the public, they would be a true service

both to broadcasters and the public they are

to serve. We doubt anyone can make a case

In favor of the rating organizations that

would prove them to be providing a construc-

tive service to the medium or the public. We,

therefore, recommend that Congress investi-

gate the program rating services which ap-

pear to exercise an inordinate influence upon

television programming and which have thus

far successfully resisted public scrutiny.

As for the broadcast industry we strongly

urge all broadcast licensees, whether net-

work affiliates or independents, whether

members of the NAB or not, to reflect anew

upon their responsibilities to the public they

are licensed to serve and to examine how

well they are meeting those responsibilities.

We fully appreciate that service to the com-

munity by commercial broadcasters cannot

be delivered without a profitable operation.

Yet the profit motive can never justify pro-

gramming that debases rather than builds

community.

As for the viewing public, it must respond

and demonstrate to local station manage-

ment that it cares and Is ready to work with

management for the achievement of a pro-

19



gram schedule that serves the community’s

needs. In particular, we encourage
our

Catholic people, under the leadership of
their

bishops and pastors, to take an active
and

affirmative role In working with their
fellow

j

citizens, especially on an interfaith
basis, in

pursuit of the same objectives. Neither net- |

works nor advertisers, neither Hollywood
nor

government can influence station managers

who have their communities strongly
behind

them.

For its part, the Federal
Communications

Commission must demonstrate that it
is

more concerned about how well the public

Interest is served by commercial
broadcast-

ers than how well it serves the interests
of

commercial broadcasters. In particular,
a

scrupulous enforcement of the spirit as
well

as the letter of the community
ascertainment

requirement is essential.

Moreover, recent efforts either to
exempt

certain broadcasters from the
requirement

to ascertain community problems
or to re-

duce the requirements for others
must be

resisted by the Commission. The
Commis-

sion must also fully support the right
of the

public to challenge license
renewals. This

requires that communities have access
to all

necessary information and be afforded
ade-

quate time to exercise the right to
challenge.

Finally, the business community
has a

special responsibility for the
quality of com-

mercial broadcasting. It is their
advertising

dollars that either enhance or
debase the

medium. If all advertisers had been
as sensi-

tive to the broadcast needs of
the American

public, especially of the family,
as some have

been, this statement might not
be necessary.

1975

Publications Office, UNITED
CATHOL^^

1312 Massachusetts Avenue, N.W.,
Washington,

CONFERENCE
D.C. 20005