Media

Media

Filing FCC Comments Online: Cablevision Encryption Follow Up

Last month, I wrote a blog post about Cablevision seeking to encrypt basic cable in New York City. I wrote about submitting a comment to the FCC about this a couple weeks later, and a review of some of the comments in the Battle for Digital Cable.

The original public notice listed the reply date as November 6th. The public notice also had a section that said,
"Comments and oppositions filed must indicate that they have been served on Petitioner." It provided a physical address for the lawyers for the petitioner and provided no means of serving the comments on the Petitioner electronically.

As I read through the comments, the only comment that indicated that it had been served on the petitioner was in an errata submitted by the New York City Department of Information Technology and Telecommunications.

I contacted to the FCC to ask how they would consider the comments that have been submitted without having been physically served on the Petitioner and without notice in the comment that it had been so served.

Friday, I received a message back from the FCC pointing to a Memorandum Opinion and Order. In the order, they waived, sua sponte the requirement that required service on all parties and the indication of such service in the responses. They go on to explain that since this was a docketed proceeding in which all of the comments are available in the Electronic Comment Filing System, the needs to service the petitioner directly is unnecessary. In doing so, they provided Cablevision an extra ten days to provide their response.

Personally, I’m very pleased with the development. It means that important comments will be considered as part of the public record. I would like to see this set as a standard. Any time the public can file comments in the Electronic Comment Filing System there should be no additional requirement for service of comments.

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Final FTC Comment How Will Journalism Survive the Internet Age?

Today is the last day to submit comments to the FTC for their Public Workshops and Roundtables, “From Town Crier to Bloggers: How Will Journalism Survive the Internet Age?”. When I had written about this previously I noted that there were only two comments. As of this morning, there were eleven comments and the response that I received from the submission form indicated that my comment was the nineteenth.

The comments are text comments, with the option of adding attachments. The text is unformatted and can become unreadable for long comments. So, I wrote an abstract which I pasted as the text, and the provided the details of my comments as a PDF file.

If my comment gets processed and the system behaves as it has for previous commenters, my comment should be at 544505-00019.pdf. However, as of yet, the most recent eight comments have not appeared.

That said, I would like to highlight a couple comments that struck me is particularly noteworthy. Mark MacCarthy, whom I believe to be an adjunct professor of Communications, Culture and Technology at Georgetown has a long interesting comment about increasing federal funding for public service media. I’ve only scanned it briefly, but hope to find more time to read it in detail before the workshops.

Mark Nadel, of the AEI-Brookings Joint Center for Regulatory Studies, has a very interesting comment on How Copyright Law Discourages Creative Output. It is seventy four pages, so I have a lot of reading on this before I can comment more on it.

Limor Peer from Yale’s Institute for Social and Policy studies, together with Pablo Boczkowski from the Department of Communications Studies at Northwestern share a thirty seven page working paper, The Choice Gap: The Divergent Online News Preferences of Journalists and Consumers. It looks like fascinating research that I hope to delve into in much more detail.

All of this dwarves my brief three page comment. Yet I hope I’ll have added something to the discussion. If you can’t read the final draft of my comment at the FTC website, it isn’t substantially different than my earlier draft.

I look forward to reading other comments and perhaps even getting a good online discussion going before the roundtables. Let me know what you think.

Update: The Society of Professional Journalists (SPJ) has posted SPJ’s DMC FTC Statement statement on their blog. It is another long and interesting comment.

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Preparing a comment to the FTC on the Future of Journalism

Friday is the deadline to submit comments to the FTC public workshops and roundtables, “From Town Crier to Bloggers: How Will Journalism Survive the Internet Age?”. As of Wednesday afternoon only two public comments are showing up on the FTC website.

Last month, I submitted a comment to the FCC about Cablevision’s petition to encrypt basic cable in New York City. I hope to submit a comment to the FTC for their workshops and roundtables and several others I know have been talking about submitting comments. In particular, the Society for Professional Journalists has a blog post asking for comments for their comment.

With that, let me present my initial draft of things that I believe the FTC, and more importantly, the Government as a whole should be considering to address the future of journalism.

Media Education: Journalism and Media Literacy

First and for foremost, I believe that we need much more media education in our schools. We need to be teaching students how to be journalists. From this, they will develop a great appreciate of what is involved in good journalism and why it needs to be supported. Related to this, we need much more education in our schools about media literacy. How do students understand what is being said and unsaid by news organizations, advertisements, websites and so on? How do they determine truth from fiction?

One suggest that has been floating around has been various forms of ‘Write for America’, where newly minted journalists would write in underserved areas, similar to how ‘Teach for America’ works. This seems like a good idea to me. There are many ways that I could see this taking place, such as forgiveness of student loans for those who take jobs reporting in underserved areas up through a twenty first century WPA producing a new generation of great literature.

Reverse Media Consolidation

In theory, it would seem, media consolidation would be a good thing for news organizations. Overhead could be reduced and synergies found. However, in practice it appears that media consolidation has resulted in increased debt loads that news organizations have had to carry, as well as a loss of good local reporting. This has decreased the value of many news organizations’ products. In addition, it appears to have resulted in advertising being driven by larger corporate organizations that have less contact with local businesses. This in turn drives down the advertising dollars received.

One aspect of this is the FCC’s rules on over the air television and radio stations. In looking at whether or not to grant a license, a renewal, or permission to consolidate, the FCC used to look more at the public needs. As we are seeing, a key part of the public need is quality local journalism, and this should be much more carefully considered for all spectrum requests.

Journalism Stimulus Packages

Beyond a new WPA or Write for America project, there are many other ways that journalism is directly or indirectly funded by the government. One large existing package is the paid public notices that local governments are required to put in local papers. There is a continuing battle over whether these public notices should or could be better served by online news organizations.

Here in Connecticut, we have the public funding of State elections. Some of the funding from this goes to advertising, and some of that may go to advertising with local news organizations. Two other states have public funding of elections and there is a bill in Congress to consider public funding of Congressional campaigns. It might be beneficial to designate some portion of such public funding to go to advertising to local news organizations.

Beyond that, other stimulus packages may have had some effect. I cannot help but wonder how many advertisements were bought from local news outlets promoting new cars as part of the cash for clunkers program, or how much real estate advertising has been created as a result of the first time homebuyers’ credit. As legislators draft stimulus packages, they should consider not only how the package affects Main Street, but also how it affects the journalist coverage of Main Street.

To the extent that we can reverse media consolidation and return news organizations to being small businesses providing local coverage, it may be beneficial to look at how the Small Business Administration can help news organizations similar to how they help other small businesses. The FTC and other organizations might also want to work more closely with marketing and advertising firms to help make advances in digital advertising more accessible to smaller organizations.

Better Data Access

Most of my previous comments have been on the business side of journalism. However, there is another very important trend that needs to be considered. Slowly, more and more government information is becoming easily available via the Internet. This helps out reporters get the information that they need. All levels of government from the local up to the national, should be encourage to make more data easier to access. This should include the ability to subscribe via email, feeds like RSS, and increasingly via real time data feeds. Governments should include the ability to retrieve raw data in structured formats so that reporters can better analyze the data. Finally, governments should provide training in accessing this data to reporters and citizens a like.

So, this is my initial draft of comments. What do you think? Care to comment on this draft? Going to create a comment of your own? Let me know.

Updates: Thinking more about media consolidation, not only should the FCC be concerned about this when it relates to the public airwaves, but the FTC should be concerned on how it affects competition and governments providing franchise agreements for companies that use the public right of way to deliver television and telecommunications should be concerned about this.

The public right of way issue also needs to be considered in terms of making sure that public access television is given a proper chance to flourish in this new media ecosphere.

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Rabbit, Rabbit, Rabbit

#NaNoWriMo, Google Voice, StatusNet, Karmic Koala, Matlab in Joomla, Portfolio Analytics, Ad:Tech, Citizen Journalism conference, Trip to Virginia and to Cape Cod, proceedings in the Cablevision request, CEP, Doninger Case, making cider. The list seems to go on and on.

I often start each months’ blog posts with the old childhood saying, “Rabbit, Rabbit, Rabbit” meant to bring good luck for the month. Yet there is also an old saying, chase two rabbits, catch none. I feel more like a young kid in with ADHD in a field full of rabbits randomly running this way and that, sort of like Brownian motion.

I’ll keep this post short as short as I can, so I can start chapter one of Liza’s Party, my NaNoWriMo project. If you are interested in sharing ideas, or reading and commenting on my rough draft, please contact me directly.

When I’m not writing fiction, I’ll be busy writing and testing code, for both fun and profit. My Google Wave Federated Server is up. I’m working on setting up a second so I can actually test federation. If you have a federated server, let me know and we can collaborate. If you want to get text console access to a Google Wave server that is not connected yet to the main Google Wave servers, let me know. I’ve done some interesting hacking to make that possible. It isn’t as nice as the full Google experience, but it is a way to play with the technology.

Then, when I get a chance, I’ll continue my StatusNet migration. My previous installation was so old, that I’m planning on dumping what I had and starting from scratch. I’m partway through the installation, and I really want to connect it up to my XMPP server so that I can explore StatusNet to Google Wave integration options. Again, if you’re interested in this, ping me, but it may be a little while before I can really explore this.

In order to upgrade my laptop for testing with Google Wave, I’ve kicked off the upgrade to Ubuntu 9.10, also known as Karmic Koala. I left it running last night and it said it would take several hours to download all the updates. Now, it is sitting with the message fetching file 1295 of 1295 on the screen. It has been like that for a while, and not moved to the Installing the upgrades phase. I’ll keep glancing at that, and then eventually test some of my Google Wave Federation from that machine.

Of course all of this needs to happen in the background as I work on two paying projects involving Matlab. One is in the final phases of testing and hopefully will be completed soon. The other involves implementing a routine written with the Matlab Runtime Executable into a Joomla website. Most of the pieces are in place, and now I need to try putting them together to see how they work, and then fine tuning the result.

Then, there are the conferences. Ad:Tech is coming up this month, as is a conference on Citizen Journalism. It looks like the conference on Drama Therapy is likely to fall by the wayside. For other travels, there will be a trip to Virginia for a weekend at my daughters’ college, and a trip to Cape Cod for an extended family Thanksgiving celebration.

In legal and rules making activity, there is the Cablevision case, where their replies are due in about a week. There is the Citizens’ Election Program case, where replies are still being written, and there is the Doninger Case where I believe the replies are all written and we’re just waiting for oral arguments. This may involve another trip to blog from the Second Circuit in New York City before I know it.

Beyond all of this there are ongoing projects like the cider making, Fiona’s Radio Show, and who knows what else. Time to end this blog post, without spending time for editing and getting on with #NaNoWriMo 2009 – Word Count 0. Rabbit, Rabbit, Rabbit, indeed.

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Debunking Digital Publishing and Advertising Myths

Many great speakers presented many great ideas at the Digital Publishing and Advertising Conference in New York City earlier this week. However, some of these great ideas are myths that need to be debunked.

Leading off the list was a comment by Walker Jacobs, Senior Vice President of New Media Ad Sales for Turner Entertainment. In the Keynote Panel, The Media Moguls Address the Digital Content and Advertising Economy, he suggested that all of their content is paid content, the question is who is paying for it. This exposes an interesting myth that takes several different forms about the divide between paid content and truly free, user generated content.

One form of the myth is that the only good content is content that people get paid for. Other forms include the idea that free content is some new creation of the digital world and that people who share free content, perhaps even making money off of this are bad.

So, let’s look at some forms of free content. I don’t know if there were many academics in the audience that have published significant articles in peer reviewed journals. If so, I suspect most of them did not get paid for their content. I know that I have not been paid for articles I’ve written for peer reviewed scholarly journals. Related to this are the chapters that people write for books edited by others. Many of these chapters add significantly to the literature on one topic area or another, but again, it is typically the editors that get paid, and not the people creating the content. Again, I’ve had chapters published in a couple different books which I’ve not been paid for.

There is nothing new about free content being produced, and sold at a profit by book companies, editors, and journal publishers, and much of this content is very high value content.

Of course, all of this is based on a fairly narrow view of what it means to be paid. Free content producers are often paid in social capital; strokes or accolades. I remember years ago, when a friend of mine who wrote for the Wall Street Journal had her first article front paged on that newspaper. She had a party to celebrate. Accolades for financially remunerated articles and for articles where there is no financial remuneration can be a significant payment. I still get a little thrill when one of my blog posts gets front paged on a site where I had not been expecting such an honor.

This takes me to “The Ultimate Digital Content Debate: Paid or Free?” The first piece of free content about the debate at DPAC was from @scanlon_pittPG who tweeted, “Wow what an ego! ‘the debate about pay walls and journalism over’ because of myself and my partner Steven Brill #dpac4” Brill went on to defend his statement with the assertion that “People are realizing that advertising alone cannot support news”.

While Mr. Brill might be ‘realizing’ this, or at least attempting to realize a profit based on this assumption, it is unsupportable in many ways. First, it is based on a “but we’ve never done it that way before” assumption. I’m assuming you know those corporate meetings. Some young creative innovator comes in with a great idea and one of the large old egos sitting at the end of the table says, “But we’ve never done it that way before”. If the innovator is smart and lucky, he leaves the meeting, finds an angel investor and sets up a company to champion the new disruptive approach, taking down the large old egos.

Yes, it is true that in the past, newspapers have had to rely on both subscriptions and advertising to cover their costs. As an example, based on a 2008 10-Q filed by the New York Times corporation, 60% of their revenue came from advertising and 40% came from subscriptions. However, with print versions, there are costs of raw material, printing and distribution that are much more expensive than the cost of web hosting today. In addition, much of the cost of newspapers include significant interest payments covering the debt servicing of leveraged buyouts from corporate consolidation that wracked the market years ago as well as the payout needed to investors and the large salaries demanded by top executives. For a good example of this, look at the bankruptcy filing of the Journal Register Corporation which included a $1.7 million dollar incentive pay plan for 31 officers and key employees.

One needs to question whether a properly set up online news organization without the cost of printing, excessive corporate debt, and excessive executive compensation really does need subscription revenues to survive. Early successes of some online only local news sites give reason to believe that the assumption must be questioned.

Ignoring for a moment the issue above about whether there can be quality free content, @scanlon_pittPG tweets that Steve Brill believes “You should pay for content because reporters have families.” @scanlon_pittPG goes on to observe, “Nice, but that is NOT a business model.” This gets to a very important point. Just because it might cost money to produce something, doesn’t mean that it is valuable or that people are willing to pay, a point that @bjornjeffery made on Twitter.

Yet the place where Brill seems to cling most firmly to outdated notions is the idea that the role of a paid editor to organize and make sense is required. As I walked home from the DPAC conference, I saw news scrolling freely on the side of a building. It announced a report that the Coast Guard’s exercise on September 11th did not violate any policies, but may not have been a good idea anyway. The reason it may not have been a good idea is perhaps because of these paid editors that Brill lauds that decided to run unsubstantiated stories on September 11th, the same editors that decided the Balloon Boy hoax was more newsworthy that the general strike in Puerto Rico on the same day. Just because it costs money to produce something, doesn’t mean what is produced is valuable.

Now this is not to say that there is not some valuable journalism being done where the journalists deserve to get paid. Here in Connecticut, Ted Mann of the New London Day has recently been doing investigative reporting into the Governor’s use of polling help from a UConn professor that is outstanding. This sort of reporting does provide a value; a value that people who care about our state should be willing to support in one way or another. National Public Radio has long produced reporting that people are willing to support and Spot.Us is creating a new model for funding investigative reporting that needs to be considered.

There is a lot of valuable content that is being produced. Some gets paid for, some doesn’t. We need to explore new models to make sure that the most valuable content does get properly paid for. We need to change models so that the overhead in producing and distributing valuable content gets reduced. More efficient ways of selling and purchasing online advertising and data could be a great help. Ways of making this available to smaller publishers would be a great help. However, setting up more paywalls, and supporting overhead like Mr. Brill may just be a step in the wrong direction.

(Originally published at DigidayDaily.)

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