This comment examines: (1) the history of the ascertainment procedures, including the function of the original Primer; (2) the effect of the Renewal Primer amendments on the ascertainment procedures; and (3) the significance of the Bamford cases in light of the treatment of badly-organized groups under prior ascertainment procedures, and in light of the issuance of the Renewal Primer. The comment argues that the Primer's purpose of increasing the responsiveness of a broadcast applicant to the needs of its proposed service area has improved the situation for the more organized significant groups, such as minority groups, but its effectiveness as to badly-organized significant groups such as the poor is questionable. It also raises question as to the Renewal Primer's effect on promoting community interests in a licensee's programming decisions and concludes by raising two suggestions to improve representative broadcasting.
Arthur P. DeLuca,
FCC Broadcast Standards for Ascertaining Community Needs,
5 Fordham Urb. L.J. 55
Available at: http://ir.lawnet.fordham.edu/ulj/vol5/iss1/3