Coalition for the Prevention of
October 24, 1996
The Honorable Reed Hundt
Dear Chairman Hundt:
We are writing you on behalf of the Coalition for the Prevention of Alcohol Problems to share with you our concerns about Seagram's abandonment of the liquor industry's voluntary ban on broadcast liquor ads. In addition, we would like to offer assistance to the Commission in exploring whether such advertising comports with broadcasters' public interest responsibilities, particularly with regard to protecting children from additional broadcast inducements to drink.
We are especially concerned about this issue for the following reasons:
Two government agencies -- the Federal Trade Commission (FTC) and the Bureau of Alcohol, Tobacco, and Firearms (BATF) -- share statutory authority over alcohol advertising. However, we believe that the Federal Communications Commission, which oversees broadcast licensee compliance with public interest responsibilities that flow from the use of publicly owned airwaves, has adequate authority and a unique opportunity to protect children from liquor advertising that may increase their risk of alcohol problems. Based on the concerns identified above, we think the Commission has an obligation to explore the following approaches:
1. Initiate a forum for public comment on broadcast advertising of distilled beverages. That inquiry could include widely publicized public hearings. Ideally, several stages of inquiry would examine the state of research into the effects of alcohol advertising on youth attitudes and expectations about alcohol, as well as the beliefs of parents and the general public about the effects of broadcast alcohol commercials. Such a process could also involve young people.
2. Request information from broadcasters about the age distribution of viewers during specific programming throughout their broadcast schedules. This information can be used to assess whether there are periods during the day when youth viewership is so limited that alcohol advertising might not be inappropriate during that time-slot. In developing a standard for determining when youth viewership is sufficiently limited, the Commission could refer to new regulations at the Food and Drug Administration developed to protect children from promotions for tobacco products.
3. Develop detailed information on the distribution of liquor advertising throughout various day parts (and programming) to determine the degree to which young people are reached by the ads. Establish estimates for the total amount of liquor advertising anticipated if other distillers follow the Seagram Company's lead, and develop estimates for the increase in exposure to alcoholic-beverage advertising among young people. Solicit expert analyses of the effects on young people of this extra amount of alcohol promotion.
4. Request information from broadcasters (and alcohol producers) on the potential effects on young people of anticipated increases in advertising for new products on television. In much the same way we require developers to submit environmental impact statements before commencing a building project, we should require alcohol producers and broadcasters to assure the public that massive new advertising campaigns for products that appeal to new drinkers will not add to alcohol problems, particularly among young people. Those analyses would help assure that such advertising would not compromise broadcasters' public interest responsibilities.
5. Relying on testimony and written submissions from academic and other experts (as well as children themselves), determine whether certain kinds of appeals or characters in alcohol advertising have a strong impact on young people. A small study on the appeal of the Budweiser frogs and a more sophisticated analysis of RJR's Joe Camel character provide models for further inquiry.
6. Poll broadcasters regarding the level of advertising revenues (as a percentage of total revenues) each receives from alcoholic-beverage producers. Citizens could then use this information to question whether the broadcaster's public interest responsibilities may have been compromised by broadcaster dependence on those revenues. This would assist the public in commenting on broadcasters' license renewal applications, as well as help the Commission determine whether the applicant broadcaster has met the public interest standard.
In addressing liquor advertising on television and radio, the Coalition believes that it is essential that the Commission not become fixated on the current, inconclusive state of research into the quantitative effects of alcohol advertising on consumption and harm. In fact, there is research that supports adverse effects of alcohol advertising and no effects, as well as research that demonstrates the relationship of the ads with beliefs and expectations among young people about drinking. Further inquiry seeking behavioral outcomes alone can better inform us, but will never adequately resolve the question.
As Janet D. Steiger, then Chairman of the Federal Trade Commission, testified before Congress, "the research methodology by itself may simply be incapable of accurately measuring [the relationship between advertising and consumption and harm]." For that reason, we urge the Commission to take a far broader approach in its examination of the potential consequences for children of an expansion of broadcast alcohol advertising. We believe the Commission must look beyond the elusive quantitative measures of behavioral response to alcohol ads, and also examine the degree to which those ads reach young people, appeal to them, and influence how they think and feel about alcohol.
We deeply appreciate your concern for young people and your interest in protecting them from a new onslaught of powerful broadcast ads for alcohol. We look forward to meeting with you soon and to working with you and the Commission to insure that broadcasters meet their responsibilities to children and teenagers.
George A. Hacker, Director