Background

     FCC concerns about radio advertising and programming were anything but new-they had been a part of commission discussion and some legal cases since the commission's creation in 1934. With the approaching end of World War II, the FCC was better able to focus on domestic issues, and incoming chairman Paul Porter proposed a study of radio program practices on which the commission might base overall policy guidelines that could assist in its station licensing decisions. What several commissioners felt was needed was a comprehensive analysis of program and advertising promises stations made in applying for licenses versus their actual performance three years later when that license came up for renewal.

     In mid-1945 former British Broadcasting Company (BBC) official Charles A. Siepmann was hired to work with attorney Elinor Bonteque and the FCC staff to develop a workable study of "promise versus performance" measures, including such measures as the amount of advertising a station carried per hour or week, the proportion of locally produced programs provided, and the proportion of sustaining (non-spon­sored) programs offered. Because it was too costly and time consuming to survey all 900 AM radio stations then on the air, a few sample cases would have to be relied on to provide a picture of current industry practices. Even before the study got under way, the commission began to hold up once-routine license renewals in cases where there was evidence of serious promise-versus-performance problems. By early 1946 more than 300 stations-nearly a third of all those on the air-were in license limbo.

What It Said

     On 7 March 1946, the FCC released a 149-page mimeographed report in light blue covers titled Public Service Responsibilities of Broadcast Licensees. Demand for copies led to a printed version of 59 pages, and it is these that are usually found in libraries and archives today. The "Blue Book" (as it was quickly dubbed by all parties) was divided into five parts: (1) a discussion of the commission's concern with program service (which presented five case studies of specific stations found wanting); (2) the FCC's legal jurisdiction with respect to program service; (3) four specific aspects of the public interest in program service; (4) a review of relevant economic issues; and (5) a summary and conclusion including proposals for future commission policy.

     The five case studies in Part I each pinpointed a different problem. KIEV in Glendale, California, was found to have promised considerable local cultural and public service programming and limited advertising-but instead to have provided a largely sponsored recorded music service, meeting almost none of its original promises. WSNY in Schenectady, New York, had been granted a license in a comparative hearing based on programming promises that, at renewal time some years later, had not been fulfilled. Station WTOL in Toledo, Ohio, had obtained a full-time authorization (it had been a daytime-only operation), again based on certain promises concerning local public service programs, which were found "conspicuous by their absence" four years later. Baltimore station WBAL changed ownership in the mid-193os, and a decade later it was found to be providing a service largely bereft of promised local sustaining programs. And finally, station KHMO in Hannibal, Missouri, obtained a license in a court action in the mid-1930s, based in part on programming commitments that it was not fulfilling by early 1945·

     The second part of the Blue Book, concerning the "commission jurisdiction with respect to program service," focused on legal issues raised at the time of the FCC's creation from the former Federal Radio Commission. Written by Bonteque, this section concluded that the FCC "is under an affirmative duty, in its public interest determinations, to give full consideration to program service."

     The specifics of that determination were spelled out in Part 3.  The Blue Book defined the public interest to include four specific requirements of all radio stations. The first was to carry sustaining programs-those not paid for by commercial sponsors-because such programs provided a vital balance to advertiser-supported programs, especially for minority audiences and program experimentation. Including several full­ page charts illustrating station practices, this was the longest single part (nearly 24 pages in the printed version) of the Blue Book. The second requirement was to carry local and live programs to reflect local community concerns and interests. Excessive reliance on national commercial programs was held to be an example of poor practice. Carrying discussion of public issues was the third requirement. Another lengthy section of eight pages was devoted to the fourth requirement-not carrying too much advertising.

     The 4th portion of the Blue Book focused on economic aspects-essentially the profits made by the industry. Here 14 tables demonstrated the substantial returns stations had made during the war, suggesting that a profitable business like radio broadcasting could easily support a larger public service role.

     Finally, the Blue Book turned to the role of the public and government with some specific procedural proposals for future regulation (some of this section was written by Siepmann). Among these proposals were creation of uniform definitions of program types, segments of the broadcast day, selection of a composite week on which program reports would be based, some revisions in license and renewal application forms, and procedures on renewal actions. All of these proposals were designed to allow ready comparison of practice across stations. The same section also called for more radio criticism, self-regulation, radio listener councils, and education about radio in colleges and universities.

Impact

     Publication of the Blue Book brought forth an instant negative radio industry response, including rhetoric that the government was trying to take control of radio CH censor broadcasters. At the least, industry figures argued, they should have had a chance to comment upon the cases and methods used and the findings reached before the report was released. Along with other critics, they also held that the FCC had no authority to regulate as it seemed to intend; at the same time, the report was criticized for emphasizing a few bad actors in an otherwise well-meaning and effective industry. Even some of those sympathetic to the report's intent felt the distinction concerning benefits of sustaining and commercial programming was overstated. And the financial section probably overstated the industry's profits, because the war years, in retrospect, were clearly an unusual period (given wartime limits on newspaper advertising to save paper and tax provisions making it beneficial for companies making war products to keep their names in the public eye with radio advertising).

     Did the publication have any lasting effect? In the end, no station lost its license for the kind of transgressions described in the Blue Book. Virtually all the licensees designated for renewal hearings because of Blue Book issues were eventually renewed-and hundreds of new stations took to the air as well. Yet the FCC never withdrew or replaced the document, which remained in place as a statement of policy thinking for years to come. Still, a decade later, radio broadcasters were carrying even fewer sustaining programs in what had become a "local," although heavily commercialized, music service. By 1959 the trade weekly Broadcasting noted that the report was long out of print and was "now something of a collector's item."