A Report Prepared by the Civil Rights Forum on Communications Policy
Being No. 1
Is Not Enough:
The Impact of Advertising Practices On Minority-
Owned & Minority-Formatted Broadcast Stations
Kofi Asiedu Ofori
submitted to the
Office of Communications Business Opportunities
Federal Communications Commission
All Rights Reserved
to the Civil Rights Forum on Communications Policy
a project of the Tides Center
As part of its mandate to identify and eliminate market entry barriers for small businesses
under Section 257 of the Telecommunications Act of 1996, the Federal Communications Commission chartered this study to investigate practices in the advertising industry that pose potential barriers to competition in the broadcast marketplace. The study focuses on practices called "no Urban/Spanish dictates" (i.e. the practice of not advertising on stations that target programming to ethnic/racial minorities) and "minority discounts" (i.e. the practice of paying minority-formatted
radio stations less than what is paid to general market stations with comparable audience size). The study consists of a qualitative and a quantitative analysis of these practices.
Based upon comparisons of nationwide data, the study indicates that stations that target
programming to minority listeners are unable to earn as much revenue per listener as stations that air general market programming. The quantitative analysis also suggests that minority-owned radio stations earn less revenues per listener than majority broadcasters that own a comparable number of stations nationwide.
These disparities in advertising performance may be attributed to a variety of factors
including economic efficiencies derived from common ownership, assessments of listener income and spending patterns, or ethnic/racial stereotypes that influence the media buying process. As a preliminary investigation, it was beyond the scope of this study to determine in quantitative terms the degree to which each of these factors may explain these disparities. Further statistical research should be undertaken to find the answer to this question. Anecdotal data collected by the study suggest that in certain instances, the media buying process is guided by ethnic/racial stereotyping, underestimations of disposable income, the desire to control product image, unfounded fears of pilferage, etc. Factors such as these form part of the basis for "no Urban/Spanish dictates"and "minority discounts" as practiced by advertisers and/or ad agencies.
As preliminary findings, the anecdotal and quantitative evidence suggests that certain
practices in the advertising industry undermine marketplace competition and First Amendment principles favoring diversity of viewpoint. The study recommends further research that is sufficiently funded to fully examine these preliminary findings. The study also recommends that the federal government, based upon subsequent research and public comment, develop a policy
statement on advertising practices and issue an executive order prohibiting federal agencies from contracting with ad agencies that engage in unfair or discriminatory advertising practices. With regard to the private sector, broadcasters, advertisers, and ad agencies should adopt a voluntary code of conduct that prohibits "no Urban/Spanish dictates"and "minority discounts" and that promotes
a broad and diverse range of programming for all Americans.
Key words: advertising and discrimination; advertising and minorities; advertising and minority radio programming; small business competition and radio advertising.
A. An analysis based upon 1996 data for 3,745 radio stations indicated that:
- Stations that target programming to minority listeners earn less revenue per listener than stations that air general market programming.
- Minority-owned radio stations earn less revenue per listener than majority
broadcasters that own a comparable number of stations nationwide.
B. Minority radio broadcasters responding to the study survey provided the following estimates of the magnitude and impact of "no Urban/Spanish dictates" and "minority
- Ninety-one percent indicated that they had encountered "dictates" not to buy
advertisements on their radio stations.
- Efforts to overcome "dictates" with market research that justifies ads on minority-formatted stations were most commonly met with no response or no recission of the dictate by advertisers or ad agencies.
- Survey respondents estimated that sixty-one percent of the advertisements purchased on their stations were discounted. The average amount of the discount was estimated to be 59 percent.
- Survey respondents estimated that "no Urban/Spanish dictates" and "minority
discounts" reduce their revenues by an average of 63%.
- Forty-four percent estimated that "no Urban/Spanish dictates" and "minority
discounts" interfere with their ability to raise capital and to acquire minority-formatted stations.
- Forty-four percent estimated that "no Urban/Spanish dictates" and "minority
discounts," detract from the value of minority-formatted stations when they are being sold.
- "No Urban/Spanish dictates" and "minority discounts" constitute barriers to
competition because they detract from the amount of revenue earned per listener, and thus hinder a broadcaster's ability to attract investment capital, and to produce high quality news, information and entertainment programming in response to the needs
- Most radio stations that air minority-formatted programming are adversely affected
by advertising practices directed against minority listeners. Minority-owned stations, however, are disproportionately affected because 75% of them air programming targeted to minority listeners, compared to 8% for majority broadcasters.
- To the extent that minority formatted stations are unable to obtain advertising, their ability to serve the needs of listeners is impeded. The interest of all Americans, particularly minorities, in a broad and diverse range of informational and entertainment programming is undermined by advertising practices directed against
minority consumers. Hence, "no Urban/Spanish dictates" and "minority discounts," undermine competition and detract from the First Amendment goal of diversity of viewpoint.
- Subsequent research should endeavor to quantify the causal relationship between
advertising practices and disparities in the advertising performance of minority-formatted and general market stations, and minority and majority-owned stations controlling for various factors such as ownership size, audience income, and market location.
- The Federal Communications Commission and the Federal Trade Commission
should assemble a joint task force for the purpose of adopting a policy statement on acceptable advertising practices.
- Based upon the findings of subsequent research, the federal government should
decide whether to issue an executive order that prohibits federal agencies from contracting with advertising agencies that practice "no Urban/Spanish dictates" and "minority discounts," or that otherwise fail to comply with the policy statement of the
joint task force.
- The advertising and broadcast industries should adopt a code of conduct that requires buying decisions to be based upon market research and not flawed stereotypical assumptions. "No Urban/Spanish dictates" and "minority discounts" should be prohibited. Broadcasters should be required to prominently disclose whether the
market research they use in conjunction with sales promotion has been prepared by a service that has been accredited by the Media Ratings Council. In instances where a non-accredited market research service is used, broadcasters should be required by
the FCC to show cause why they do not use a service that is currently accredited by the Media Ratings Council.
Comparison of Minority and Major Broadcasters by Format
(All figures are averages. Currrency in thousands)
|(Number of Stations)
||'96 Nat Rev
||# Nat. Stat.
||'96 Stat. Rev.
|Majority Owned - All (3293)
|Majority Owned - Small (2,288)
|Minority Owned - All (39)
|Minority Targeted Formats
|Majority Owned - All (297)
|Majority Owned - Small (193)
|Minority Owned - All (116)
Source: "When Being No. 1 Is Not Enough: The Impact of Advertising
Practices On Minority-Owned & Minority-Formatted Broadcast Stations." (page 79)
Civil Rights Forum on Communications Policy.