NPR and SPR Underwriting Guidelines

May 31, 2013

Public Broadcasting: Who Pays?
from SPR President and General Manager Cary Boyce

I’ve received various questions about underwriting practices on Spokane Public Radio and NPR. This is a good opportunity to talk through some of the complex issues surrounding seemingly simple questions.

NPR is solely responsible for its content. But as an NPR affiliate station, SPR adheres to their journalistic guidelines, as well as to the Federal Communications Commission restrictions on the kind of non-commercial/educational license we have. Steps are periodically taken to review our ethical guidelines, and more detailed information is available at www.ethics.npr.org. NPR ethics were externally reviewed recently by Robert Steele, a specialist in journalistic ethics at DePauw University. I quote from some of the resulting NPR guidelines below:


"Independence: To secure the public’s trust, we must make it clear that our primary allegiance is to the public. Any personal or professional interests that conflict with that allegiance, whether in appearance or in reality, risk compromising our credibility. We are vigilant in disclosing to both our supervisors and the public any circumstances where our loyalties may be divided—extending to the interests of spouses and other family members—and when necessary, we recuse ourselves from related coverage. Under no circumstances do we skew our reports for personal gain, to help NPR's bottom line, or to please those who fund us. Decisions about what we cover and how we do our work are made by our journalists, not by those who provide NPR with financial support."

The part about disclosure is worth noting. FCC guidelines clearly require us to disclose on our airwaves where our funding comes from. The result is the final line above about where the news decisions are made. These actions are critical to our integrity. The FCC also chimes in on transparency: 

"Sponsorship Identification: The sponsorship identification requirements contained in the Communications Act and the Commission’s rules generally require that, when money or other consideration for the airing of program material has been received by or promised to a station, its employees or others, the station must broadcast full disclosure of that fact at the time of the airing of the material, and identify who provided or promised to provide the consideration. This requirement is grounded in the principle that members of the public should know who is trying to persuade them with the programming being aired. This disclosure requirement also applies to the broadcast of musical selections for consideration (so-called “payola”) and the airing of certain video news releases. In the case of advertisements for commercial products or services, it is sufficient for a station to announce the sponsor's corporate or trade name, or the name of the sponsor's product (where it is clear that the mention of the product constitutes a sponsorship identification)."

The FCC guides how we frame these announcements. They require that there are no “value” statements or clearly commercial implications are made. Acceptable announcements generally state the name of an organization, what the services or products are, and minimal contact info. Occasional exceptions are made when an organization has a slogan that they can document has been in use for some time. Admittedly, there is some flexibility of interpretation depending on the submissions, but SPR strives to remain well within a reasonable and conservative view.
This is where the “firewall” comes in, essentially an administrative structure to keep any money-raising endeavors of the station separated from any news decisions. The idea is that no employee conspires in any way to encourage journalistic coverage of a topic based on “pay for play” basis—a practice expressly forbidden by the FCC for non-commercial/educational licensees like SPR.

Occasionally, funding may come from competing organizations or individuals with dearly held views or businesses with vested interests that some listeners may take issue with. NPR Corporate Sponsorship Manager John King says NPR does not have a list of sources from which funding will not be accepted. But NPR follows guidelines, approved by its Board of Directors, stating that NPR "seeks underwriting representing a broad spectrum of funding sources: corporations, foundations, individuals, government agencies, and others." This general guideline also helps assure that a broad spectrum of perspectives can be represented, and that dependence upon any single one doesn’t take over or hold sway.

But news coverage of a particular organization does not preclude that organization from making donations or taking out underwriting, either with us or with NPR, so long as the announcements are within FCC guidelines. NPR Ombudsman Alicia Shepard goes on to say that about 20 percent of listener concerns have to do with NPR's funders. "There's a general feeling that they want the John D. and Catherine T. MacArthur Foundation, something so neutral, to be the funders. But NPR has grown a lot in corporate sponsorships. When listeners hear sponsors that they dislike … they call in to say NPR should not accept those funds." SPR follows suit, taking dollars from a host of sources.
Whether a sponsorship comes from an individual, a corporation, or a foundation, NPR and public radio stations like SPR follow the same guidelines to protect the firewall between its news service and its development departments. It’s neither prudent nor fair to exclude a business or organization from underwriting on SPR, unless they happen to fall within very specific legal or ethical reasons to turn someone down. Even here, both categories can easily fall within a very broad gray area that can be difficult to parse out.

Some recent listener questions have inspired us to look at other station guidelines in an effort to develop our own. We’re in the process, but some typical guidelines we’ve come across prohibit announcements for hate organizations, pornography (yet another gray area fraught with legal landmines), or announcements for political and religious organizations that specifically advocate a particular view. And many businesses that advertise on commercial media will often exclude themselves from public media airwaves because they feel, appropriately, that we don’t reach or track their target market or demographic.

Public broadcasting is a public trust. And so we strive to earn and preserve that trust every day. The moment we “cave” to commercial pressures, we erode that trust. Even from a commercial standpoint, “trust” is the very basis of our brand. It therefore makes commercial as well as ethical sense to preserve it as best we can.

I hope this rather lengthy explanation provides some insight into a complex subject. If there are any other questions, please send a note to kpbx@kpbx.org
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