Our fictional station team reflects on the growing regulatory storm

This is an account of an imagined second senior staff meeting at a major university joint licensee in the wake of the U.S. House DOGE subcommittee hearing on public broadcasting in March 2025 and the earlier FCC announcement of an inquiry into public media underwriting practices. The first account recorded the staff’s thoughts about the hearing. This account shares the staff’s thoughts two weeks later about the original FCC inquiry, analyzing it in light of the hearing and their earlier discussions.

As before, those attending the meeting were the Division Director and the management team — the Television and Radio Station Managers and the Associate Directors for Communications, Development, Engineering and Technology, Online Content and Membership.

The Director: Welcome, everyone. I’m glad that we can take a little time now to refocus more intently on the FCC inquiry. The DOGE subcommittee hearing was so attention-grabbing that it interfered with our discussions of some of the equally if not more serious implications of the investigation of our underwriting practices. As we’ve already seen, given our particular audience reach and prominence in this region, our shop is coming under close scrutiny.

TV Manager: Yes, that letter to us from the commission last week pretty much spells it out: They’re looking to find us behaving illegally. Even though we really haven’t been doing anything wrong, it’s a real worry. As I think everyone is finally beginning to see, the inquiry is more than just a direct threat to our federal funding — it’s an assault on our general business model. After Project 2025, we had expected the attack on CPB and any form of federal support. But it had never occurred to me that they were going to go after our private fundraising, too.

Membership: Given all that we’ve learned from the hearing and the apparent coordination among the White House, Congress and the commission, it’s clear that it’s more than a federal funding issue. I suspect this is really about not wanting us to be in any way broadly entertaining or seriously journalistic, and it may be worse.

Radio Manager: Well, that’s in large part why for a long while now a significant portion of my radio colleagues around the country have been less enthusiastic than their TV counterparts about lobbying for the appropriations. Federal funds represent a tiny fraction of the radio budget nationally and locally, and efforts to seek them compromise the integrity of precisely that news and public affairs orientation that has become such a staple of our service in recent years.

TV Manager: We have to be very careful about how we handle that argument. The system actually has been remarkably effective in avoiding government interference. We’ve been pretty good at building firewalls most everywhere, and at the local level we’ve successfully mitigated some of the most egregious state government cases. 

Online: Beyond that, any sophisticated rationale for public funding can point to the many models abroad for independent tax-based public broadcasting. We’ve just been too trapped in our own restricted U.S. perspectives of the meaning and possibilities for “public service” media to know how to appeal to those successful alternatives.

Communications: I’d also argue that we’ve been too careless in conceding that commercial media are somehow freer and less constrained than public media. Quite apart from questions of partisan bias among cable and podcast channels, we now know a great deal about how social, economic and cultural values shape all forms of media. “Free enterprise” is not necessarily all that free, and in promoting the public media alternative we should be saying much more about the institutional constraints in the market-based system.      

TV Manager: Coming back to the federal funding question, are you saying that radio can probably make it without the CSGs, as well as the national program fund and interconnection support, even if TV can’t?

Radio Manager: Yes, I guess I am. We all know how successful the local fundraising model has been and that radio has been driving a disproportionate share of it for some time. It’s become a powerful fiscal engine that has allowed us to leapfrog the decline in state and institutional support and the weak federal amounts. But the corporate support element has been crucial. As we’ve previously discussed, it appears now that our ability to maintain that part of our progress is being directly challenged and we’ll be forced to rely too heavily on membership.

Development: It’s infuriating that the chairman is taking this stand. It’s contradictory and hypocritical. He knows very well that we’re not breaking any laws. It’s really just a matter of how to interpret the FCC’s own rules. It’s almost as if he were arguing that public media should retreat to the largely instructional mission of the old educational broadcasting days.

The Director: Agreed. The fact is that federal, state and institutional funding have been on the ropes for decades and, because they’ve known that, the commission staff and our friends in Congress have long been signaling that we should be doing all that we can to enhance our private support, and they’ve even helped us by adjusting the rules. So here we’ve been doing just what’s been asked of us, and now our licenses are going to be challenged?

Online: It’s just like their wholesale assault on DEI; they’ve flipped the script and redefined the terms of the law.

Membership: Right, and while our audience numbers aren’t as robust as we’d like, we know that the income and education levels of our viewers and listeners are really attractive to much of the business sector. So we’ve been working hard to frame things that way.

Communications: All true, but in all honesty, I have to point out that our corporate messaging tendencies have revealed an emerging truth that the chairman is going to be able to exploit.

Engineering: What’s that?

Communications: It’s buried in that slowly growing number of emails and phone calls that we’ve been getting about the frequency and tone of all our messages.

Radio Manager: What do you mean?

Communications: It had been pretty sotto voce, but prior to January some commentary had been hinting at precisely the chairman’s point — that our underwriting spots had become more and more like general media ads. We hadn’t yet been making price comparisons or calls to action, but we’d already edged right up to product and service descriptions.

Membership: I’m afraid that’s what I’ve been hearing, too, but it could be even more serious. They’d also begun to complain that, in conjunction with those spots and particularly in radio, we overall seem to have had an unrelenting stream of commercial messaging, hour after hour, for things like sustaining memberships, vehicle donations and sponsorships of all kinds.

Radio Manager: Come on! We’ve been conscientiously crafting those messages and painting within the lines. Sure, as we’ve discussed around this table many times, we’ve been testing the limits, but we’re still following the rules, right?

The Director: Technically, yes, but we may be missing the real undercurrent out there. Our audiences don’t know what the FCC rules are, nor do they care about how carefully we think we’ve been following them. As much as they may love us, what they also hear on air and see online is a great deal of promotional clutter that, whether correct or not, sounds and looks to them very much like commercial media. No matter how unfair it is, the chairman’s argument is going to resonate with many.

Communications: Things may be catching up with us. We’ve always known that “underwriting” is a euphemism, and in recent years we’ve even been hearing some of our less careful people use the term “ads.” It’s a transition in sponsorship forms not unlike that of commercial radio in the 1920s and ’30s.

Online: So why are we trying so vigorously to protect the licenses? We know that the vast majority of public service systems abroad are funded by a mix of tax-based sources and conventional advertising. We also know that the future’s increasingly online and digital. The audience is highly fragmented, and it’s thoroughly done now with the old mass media “push” models. It’s been more and more “pull” — on demand — for years now.

Engineering: You can’t be serious. Those licenses are incredibly valuable, especially with their HD multicast channels and use for the emergency alert system. And would you give up our reservation status?

Online: I am serious. Our platforms, as for all content, are more and more podcasting and social media. Let’s be honest. Think about how much time each of us personally invests in commercial services like YouTube, Instagram and streaming of all kinds. It’s an entirely different and seemingly democratic new model — everyone can engage in it. There’s just no dispute that the days of our being top-down, hard-schedule programmers are nearly over. Our transmitters are century-old relics. Let’s finally bite the bullet and get beyond a too-precious noncommercial spectrum-based rationale.

The Director: Well, that really frames the debate for us, and the environment is, to say the least, challenging. I know how hard each of you has been working to build our audiences and our entire palette of nonfederal financial support. So it’s discouraging to be slapped with this kind of blanket opposition.

Communications: Ironically, it’s probably been the growing success of the enterprise that’s reenergized the critics. We can’t quite say it publicly, nor this directly, but I believe they’re afraid of the intelligence and civic consciousness in the public media discourse.

TV Manager: Bingo! That’s always been their real dislike — the fear of an enlightened public. It’s the same as the attack on journalism generally — they can’t abide critical inquiry. But that said, and if we’re being candid in this room, I should note that I’ve long feared this attack on our alleged commercialism. What surprises me, though, is that it’s coming from the right. Frankly, I’d been worrying that it would emerge more on the left. Could we be in more trouble than we’ve realized?

The Director: Indeed, as we saw more clearly in the hearing, we could be. On the one hand, the chairman is playing to an aspect of that old, largely partisan opposition that public media have faced ever since the ’67 Act, and he’s giving space for it to ramp back up. We know, for instance, that while they’ve been conflicted over the years, a couple of members of our own state’s congressional delegation have been emboldened enough to forego their prior, albeit muted, bipartisan support for us. They wouldn’t necessarily join the congressional public broadcasting caucus, but at least they wouldn’t speak in opposition.  Now, however, they’re sharpening their knives to join the general assault. 

Communications: And the terrible irony is that the chairman is also teaching Congress that the fight can be about more than our alleged “liberal biases.” He’s shaping that attack to draw from the other side’s traditional lament — that we’ve sold out to the corporate world.

The Director: Precisely. So, we’re being pincered in a no-win situation. Seen in broad perspective, it seems that we’re now living in a widespread matrix of disruption politics and deliberately driven institutional instability, and the chairman seems to have become an avatar of that new reality.

TV Manager: So, carrying through on that logic, the intent here may be much more than restriction?  

The Director: Very much so. I had hoped that I was wrong about this, but as we discussed the other day after the DOGE hearing, this attack is existential. I’m increasingly afraid that, as a couple of you hinted earlier, it’s now looking to be all about the wholesale destruction of the entire public media project.

Communications: Boy, that really redefines what may be at stake here.

The Director: I’m afraid so, but in any case, thanks for all your thoughts on this and all the good recent work around our underwriting messages. As you know, in conjunction with the PBS and NPR responses to the commission, we’ll be crafting our own reply to the questions they’ve put to us. I think we can credibly demonstrate that we’ve been following their own rules and congressional intent, but the worry these days is that appeals to evidence and reason may no longer be sufficient. 

Willard D. (“Wick”) Rowland, Ph.D. is Dean & Professor Emeritus, School of Journalism & Mass Communications, University of Colorado Boulder and President & CEO Emeritus, Colorado Public Television (PBS 12, KBDI), Denver.