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This approach would also overcome another problem currently faced by many public interest groups; i.e., the reluctance of established public relations and advertising agencies to undertake assignments from these groups. John O'Toole of Foote Cone & Belding says that ad agencies may turn down such accounts because the amount of billings involved is likely to be quite small. And yet by accepting them an agency may drive out other commercial accounts with substantial billings even when there is no direct conflict of interest.

Lest I give the impression that NCPI is a top-heavy bureaucratic organization, let me state that I envisage the number of campaigns approved each year by NCPI to be no more than ten. Therefore, the amount of work involved in the selection and approval process should be manageable. Moreover, the structure of NCPI as outlined here is not rigid, but is offered as a basis for further discussion and refinement.

Financing NCPI

One method of financing NCPI activities would be to allocate it a portion of the funds collected through user charges from broadcast license holders in the current proposals for the reform of the Federal Communications Act made by Congressman Van Deezlin's Subcommittee on Communications (H.R. 13015, 95th Congress, 2nd Session).

Another form of funding would be through voluntary support from business corporations and trade groups. In addition, it will receive contributions of ad space and commercial air time from the news media. The news media

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contributions will represent a part of what the various media allocate to public service advertising and commercial announcements. The rationale

for the business and the media participation in NCPI, and the broad outline of its organizational structure and modus operandi, are discussed below.

It is suggested that corporations should allocate funds equal to, say, between 25 to 50 percent of the amount spent by them on advocacy advertising to be used for purchasing advertising space for public expression of those viewpoints which, though important, would not receive exposure because of lack of funds. A policy of supporting the public expression of alternative viewpoints is not contrary to the corporation's self-interest. Instead, it should help in the development of a company's planning process, and also contribute to its public credibility. It could go a long way in reducing the legitimacy gap between societal expectations and corporate performance.

A company's advocacy advertising

is aimed at telling the public about its position on major public policy issues in which the company has a vital stake. However, to improve its credibility, the company contributes to the purchase of commercial time and space to give public expression to other experts who offer solutions different from those supported by the company.

Media Participation

I believe that it would be appropriate for the broadcast media to participate in such a program. The media participation could be around 25 percent of the ad space allocated by them to public advertising.

The

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implications for participation by the media in this program can be briefly summarized as follows:

1. It would broaden the scope of viewpoints represented in public service advertising.

2. It would indicate a willingness on the part of the news media, especially the electronic media, to experiment with new formats. The electronic media have been criticized by both business and nonbusiness groups for their unwillingness to explore different alternatives in their public affairs programming and discussion of socially important issues.

3. There is no danger that participation in this program would in any way adversely affect the responsibility of the media in determining their news and editorial agenda. The media would have the sole discretion of accepting or rejecting an advertisement. Since the ads and commercials are received through NCPI, they are one step removed from the corporate sponsor. So there is no direct response to a controversial ad. Furthermore, the news media in general, and the electronic media in particular, need accept only those ad messages that would add to the medium's own coverage of an issue.

In terms of the electronic media, this should apply not only to allocation of free time, but also the sale of air time for discussion of those issues that are being covered in their regular public affairs programming. The objective is to complement and not replace a radio

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or a television station's, or a network's, efforts in the discussion of

a public issue. A station or the network does not have to air a commercial on a given issue if it feels that the station's own coverage has been adequate. The problems of the fairness doctrine are minimized because the emphasis in the selection of ad messages will not be so much on opposing a specific course of action but on the discussion of alternative approaches to complex social issues. The NCPI selection process for ad campaigns is designed to achieve this end.

1. Testimony of Victor L. Lowe, Director General Government Division, Before the Subcommittee on Commerce, Consumer and Monetary Affairs, House Government Operations Committee on Tax Deductions for Grassroots Lobbying, May 23, 1970, p. 10. (Hereinafter cited as Victor L. Lowe)

Report of the Comptroller General of the United States, Auditing of Political Advertising by Electric Utilities and Gas and Oil Companies, July 16, 1976. (hereinafter cited as Comptroller General)

Common Cause, The Power Persuaders: A Common Cause Study of what the Federal Lobby Law Does Not Reveal About Special Interest Lobbying in the Carter Energy Package, February 1978, pp. ii-iii and 19-28.

2. Ibid.

3. Peg Dardene, "The Cost of Corporate Advertising in 1976", Public Relations Journal, November 1977, pp. 22-24.

6. Sylvan M. Barnet, "A Global Look at Advocacy Advertising", Public Relations Journal, November 1975, pp. 20-21.

The

7. U. S. Senate, Energy and Environmental Objectives, Hearings Before Subcommittee on Environment of the Committee on Commerce, Part 2 (Washington, D. C., 93rd Congress, 2nd Session, May 6 and July 18, 1974), pp. 41, 73. companies providing the data were Atlantic Richfield, Exxon, Gulf (estimates made by Media Access Project), Mobil, Phillips, Shell, Texaco, and American Petroleum Institute (industry trade association). (Hereinafter cited as Hearings)

8. Supra, note 1; see also: Testimony of Lester G. Font III Before the Subcommittee on Commerce, Consumer and Monetary Affairs of the Committee on Government Operations of the United States House of Representatives, May 22, 1978, and Testimony of Harvey J. Shulman, Executive Director, Media Access Project, Washington, D. C., Before the House Subcommittee on Commerce, Consumer and Monetary Affairs, May 22, 1978.