Coalition for the Prevention of Alcohol Problems
1875 Connecticutt Ave. NW, Suite 300
Washington, DC 20005

 

October 24, 1996

The Honorable Reed Hundt
Chairman
Federal Communications Commission
1919 M Street, N.W.
Washington, D.C. 20554

Re: Broadcast Liquor Advertising

Dear Chairman Hundt:

We are writing you on behalf of the Coalition for the Prevention of Alcohol Problems to share with you our concerns about Seagram's abandonment of the liquor industry's voluntary ban on broadcast liquor ads. In addition, we would like to offer assistance to the Commission in exploring whether such advertising comports with broadcasters' public interest responsibilities, particularly with regard to protecting children from additional broadcast inducements to drink.

We are especially concerned about this issue for the following reasons:

  • Liquor advertising will reach millions of underage persons who are not now exposed to those messages. Data from Nielsen Media Research ("1992-1993 Report on Television") indicate that, on a national basis, as many as 18 million 2- to 17-year-olds watch television during the 9:00 to 9:30 P.M. prime time segment, when broadcasters have indicated the ads would begin running. Those young people comprise more than 30% of the entire population for that age group and total more than 17% of the viewing audience during that time slot.
  • Liquor advertising will influence the perceptions of millions of children regarding the uses of alcohol. Repetitive advertising images seep subtly into youth understandings of the roles of alcohol in our culture and in their lives. Advertising for alcohol affects the manner, style, and meanings of drinking in society. It helps establish expectations about the role of alcohol in one's life, defines drinking as a positive and normative behavior, provides legitimacy for individual consumption as well as for the advertised products, and, invariably, presents an exaggerated view of the degree to which alcoholic beverages are used in society.
  • Powerful television advertising images that promote liquor will add to children's knowledge of the existence and availability of products they are too young legally to purchase, possess, or consume; by breeding familiarity, they can only add to the many other pressures to drink that young people face. Several studies have begun to explore those effects of alcohol advertising, and we will soon provide the Commission with both a compilation of the available research and a list of experts who can provide appropriate guidance in this area.
  • The expansion of liquor advertising into broadcast will inevitably unleash new competitive forces that may result in a massive increase in alcohol advertising as other liquor companies follow Seagram's lead and as brewers and vintners boost their advertising in response. A flood of new alcohol advertising could dramatically affect children's perceptions of the relative role and importance of alcohol in society.
  • The increased dependence of broadcasters on revenue from alcoholic-beverage producers may also have more subtle and undesirable effects. Those include: influencing station programming decisions; compromising news and public service coverage of alcohol health and safety issues; jeopardizing licensees' implementation of their statutory public interest responsibilities; and hardening broadcaster opposition to policy efforts to balance pro-drinking advertising messages with public health information about the risks of alcohol consumption. Numerous studies have documented how the heavy reliance by some magazines on tobacco advertising revenues has distorted -- and in some cases, extinguished -- their coverage of health issues related to smoking.
  • The expansion of liquor advertising to television will also likely add substantially to the number of new, specialty products that are introduced to the marketplace. In the past, such products as wine coolers, low-alcohol "refreshers," and Coors' Zima have had considerable appeal among new drinkers, including young women and underage consumers for whom alcohol consumption poses special risks. The heightened level of efforts to attract new users with products that disguise the taste of alcohol and package adult beverages in youth-oriented soft-drink images can only have disastrous consequences for campaigns to deter underage drinking and reduce the toll of alcohol on young people.
  • As liquor advertising becomes more commonplace on radio and television distillers will transform current print campaigns targeting "entry-level" consumers into broadcast appeals that will have tremendous impact on underage persons as well. Many ads for alcoholic beverages (e.g. Absolut vodka, Budweiser frogs) already blatantly attract the attention of teenagers and children. Similar broadcast commercials for liquor can only compound the serious drinking problems that now occur among underage persons.

Two government agencies -- the Federal Trade Commission (FTC) and the Bureau of Alcohol, Tobacco, and Firearms (BATF) -- share statutory authority over alcohol advertising. However, we believe that the Federal Communications Commission, which oversees broadcast licensee compliance with public interest responsibilities that flow from the use of publicly owned airwaves, has adequate authority and a unique opportunity to protect children from liquor advertising that may increase their risk of alcohol problems. Based on the concerns identified above, we think the Commission has an obligation to explore the following approaches:

1. Initiate a forum for public comment on broadcast advertising of distilled beverages. That inquiry could include widely publicized public hearings. Ideally, several stages of inquiry would examine the state of research into the effects of alcohol advertising on youth attitudes and expectations about alcohol, as well as the beliefs of parents and the general public about the effects of broadcast alcohol commercials. Such a process could also involve young people.

2. Request information from broadcasters about the age distribution of viewers during specific programming throughout their broadcast schedules. This information can be used to assess whether there are periods during the day when youth viewership is so limited that alcohol advertising might not be inappropriate during that time-slot. In developing a standard for determining when youth viewership is sufficiently limited, the Commission could refer to new regulations at the Food and Drug Administration developed to protect children from promotions for tobacco products.

3. Develop detailed information on the distribution of liquor advertising throughout various day parts (and programming) to determine the degree to which young people are reached by the ads. Establish estimates for the total amount of liquor advertising anticipated if other distillers follow the Seagram Company's lead, and develop estimates for the increase in exposure to alcoholic-beverage advertising among young people. Solicit expert analyses of the effects on young people of this extra amount of alcohol promotion.

4. Request information from broadcasters (and alcohol producers) on the potential effects on young people of anticipated increases in advertising for new products on television. In much the same way we require developers to submit environmental impact statements before commencing a building project, we should require alcohol producers and broadcasters to assure the public that massive new advertising campaigns for products that appeal to new drinkers will not add to alcohol problems, particularly among young people. Those analyses would help assure that such advertising would not compromise broadcasters' public interest responsibilities.

5. Relying on testimony and written submissions from academic and other experts (as well as children themselves), determine whether certain kinds of appeals or characters in alcohol advertising have a strong impact on young people. A small study on the appeal of the Budweiser frogs and a more sophisticated analysis of RJR's Joe Camel character provide models for further inquiry.

6. Poll broadcasters regarding the level of advertising revenues (as a percentage of total revenues) each receives from alcoholic-beverage producers. Citizens could then use this information to question whether the broadcaster's public interest responsibilities may have been compromised by broadcaster dependence on those revenues. This would assist the public in commenting on broadcasters' license renewal applications, as well as help the Commission determine whether the applicant broadcaster has met the public interest standard.

In addressing liquor advertising on television and radio, the Coalition believes that it is essential that the Commission not become fixated on the current, inconclusive state of research into the quantitative effects of alcohol advertising on consumption and harm. In fact, there is research that supports adverse effects of alcohol advertising and no effects, as well as research that demonstrates the relationship of the ads with beliefs and expectations among young people about drinking. Further inquiry seeking behavioral outcomes alone can better inform us, but will never adequately resolve the question.

As Janet D. Steiger, then Chairman of the Federal Trade Commission, testified before Congress, "the research methodology by itself may simply be incapable of accurately measuring [the relationship between advertising and consumption and harm]." For that reason, we urge the Commission to take a far broader approach in its examination of the potential consequences for children of an expansion of broadcast alcohol advertising. We believe the Commission must look beyond the elusive quantitative measures of behavioral response to alcohol ads, and also examine the degree to which those ads reach young people, appeal to them, and influence how they think and feel about alcohol.

We deeply appreciate your concern for young people and your interest in protecting them from a new onslaught of powerful broadcast ads for alcohol. We look forward to meeting with you soon and to working with you and the Commission to insure that broadcasters meet their responsibilities to children and teenagers.

Sincerely,

George A. Hacker, Director
Alcohol Policies Project
Center for Science in the Public Interest

Sarah K. Kayson
Director for Public Policy
National Council on Alcoholism
and Drug Dependence

The signers co-chair the Coalition for the Prevention of Alcohol Problems.

[Letter to Associaton of National Advertisers]