At a luncheon speech today to the National Governmental Affairs Conference of the American Advertising Federation, FCC Commissioner Rachelle B. Chong called for broadcasters and advertisers to be "responsible and responsive" to concerns about TV violence and alcohol advertising as a way to quell calls for more government regulation of media content. She also said that calls to quantify public interest obligations "would be government regulation that crosses the [constitutional] line" and is beyond what is "reasonable and necessary."

Chong warned that quantifying public interest obligations could be "a slippery slope" to undue government intrusion into programming discretion. A "numbers-oriented approach ignores the fact that 'serving the public interest' is a subjective concept. People can differ on how the public interest ought to be served, depending on the local community's needs. . . . I think Congress realized this and thus, trusted the broadcasters to use their discretion to serve their particular audience well," she said. Chong then called on advertisers to "unite with the media and government to promote sensible, reasonable and First Amendment friendly solutions to the problems that underlie the calls for more government regulation."

Chong expressed support for the concept of the television V-chip as a viewer empowerment tool. Without expressing a view about the merits of the industry's proposed TV rating system, she argued that an FCC-devised rating system would raise serious constitutional questions. Chong observed that recent press reports indicated that the industry was open-minded to the idea of including more content depictors in the rating. She called on advertisers "to sponsor good quality programming, public service announcements, children's educational programming, documentaries, [and] public television programming."

On the issue of alcohol advertising, Chong said that it is not "necessary or reasonable for the FCC to take the drastic action of completely banning such advertising." Noting that the Federal Trade Commission has primary jurisdiction over misleading advertising, she

questioned whether duplicate regulation was needed. Moreover, because there is no statute directing the FCC to act in this area, Chong said that any FCC-devised ban of liquor ads would face a high hurdle in the courts. She also highlighted a decision of the Supreme Court indicating that any government imposed ban on hard liquor advertising would be subject to special constitutional scrutiny.

As a final matter, Chong told the advertisers that the Commission would soon be issuing an order addressing toll-free numbering. The order will address how the FCC plans to promote the efficient use of toll free numbers and prevent the practice of hoarding and warehousing these numbers.