July 29, 2005

For upcoming media policy events, see http://www.benton.org/calendar.htm

FCC
Open Meeting Agenda
Short-Handed FCC's Agenda Remains Stalled

OWNERSHIP
Buyouts, Payoffs, and the Public Interest
=91Ethnic Media' Give Mainstream a Shove

RADIO/TELEVISION
FCC Could Make a Federal Case out of Payola
Less Payola, More Ella
Women Find a Voice At Iraq Radio Station
FEC Clears Rather, Sinclair Shows
Farmers Need Multiple Streams
DTV Divides Religious Flock
DTV Rollout Lags In Western Europe

MORE REACTION TO TELECOM REFORM LEGISLATION
Centrist Senate Democrats Urge Telecom Law Reform
Baller on Municipal Network Provisions in Ensign Bill
TIA Applauds Ensign Bill

FILE-SHARING
P2P Advocate Wants Roundtable Talks on File-Sharing Fate

QUICKLY -- Cellphone Marketing to Children Attacked; The Role of Grassroots=
=20
Organizers in Challenging Media Consolidation; David Brock & Media Matters=
=20
for America; Martin at NARUC; SAG Members OK Contract With Video Game=20
Makers; Did President Bush Give Media the Finger?

FCC

OPEN MEETING AGENDA
The Federal Communications Commission will hold an Open Meeting on=20
Thursday, August 4, 2005, which is scheduled to commence at 9:30 a.m. in=20
Room TW-C305, at 445 12th Street, S.W., Washington, D.C. Audio/Video=20
coverage of the meeting will be broadcast live with open captioning over=20
the Internet from the FCC's Audio/Video Events web page at=20
www.fcc.gov/realaudio. There are three items on the agenda. The Commission=
=20
will consider: 1) a Notice of Inquiry that seeks comments and information=
=20
for the Twelfth Annual Report on the status of competition in the market=20
for the delivery of video programming, 2) an Order on Reconsideration=20
concerning the Service Rules for Advanced Wireless Services in the=20
1710-1755 MHz and 2110-2155 MHz bands, and 3) a Notice of Inquiry=20
concerning the effects of anticompetitive conduct and circuit disruption by=
=20
foreign carriers on U.S.-international routes.
[SOURCE: Federal Communications Commission]
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-260318A1.doc

SHORT-HANDED FCC'S AGENDA REMAINS STALLED
The five-member Federal Communications Commission has only four spots=20
filled, leaving an even division between Republicans and Democrats and the=
=20
potential for stalemate along political lines. Chairman Kevin Martin faces=
=20
trying to set his regulatory agenda with only one other GOP ally on the=20
commission. Few believe the FCC will get a fifth member -- and Martin=20
another Republican ally -- before the fall, leaving the possibility that=20
contentious issues like media ownership will remain stalled until then.=20
"More and more the problem is that nominations at the FCC are not a high=20
priority and they're likely to get pushed even lower by nomination politics=
=20
at the Supreme Court," said Rudy Baca, a former FCC official who is an=20
analyst for the Precursor Group, an independent research firm.
[SOURCE: Associated Press, AUTHOR: Jennifer Kerr]
http://news.yahoo.com/news?tmpl=3Dstory&u=3D/ap/20050727/ap_en_bu/deadlo...
d_fcc_3

OWNERSHIP

BUYOUTS, PAYOFFS, AND THE PUBLIC INTEREST
[Commentary] The recent payola scandal becomes a springboard for a new look=
=20
of the dangers of media ownership consolidation. Sony negotiated deals with=
=20
Clear Channel, in addition to several other large station owners, in which=
=20
the record company offered kickbacks in exchange for airplay on the=20
company's national roster of stations. Sony understood that it was dealing=
=20
with companies that dominated local radio in markets across the country,=20
and in striking deals with them, it could blanket the airwaves with no=20
competition from smaller stations -- since so many had already been either=
=20
bought out or quashed by the megaliths. Moreover, in many communities=20
around the country, newspapers and TV station news outfits are teaming=20
up to work on stories and share content at a level that many may not be=20
aware of. But a problem with this kind of "cross pollination" approach is=
=20
that the more media conglomerates can combine their print and broadcast=20
operations in single markets, the easier it may be for them to nudge them=
=20
to speak with one voice, thereby lessening the impact of independent,=20
critical thought. Without the hullabaloo that accompanied Michael Powell's=
=20
attempted corporate giveaways before he left the chairmanship of the FCC --=
=20
a public outcry that led to Powell's plans being thwarted -- his successor=
=20
Kevin Martin may quietly begin rewriting media ownership rules to allow=20
corporate behemoths to own more TV stations and newspapers in single=20
markets -- thus shutting out smaller, independent voices. If he succeeds,=
=20
and this melding of editorial functions continues apace, it looks like some=
=20
markets would be fully subsumed under the watchful eye of a single company,=
=20
which would control the stories the public sees, and they way they see=20
them. If Mr. Martin has his way, America will look more and more like a=20
small town with only one voice. And the freedom to determine the course of=
=20
our political debates will rest only with those wealthy enough to own not=
=20
merely a printing press, but billions of dollars worth of broadcast=20
satellites, fiber-optic cables, and studios -- as well as a few hundred=20
printing presses. In hastening that day, the FCC will be helping to destroy=
=20
a vital lifeline of democracy.
[SOURCE: Center for American Progress, AUTHOR: Eric Alterman]
http://www.americanprogress.org/site/pp.asp?c=3DbiJRJ8OVF&b=3D932795

'ETHNIC MEDIA' GIVE MAINSTREAM A SHOVE
[Commentary] The core of the ethnic media are newspapers, radio and TV=20
stations dedicated to reaching minorities who are underserved by the=20
mainstream media. A recent poll on consumers' attraction to ethnic media=20
should wake up an industry that is still sleeping when it comes to hiring=
=20
minorities. As the ethnic media have discovered, hiring minority=20
journalists is the only way to effectively penetrate these communities =97=
=20
and ultimately command their allegiance. The findings of a poll taken in=20
April and May by the New California Media, a national association of more=
=20
than 700 ethnic media organizations, found that nearly half of U.S.=20
minorities =93prefer=94 ethnic media outlets. The poll, which surveyed 1,89=
5=20
African-American, Hispanic, Asian-American, Arab-American and=20
Native-American adults, revealed that 45% of respondents prefer ethnic=20
media to mainstream media. Subjects such as immigration and discrimination,=
=20
along with entertainment programming and advertising, are designed to=20
reflect ethnic interests. According to the poll, more than half of adults=
=20
of Chinese or Vietnamese heritage read an ethnic newspaper regularly.=20
Spanish-language radio and newspapers audiences are growing along with the=
=20
success of the Univision and Telemundo TV networks. Among blacks, radio is=
=20
the most popular ethnic medium. The clear demand in these communities,=20
wedded with an increasing fragmented and competitive media market, provides=
=20
a moment of opportunity. Recent data show how far the media have to go: 1)=
=20
The American Society of Newspaper Editors said the percentage of minority=
=20
journalists in mainstream newsrooms in 2004 was 13.42%. 2) The Radio and=20
Television News Directors Association reported that the percentage of=20
minorities in TV was 21.8% last year. That's up from 18.1% in 2003. 3) In=
=20
radio, minorities were just 11.8% of journalists in 2004, but that's a big=
=20
jump from the 6.5% in 2003.
[SOURCE: USAToday, AUTHOR:Joyce King]
http://www.usatoday.com/printedition/news/20050729/opcom29.art.htm

RADIO/TELEVISION

FCC COULD MAKE A FEDERAL CASE OUT OF PAYOLA
The FCC may do its own investigation into the payola practices uncovered by=
=20
New York Attorney General Eliot Spitzer, says a spokesman for FCC=20
Commissioner Jonathan Adelstein. Adelstein, who called for such an=20
investigation this week, is "aggressively pursuing the matter" with FCC=20
Chairman Kevin Martin, says Adelstein legal adviser Rudy Brioche. Both=20
legislation and FCC regulations make it illegal for a broadcaster not to=20
disclose considerations received in return for putting material on the air.=
=20
So if a radio station or individual received money or other items of value=
=20
in return for airplay, that could be a violation. An FCC investigation=20
would probably not involve public hearings, though it would allow for=20
public comment. The procedure would be the same as with indecency=20
complaints: If violations were uncovered, the agency would send a Notice of=
=20
Apparent Liability, with the recipient given a period of time for a respons=
e.
[SOURCE: New York Daily News, AUTHOR: David Hinckley]
http://www.nydailynews.com/entertainment/ent_radio/story/332041p-283729c...
ml

LESS PAYOLA, MORE ELLA
Thanks to New York Attorney General Eliot Spitzer, now we know one reason=
=20
why most of the music that gets played on the radio is such unchallenging=
=20
pap: record labels have been bribing radio stations and their employees to=
=20
play certain songs. There are other reasons why the music on broadcast=20
radio is so uninteresting. One is the consolidation of station ownership by=
=20
behemoths such as Clear Channel, Infinity and ABC, which leads to=20
standardization of formats and playlists. You might hear a little more=20
go-go in Washington and Baltimore, or a little more R. Kelly in Chicago,=20
but basically we get the same music from coast to coast. Another reason is=
=20
the decline of music education in the nation's public schools. The next=20
Stevie Wonder may be out there somewhere, brimming with undeveloped talent,=
=20
but he might never get the chance to learn to play the piano. Instead, he=
=20
might settle for laying down a few computer-assisted drum tracks and=20
seeking fame as a rapper, calling himself MC Blind or something like that.
[SOURCE: Washington Post, AUTHOR: Eugene Robinson]
http://www.washingtonpost.com/wp-dyn/content/article/2005/07/28/AR200507...
1789.html
(requires registration)
See also:
* The Price of Fame
Payola enriches just about everyone but musicians.
[SOURCE: New York Times, AUTHOR: Jacob Slichter]
http://www.nytimes.com/2005/07/29/opinion/29slichter.html
(requires registration)
* Broken Record
Payola has been as constant and pervasive a force as gravity for more than=
=20
a century.
[SOURCE: New York Times, AUTHOR: Cliff Doerksen]
http://www.nytimes.com/2005/07/29/opinion/29doerksen.html
(requires registration)

WOMAN FIND A VOICE AT IRAQ RADIO STATION
Radio Almahaba is Iraq's only radio station dedicated to women's issues.=20
With policymakers debating just how many legal protections women should=20
enjoy in the country's new constitution, the United Nations-funded station=
=20
finds itself on the frontlines of a bitter showdown over women's rights.=20
Several employees have been threatened with death for working at the=20
station, although no one has been attacked. Many Shiite clerics have=20
ordered their followers to boycott it. The station has responded by=20
shifting from simply covering the raging debate over Iraqi women's=20
political and legal standing to actively participating in it. At issue is=
=20
whether Iraq's new constitution should include expansive women's rights,=20
including a guaranteed 25% of the seats in Iraq's parliament, enshrined in=
=20
the temporary constitution written last year with heavy American=20
involvement. The Shiite religious parties that dominate Iraq's government=
=20
have long disapproved of those provisions and are now pushing to strip them=
=20
out. Almahaba, named after the Arabic word for love, regularly broadcasts=
=20
portions of U.N. resolutions on gender equality and encourages listeners to=
=20
make sure their interests are represented in the country's draft=20
constitution. After recording several interviews at a recent rally against=
=20
proposed cutbacks in women's rights, meanwhile, an Almahaba reporter put=20
down her microphone and began helping protest leaders pass out fliers and=
=20
petitions. The station's willingness to openly advocate its views of a=20
highly politicized issue sets it apart from many of the country's other=20
media outlets, which try to avoid picking sides for fear of sparking an=20
attack by the insurgents and sectarian militias responsible for Iraq's=20
near-daily violence. But Almahaba executives say that Iraq has too few=20
voices devoted to women's issues for them to sit out the current=20
constitutional debate, which pits secular-minded Kurds and Sunni Arabs who=
=20
want to preserve the rights accorded to women -- who make up an estimated=
=20
60% of Iraq's population -- by the country's temporary constitution,=20
against fundamentalist Shiite Arabs eager to curb women's rights and give=
=20
Islamic law greater prominence. Iraqi policymakers face a critical Aug. 15=
=20
deadline for delivering a draft constitution, but remain far apart on a=20
range of issues.
[SOURCE: Wall Street Journal, AUTHOR: Yochi J. Dreazen yochi.dreazen( at )wsj.co=
m]
http://online.wsj.com/article/0,,SB112260214586199584,00.html?mod=3Dtoda...
us_marketplace
(requires subscription)

FEC CLEARS RATHER, SINCLAIR SHOWS
The Federal Election Commission has dismissed complaints against both CBS=
=20
and Sinclair Broadcast Group for reports that cast President Bush and=20
Democratic challenger John Kerry in harsh lights. The FEC said CBS and=20
former anchorman Dan Rather could not be held liable for a discredited 60=
=20
Minutes report questioning whether the President fulfilled his National=20
Guard obligations. The FEC found Sinclair's airing of excerpts from Stolen=
=20
Honor, a documentary criticizing 2004 presidential candidate John Kerry's=
=20
military service in Vietnam and his subsequent anti-war activities, did not=
=20
violate federal election laws because the broadcast was protected by the=20
government's exemption of news shows from campaign finance restrictions.=20
The FEC also dismissed a complaint filed by an individual in Cedar Rapids,=
=20
Iowa, about anti-Kerry editorials by Sinclair commentator Mark Hyman.=20
Sinclair said it was "pleased" by the rulings.
[SOURCE: Broadcasting&Cable, AUTHOR: Bill McConnell]
http://www.broadcastingcable.com/article/CA630787?display=3DBreaking+New...
eferral=3DSUPP
(free access for Benton's Headlines subscribers)

FARMERS WANT MULTIPLE STREAMS
Larry Mitchell, CEO of the American Corn Growers Association, is part of a=
=20
group calling itself the Coalition for a Smart Digital TV Transition, with=
=20
"smart" implying the mandatory cable carriage of all a broadcaster's=20
multiple digital TV channels and aiding rural viewers in the transition.=20
The group includes unions, minority advocates, and the affiliate groups of=
=20
three of the Big Four (ABC is not a member). Farmers care about the digital=
=20
transition because they depend on the sort of hyper-local weather and=20
market information broadcasters are promising with some of their digital=20
multicast channels.
[SOURCE: Broadcasting&Cable, AUTHOR: John Eggerton]
http://www.broadcastingcable.com/article/CA630644?display=3DBreaking+New...
eferral=3DSUPP
(free access for Benton's Headlines subscribers)

DTV DIVIDED RELIGIOUS FLOCK
Charlotte, N.C.-based Inspiration Networks was in Washington this week=20
lobbying hard against requiring cable to carry all of a broadcaster's=20
multicast digital channels. Although the network is a member of the=20
National Religious Broadcasters (NRB), it does not support that group's=20
endorsement of multi-cast must-carry.
NRB is primarily made up of religious broadcast stations, which are afraid=
=20
cable will not carry them unless the government requires it. Smaller cable=
=20
nets, on the other hand, fear that mandatory carriage of all those=20
broadcast signals could bump them off cable lineups.
[SOURCE: Broadcasting&Cable, AUTHOR: John Eggerton]
http://www.broadcastingcable.com/article/CA630701?display=3DBreaking+New...
eferral=3DSUPP
(free access for Benton's Headlines subscribers)

DTV ROLLOUT LAGS IN WESTERN EUROPE
A report released Thursday says Western European countries are expected to=
=20
miss their deadlines for analog TV shutoff, a key component of the digital=
=20
television transition, by as much as 15 years. The report cited a slow=20
rollout of digital television and resistance from consumers for the delay.
[SOURCE: Broadcasting&Cable, AUTHOR: Joel Meyer]
http://www.broadcastingcable.com/article/CA630724?display=3DBreaking+New...
eferral=3DSUPP
(free access for Benton's Headlines subscribers)

MORE REACTION TO TELECOM REFORM LEGISLATION

CENTRIST SENATE DEMOCRATS URGE TELECOM LAW REFORM
In a Tuesday letter to the chairman and senior Democrat of the Senate=20
Commerce Committee, the group Third Way said that "telecom policy is not=20
and should not be a partisan issue. Congress should adopt thoughtful,=20
bipartisan reforms that can spur the U.S. economy and provide economic=20
opportunity and jobs for all." The letter said that the 1996 act "assumed a=
=20
world that soon ceased to exist. Any future reform must be flexible enough=
=20
to encompass global changes to the systems we use for communications,=20
information and entertainment." The letter was signed by six of the seven=
=20
Democrats who are members of the group: Evan Bayh of Indiana, Tom Carper of=
=20
Delaware, Mary Landrieu of Louisiana, Joseph Lieberman of Connecticut,=20
Blanche Lincoln of Arkansas and Ken Salazar of Colorado. The group, which=
=20
was incorporated in December, calls itself a "strategy center."
[SOURCE: Technology Daily, AUTHOR: Drew Clark]
http://www.njtelecomupdate.com/lenya/telco/live/tb-VHEB1122581915648.html

JIM BALLER ON MUNICIPAL NETWORK PROVISIONS IN ENSIGN BILL
In the floor statement accompanying his bill, Senator Ensign said that the=
=20
bill=92s municipal networks provision is not extreme and is intended to=20
encourage public investment in communities in which =93the private sector=
=20
does not show up and offer to build.=94 Unfortunately, the provision itself=
=20
undermines Senator Ensign=92s goals. The provision rests on numerous false=
=20
assumptions. The procedures set forth in the bill are unnecessary,=20
unworkable and counterproductive. The municipal networks provision of the=
=20
Ensign bill would also create a host of disincentives and unintended=20
consequences. In short, the provision falls far short of the fair and=20
balanced approach that Senators Lautenberg and McCain have proposed in S. 1=
294.
[SOURCE: Baller Herbst Law Group]
http://www.baller.com/pdfs/Baller_Response_Sen_Ensign.pdf

TIA APPLAUDS ENSIGN BILL
TIA applauds Senator Ensign for once again demonstrating his leadership on=
=20
telecom and high-tech policy. He should be commended for striving to update=
=20
the nation=92s telecom laws to better reflect the realities of today=92s hi=
ghly=20
competitive, dynamic and converging industry. As the information and=20
communications technology industry continues to rapidly evolve, TIA=20
especially supports the goal of establishing a firm foundation that is=20
forward-looking in encouraging competition, investment, innovation and the=
=20
deployment of next-generation technologies across all segments of the=20
industry. We look forward to examining the proposed legislation in detail=
=20
and commit to working with Senator Ensign and all of his colleagues in both=
=20
chambers of Congress to ensure any final telecom reform legislation that=20
emerges is built on these principles and establishes a national framework=
=20
of limited regulatory oversight of the competitive and converging broadband=
=20
communications marketplace. Such a result is critically important for the=
=20
industry, consumers and the nation=92s economy.
[SOURCE: Telecommunications Industry Association]
http://www.tiaonline.org/media/press_releases/index.cfm?parelease=3D05-45

FILE-SHARING

P2P ADVOCATE WANTS ROUNDTABLE TALKS ON FILE-SHARING FATE
The Senate Commerce Committee started Thurs. what some expect to be a=20
complex copyright battle over peer-to-peer (P2P) networks. The committee=20
convened a panel of the heads of the music and movie industries, one of the=
=20
file-sharing sector=92s most determined devotees, an ISP executive and the=
=20
CEO of an up-and-coming licensed P2P firm. The hearing was an expected=20
result of the Supreme Court=92s MGM v. Grokster decision last month, which=
=20
determined that file-sharing companies can be liable for users=92 sharing=
=20
copyrighted files. During the hearing, Commerce Chairman Stevens (R-Alaska)=
=20
had strong words for the P2P industry. =93We are going to be watching. We=
=20
want to know what you are going to do to follow up on this [court decision]=
=20
to give greater protection to this copyrighted material,=94 he said: =93I d=
on't=20
hear much myself that indicates that there'll be any attempt at finding=20
ways to set standards and bring into new generations a concept that we=20
don't condone stealing property.=94 Some lawmakers are eager for the Senate=
=20
to =93move now=94 but Sen Stevens said his committee wants to proceed sensi=
bly=20
and figure out what might be done to =93terminate this illegal activity.=94
[SOURCE: Communications Daily, AUTHOR: Andrew Noyes]
(Not available online)
* Congress threatens P2P networks on porn
Congress remains reluctant to rewrite copyright law in the wake of the U.S.=
=20
Supreme Court's landmark decision on file-swapping--but Internet=20
pornography on peer-to-peer networks is likely to be a legislative target=
=20
this fall.
http://news.com.com/Congress+threatens+P2P+networks+on+porn/2100-1028_3-...
9223.html?tag=3Dnefd.top
* Senators Hammer File-Sharing Nets
http://www.broadcastingcable.com/article/CA630786?display=3DBreaking+New...
eferral=3DSUPP
(free access for Benton's Headlines subscribers)
For more on the hearing, see=20
http://commerce.senate.gov/hearings/witnesslist.cfm?id=3D1594

QUICKLY

CELLPHONE MARKETING TO CHILDREN ATTACKED
Some 30 health, education and privacy advocates, led by the Ralph Nader=20
group Commercial Alert, are demanding Congress regulate mobile phones=20
marketed to children. A letter to members of the Senate and House Commerce=
=20
Committees said the telecommunications industry is targeting young children=
=20
as its next growth market, a move called "one of the worst ideas to appear=
=20
in the American economy in a long time." Even though cell phones for=20
children are marketed as a tool for children to contact parents in an=20
emergency, in reality the phones allow advertisers of all kinds to better=
=20
market to children, the letter said.
[SOURCE: AdAge, AUTHOR: Alice Z. Cuneo]
http://adage.com/news.cms?newsId=3D45651

THE ROLE OF GRASSROOTS ORGANIZERS IN CHALLENGING MEDIA CONSOLIDATION
A seven minute video which features YMC, Media Alliance, Code Pink, Media=
=20
Tank, Prometheus Radio Project and many other media activists from all over=
=20
the U.S..
[SOURCE: Youth Media Council]
http://www.youthmediacouncil.org/news.html

REDEMPTION TALE
A look at former conservative David Brock, the man behind media critic=20
Media Matters for America.
[SOURCE: The Boston Phoenix, AUTHOR: Mark Jurkowitz]
http://www.bostonphoenix.com/boston/news_features/dont_quote_me/multi-pa...
documents/04855838.asp

REMARKS BY FCC CHAIRMAN MARTIN TO NARUC SUMMER MEETING
Speech covered earlier this week is now online.
[SOURCE: Federal Communications Commission]
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-260312A1.pdf

SAG MEMBERS OK CONTRACT WITH VIDEO GAME MAKERS
Actors who voice video games voted overwhelmingly Thursday to approve a new=
=20
contract with game makers. More than 81% of the nearly 1,500 Screen Actors=
=20
Guild members who voted approved the pact, which calls for a 36% rise in=20
minimum pay over 3 1/2 years. Affected are about 2,000 performers who voice=
=20
characters in games. The new contract will go into effect today and run=20
through 2008. Pay levels will rise over the life of the contract from $556=
=20
per four-hour session to $759. SAG negotiators also had sought residual=20
payments for top-selling games. But the companies, including Electronic=20
Arts and Activision, refused to budge.
[SOURCE: Los Angeles Times, AUTHOR: James Bates]
http://www.latimes.com/business/printedition/la-fi-sag29jul29,1,2672332....
ry?coll=3Dla-headlines-pe-business
(requires registration)

TRYING TO PUT A FINGER ON A PRESIDENTIAL GESTURE
Did President Bush show what he really thinks of the media with a flip of=
=20
his middle finger? Jay Leno thinks so. On "The Tonight Show" Wednesday, the=
=20
late-night comic showed videotape of the president leaving a meeting with=
=20
congressional Republicans on Capitol Hill earlier in the day and passing by=
=20
a clutch of reporters shouting questions on the fate of the Central=20
American trade pact. On the video, Bush striding away from the camera=20
suddenly thrusts his right hand into the air and extends a finger --=20
precisely which one was unclear. White House officials yesterday said it=20
was his...um, er... thumb. Yes, yes, let's insist it was his thumb.
[SOURCE: Washington Post, AUTHOR: Peter Baker]
http://www.washingtonpost.com/wp-dyn/content/article/2005/07/28/AR200507...
1906.html
(requires registration)
--------------------------------------------------------------
...and we're outta here. Have a great weekend and GO CUBS!
--------------------------------------------------------------
Communications-related Headlines is a free online news summary service=20
provided by the Benton Foundation (www.benton.org). Posted Monday through=
=20
Friday, this service provides updates on important industry developments,=
=20
policy issues, and other related news events. While the summaries are=20
factually accurate, their often informal tone does not always represent the=
=20
tone of the original articles. Headlines are compiled by Kevin Taglang=20
(headlines( at )benton.org) -- we welcome your comments.
--------------------------------------------------------------