I have a little experience in FCC broadcast licensing and so it occurred to me that there is one way to get the attention of ABC affiliates who will be airing the documentary about 9/11 - Petitions to Deny license renewal. This isn't some sort of revelation, I know, and it may have been diaried already, but in case not....
If you're unaware, radio and broadcast TV (primarily all ABC, NBC, CBS and Fox affiliates and generally anything that shows local news) broadcast their content under a license from the FCC. These licenses need to be periodically renewed so as to give the FCC and the public the opportunity to review the behavior of the broadcaster to make sure it's meeting its obligations. The public has the right to file Petitions to Deny renewal. And trust me, Petitions to Deny are taken very seriously by station owners.
Added benefit: license periods are 8 years. That would suck if we were in the off period because we couldn't do anything. But it turns out that we're in the middle of the license renewal process (which lasts several years).
First, this is not the same as the type of thing the Christian Right mobilizes to do when they're upset about nipple slips and wardrobe malfunctions. Those are generally protests to get the FCC to either fine or pressure stations in other ways to change their behavior.
Petitions to Deny renewal of broadcast licenses are complaints to the FCC that a broadcaster is violating the terms of their license and therefore should not be allowed to continue broadcasting. 100% of the value of a broadcast company - radio or TV - is in the license. No license means no broadcast means no ads means no revenue means no company. What are licenses worth? Depends on the market, but tens if not hundreds of millions of dollars.
To be honest, I'm unaware of any actual denials of license renewals (though that doesn't mean it hasn't happened). Denial is the LAST option and the FCC generally tries to give the broadcaster the opportunity to improve their behavior. Nonetheless the risk is so high that broadcasters really do take it seriously. Even if it's a long-shot, it still presents problems.
So what can you do or threaten to do? Well, you can include in your comments to ABC affiliates along with threats not to watch or to boycott advertisers, that you will file a Petition to Deny if and when they air the movie. That will get their attention a lot quicker than just generally complaining
Anyone can file a Petition to Deny. So check out this link which has the dates for license renewals and you can see when licenses in your state are slated for renewal. Petitions to Deny must be filed ONE MONTH before the expiration. For instance, in California, TV broadcast licenses expire December 1. So you could file a Petition to Deny with the FCC for you local ABC affiliate right now. The renewal applications themselves for California stations have already been submitted and are being reviewed as we read.
Unfortunately, there are only a handful of states that have upcoming license renewals, but over the next twelve months there are some big ones including CA, NY, NJ and PA. We just missed a bunch that would have been due last week.*
There are some restrictions - to file a Petition to Deny you pretty much have to live in that market. If you don't, you CAN file an informal objection. That has a lot less weight and basically only matters cumulatively over time. Still worth doing, however, if you don't mind the stamps it will take. Here are the qualifications/requirements for both:
Petition to Deny Requirements First, to file a petition to deny, a person must be a "party in interest" and have "standing." That means, generally, that the person must have more than a passing interest in the station. He or she must be a regular listener or viewer or have some other contact with the station that gives the petitioner a real stake in outcome of the renewal process. Also, a petition must be supported by an affidavit of a person or persons with personal knowledge of the allegations of fact contained in the petition. Additionally, a petition to deny license renewal must be "timely." That is, as noted above, a petition to deny must be filed at least one month prior to the license expiration date. Finally, as noted above, failure to include a certification that a copy of the petition was also mailed to the station and the affidavit may result in dismissal of the petition to deny.
Procedure for Filing Informal Objections. A person or entity opposing the grant of a radio station's license renewal application may file an informal objection against the license renewal application at any time prior to staff action on the license renewal application. An informal objection is less formal than a petition to deny, but some requirements still apply. It may take the form of a letter signed by the objector and mailed or delivered to one of the FCC addresses above. An informal objection need not contain the affidavit required for a petition to deny. It should, however, contain sufficient information to establish any violation alleged. Additionally, an informal objection not received by the time the station's license renewal application has been granted by the Commission will not be considered.
To help the staff expeditiously associate a petition to deny, informal objection or positive comment with the proper license renewal application, a petition to deny, informal objection or positive comment should identify (1) the station's call sign, city and state, (2) the station's facility ID number, and (3) the license renewal application file number. This information, which is available on CDBS through the Commission's website, should be listed on the first page of the submission.
Link has addresses, etc. for filings.
Unfortunately, Petitions to Deny aren't just forms that you fill out - you have to write up the affidavit, as in those clearly recognizable legal pleadings that have the funny center-justified close parentheses on the first page - and send it in certified to the FCC and the station. Here are some examples. Here's one that has to do with biased news which seems fairly similar to this situation.
If you live or work in a city that has an affiliate, you can go in and ask to see their public file. They HAVE to show it to you right then and there and it will have all the complaints over the last three years they've received. If they have any that are relevant to this type of thing - I bet a lot of Sinclair stations have complaints from their Kerry documentary aired during the presidential campaign - they could be added to the Petition as added evidence.
* Also, it is possible to get an extension to file a Petition to Deny if there are compelling unusual circumstances that prevented timely filing. I think that a Petition to Deny filed regarding this "docudrama" it could be argued that it was not until this week - after the deadline last Friday for AZ, ID, NV, NM, UT and WY - that the details about the program came to light.