PUBLIC COMMENT

January 24, 2013

on the Strategic Enforcement Plan (SEP) of Equal Employment Opportunity Commission Submitted by Media & Technology Task Force, National Council of Women's Organizations Thank you for this opportunity to present a slumbering gigantic work discrimination issue before the Equal Employment Opportunity Commission. The pervasive and all encompassing effects of corporate media fuel every aspect of American societyfrom local human interest stories to politics. The lack of diverse concerns of women in news (28% in US) (1) or zero speaking roles for powerful women political characters vs. 45 for men out of 5,839 speaking characters in 129 family films (2) shape Americans views about women. Especially for girls the hyper-sexualization of ever younger girls through music videos and glossy magazines belittles girls, lowering their self-esteem. Concurrently, it provides boys with egregiously distorted views of their female peers. The deeply disturbing effects of this misconstrued social-sexual dynamic are well documented in the American Psychological Association report identified at the very end of the addendum. While in its broadest range what we outline might be seen as beyond the scope of issues of employment, there are core aspects that fall within EEOC's sphere specifically, we encourage the EEOC to examine the diversity in Hollywood/commercial media jobs, federal agencies that regulate and or support media, and to create an Interagency Working Group on Women & Media. We hope EEOC will examine these issues as a part of its SEP Priorities, especially under points 1 and 3. In the 1970s there were critical sex discrimination cases at media entities like Newsweek, New York Times, and WABC-TV. Sadly the settlement victories won then are forgotten and the positive, legal effects are badly eroded (3). Now, many women believe barriers around gender are largely solved, are other women's problems, and/or can be worked out on an individual basis. Under these perceptions the deeply held male (white) cultural domination of ideas, leadership, viewpoints, and jobs persist. The attached addendum of 47 separate reports (33 from 2012 alone) on various aspects of media bias against women speaks to the range and depth of the problem that insidiously remains in place. Issue 1 - Counter the Pervasive Hollywood Job Discrimination for Women Both Technical and Creative falls under SEP Priorities 1. Eliminating Barriers in Recruitment and Hiring The wide-spread under-representation of qualified women in commercially made films and television, in front of and behind the camera, is well documented by years of study by Martha M. Lauzen, Ph.D, Center for the Study of Women in Television & Film, University of San Diego. Within the guilds and unions that govern major film workers, as well as within the independent film community, there is little willingness to personally speak out and or challenge this persistent, entrenched bias. There are historic reasons (blacklisting) that augment people's fear of reprisal in a world where perceived talent reigns. We call on the EEOC to take leadership here. Starting with the extensive documents created by Lauzen we urge EEOC to call on unions, guilds and studios to account for their failing women employment efforts, and for the EEOC to guide them to make corrective plans to increase women's hiring. Such an effort especially fits the first four points outlined in Criteria for Determining Priorities. Issue 2 - Examine Federal Agencies That Oversee/Fund Media for Their Gender Representation
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falls under SEP Priorities 1. Eliminating Barriers in Recruitment and Hiring and 3. Addressing Emerging and Developing Issues

Studies and documentation of this issue in the attached list of reports are more limited and not on-going. Within the federal government there are agencies that impact women's media issues: A. The Federal Communications Commission by law must address women's ownership issues which remain (if even!!) at a paltry 5% (television) and 6% (radio). But the FCC punts at every turn despite court rulings (4)failing to redress the disparity for women and minorities. At present the FFC again is calling for more media consolidation, which unequivocally counteracts diverse voices. Women's ownership is fundamental to improved gender storytelling as well as hiring of more women as is seen from many of the reports attached. B. The Humanities (NEH) is the single largest funder of independent filmmaking in the US. The continuing and threatened decrease in its funding impacts the number of projects it can support severely limiting access for women-made work to gain funding. We encourage the EEOC to oversee a study to ensure that women-made work and women-centric subjects are well represented in its media funding. This is critical since the statistics also show that women are more involved in independently produced media and thus rely on grants and other funding sources to bring their vital stories to screens. C. The Arts Endowment (NEA) is a vital gateway for support of local, regional and national arts to flourish and reach new audiences. It has historically been the major contributor to women's cultural organizations advancing women artists work. A preliminary report (5) shows decline. We encourage the EEOC to oversee a study to ensure that women artists work, often advanced first within women's cultural and media organizations, are well represented within the NEA's funding. This is essential to women artists achieving full and equitable representation within all aspects of American culture. D. The Corporation for Public Broadcasting (CPB) has been the steward of the federal governments investment in public broadcasting and the largest single source of funding for public radio, television, and related online and mobile services since 1968. The local public television and radio stations it funds collectively reach more than 98 percent of the U.S. population with free programming and services and play a critical role in the furtherance of an informed citizenry. The EEOC should ensure that women are well represented in its funding initiatives and the resulting programming so it can more fully reflect the American population. A deeper investigation by the EEOC into these agencies addressing their support and or representation of women is warranted based on various preliminary studies. We believe this fits under Number 5 of Criteria for Determining Priorities based on the EEOC's access to information, data, and research. Further we would hope if persistent bias is seen against women's employment or funding (which translates into 'employment' income) that corrective measures be put in place. If positive change were forthcoming from the federal government around media issues for women, this would provide incentive for leadership and change in the private sector. Issue 3 An Interagency Working Group on Women & Media: Job Discrimination & Policy falls
under SEP Priorities. 3. Addressing Emerging and Developing Issues and under II A. The Strategic Plan 2) prevent employment discrimination through education and outreach

On a more sweeping assessment, a larger examination of women's media issues needs addressing. The sheer breadth of the 47 separate reports (summaries attached in addendum) speaks to such a need. Employment is the heart of many of these concerns: getting a by-line writing job or funding for your technology start up by venture capitalists all have work related equity ramifications. Clearly, if New York Review of Books hires only 19 women to 133 male writers, there is gender bias. But, women's collective income power at that paper is significantly below the national average of the 77% to the dollar of men that women earn. (6) A deeper examination of this income disparity is necessary to unravel gender (and race) discrimination within the very broad array of media. We urge EEOC establish an InterAgency Working Group on Women & Media: Job
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Discrimination & Policy (which as well includes outside women-media practitioners to provide gender analysis gained in the field) that will undertake a longer, deeper examination of the issues raised by these combined reports. While we believe equity at work within media entities remains a primary stumbling blockespecially in senior, management positionsother factors equally intersect: health concerns corporate media's negative portrayal of women leads to mental health effects on girls and boys; educational concerns are media being used in schools that equally, and positively, represent boys and girls?; safety concerns A. commercial media tends to glorify perpetrators and belittles the victims in Violence Against Women issues, thereby endangering all women (see Learning Resource Kit, Conceptual Issues, page1 of addendum); B. on gun violence, use of guns is glorified in the media, yet peaceful means of negotiation or exchange, for example as relate to women's peace efforts, are all but ignored. These factors, which favor white male privilege (and within a hierarchical, dominate structure), repeated at all levels of media, reflect horribly on the culture, fostering additional violent incidents. Hundreds, if not thousands, of media created independently by women are available today to counter many of the negative effects of corporate media. If purchased and used in health centers; educational institutions; by corporate/educational media outlets, etc. the income and economic viability of all women media makers will rise. We believe the persistent and ingrained media discrimination of women-created and womencentric programs within media warrants such a federal examination. An Interagency Working Group can begin to parse through the thicket of barriers and present solutions. Creation of a gendered media policy as it affects all aspects of the culture, and work environments, can be very effective. The Learning Resource Kit for Gender-Ethical Journalism and Media House Policy, both the one on Conceptual Issues and Practical Resources (in addendum, page 1), provide excellent guides of such endeavors in many other countries. Media work is a women's pocketbook issue at its very core. A comprehensive investigation also commands evolution of media policies that speak to the essence of American democracy, strengthening the diverse voices mandated in the 1934 Communications Act, reaffirmed in the Telecommunications Act of 1996, and assured in international agreements like Universal Declaration of Human Rights. Gender portrayal is not a womens issue. Portraying gender in a fair and ethical manner will only occur when it becomes a concern for everyone in the newsroom and beyond. (7) We hope EEOC will accept such a task. The work would start to correct two overlooked, vexing problems: One, is the income disparity of women across all kinds of media. Two, bringing full equity and voice to women in all realms of media will shift the cultural picture in a fair and ethical manner. Article IX of the UDHR affirms that right to both receive and create information. Women are presently underserved on all counts in the USA. We appreciate the EEOC's consideration of this matter. We remain available to assist the EEOC to achieve a more equitable media that supports all US citizens both as paid creators/workers as well as viewers. Submitted by the Media and Technology Task Force, National Council of Women's Organizations a non-partisan network of over 240 organizations representing more than 12 million women Shireen Mitchell, Co-Chair of Task Force, Founder & Executive Director, Digital Sisters, Inc. and Vice President, National Council of Women's Organizations Ariel Dougherty, Co-Chair of Task Force, and National Director, Media Equity Collaborative Nancy Gruver, Founder and Publisher, New Moon Girls, Inc.
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Melissa Houghton, Executive Director, Women In Film & Video/DC Kathleen Sloan, National Organization for Women (NOW), Board of Directors and UN Representative, Global Feminist Strategies & Issues Committee Frieda Werden, Founder and Executive Producer, Women's International News Gathering Service and Past President, International Association of Women in Radio & Television / IAWRT Contact: Shireen Mitchell, 202.642.1881 digitalsista@gmail.com Ariel Dougherty, 575.740.5868 ArielCamra@gmail.com MTTF, NCWO 714 G Street, SE, Washington, DC 20003
(1) Who Makes The News http://whomakesthenews.org/ (2) Gender Roles & Occupations: A Look at Character Attributes and Job-Related Aspirations in Film and Television by Stacy L. Smith et al, page 4 http://www.seejane.org/research/ (3) Are We There Yet? By Jessica Bennett, Jesse Ellison and Sarah Ball, Newsweek, March 18, 2010

http://www.thedailybeast.com/newsweek/2010/03/18/are-we-there-yet.html
(4) Prometheus Radio Project Vs. Federal Communications Commission of the USA, UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT http://www.fcc.gov/document/prometheus-radio-project-v-

fcc-usa-no-08-3078-3rd-cir
(5) Not A Pretty Picture: The Economics of Feminist Culture, paper presented by Ariel Dougherty, Sarah Lawrence College, March 2, 2012 (6) The Count (2012), by VIDA-Women In Literary Arts http://www.vidaweb.org/the-count (7) The Learning Resource Kit for Gender-Ethical Journalism and Media House Policy, page 6,

http://whomakesthenews.org/

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