The Federal Communication Commission’s Third Biennial Review of media ownership rules stands out ten years later for two reasons: the policy process received an enormous number of publically filed comments, and secondly, the FCC has not resolved any of the issues raised within the policy. The acknowledged ignoring of many individually filed comments along with the partisan vote on the policy created an appearance of a policy process failure.

This research illustrates the value of Network Text Analysis (NTA) and Social Network Analysis (SNA) to policy analysis and perhaps policymaking. The strength of this methodology is its ability to produce both quantitative and qualitative results. The FCC wanted empirical data on which to build the policy; because NTA and SNA are based on mathematical graph theory, the methodology fits within a positivist framework. Additionally, the qualitative data provides insight into the nature of the numbers. When taken together, the results have the potential to bring wholeness to the policy process.

The data reveals a number of significant and consistent findings: 1) that among the policy goals of competition, localism and diversity, competition is the most important; 2) legal is the most powerful concept in the policy itself; and 3) the role of argument (reasoned analysis) is important for public comments. Additionally, the qualitative data provides further insight/knowledge into the numbers: 1) While competition is important, there is disagreement as to the nature of competition for broadcasters; 2) concern over judicial review is a boundary throughout the process; and 3) even if an argument is faulty, people have reasons for opposing this policy decision.