While the First Amendment guarantees an individual the right to be heard, this is an issue distinct from assuring the opportunity to be heard. In broadcast media, the opportunity, or access, has been largely determined by two factors: economics, or who owns the means to an audience, and the Federal Communications Commission (FCC) regulation of the limited frequency spectrum. Historically, the Supreme Court has extended the FCC power beyond license distribution to matters involving programing. Eventually, the "fairness doctrine" evolved to ensure the consumer's right to hear, through a federal evaluation of the broadcaster's fulfillment of editorial responsibilities. However, a reasonable interpretation of the First Amendment states that the government is to have no direct control over the process by which people are informed. The means of transmission may be subject to external constraints, while the message is free from any form of intervention. If broadcasters are to be held accountable for their programing, then they must be free to accept responsibility for their expressions. (MAI)