04/01/2026
Public Comment on GoBiz Agenda from The Ark
April 1, 2026 California Civic Media Program Advisory Board Governor's Office of Business and Economic Development (GO-Biz)
RE: Public Comment — Draft Eligibility Guidelines and Definitions, April 3, 2026 Meeting Dear Advisory Board Members:
We write on behalf of The Ark, an independently owned, award-winning community newspaper serving Tiburon, Belvedere, and Strawberry in Marin County, to comment on the draft eligibility guidelines and definitions circulated in advance of the April 3 meeting. We submitted public comment to this board on February 18, 2026, endorsing the distribution framework proposed by the California Independent News Alliance (CINA). We write again because the draft guidelines, while promising in several respects, omit the most consequential provisions of that framework and conflict with others in ways that would undermine the program's stated goals. What the draft gets right We commend GO-Biz and the James B. McClatchy Foundation for producing a serious first draft that reflects months of stakeholder engagement. Several provisions align well with what independent local news organizations need. The $100,000 annual revenue minimum is an appropriate floor that protects public funds from shell operations while remaining accessible to genuine community outlets. The requirement to carry media liability insurance and maintain a publicly disclosed ownership structure are baseline standards that any professional news organization should already meet — and that signal to the public the program is funding journalism, not partisan pamphlets. Excluding 501(c)(4)- or PAC-controlled entities is essential to preserving press independence. Prohibiting broadcast licensees whose principal business is audio or visual distribution is consistent with the legislative intent of the program. Requiring an ethics and corrections policy is a reasonable accountability measure that we support. We also note with appreciation the board's consistent emphasis, reflected in the February 20 minutes, on prioritizing underserved communities, equitable distribution, and newsroom sustainability. The final guidelines should reflect those priorities structurally, not merely rhetorically — and several of our concerns below speak directly to that gap. What is missing: The funding formula The most serious deficiency in the draft guidelines is not what they get wrong but what they omit entirely. The document defines who may apply for the California Civic Media Program but says nothing about how funds will actually be allocated among qualifying organizations.
The CINA proposal provided a specific, tiered reimbursement framework that this board discussed at length in P.O. Box 1054, Tiburon, CA 94920 • ph. 415.435.2652 • fx: 415.435.0849 • www.thearknewspaper.com
RE: Public Comment — Draft Eligibility Guidelines and Definitions, April 3, 2026 Meeting Page 2 of 3 February. That framework — or something functionally equivalent — must be incorporated into the guidelines before applications open. Without a published distribution formula, GO-Biz cannot ensure equitable allocation, applicants cannot assess whether participation is worthwhile, and the public cannot evaluate whether the program is achieving its stated mission. Allowing a third-party administrator to determine allocation methodology without board-approved guidelines also creates unnecessary risk to press independence — the very concern that motivated the arm's-length contracting structure in the first place. We urge the board to incorporate the tiered structure proposed by CINA: fully funding the first five journalists at each qualifying outlet before moving to the sixth through tenth, and so on, until funds are exhausted. This sequencing ensures that the program's limited, one-year appropriation reaches the widest possible number of communities rather than concentrating awards in a handful of large metropolitan newsrooms. We also urge the board to adopt a hard per-outlet cap of $250,000. We recognize this question generated real disagreement at the February meeting, and we do not dismiss those concerns lightly. But without a cap, a formula-based model will disproportionately benefit the largest newsrooms in Los Angeles and the Bay Area, leaving dozens of communities with nothing — the outcome that Member Wilson identified as the central risk of an uncapped pro rata approach. What is missing: Print reimbursement The draft guidelines make no mention of reimbursing print production costs. This is a significant omission.
CINA proposed allocating 15% of total program funds — approximately $3 million — as a flat $8,000 annual reimbursement for qualifying newspapers that publish in print at least every two weeks and can provide verified print bills. We endorsed that proposal in our February comment and reiterate that support here. Newsprint costs have risen sharply in recent years, and for many small independent papers, the print bill is the single largest variable expense. But the case for print reimbursement is not merely economic. A printed newspaper is a permanent, unalterable public record — it cannot be edited, deleted, taken behind a paywall, or manipulated after publication. That civic function is irreplaceable, and the program's guidelines should acknowledge it explicitly.
If the board believes the $8,000 figure or the 15% allocation requires further analysis, we request that the question be resolved before guidelines are finalized — not delegated to the administrator without board direction. What is missing: A three-year operational threshold The draft includes no minimum operating history as a condition of eligibility. CINA proposed limiting funding to outlets that have been providing professional journalistic content since at least January 2023 — a three-year threshold that ensures the program supports established news operations with demonstrated track records, not entities created opportunistically to capture public funds. We strongly support this provision and urge the board to adopt it.
The absence of any operational history requirement is an invitation to abuse. Where the draft conflicts with CINA and our recommendations The journalist definition improperly excludes independent contractors and freelancers.
1550 Tiburon Blvd Ste D, Tiburon, CA 94920 • 415-435-2652 • thearknewspaper.com RE: Public Comment — Draft Eligibility Guidelines and Definitions, April 3, 2026 Meeting Page 3 of 3 The draft defines a "Qualified Journalist" as a person employed for an average of at least 30 hours per week. This language appears to exclude independent contractors and full-time equivalent arrangements — and makes no provision for experienced freelancers who contribute substantially to a publication's output. Community newspapers, including The Ark, depend on a mix of staff journalists, part-time employees, and trusted contract contributors. CINA's framework explicitly accounts for this reality by recognizing three distinct tiers: full-time employees and 1099 contractors working 32 or more hours per week; full-time equivalents consisting of two or more workers combining at least 40 hours per week; and independent contractor stringers paid at least $10,000 annually by the qualifying newsroom.
We urge the board to revise the journalist definition to align with CINA's, tying contractor eligibility to verifiable tax filings and minimum compensation thresholds. This provides a clear, auditable standard while reflecting how community journalism is actually practiced. The print publication frequency requirement is too low. The draft defines a Qualified Print Publication as one that has published at least one issue per month, or 12 times per year. CINA proposed a minimum of 24 issues per year — biweekly publication — as the threshold. We agree with CINA's standard. A newspaper that publishes 12 times per year is a monthly; it does not provide the continuous, week-to-week coverage of local government and community affairs that this program is designed to support. Funding monthly publications on the same terms as weekly papers would dilute the program's impact and reward organizations that are not performing the core civic function the statute contemplates. We urge the board to adopt the 24-issue annual minimum. A word on timeline We noted in our February comment that every month of delay is a month in which another California community risks losing its only reporter. The board's stated goal of opening applications this summer and making awards by fall is ambitious, and we support it. But a rushed application process built on incomplete guidelines will generate confusion, litigation risk, and inequitable outcomes. The board should take the time needed to resolve the structural questions raised above — distribution formula, print reimbursement, operational threshold, contractor eligibility — before guidelines are finalized. Getting those decisions right is worth a modest delay. Getting them wrong, or leaving them to be decided without board direction, is not. We remain committed to the success of the California Civic Media Program and grateful for this board's serious engagement with these issues. We are available to provide additional information or to testify at any future meeting. Respectfully submitted, Henriette Corn, owner & publisher Kevin Hessel, owner & executive editor 1550 Tiburon Blvd Ste D, Tiburon, CA 94920 • 415-435-2652 • thearknewspaper.com
The Ark is the nationally award-winning weekly newspaper serving Tiburon, Belvedere and Strawberry, Calif., since 1973.
