than in all cases where status quo is changed, it is the responsibility of the commission to articulate and prove that the changes are in the public interest, through rational analysis and explanation. The benefit of the doubt is given to the status quo, unless an agency can prove that changes result in positive effects for the public interest. Proving diversity was shown to be difficult because it is inherently different from welfare or efficiency. As Johannes Bauer and Steven Wildman noted in the Federal Communications Law Journal, "By no stretch of the imagination could it be said that new ownership policies were produced through application of a welfare calculus employed to identify new policy optima. The calculus simply did not exist. While the definition of economic surplus that would presumably be central to the efficiency component of such a calculus was conceptually clear and in principle measurable, the same could not be said for diversity." The problem is that diversity is not a clear concept, and therefore difficult to prove. Opinions The Media Access Project, one of the additional petitioners in the case, summed up the victory as the court "effectively deciding that preserving democracy is more important than helping big media companies grow bigger." They viewed it as a directly impacting people's First Amendment rights to freely express themselves and the views of their communities through local and national media outlets." According to Aaron Perzanowski of the Berkeley Law Review, the case points to the need for Congress to step up its role in disputes of regulation. Rather than delegate the decisions to agencies and commissions, Congress needs to reassert itself as the final arbiter of media policy. Perzanowski bases this on a belief that "Media concentration, because it results in an ever-decreasing number of sources of publicly available information, poses a serious threat to the development of an informed public." Stephanie DeClerk of the Arkansas Law Review believed that the outcome of the case would force the FCC to take a look at heading in a different direction, saying: "Hopefully, the FCC will begin to recognize the drawbacks of media ownership deregulation and will begin to "create new media rules for the [twenty-first] century that foster diversity and protect local media". Writing in Communication Law and Policy, David Pritchard, Christopher Terry and Paul R Brewer did not agree with the ruling, or the premises behind the Citizen