EUROPEAN BROAD CASTING LAW AND POLICY Part 2 pdf

2 The value and functions of the broadcast media: protecting the citizen viewer Introduction In chapter 1,weintroduced a basic distinction between the consumer and the citizen, a distinction, we argued, which affects the nature of the view- ing experience and the details of the relationship between broadcaster and viewer. We further contended that this distinction has implications for the range and type of content offered,aswellasaccesstothatcontent, and underpins the nature of regulatory concerns that the Union needs to address. Although broadcasting can be seen as a commercial activ- ity and content regarded as a commodity, there are arguments about its functions and values beyond its many and varied commercial aspects that need to be considered. These arguments are to be found in discussions of the relationship broadcasting has to citizenship, or, in other words, the way broadcasting meets the needs of viewers as citizens. 1 In this chap- ter weexplore the underlying theories about the value and functions of broadcasting which have underpinned regulatory rhetoric, particularly that which claims to be serving the public interest. We begin this chapter with a discussion of these theories, after which we go on to explore our distinction between citizens and consumers in more depth. We then consider the impact that this distinction has, expressly or implicitly, on the concept of public interest. This is followed by a dis- cussion of the issue of access to broadcast content in relationship to the needs of citizens. We conclude with a discussion of how the interests of the citizen viewer can be protected and how technological change, and developments in the broadcasting sector, particularly commercialisation, affect the viability of broadcasting’s social, political and cultural func- tions. There are three aspects to our discussion. The first concerns the 1 D. McQuail, Media Performance: Mass Communication and the Public Interest (London: Sage, 1992); W. Lippmann, Public Opinion (New York: Harcourt, 1922); P. Dahlgren, Tele- vision and the Public Sphere (London: Sage, 1995), all passim. 18 theories about value and functions of broadcast media 19 public sphere and its relationship not only to the media in general but also to public service broadcasting (PSB) and how this latter relation- ship may encourage active citizenship. The second aspect concerns the diversity and quality of services available to viewers and their univer- sality. Both sets of concerns are associated with the third aspect of our discussion, traditional public service broadcasting, especially the way in which it is regarded as catering for the needs of passive and active citizen viewers. Theories about the value and function of the broadcast media Evaluation of the importance and value of the broadcast media in society is, in part, centred upon contested views about the active and passive nature of viewers and the function of the media. We shall deal with these in turn. As we have argued, different types of viewing experience can be identified (seechapter1,table1);however, early theories of the massmedia tended to be based on an overall pessimistic perception of the gullibility of viewers. The approach has often been referred to as the magic-bullet theory or hypodermic model of the media. It assumes that the mass media are highly persuasive and have a direct effect on viewers. Research which has extensively tested if a causal link between media content and the behaviour of the viewer exists has generally produced results which are equivocal about the correlation between content and effect. This lack of ‘proof’ is due to the numerous other variables that must be taken into account when considering the effects of media content on viewing. Where research has demonstrated a link between viewing and behaviour, the methods used have been widely criticised. 2 Despite uncertainty about any harm that the broadcast media may cause, claims about the power of television in particular still attract media, public and policymakers’ interest. Sometimes (and along with other theo- ries; see below) such interest underpins broadcasting regulation aimed at protecting the public, especially children, from particular types of broad- cast content (e.g. Article 22 of the Television Without Frontiers Directive (TWFD); 3 see chapter 10). Still, direct policy interventions in response 2 See, e.g., D. Gauntlett, Moving Experiences: Understanding Television’s Influence and Effects (London: John Libbey, 1995), p. 1. 3 Council Directive 89/552/EEC of 3 October on the co-ordination of certain provisions laid down by law, regulation or administrative action in member states concerning the pursuit of television broadcasting activities, OJ [1989] L298/23, as amended by Directive 97/36/EC OJ [1997] L 202/30. 20 jackie harrison and lorna woods to specifically perceived media effects are relatively rare, 4 and such action is often dismissed in academic circles as being an over-reaction, or as an attempt to turn the media into a scapegoat rather than examine wider cir- cumstances. 5 Recently the power of the media to shape or mould messages in a way which is then integrated into the audience’s viewing choices has become a central theme in the study of political communications, partic- ularly where the media are seen to be responsible for engendering a lack of civic engagement and disenchantment with politics. 6 This so-called ‘agenda setting’ role of the media, that is not telling viewers how to think but what to think about, is still today regarded as significant. 7 Some academic researchers have, however, exercised scepticism about theories based on what the media do to people, and have refocussed their research on the question of what do people do with the media? 8 Interest in this area is evident in current attempts to stimulate media literacy and to teach people how to operate new media technologies, choose what to watch and to filter out different types of content. 9 Critics of this ‘opti- mistic’ approach(optimistic because all you have to do is teach people how to)argue that this approach ignores the real constraints which viewers faceintheireveryday lives(forexample, levelsofeducational achievement, socio-economic status, and a strong and powerful media industry dom- inating the encoding process and so on) which may limit the audience’s 4 In Britain the murder of 2-year-old Jamie Bulger by two 10-year-old boys in 1993 was ini- tially believed to be a copycat killing resulting from one of the murderers having watched avideocalled Child’s Play Three, although this assumption was later dismissed. The pol- icy response was to produce a series of amendments to the Video Recordings Act in the belief that video films needed stricter ratings than cinema films as children were likely to have easier access to the former. See also the American attitude to screen violence at www.apa.org/pubinfo/violence.html and http://europa.eu.int/comm/avpolicy/regul/ new srv/workshop children.pdf 5 B. Gunter, ‘Media Violence: Social Problem or Political Scapegoat?’, Inaugural Lecture (Department of Journalism Studies: University of Sheffield, 1995), passim. 6 See the critique of the so-called ‘media malaise’ approach in P. Norris, AVirtuousCircle (Cambridge: Cambridge University Press, 2000), p. 4. 7 Foranoverview of the agenda-setting debate see, e.g., M. E. McCombs and D. L. Shaw, ‘The Agenda-setting Function of Mass Media’, Public Opinion Quarterly,36(1972), 176– 87, passim;M.E.McCombs and D. L. Shaw, ‘The Evolution of Agenda-Setting Research: Twenty-five Years in the Marketplace of Ideas’, Journal of Communication,43(2) (1993), 58–67, passim. 8 J. Halloran, The Effects of Television (London: Panther, 1969), pp. 18–19. 9 See Commission, The Work Programme 2003–2004 which calls for proposals to implement media literacy where the changing media landscape, due to new technologies and media innovation, makes it necessary to teach children (and parents) to use the media effectively. V. Reding, SPEECH/03/400. Also see the British Communications Act 2003, Section 11, ‘Duty to Promote Media Literacy’. theories about value and functions of broadcast media 21 ability to manipulate and critically choose content, to interpret media messages and to filter out unwanted programming. 10 To day research into viewer engagement with the media reflects an ongoing debate between those who believe in the ‘power of the media to shape people’s knowl- edge, beliefs and attitudes’ 11 and active audience theorists, who argue that viewers are capable of understanding and resisting media images. Political and public debate is increasingly influenced by both concerns: that is the power of the media both to influence viewers and also to engage them. Broadcasting policy aims to protect the viewer from content which may be harmful. At the same time policymakers assume that audiences can be active, in that some audiences are already media savvy and those that are not can easily become so. This latter assumption underpins the current advocacy and promotion of media literacy. This debate, however, is noth- ing new and with some variation is to be found in a media functionalist approach. Media functionalism argues that the media have a direct influence on social change, both for positive and negative reasons. That is, it sees the media as both performing an integrative function but having the capacity to cause harm. The integrative function expressed, in their terms, is the media’s promotion of social cohesion and solidarity. The risk of harm, again in their terms, is the dysfunctional aspect of the media, which is their capacity for dissidence and potential to contribute to the breakdown of agreed values, agreed social norms and accepted social patterns of behaviour. This approach, combined with a belief in media effects, is influential for policymakers and regulators, and pro- vides them with two distinct spheres of concern, positive and negative. To day the negative sphere rather than the positive sphere has priority, but it is useful to look closely at them both because each has continuing relevance. The negative or dysfunctional aspectofthe media which attracts con- cern is that attributed to its possible narcotising effect, where the stream of information which emerges from the media is superficial and irrelevant and dulls viewers’ cognitive skills, psychological insights and emotional reactions. Television is heavily criticised in academic circles in this respect, particularly when commercialisation and the dumbing down of content are linked together. This association has generated concerns for the need 10 See, e.g., S. Hall, ‘Coding and Encoding in the Television Discourse’, in S. Hall, D. Hobson, A. Lowe and P. Willis (eds.), Culture, Media, Language (London: Hutchinson, 1980), pp. 197–208, passim. 11 K. Williams, Understanding Media Theory (London: Arnold, 2002), p. 209. 22 jackie harrison and lorna woods for television to provide for a variety of programmes to ensure that the television diet does not only comprise entertainment programming or endless sport. Whether a viewer is passive or active, the risks are atten- dant to both. For the active viewer, their programme diet could in theory be purely based around a very narrow range of content pumped out across awide range of channels. In parallel, passive citizens who relied on a varied diet of programmes provided by a few channels or a single public service broadcaster find that, in the face of the commodification of content and the decline in traditional PSB offerings, an ever diminishing range of programming is available. Twoarguments have been advanced on the positive aspect of the media. First, although it does not sound very positive, it was argued that the media perform a surveillance function. That is, where they are seen to be provid- ing a continuous stream of information about the world, which can help viewers to assess risk and danger and to participate in society. 12 Problem- atically, for the advocates of this argument, it must also be recognised that the media can also provide information which is poorly contextualised, or badly explained, resulting in unnecessary levels of viewer anxiety or media scares. 13 The second positive argument seems to have carried more weight with policymakers. Media functionalists argued that the media can, and do, enforce or transmit desirable social norms and values (usually associ- ated with liberal democracies), such as respect, freedom, equality and order. Here, it is argued that the media promote such ideas and values by bringing to society’s attention the consequences of so-called deviant or illegal behaviour. Moral, political and social boundaries can therefore be established by the media and can, in turn, be subsequently reinforced through regulatory requirements: for example, the requirement to show certain types of programming that reflect national life and culture. Some- times the media over-emphasisethenature of so-called deviant behaviour, where a condition, episode, person or group of persons are defined as threatening and are presented in a stereotypical fashion, 14 again with 12 See P. Shoemaker and A.Cohen, News Around the World (New York: Routledge, 2006), for a discussion of the links that have been made between social behaviours such as surveillance and the mass media, pp. 12–13, 16–18 and 303–5. 13 Forageneral discussion of these themes, see McQuail, McQuail’s Mass Communication Theory (London: Sage, 2005), p. 97. 14 The most oft-cited case of this occurred in Britain in 1964, when the media reported that the gathering of Mods and Rockers on the beaches in the south-east of England signalled a breakdown in social order. See S. Cohen, Folk Devils and Moral Panics (Oxford: Blackwell, 1973), who described the coverage of this new youth culture as a ‘moral panic’, passim. theories about value and functions of broadcast media 23 the effect of reinforcing boundaries. Other scholars have focussed on the media’s ability to influence society through their broadcasting of par- ticular social norms and values, which themselves may have the power to mobilise people to participate in social change. In this vein, other analysts have argued that the media also have the ability to transmit cultural values, passing on crucial information about society’s history, cultural heritage and identity. Here the media act as agents of socialisa- tion. 15 These arguments have provided some insight, albeit ata descriptive level, into how broadcasting might work at a macro level and in so doing they provided some justification for PSB by emphasising broadcasting’s non-commercial importance, potential political and social power and relevance. Opposing all of the above approaches are the Marxist-influenced crit- ical theorists of the media. Here ideology and conflict are the keys to understanding the media. To understand how the media work you have to question their power base and structure; their influence both directly through their programmes and indirectly through their ideological nar- rowness. Ultimately their criticism focusses on two aspects: first, the way the media justified certain forms of politics and economic activities; and secondly, the way the media trivialised the world by lacking, or diminish- ing the role of, any critical, cultural or moral quality in their broadcast content. Critical theorists remain concerned about the reduction of diver- sity and plurality of media content and services as a consequence of the structure of ownership and control and the operation of global media enterprises. Some of the more interesting critical theorists have noted the tensions inherent in competing public-interest claims made by a range of actors involved in broadcasting. Originally, critical approaches tended to explain the relationship between capitalist ownership and media content in relation to the con- centration of economic power, arguing that ‘that power, the men – owners and controllers – in whose hands it lies enjoy a massive preponderance in society’. 16 More recently, researchers have concentrated on the ‘imper- sonal economic determinants of the marketplace’, 17 which can have an 15 Socialisation is the process whereby the individual is converted into the person and is an inter-disciplinary term used to explore human development. Sociologists use the term to concentrate on the effects of social institutions such as the family, school and the media on the individual. See K. Dabziger, Socialization (London: Harmondsworth, 1971), passim. 16 R. Miliband, The State in Capitalist Society: The Analysis of the Western System of Power (London: Quartet Books, 1973), p. 237. 17 S. Cottle (ed.), Media Organization and Production (London: Sage, 2003), p. 9. 24 jackie harrison and lorna woods impact both on the content available and the accessibility of that con- tent. For these critics, the way that owners gain commercial control over sectors of the media industry through concentration, vertical and hori- zontal integration and competitive activity is problematic. This is because, they argue, the primary rationale for such owners is to achieve share- holder value through increased profits and dividends, which means that they must maximize audience ratings to sell to advertisers, as well as seek to create other revenue streams through the expansion of other services, rather than focussing on citizen viewers’ wider interests. The viewer is regarded as a consumer of those products advertised or services sold, and in addition the viewer is also ‘sold’ by the broadcaster to advertisers. In this way viewers are commodified as a media product. The concerns relating to this process of commodification of viewers in the broadcasting market underpin regulation of advertising, particularly its frequency (see chapter 9). Research from the perspective of assessing the effects of the imper- sonal economic forces within the broadcasting market place also focus on the argument that powerful economic interests tend to exclude voices which do not have economic power or resources, usually minority groups, thereby, it is argued, reducing plurality of access and diversity of represen- tation. 18 As table 1 in chapter 1 indicates, the responses of viewers to lack of choice differ depending on their circumstances, but it is easy to imagine that if plurality of access and diversity of representation are overtaken by sheer economic calculation, then the broadcast content and programme range becomes correspondingly narrow. Although critical theorists accused both effects and functionalist theo- ries of possessing a ‘fundamental theoretical vacuity’, 19 some of the under- lying assumptions in those theories can be found in regulatory concerns. Ideas that ‘in many ways mass media contribute (by their “effects”) to this or that “positive” (functional) or “negative” (dysfunctional) outcome for “society” ’ 20 remain important and are subject to ongoing research into the mass media. Both effects analysis and the assessment of the positive and negative functions of broadcasting provide a basis for the media to 18 G. Murdock and P. Golding, ‘For a Political Economy of Communications’, in R. Miliband and J. Saville (eds.), The Socialist Register (London: Merlin Press, 1973), pp. 205–34. 19 Akey problem has been in defining ‘function’ and it is not ‘obvious which media activity is functional (or dysfunctional) to the stable operation of society. Nor is it clear for whom it is helpful and how.’ See Williams, Understanding Media Theory,p.49. 20 McQuail, McQuail’s Reader,p.7. theories about value and functions of broadcast media 25 be taken seriously by regulators and policymakers when considering the regulation to be undertaken in the public interest. 21 Citizens and consumers Although it is beyond the scope of this book to explore the contested nature of citizenship and to assess the enormous amount of literature on the subject, 22 the idea of the citizen viewer is central to our arguments. We agree with Lewis that ‘the citizen is one way of imagining a link between the state and the individual’. 23 Correspondingly, we believe that citizens’ viewing choices reflect the nature of that linkage. Equally, we recognise that, if broadcasting provides the content which meets citizens’ needs and interests, then in theory citizens’ viewing should reinforce their cit- izenship, with its attendant rights, responsibilities and obligations. Such content is typically found (though by no means exclusively) in broad- casting which is underpinned by positive regulatory requirements that place specific obligations on broadcasters. This type of content tends to be expensive to produce and is increasingly being compromised due to increased competition, deregulatory policiesand the diminution of public service broadcasters’ funding, in some cases accompanied by a narrowing of their remit. Alongside the various aspects of their citizenship, there are other activ- ities through which people engage with the media, the most important of which, from our point of view, is being a consumer. Where citizenship has a higher level of significance (referring to intangibles like identity and belonging), being a consumer implies a concrete, economic activity that is defined and de-limited by the structure, workings and efficiency of the market. To confuse the citizen with the consumer is to mix two very different things of unequal standing. However, it is important to note that consumer power has become increasingly evident as consumers 21 T. Gibbons, Media Regulation, 2nd edn (London: Sweet and Maxwell, 1998), p. 2. 22 See, e.g., T. H. Marshall, Class, Citizenship and Social Development (Greenwood: Westport, 1973), passim;M.Roche,Rethinking Citizenship (Cambridge: Polity Press, 1992), passim; C. Closa, ‘The Concept of Citizenship in the Treaty on European Union’, Common Market Law Review,29(1992), 1137–70; H. U. J. d’Olivera, ‘Union Citizenship: Pie in the Sky?’, in A. Rosas and E. Anatola (eds.), ACitizen’s Europe (London: Sage, 1995), pp. 58–84; K. Faulks, Citizenship in Modern Britain (Edinburgh: Edinburgh University Press, 1998), passim. 23 G. Lewis, ‘Citizenship’, in G. Hughes (ed.), Imagining Welfare Futures (London: Routledge/ Open University Press, 1998), pp. 103–50. 26 jackie harrison and lorna woods accrue greater amounts of money and are seen to demand more choice. As consumers become better informed shoppers, consumer rights are more regularly and strongly expressed. Whether these strengths are evenly dis- tributed among all consumers is unlikely; and our model (in table 1, chapter 1) assumes differences in spending capacity between different consumers. The politicisation of consumption in certain areas appears to make it more difficult to claim that citizenship is about identity and belong- ing, while consumption is merely about shopping and a matter of occa- sional activity. In other words, we need to recognise that discerning and politicised consumers exist alongside consumers who merely consume for pleasure, or for want of anything better to do. As we discuss later, the idea of consumption for pleasure can be linked to broader and more difficult questions about programme quality, for example in the case where consumption requires products or services which seek to enter- tain. While entertainment programmes are not necessarily poor quality, they are usually used by the television broadcasting sector to attract audi- ences. Large audiences are, obviously, seen as revenue-generating, either viaincreased subscriptions or enabling the broadcaster to charge higher prices for advertising. Today targeting large audiences to stimulate mass consumption is more and more associated with lowest common denom- inator populist programming, which predominantly seeks to titillate and excite the audience. In short, the nature and value of broadcast content is measured in terms of its economic value, rather than its social and cul- tural value. In principle, this makes viewers, in their role as consumers, actors in an exchange commission and nothing else. Broadcasting and the public interest Although the term ‘public interest’ has been used in relation to the entire range of media, what actually constitutes the public interest has been notoriously difficult to define. Scholarsnotonly‘disagree on the definition of the public interest, they also disagree about what they are trying to define: a goal, a process, or a myth’. 24 Held noted difficulties in definition which she described as ‘assertions of confusion’, but she also argued that ‘the concept is indispensable’. 25 Providing a simple definition of public 24 F. Sorauf, ‘The Conceptual Muddle’, in C. J. Friedrich (ed.), The Public Interest (New York: Atherton Press, 1962), p. 186. 25 V. H e ld, The Public Interest and Individual Interests (New York: Basic Books, 1970), p. 2 and pp. 203–28. theories about value and functions of broadcast media 27 interest has not proved to be impossible, but problematically definitions themselves generally contain frequently contested value judgements. Held’s consideration of theories of public interest led her to identify three approaches to determining its meaning. These approaches illustrate the differences arising between individual interests and the public inter- est. First, preponderance theories hold that the public interest must not be in conflict with ‘a preponderance or sum of individual interests’. 26 Pre- ponderance can be related to amounts of power a group of individuals holds, or be based on the votes of a majority of individuals. Secondly, common interest theories hold that the public interest is met when there is unanimity and agreement among all members of a polity. The agree- ment of a common interest is synonymous with the public interest. While the possibility of conflicting individual interests is recognised, they do not constitute or contribute to the public interest. Both the preponderance and common interest theories adopt a ‘majoritarian’ approach to the pub- lic interest, which could be equated with ‘giving the public what it wants’. The ‘majority of consumers in the media market’ 27 have their desires met, but it is at the expense of other groups. Such an approach ignores minority or dissenting voices. Here we can see the important role that PSB has tra- ditionally played in providing content that caters for both minority and majority needs. The third theory identified by Held refers to ‘unitary con- ceptions’, which are determined in accordance with one dominant value or viewpoint. This approach does not allow for dissent from individual interests and ‘what is a valid judgement for one is a valid judgement for all and consistent with the public interest’. 28 Such an approach to the public interest results in paternalism. McQuail argues that any attempt to chart amiddle way between the free-market majoritarian approaches and the paternalist unitary approach is usually undertaken via ‘ad hoc judicial determinations of what is or is not in the public interest in a given case’. 29 This latter approach would still leave us with the problem of having con- stantly to consider a range of competing public-interest claims. Indeed, as we shall see in chapters 4 and 5,law-making is not the sole preserve of political institutions, even if the judiciary claims just to be applying or interpreting existing legal rules. As we can see from the above three definitions of public interest, the constituent elements identified as referring to the public interest are often 26 Held, The Public Interest,p.42. 27 McQuail, McQuail’s Communication Theory,p.143. 28 Held, The Public Interest,p.45. 29 McQuail, McQuail’s Communication Theory,p.143. [...]... available: http://europa.eu.int/comm/avpolicy/stat /20 05/coregul/coregul-interim-report .pdf European Parliament, Report on the Application of Articles 4 and 5 of Directive 89/5 52/ EEC, as amended by Directive 97/36/EC for the period 20 01 20 02 (20 04 /22 36(INI)), A6 020 2 /20 05 (The Weber Report), p 13 regulation and the viewer 51 members would be reluctant to set standards at a high level There is also a... e.g., The Broadcasting Research Unit, The Public Service Idea in British Broadcasting: Main Principles (Luton: John Libbey, 1985), pp 25 – 32; The Report of the European Broadcasting Union’s (EBU) Perez Group, Conclusions of the TV Programme Committee’s Group of Experts on the Future of Public Service Broadcasting (EBU: Mimeo 1983), p 4; and, more recently, G F Lowe and T Hujanen, Broadcasting and Convergence:... Articles 22 and 22 a of the Television without Frontiers Directive (TWFD), Council Directive 89/5 52/ EEC on the co-ordination of certain provisions laid down by law, regulation or administrative action in member states concerning the pursuit of television broadcasting activities, OJ [1989] L298 /23 , as amended by Directive 97/36/EC OJ [1997] L 20 2/30 See, e.g., D Gauntlett, Moving Experiences: Understanding... about the nature of broadcasting, particularly its value, function and possible impact on the viewer (see chapter 2 and below) Here, and in spite of the fact that broadcasting technology originally developed from private innovation, the market-driven approach was abandoned in favour of a state-organised monopoly The position changed again when the means adopted to control broadcasting and support the values... the content of broadcasting with any clarity or consistency’ regulation and the viewer 43 was the formation of the British Broadcasting Corporation (BBC) The BBC was set up by Royal Charter on 1 January 1 927 , no longer a private company, and was licensed to provide public service broadcasting (PSB) The BBC was to hold a monopoly of radio broadcasting in the UK until the Sound Broadcasting Act legalised... Networks and Services SEC (20 06)816, p 12 As we shall see in chapter 6, the Union is currently considering the possibility of introducing spectrum trading D Krebber, Europeanisation of Regulatory Television Policy: The Decision-making Process of the Television Without Frontiers Directive from 1989 and 1997 (Baden-Baden: Nomos Verlagsgesellschaft, 20 02) , p 9 J Le Grand and B New, ‘Broadcasting and Public... Nordicom, 20 03), o passim McQuail, McQuail’s Mass Communication Theory, p 156 Ofcom, Review of Public Service Television Broadcasting: Phase 1, sect 24 , www.ofcom org.uk/consultations/past/psb/psb/psb .pdf? a = 87101 G Born and T Prosser, ‘Culture and Consumerism: Citizenship, Public Service Broadcasting and the BBC’s Fair Trading Obligations’, The Modern Law Review, 64(5) (20 03), 657–87 Born and Prosser,... Europe .22 18 20 21 22 19 Tracey, The Decline and Fall of Public Service Broadcasting, p 19 Ibid., p 19 Krebber, Europeanisation of Regulatory Television Policy, p 39 Note that, increasingly, private bodies are exercising public functions and it is arguable that they also should be included within a concept of regulation: M Feintuck, The Public Interest in Regulation (Oxford: Oxford University Press, 20 04),... Television e Systems’ in 1990; Blumler in 19 92 and the list referred to by Born and Prosser, ‘Culture and Consumerism’, p 670 Gibbons, Regulating the Media, p 3 02 3 Regulation and the viewer in a changing broadcasting environment Introduction The dual nature of broadcasting as a cultural phenomenon and a commercial product causes difficulties for policymakers and regulators seeking to reconcile the conflicting... See also B Franklin (ed.), British Television Policy: A Reader (London: Routledge, 20 01), p 21 40 jackie harrison and lorna woods Conclusions Policy decisions and regulatory structures in the broadcast sector have recognised that broadcasting requires special levels of responsibility to be imposed upon it The obligations placed on broadcasting are, in part, a cautious reaction to a variety of theories . Press, 19 62) , p. 186. 25 V. H e ld, The Public Interest and Individual Interests (New York: Basic Books, 1970), p. 2 and pp. 20 3 28 . theories about value and functions of broadcast media 27 interest. and P. Willis (eds.), Culture, Media, Language (London: Hutchinson, 1980), pp. 197 20 8, passim. 11 K. Williams, Understanding Media Theory (London: Arnold, 20 02) , p. 20 9. 22 jackie harrison and. see, e.g., The Broadcasting Research Unit, The Public Service Idea in British Broadcasting: Main Principles (Luton: John Libbey, 1985), pp. 25 – 32; The Report of the European Broadcasting Union’s