Commercialization, concentration, convergence, and globalization have dramatically changed the way that media is governed today. European Media Governance analyzes how the governments in thirty-two European countries have slowly but steadily ceded control of the media to marketplace, professional, and public forces.
This landmark study offers an overview of media ownership structures in each country as well as analyses of policies, accountability systems, and technological developments in the regions discussed. This book will be an incomparable resource for all students and scholars of European media.
About the Author
Georgios Terzis is chair of the Communications Department at Vesalius College, Vrije Universiteit Brussels.
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European Media Governance: National and Regional Dimensions
By Georgios Terzis
Intellect LtdCopyright © 2007 Intellect Ltd
All rights reserved.
THE NORTH ATLANTIC OR LIBERAL MEDIA MODEL COUNTRIES
Dan Hallin & Paolo Mancini
The Liberal, or as it is often called the Anglo-American, model of the mass media is in some sense the only model that has really been analyzed in media studies as such, as a coherent model. Indeed, while other media systems have rarely been conceptualized as coherent wholes, it could be said that the "Anglo-American" model has been treated as far more coherent and unitary than it actually is. There are, in fact, substantial differences between the US – which is a purer example of a liberal system – and Britain or Ireland.
Nevertheless, there are important common features of the media systems which distinguish Britain and Ireland along with the US and Canada from continental European media systems. In all these countries newspapers developed relatively early, expanded with relatively little state involvement and became overwhelmingly dominant, marginalizing party, trade union, religious and other kinds of non-commercial media. An informational style of journalism has become dominant, and traditions of political neutrality tend to be strong – though with a very important exception in the British press. Journalistic professionalism is relatively strongly developed. And the state plays a more limited role in the media system than in continental Europe.
Liberalism and the Development of a Commercial Mass-Circulation Press
The most distinctive characteristic of the media history of the North Atlantic countries is the early and strong development of commercial newspapers, which would dominate the press by the end of the nineteenth century, marginalizing other forms of media organization. Newspaper circulations fell from their peak in the Liberal countries following the introduction of television, and are not as high today as some countries of continental Europe and East Asia, but remain relatively strong. Commercialization not only expanded circulations but transformed newspapers from small-scale enterprises, most of which lost money and required subsidies from wealthy individuals, communities of readers, political parties or the state, into highly capitalized and highly profitable businesses. This in turn transformed the political role of the press. The nature of this transformation and its implications for democracy has been the subject of one of the most important debates in media scholarship in the Liberal countries, a debate posed most explicitly in Britain, though it is present in some form in all four countries. The traditional interpretation, dominant in media scholarship for many years as well as in public discourse about the Liberal media system which has been diffused around the world, is the view that "the increasing value of newspapers as advertising mediums allow[ed] them gradually to shake off government or party control and to become independent voices of public sentiment" (Altick 1957: 322). This view was challenged by a revisionist scholarship which began to develop in the 1970s, which saw the commercialization of the press as undermining their role in democratic life, first by concentrating media power in the hands of particular social interests – those of business, especially – and, second, by shifting the purpose of the press from the expression of political viewpoints to the promotion of consumerism. The kinds of "representative media" that played central roles in the media history in continental Europe – media directly tied to political parties or other organized social groups, have been far more marginal in the Liberal countries.
The commercial press that developed so strongly in North America and in Britain played a pioneering role in developing what Chalaby (1996) calls a "fact-centred discourse". Commercial papers emphasized news at the expense of the political rhetoric and commentary which had dominated earlier papers. They were innovators in the development of organizational infrastructure to gather news rapidly and accurately, as well as in the development of the cultural forms of factual reporting
Often it is assumed that this kind of "fact-centred discourse" goes naturally with a stance of political neutrality and that a strong commercial press inevitably means a low level of political parallelism. In fact, there are significant differences among Liberal countries in the extent to which political neutrality or partisanship prevails. In the U.S., Canada and Ireland political neutrality has come to be the typical stance of newspapers. The British press, on the other hand, is still characterized by external pluralism; it is no coincidence that the concept of "party-press parallelism" was developed in Britain, where despite their commercial character and despite the importance of the fact-centred discourse stressed by Chalaby, the press has always mirrored the divisions of party politics fairly closely.
As in other countries, the party affiliations of British newspapers have become weaker over the post-war period. Newspapers became less consistent in their support for one party or another, less inclined to follow the agenda set by party leaders and less focused on the rhetoric of party politics.
Despite this general trend toward diminishing political parallelism, however, the political orientations of British newspapers today are as distinct as anywhere in Europe, with the possible exceptions of Italy and Greece. The spectrum of political views is surely not as wide – Britain is characterized by moderate pluralism, and its politics have a strong orientation toward the centre. Nevertheless, within the limits of the British political spectrum, strong, distinct political orientations are clearly manifested in news content. Strong political orientations are especially characteristic of the tabloid press. But the British quality papers also have distinct political identities. This can be seen in the political affinities of their readers. The readerships of British national papers, for example, are differentiated politically very much like those of newspapers in the Polarized Pluralist or Democratic Corporatist countries. In broadcasting, in contrast to the press, political neutrality is the rule; in Britain, both the BBC and the ITV companies are bound by requirements for impartiality and balance in news and public affairs.
Journalistic professionalism is relatively strongly developed in the Liberal countries. Certainly journalism has developed into a distinct occupational community and social activity, with a value system and standards of practice of its own, rooted in an ideology of public service, and with significant autonomy. At the same time, many contradictions in the nature and significance of professionalization emerge when we look at journalism in Liberal systems.
In Britain as in all the Liberal countries journalism is strongly professionalized in the sense that journalists have their own set of criteria for the selection and presentation of news; this is closely related to the strong development of the press as an industry in Britain, and in this way Britain is very different from, say, Italy, where the standards of journalistic practice are less separated from those of politics. With the development of the press as an industry, as Chalaby (1998: 107) puts it, "journalists began to report politics according to their own needs and interests, covering the topic from their own perspective and professional values." As far as journalistic autonomy is concerned, the picture is mixed. Broadcast journalists in Britain are probably more autonomous than their counterparts in the commercial media of the US or Canada. Donsbach (1995), however, reports that British journalists were second, after Italians, in the percentage reporting that their stories were changed "to give a political slant," 6 per cent saying that this happened at least occasionally, as compared with 8 per cent in Italy, 2 per cent in the US and Germany and 1 per cent in Sweden (a lower percent of the news in Britain concerns politics, compared with Italy, it might be noted). Another survey showed 44 per cent of British journalists saying they had suffered "improper editorial interference" with a story (Henningham & Delano 1998: 154).
Formal institutions of self-regulation of the media are less developed in the Liberal than in Democratic Corporatist countries, though more so than in the Mediterranean region. Ireland has no news council or press complaints commission. Britain moved in 1991 from a very weak Press Council to the Press Complaints Commission, a move intended to avoid continental-style privacy and right-of-reply legislation. The British tabloids, especially, have a heavy emphasis on sex scandals, about both public and private figures. The PCC is clearly stronger than its predecessor, and its presence is a characteristic the British system now shares with the Democratic Corporatist countries, though it is still essentially run by the newspaper industry, "illustrative of the enduring British commitment to 'hands-off' self-regulation" (Humphreys 1996: 61).
The Role of the State
The Liberal countries are, by definition, those in which the social role of the state is relatively limited, and the role of the market and private sector relatively large. Britain was the birthplace of industrial capitalism, and the United States the centre of its twentieth-century growth. Market institutions and liberal ideology developed strongly in both countries – in general, and specifically in the media field, where they are manifested in the early development of commercial media industries and of the liberal theory of a free press rooted in civil society and the market.
In Britain, a strong liberal tradition is modified both by a legacy of conservative statism and by a strong labour movement, whose integration into the system of power in the 1940s shifted Britain in the direction of liberal. Britain, moreover, has no written constitution, and the doctrine of parliamentary sovereignty is central to its legal framework, so freedom of the press remains an important cultural tradition but not the privileged legal principle it is in the US. The press sector remains essentially liberal in character, with neither subsidies nor significant regulatory intervention, though the threat of such intervention did induce the formation of the Press Complaints Commission – and it continues to be discussed, as many argue that the PCC is ineffective. Important manifestations of Britain's strong state tradition include the D-notice system, which restricts reporting of information that affects "national security", and the Official Secrets Act, under which both journalists and public officials can be punished for "leaking" privileged information.
It is in the sphere of broadcasting, however, that the differences between the US and Britain have been most marked, with Britain building a strong public service broadcasting system. In 1954 Britain became the first major European country to introduce commercial broadcasting; even then, however, its broadcasting system retained a strong public service orientation. The BBC and ITV competed for audiences but not for revenue, with the BBC relying on the licence fee and ITV on advertising. And the Independent Broadcasting Authority, which regulated commercial broadcasting until the Broadcasting Act of 1990, was a far different, far stronger institution than the American FCC. Like the rest of Europe, British broadcasting, including the BBC, is increasingly affected by market logic, though the public service system remains stronger in Britain than in much of Europe.
In Ireland concerns about national culture have modified the logic of the Liberal model. Ireland is a postcolonial state, and also a small country proximate to a larger one with the same language. Its political culture combines a tradition of liberalism with a strong official ideology of nationalism. It also has a history of economic dependency and weak development of domestic capital, which like other postcolonial societies – Greece, for example – has resulted in a post-independence tradition of an interventionist state (Bell 1985). Public broadcasting has therefore been strongly dominant in Ireland, with free-to-air commercial television introduced only in 1998, although Irish public broadcasting has a high level of commercial funding, 66 per cent in 1998. Unlike Canada, Ireland has not protected its print industry. About 20 per cent of daily newspaper circulation today represents British titles. The Censorship of Publications Act, which lasted until 1967, resulted from the political conflicts of the civil war of the 1920s, and Ireland, like Britain, has restrictions on media related to the conflict in Northern Ireland.
The early consolidation of liberal institutions in Britain and its former colonies, together with a cluster of social and political characteristics related to this history – early industrialization, limited government, strong rational-legal authority, moderate and individualized pluralism and majoritarianism, are connected with a distinctive pattern of media-system characteristics. These include the strong development of a commercial press and its dominance over other forms of press organization, early development of commercial broadcasting, relatively strong professionalization of journalism, the development of a strong tradition of "fact-centred" reporting, and the strength of the objectivity norm. Media have been institutionally separate from political parties and other organized social groups, for the most part, since the late nineteenth century. And state intervention in the media sector has been limited by comparison with the Democratic Corporatist or Polarized Pluralist systems.
We have also seen that there are important differences among the four countries, enough that we should be careful about throwing around the notion of an "Anglo-American" media model too easily. The British and, to a lesser extent, the Irish and Canadian systems share important characteristics in common with continental European systems –particularly those of the Democratic Corporatist countries – both in their political institutions and cultures and in their media systems. This is manifested most obviously in the strength of public broadcasting and in the persistence of party-press parallelism in the British press. The latter also suggests that the common assumption that commercialization automatically leads to the development of politically neutral media is incorrect.
There are, finally, many tensions or contradictions in the Liberal media systems: there is a tension between the fact of private ownership and the expectation that the media will serve the public good and a closely related tension between the ethics of journalistic professionalism and the pressures of commercialism; there is also a tension between the liberal tradition of press freedom and the pressures of government control in societies where the "national security state" is strong.
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Table of Contents
The Current State of Media Governance in Europe
The North Atlantic/Liberal Media Model Countries
Dan Hallin and Paolo Mancini
The Irish Media Landscape
The United Kingdom Media Landscape
The Northern European/Democratic Corporatist Media Model Countries
The Austrian Media Landscape
The Belgium Media Landscape
Els de Bens
The Danish Media Landscape
Per Jauert and Henrik Søndergaard
The Finnish Media Landscape
The German Media Landscape
Hans J. Kleinsteuber and Barbara Thomass
The Icelandic Media Landscape
The Luxembourgian Media Landscape
The Dutch Media Landscape
Piet Bakker and Peter Vasterman
The Norwegian Media Landscape
The Swedish Media Landscape
Lennart Weibull and Anna Maria Jönsson
The Swiss Media Landscape
Werner A. Meier
The Mediterranean/Polarized Pluralist Media Model Countries
The Cypriot Media Landscape
The French Media Landscape
Bernard Lamizet and Jean-François Tétu
The Greek Media Landscape
Maria Kontochristou and Georgios Terzis
The Italian Media Landscape
The Maltese Media Landscape
The Portuguese Media Landscape
Fernando Correia and Carla Martins
The Spanish Media Landscape
The Turkish Media Landscape
The Eastern European/Post-Communist Media Model Countries
The Bulgarian Media Landscape
The Croatian Media Landscape
The Czech Media Landscape
The Estonian Media Landscape
The Hungarian Media Landscape
The Latvian Media Landscape
The Lithuanian Media Landscape
The Polish Media Landscape
The Romanian Media Landscape
The Slovakian Media Landscape
The Slovenian Media Landscape
Converging Media Governance Arrangements in Europe
About the Authors