EUROPEAN MEDIA GOVERNANCE: National and Regional Dimensions

Edited byGeorgios TerzisAssociate Professor, Vesalius College/Vrije Universiteit Brussel Chair, Journalism Studies Section, European Communication Research and Education Association (ECREA)

Published in February 2008 by Intellect Books, Bristol UKhttp://www.intellectbooks.co.uk/ppbooks.php?isbn=9781841501925

Editor’s Preface

This volume concentrates on the analysis of the nationaldimensions of media governance in 32 European countries [the27 EU member states, the 2 candidate countries, Croatia andTurkey, as well as Iceland, Norway and Switzerland, whichhave special political relations with the EU and where mostof the EU media governance related regulations andprogrammes are applicable]. Further, the publicationanalyses four regional dimensions of media governance thatis the North Atlantic/Liberal, Northern European/DemocraticCorporatist, Mediterranean/Polarized Pluralist, and EasternEuropean/Post-Communist as defined by the criteria set byHallin and Mancini (2004).

Governance, according to the European Union, consists ofrules, processes and behaviour that affect the way in whichpowers are exercised, particularly as regards openness,participation, accountability, effectiveness and coherence.1

Despite efforts of the EU to regulate part of the media1 European Commission, (2001) EUROPEAN GOVERNANCE, AWHITE PAPER, Brussels, 25.7.2001, COM(2001) 428 final, p. 8, Available from: http://eur-lex.europa.eu/LexUriServ/site/en/com/2001/com2001_0428en01.pdf

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industry, media governance is considerably different in thevarious national and regional domains in Europe.

A trip to the media landscapes of Europe offers us thevariety of unique characteristics such as the Berlusconiphenomenon in Italy, pirate media in Ireland, and a publicbroadcasting station (PBS) with audience rating quotas inBelgium. In Croatia the law forbids the media to promotewar, while Turkey, with 5 hours daily viewing, has one ofthe highest TV audience ratings in the world. A Germancompany is the biggest newspaper owner in Bulgaria, andalmost all the daily newspapers in the Czech Republic andHungary are foreign owned, while in Slovenia there is almostno foreign ownership of newspapers.

In Luxemburg the biggest newspaper belongs to the CatholicArchbishop, and media activities have always been almostexclusively the domain of private initiatives, while inMalta 98 percent of the population watches PBS or stationsthat belong to public institutions. In Switzerland privatetelevision does not exist, and PBS has the responsibility topromote cultural understanding among the differentlinguistic communities. On the other hand, in Poland theprogrammes of PBS should respect the Christian system ofvalues, strengthen the family ties, and combat ‘socialpathologies’.

At the same time that Finland sees the introduction ofmobile television, Norway boasts the most successfulnewspaper website and one that has more readers on theinternet than on paper. In Sweden more than 80 percent ofthe population reads a newspaper every day, while Greece andPortugal have some of the lowest newspaper readerships inthe developed world. In Iceland there is home delivery offree sheets, and in Spain, newspapers are making more moneyfrom the sale of products than the sale of newspaper copies.

In Germany there is fierce competition among news agencies,while in Romania newspaper title numbers go up and

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competition is also fierce during election periods.Competition is also fierce in the second biggest mediamarket in the world, the UK where some newspapers sawcirculation declines of up to 4.4 million. Finally, in theNetherlands one company owns almost all daily newspapers.

Despite those and other unique characteristics of the medialandscapes of the 32 countries, the same voyage through themedia landscape offers us a clear picture of the commoncharacteristics that exist across all these nationaldimensions such as commercialisation, convergence,concentration, transnationalisation, and audiencefragmentation. In addition, media governance in Europe doesnot only have national and regional dimensions, but thesedimensions are currently in a constant flux due to thetechnological, social and financial changes taking place onthe continent.

The introduction of cable, satellite and digital radio andtelevision stations and the consequent channel proliferationand new types of media content, put ‘must carry’ regulationsand public funding of PSBs under pressure, while digitalconvergence makes it hard to differentiate between sectorsand thus hard to sustain sector-specific regulation.

In the mean time, ideological and social shifts such as theprevalence of neo-liberal thinking, the reliance on marketforces for delivering choice, and individualism anddiversification of lifestyles put the whole concept of PSBand state policies of media governance in Europe intoquestion (Iosifidis, 2006). And as our journey to thedifferent media landscapes reveals, market forces andtechnological developments do not necessarily protect mediapluralism or the national public sphere and democraticparticipation. Instead, they might allow the flourishing ofmultiple identities across borders, since Europeans can nowafford to take their politics with them, as well as theirfood, when they migrate to another European country.

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External and internal media pluralism, however, depends notonly on state policies as the country landscapes reveal, butalso on geographic and linguistic market sizes and thecountry’s civil society organisations relating to media (theso-called ‘fifth estate’)2. While freedom of expression islegally protected in each of the EU Member States andfreedom of information is part of the legal and democraticframework in all member states; normally throughConstitutional Articles or Parliamentary Acts, “theirpractical implementation includes on the one hand eithervoluntary or statutory rules for publishers that ensure theindependence of journalistic output (codes on editorialindependence, confidentiality of sources, privacy rules,defamation legislation etc); and on the other hand codes forjournalists relating to standards of accuracy, fairness,honesty, respect for privacy and to ensure high professionalstandards, by avoiding plagiarism, defamation or theacceptance of bribes. Several companies have voluntarilyintroduced internal rules to protect their editorial stafffrom outside pressure and to separate managerial andeditorial responsibilities.”3

In regards to the market, the introduction, success anddominance of free sheets like the Metro almost everywhere inEurope are forcing traditional paid newspapers to rethink2 Civil society according to EU includes exactly those organisations: “trade unions and employers’ organisations (“social partners”); nongovernmental organisations; professional associations; charities; grass-roots organisations; organisations that involve citizens in local and municipal life with a particular contribution from churches and religious communities”. European Commission, (2001) EUROPEAN GOVERNANCE,AWHITE PAPER, Brussels, 25.7.2001, COM(2001) 428 final, p. 14, Availablefrom: http://eur-lex.europa.eu/LexUriServ/site/en/com/2001/com2001_0428en01.pdf

3 Organization for Security and Co-operation in Europe, Representative on Freedom of Media, TheImpact of Concentration on Professional Journalism, Vienna 2003, page 47quoted at COMMISSION STAFF WORKING DOCUMENT, Media pluralism in the Member States of the European Union, {SEC(2007) 32}

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their business models. The dominance of traditional off-linemedia on internet news also makes start-up internet newscompanies rethink their business models and proves to theinternet utopians that the new medium does not necessarilychange the old status quo and the power structures of thedefinition of the news agenda. Finally, the ‘pleonasticexcommunication’ (Fortner, 1995) from traditional televisionstations of the young population due to the introduction ofthe internet, and general audience fragmentation of TV andradio audiences due to the introduction of a plethora ofdigital and satellite channels everywhere in Europe forcesthe broadcast industry to rethink its position too.

As a result, media governance in Europe is never static andinstead constantly shifting media rules and regulationsbetween exclusively governmental domains to others, such asthe market and civil society organisations and from nationalgovernment policies to local, regional, multinational andinternational ones (McQuail, 1997 and 2005; Bardoel &d’Haenens, 2004).

Four regional dimensions rest among these uniquecharacteristics and Europe-wide trends described above.According to Hallin and Mancini, the social and politicalcharacteristics of a country shape its media system and thusthere is a ‘systemic parallelism’. As such, and despitetheir differences, European media landscapes share regionalmedia dimensions parallel to their social and politicalregional dimensions. These are analysed in the introductorychapters of each section by the respective authors.

References

Bardoel, J. & d’Haenens, L. (2004). Media responsibility andaccountability: New conceptualizations and practices,Communications: The European Journal of CommunicationResearch 29 (1): 5-25

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European Commission, (2001) EUROPEAN GOVERNANCE, AWHITEPAPER, Brussels, 25.7.2001, COM(2001) 428 final, p. 8 and14, Available from: http://eur-lex.europa.eu/LexUriServ/site/en/com/2001/com2001_0428en01.pdf

Fortner, R.S. (1995) Excommunication in the Information Society. Critical Studies in Mass Communication, 12, 133-154

Hallin, Daniel C. & Mancini, Paolo (2004). Comparing Media Systems. Three Models of Media and Politics. Cambridge: Cambridge University Press.

Iosifidis P. (2006), Public TV in small EU countries: the Greek case, Conference presentation at the Research Institute of Applied Communications, Cyprus, June 2006

McQuail, D. (2005) McQuail's Mass Communication Theory, Sage

McQuail, D. (1997) Accountability of Media to Society:Principles and Means, European Journal of Communication,Vol. 12, No. 4, 511-529 (1997)

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The Northern European / Democratic CorporatistMedia Model

By Lennart Weibull, Professor of Media Research at the Department ofJournalism and Mass Communication at Göteborg University

Eleven countries here represent what Daniel Hallin and PaoloMancini (2004:143ff) have proposed as the DemocraticCorporatist media model. They are countries of northern and,to some extent, central Europe: the Nordic countriesDenmark, Finland, Iceland, Norway and Sweden, Germany,Austria and Switzerland as well as Belgium, Luxemburg andthe Netherlands. They are all strongly urbanised and most ofthem have a long industrial tradition. However, they differsignificantly in size – from 90 million inhabitants inGermany to less than half a million in Iceland – and intheir cultural and political heritage.

Cultural and Political heritage

To a large extent the eleven countries are part of a commonhistory and culture. Germanic languages – German, Dutch,Swedish, Danish, Norwegian and Icelandic - are spoken inmost of the countries, denoting the common roots. However,Roman languages – French and Italian - coexist in the southas national languages in Belgium and Switzerland. Finnish,the national language of Finland, is part of the Fenno-Ugrian language family with no relation to most otherEuropean languages. Moreover, there are a few importantlanguage minorities. In all countries, another Germaniclanguage, English, serves as a lingua franca, normallytaught from early school years.

The language similarities indicate the intense socialcontacts between the countries. The Nordic countries forcenturies were depending on German culture as the main linkto continental Europe. The tradition was broken up after theSecond World War and replaced by a strong Anglo-Saxoninfluence. The close interaction between the countries was

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reinforced by the fact that they were small and a lot oftrade ways crossed the country borders. A typical example isthe old Hanseatic League, which in the 16th and 17th

encompassed trading cities in most of the eleven countriesof today, e.g. Bergen (Norway), Brügge (Belgium), Lübeck(Germany) and Kalmar (Sweden). Trade also meant a fastdissemination of new ideas and contributing to theestablishment of similar political, cultural and legalmodels. The rise of the first German Reich in the mid 19th

century changed meant the rise of one very strong country,but gradually also the minor nation states graduallyincreased cooperation, e.g. in the Benelux and the Nordicareas.

Probably the single most important factor in bringing thenorthern countries together was the Lutheran challenge tothe Roman Catholic Church in the early 16th century Germany,followed by other reformers in especially Switzerland. Eventhough this for more than a century meant religious warfare,it gradually changed the perspective on society. Also incountries, where the Roman Catholic Church came back topower, like in Austria, Belgium and southern Germany, thenew liberal ideas had an influence on political and culturallife. The authoritarian power structure had been challengedand new bodies had been established, fostering a basicpolitical tolerance. Further, in the Lutheran and thereformed the bible on the national language was an importantprerequisite, making reading an important factor in thenational development.

Of course, the development of coexistence in the North didnot take place without conflict. Not only religious wars butalso political rivalry characterised the 18th and 19th

centuries. Within the Nordic countries Denmark and Swedenfought for power, on the continent Prussia and Austria werethe main combatants. After the Napoleonic wars the patternsof conflict changed, first through the two world wars, laterby the openness to Anglo-Saxon culture.

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The common Northern European tradition can be found not onlyin a common culture but also in politics and economy.Political democracy was established in the early 20th

century, with the exception of Austria and Germany. Most ofthe countries are oriented to consensus politics, based onwhat Hallin and Mancini call a moderate pluralism (Hallinand Mancini, 2004:68), which in practice means a high levelof political stability based on strong parties with longtradition. One extreme is Switzerland with an almostpermanent coalition government, whereas all other countrieshave a traditional parliamentary system. In most countriesthere is a clear left-right dimension in party structure,but even though political majorities may change largedifferences in actual politics are less frequent.

Most of the countries have strongly backed the idea of freetrade, and even if some of the countries, e.g. Denmark,Norway, Sweden and Switzerland, for political reasonsoriginally were reluctant to join the European Union, theycreated the EFTA as free trade association. Today most ofthe countries have a GNP per capita, which is clearly overthe average of Europe. All countries are characterised bymarket economy and are traditionally strong welfare states.In most countries there is also a significant involvement ofthe state in the economy and a large public sector.

The legislative and governmental bodies are generallyrespected, expressing the strength of the rational-legalauthority: The state normally regarded as the guardian offreedom and justice as well a guarantor of the welfarestate, even though public trust has declined in the latestdecades in almost all Democratic Corporatist countries.

Even if the basic principles of the Democratic Corporatistmodel form the basis of the tradition of the eleven states,it does not mean that they are a totally homogenous group ofstates. There are obvious differences within some of thecountries, but in most of the areas presented above theyrepresent a common perspective, which makes them different

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from countries in the eastern and southern Europe, but alsofrom the United Kingdom. Democratic Corporatism in the Northern European MediaSystems

The common tradition of the Northern European both inpolitics, economy and culture is also reflected in theirmedia systems. Daniel Hallin and Paolo Mancini (2004:144f)points out three what they call coexistences between mediaand politics, which they regard as distinctive to theDemocratic Corporatist countries:

The first is the high degree of political parallelismbetween the development of the mass press and partypolitical development, meaning that newspaper developmenthas reflected political, cultural and social divisions ofsociety.

The second coexistence is that the political parallelism inmedia development has coexisted with a high degree ofjournalistic professionalisation, meaning the existence ofindependent media that report political events according toprofessional standards.

The third coexistence has to do with relations between thestate and the media, which on one hand has meant an earlyintroduction of press freedom (from the state) in most ofthe countries, but on the other hand means an acceptance ofstate activities in the media sphere.

The eleven chapters on the media systems of the individualDemocratic Corporatist countries shall be read in the lightof theoretical approach. Some of the main tendencies will besummarised under headings, which are taken from the overviewby Hallin and Mancini (2004:67).

The Newspaper Industry

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The cradle of the world’s newspaper industry stood withinthe Democratic Corporatist countries. The first papers werepublished at the central European trade centres of the early17th century, but before the end of the century also thefirst newspapers of the Nordic countries had beenestablished. Also the roots of the modern mass press can befound in the same area. The mass press developed during themid 19th and the early years of the 20th centuries. The firstwave of the modern commercial press aimed at industrialists,merchants, intellectuals, who were the main actors of thedeveloping industrial society.

Press freedom was established early, Sweden already in 1766,finalised in 1812, Norway in 1814, the Netherlands in 1815,Belgium in 1831 and Denmark in 1848. In the early 20th

century newspaper readership increased in the workingclasses, especially in the Nordic countries, with theintroduction of cheaper papers.

Today we find most of the countries of the DemocraticCorporatist media tradition on the top of the ranking of themost newspaper buying countries of the world. Norway,Finland and Sweden show the highest figures with between 651and 489 copes sold per 1000 adults. The other countries ofthe group range between 300 and 400 copies. Belgium is thesole example ranks fairly low with only about 170 copiessold, which places it close to the Pluralist Polarised mediatradition.

The basic pattern is the same for regular reading, where thepercentage of newspaper readers on an average day exceeds80. In the other countries the figures are around 70 and inBelgium 50 per cent. In the Nordic countries the newspapermarket is somewhat stronger in terms of exposure. In spiteof the strong tradition of paid newspapers free dailies havein recent years developed very strong in most of thecountries, especially in Iceland, Sweden and Denmark.

Political Parallelism

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The expansion of the daily press coincided in most countrieswith increased democracy. Especially the liberal played animportant role in pushing political liberties forward. Mostnewspapers became gradually affiliated to political parties,and in the early 20th century a strong party pressdeveloped, even if conditions differed between thecountries. In the Nordic countries a socialist pressdeveloped in first decades of the new century, whereas itwas forbidden in Germany because of the authoritarianlegislation. In the middle of the century there werenational newspapers representing all the major parties aswell as other social and religious groups. In Denmark, andpartly also in the other Nordic countries, this was truealso on the regional and local level. There are reasons tobelieve that this presence of a broad partisan press, calledsegmented pluralism by Hallin and Mancini (2004:152f),fostered citizens as newspaper readers, hence contributingto the high level of Nordic readership in all social groups.In Austria and Germany the Nazi regime took politicalcontrol of newspapers, but after the Second World War thepartisan character of the press was re-established.

The parallelism between political and social groups on onehand and the newspaper industry on the other took differentforms both within and between the Democratic Corporatistcountries. Generally, conservative and liberal papers wereprivately owned, whereas socialist and communist papers, atleast to a large extent, had party ownership. Editors ofmost papers also had party political positions orrepresented the parties in political bodies. During thefirst half of the 20th century the traditional politicalpress met competition from popular newspapers starting by anew type of private entrepreneurs. These were more popularin presentation, even though they did not leave out politicsand even could have a clear party affiliation.

Characteristic for the political parallelism of the modernpress was that it in Democratic Corporatist countries seems

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to have contributed to the high prestige of the press.Newspapers, even if partisan in coverage, were oftenregarded as an integrated part of political democracy andreading was a kind of political participation. Even whennewspapers changed character in the second half of the 20th

century and many party political papers had to close downthe tradition was still existent, the most obvious exampleof this tradition being Luxemburg where a strong party presstradition still characterises the newspaper market.

The State and the Media

One reason for the general acceptance of the party politicalpress in the Democratic Corporatist countries was to a largeextent a general trust in politics and political bodies. Thestate was not seen as an enemy of the media. In Denmark theprime minister has traditionally been responsible for thepress and regarded as the main guardian of free media.Typical is that direct state subsidies to the press exist inall countries with the exception of Germany and Austria.Although they sometimes have been principally debated, therehas normally been consensus in practice. The subsidies havemainly contributed to maintain a certain level pluralism onthe newspaper market, even though papers gaining supportnormally have only a small circulation. The state support isnormally given according to neutral rules, based in marketeconomy principles, and does not strong affect the basicmarket mechanisms. It is important to add that the statesubsidies are not perceived to have any impact on journalismpractice.

The important role of the state in the DemocraticCorporatist countries is most obvious in the area of radioand television. In all the countries public servicetelevision is very strong. As is pointed out by Hallin andMancini (2004:164) public service radio was developed almostas a parallel to the extension of the welfare state, as respublica, almost as an enlightenment programme. In mostcountries the state dominance, especially from the 1930s

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when the state replaced local private stations by statecontrolled broadcasting, met little criticism. Most of thepublic service organisations were modelled after the BBC,but the organisational structures differed a lot between thecountries. On one hand we have the pillarisation of Dutchbroadcasting, on the other public service as a governmentagency as in Denmark, Finland being a special case, since itwas opened up for a commercial company to broadcast in thestate television within certain time frames. The commondenominator has been to organise radio and television as anindependent organisation with internal pluralism, guaranteedby the state - even though the Dutch solution might be moreof external pluralism. In most of the governing bodiesleading there are representatives of important political andsocial groups, but programming is normally left to theprofessionals of the organisations.

The Broadcast Industry

The use of radio and television has traditionally been lowerin the north of Europe than in the south. The Nordiccountries have among the lowest figures in Europe ontelevision viewing time compared with the figures fornewspaper reading. This seems to reflect the readingtradition of the Democratic Corporatist countries. Also thestrong profile on news and current affairs in the publicservice channels, both in radio and television, mightreflect the same tradition.

During the 1980s, however, the Democratic Corporatistcountries gradually opened up for competition from privatebroadcasters, mostly both in radio and television. Privateradio was originally established mostly on the local level,often as illegal or semi-illegal stations as in Belgium orSweden, or as community radio as in Norway. When formallyaccepted they normally created national networks based onthe local stations for programming as well as foradvertising. Luxemburg differs somewhat because here

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monopoly was granted a commercial radio company – RTL - on acontractual basis.

The first country, besides Luxemburg, to accept privatetelevision was Germany in the mid 1980s, whereas Austriawere among the late-comers in 2003 and Switzerland still hasno nationwide commercial TV-channel; however in both Austriaand Switzerland foreign private channels, broadcasting inthe national languages, have an extensive reach, facilitatedby cable transmission. Commercial television developed threetypes of channels: (1) Terrestrial channels by governmentconcessions financed by advertising, (2) Satellite channelsfinanced by advertising, and (3) Satellite channels mainlyfinanced by subscription fees. The reach of the latter twowas originally depending on the high cable penetration inmost of the eleven countries, especially in The Netherlandsand Austria. The output of the private channels was mainlypopular drama and entertainment shows. In this developmentLuxemburg media politics played an important role buygranting RTL almost exclusivity for its internationaloperations.

The private television sector has gradually expanded in mostof the eleven countries. Germany hosts the biggestcommercial TV-systems with RTL and ProSieben/Sat1. Theexpansion has meant that public service television hasgradually lost market shares. In most countries publicservice channels together have around 40 per cent of theviewing time or less. The only exception is the SRG/SSR inSwitzerland with about two thirds of the audience, thereason of course being that there is no competition fromnational private television. Since most of the countrieshave already started or at least decided to introducedigital television it is expected the fragmentation oftelevision will go on. However, this has not changed thegeneral picture in the public attitude to public servicetelevision. The public service radio and television has astrong standing among politicians in most of the countries.When it comes to news the audience also prefers public

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service channels and ranks them high in credibility, usingthe private channels mostly for entertainment.

Professionalisation

The strong press of the Democratic Corporatist countriesaffected its standing in society. Newspapers and editorsformed their own associations across the borders of theparty political press. In Norway this development took placealready in the late 19th century, in most other in the early20th century. Approximately in same period also journalistsorganised themselves in professional organisations. Most ofthese organisations became very strong, not least becausetheir high rate of membership. Further, the organisationshade close contacts with one another and in some countriesthere were professional press clubs where both editors andjournalist cold have membership.

One consequence of the organisational activities was thework on principles of good journalism practice. In mostcountries this soon developed into formalised systems ofself-regulation of the press. Sweden has one of the oldestrules of good journalism practice, originally decided uponin 1916, and extended over the years. Press Councils havebeen established, normally by the newspaper industry and thejournalist associations, to handle readers’ complaintsagainst the rules of good practice. The rules and thecouncils are normally well anchored in the media culture ofthe Democratic Corporatist countries. There are in mostcountries also rules for the inner freedom of mediaorganisations, often called editorial statutes. In Norwaythere is a long tradition of written principles on thenational level whereas internal statutes play an importantrule also in Germany and the Netherlands.

Taken together these sets of professional organisations andrules form the basis of journalistic autonomy in newsreporting, that is often called professionalisation.Professionalisation here means an independent, not partisan

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journalism, where journalists perceive themselves aswatchdogs. What might be surprising is that this type ofjournalistic autonomy has developed in countries with such astrong tradition in terms of party political press andstrong public service radio and television. However, itseems to be a part of the Democratic Corporatist mediaculture to combine strength in the political reporting withan active critical reporting.

Development Trends

Even tough the political media tradition is very strong inthe Democratic Corporatist part of Europe there are manysigns of change, mainly influenced by the liberal modelbased in the United Kingdom and the United States. The mostimportant change probably took place in the 1980s, when themonopoly of the public service broadcasting was broken andopened up for new commercial actors. However, it isimportant to bear in mind the eleven countries grouped asDemocratic Corporatist are not homogenous. For example isLuxembourgian radio and television almost from its startpart of the liberal media model. The francophone part ofBelgium seems more to be a part of the Polarised Pluralisttradition, than the Democratic Corporatist one, illustratingthat media tradition probably is determined more by culturaltraditions that by the today’s nation states.

However, considering the long-term trends it is obvious thatthe 1990s meant an increasing media competition,contribution to an increase in market orientation. On thenewspaper market the development of a number of new localnewspaper monopolies also changed the character of thepress, making it more ‘selling’ in layout and content.Economic indicators of media performance – market share orprofit – became more important the political influence, ifthey did not coincide. The market orientation of both pressand broadcasting meant an establishment of new mediacompanies, not seen before in most of the eleven countries.Commercially, the Nordic countries gradually developed into

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one media market, mainly dominated by a few main actors, oneof those a U. S. investment company. In media content therole of entertainment is increasing as do the role of theadvertising market for the media development.

Another aspect of the commercialisation of the media marketis an increasing segmentation of the media audience. It isfurther strengthened by the fast development of Internet,which has especially rapid in the Democratic Corporatistcountries, probably reinforced by the strong readingtradition. Internet use, with an enormous potential ofsources and increasingly individual choices is a challengefor traditional media. Further, the fragmentation of mediaaudience leaves little room for the political public sphere,traditionally guaranteed by the main newspapers and publicservice broadcasting. As Hallin and Mancini (2004: 251ff)put it, there is a general tendency of convergence betweenthe different political media models.

However, when interpreting development trends in theDemocratic Corporatist part of Europe during the latestdecades, two things have to born in mind. The firstobservation is that the changes are not only a matter ofmedia development. These trends also reflect changes inpolitics in the Democratic Corporatist countries, the mostimportant being the decline of traditional corporatism. Newvalues, especially the strengthened individualisation, havechallenged the legitimacy of the corporate society. Thetradition of rational-legal authority is clearly weakened.It is indicated by among other things a decline in publictrust in government bodies.

The second observation is that, in spite of these changes,the Democratic Corporatist model must be said to have astrong standing in most of the eleven countries. It is truethat newspaper readership is declining, but is still veryhigh. It is also true that public broadcasting has lostsubstantially in audience shares, but it is equally truethat it is strongly trusted among the citizens than other

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media sources. In some countries, among others theNetherlands the public trust in politics is even increasing.At the same time, Internet penetration has grown very fast.It has opened up for more media sources, which probably willreinforce the impact of the liberal model. But the traditionis strong, and the increased importance of free dailiesstill points in this direction. Hence, it might be too earlyto declare the Democratic Corporatist media model dead.

References

Gustafsson, Karl Erik, Weibull, Lennart (1997) NewspaperReadership - Structure and Development. The European Journal ofCommunication Research 3/1997.

Gustafsson, Karl Erik, Weibull, Lennart (2007) NewspaperConsumption in Europe. Brussels: European NewspaperAssociation.

Hallin, Daniel C. & Mancini, Paolo (2004). Comparing MediaSystems. Three Models of Media and Politics. Cambridge: CambridgeUniversity Press.

Weibull, Lennart, Nilsson, Åsa (forthcoming)

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The North Atlantic or Liberal Model

This chapter is an extract from chapter 7 of the bookComparing Media Systems. Three Models of Media and Politics. Cambridge:Cambridge University Press, by Hallin, Daniel C. & Mancini,Paolo (2004) and it is published with the permission of thepublisher.

Dan Hallin is a Professor of Communication and Adjunct Professor of PoliticalScience at the University of California, San Diego.Paolo Mancini is a Professor at the Dipartimento Istituzioni e Societa, Facolta diScienze Politiche, Universita di Perugia

The liberal or as it is often called the Anglo-Americanmodel of the mass media is in some sense the only model thathas really been analyzed in media studies as such, as acoherent model. Indeed, while other media systems haverarely been conceptualized as coherent wholes, it could besaid that the "Anglo-American" model has been treated as farmore coherent and unitary than it actually is. There are infact substantial differences between the U.S.--which is apurer example of a liberal system--and Britain or Ireland.

Nevertheless, there are important common features of themedia systems which distinguish Britain and Ireland alongwith the U.S. and Canada from Continental European mediasystems. In all these countries newspapers developedrelatively early, expanded with relatively little stateinvolvement, and became overwhelmingly dominant,marginalizing party, trade union, religious and other kindsof non-commercial media. An informational style ofjournalism has become dominant, and traditions of politicalneutrality tend to be strong--though with a very importantexception in the British press. Journalistic professionalismis relatively strongly developed. And the state plays a morelimited role in the media system than in continental Europe.

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Liberalism and the Development of a Commercial Mass-Circulation PressThe most distinctive characteristic of the media history ofthe North Atlantic countries is the early and strongdevelopment of commercial newspapers, which would dominatethe press by the end of the nineteenth century,marginalizing other forms of media organization. Newspapercirculations fell from their peak in the Liberal countriesfollowing the introduction of television, and are not ashigh today as some countries of continental Europe and EastAsia, but remain relatively strong. Commercialization notonly expanded circulations but transformed newspapers fromsmall-scale enterprises, most of which lost money andrequired subsidies from wealthy individuals, communities ofreaders, political parties or the state, into highlycapitalized and highly profitable businesses. This in turntransformed the political role of the press. The nature ofthis transformation and its implications for democracy hasbeen the subject of one of the most important debates inmedia scholarship in the Liberal countries, a debate posedmost explicitly in Britain, though it is present in someform in all four countries. The traditional interpretation,dominant in media scholarship for many years as well as inpublic discourse about the Liberal media system which hasbeen diffused around the world, is the view that "theincreasing value of newspapers as advertising mediumsallow[ed] them gradually to shake off government or partycontrol and to become independent voices of publicsentiment" (Altick 1957: 322). This view was challenged by arevisionist scholarship which began to develop in the 1970s,which saw the commercialization of the press as underminingtheir role in democratic life, first by concentrating mediapower in the hands of particular social interests--those ofbusiness, especially--and second, by shifting the purpose ofthe press from the expression of political viewpoints to thepromotion of consumerism. The kinds of "representativemedia" that played central roles in the media history incontinental Europe--media directly tied to political partiesor other organized social groups, have been far moremarginal in the Liberal countries.

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Political Parallelism

The commercial press that developed so strongly in NorthAmerica and in Britain played a pioneering role indeveloping what Chalaby (1996) calls a "fact-centreddiscourse." Commercial papers emphasized news at theexpense of the political rhetoric and commentary which haddominated earlier papers. They were innovators in thedevelopment of organizational infrastructure to gather newsrapidly and accurately, as well as in the development of thecultural forms of factual reporting

Often it is assumed that this kind of "fact-centreddiscourse" goes naturally with a stance of politicalneutrality, and that a strong commercial press inevitablymeans a low level of political parallelism. In fact, thereare significant differences among Liberal countries in theextent to which political neutrality or partisanshipprevails. In the U.S., Canada and Ireland, politicalneutrality has come to be the typical stance of newspapers.The British press, on the other hand, is still characterizedby external pluralism; it is no coincidence that the conceptof "party-press parallelism" was developed in Britain, wheredespite their commercial character and despite theimportance of the fact-centred discourse stressed byChalaby, the press has always mirrored the divisions ofparty politics fairly closely.

As in other countries, the party affiliations of Britishnewspapers have become weaker over the post-war period.Newspapers became less consistent in their support for oneparty or another, less inclined to follow the agenda set byparty leaders, and less focused on the rhetoric of partypolitics.

Despite this general trend toward diminishing politicalparallelism, however, the political orientations of Britishnewspapers today are as distinct as anywhere in Europe, with

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the possible exceptions of Italy and Greece. The spectrum ofpolitical views is surely not as wide--Britain ischaracterized by moderate pluralism, and its politics have astrong orientation toward the centre. Nevertheless, withinthe limits of the British political spectrum, strong,distinct political orientations are clearly manifested innews content. Strong political orientations are especiallycharacteristic of the tabloid press. But the British qualitypapers also have distinct political identities. This can beseen in the political affinities of their readers. Thereaderships of British national papers, for example, aredifferentiated politically very much like those ofnewspapers in the Polarized Pluralist or DemocraticCorporatist countries. In broadcasting, in contrast to thepress, political neutrality is the rule; in Britain, boththe BBC and the ITV companies are bound by requirements forimpartiality and balance in news and public affairs.

Professionalisation

Journalistic professionalism is relatively stronglydeveloped in the Liberal countries. Certainly journalism hasdeveloped into a distinct occupational community and socialactivity, with a value system and standards of practice ofits own, rooted in an ideology of public service, and withsignificant autonomy. At the same time, many contradictionsin the nature and significance of professionalisation emergewhen we look at journalism in Liberal systems.

In Britain as in all the Liberal countries journalism isstrongly professionalized in the sense that journalists havetheir own set of criteria for the selection and presentationof news; this is closely related to the strong developmentof the press as an industry in Britain, and in this wayBritain is very different from, say, Italy, where thestandards of journalistic practice are less separated fromthose of politics. With the development of the press as anindustry, as Chalaby (1998: 107) puts it, "journalists beganto report politics according to their own needs and

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interests, covering the topic from their own perspective andprofessional values." As far as journalistic autonomy isconcerned, the picture is mixed. Broadcast journalists inBritain are probably more autonomous than their counterpartsin the commercial media of the U.S. or Canada. Donsbach(1995), however, reports that British journalists weresecond, after Italians, in the percentage reporting thattheir stories were changed "to give a political slant," 6%saying that this happened at least occasionally, as comparedwith 8% in Italy, 2% in the U.S. and Germany, and 1% inSweden (a lower percent of the news in Britain concernspolitics, compared with Italy, it might be noted). Anothersurvey showed 44% of British journalists saying they hadsuffered "improper editorial interference" with a story(Henningham & Delano 1998: 154).

Formal institutions of self-regulation of the media are lessdeveloped in the Liberal than in Democratic Corporatistcountries, 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 thePress Complaints Commission, a move intended to avoidcontinental-style privacy and right of reply legislation.The British tabloids, especially, have a heavy emphasis onsex scandals, about both public and private figures. The PCCis clearly stronger than its predecessor, and its presenceis a characteristic the British system now shares with theDemocratic Corporatist countries, though it is stillessentially run by the newspaper industry, "illustrative ofthe 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 thesocial role of the state is relatively limited, and the roleof the market and private sector relatively large. Britainwas the birthplace of industrial capitalism, and the UnitedStates the centre of its twentieth-century growth. Market

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institutions and liberal ideology developed strongly in bothcountries--in general, and specifically in the media field,where they are manifested in the early development ofcommercial media industries and of the liberal theory of afree press rooted in civil society and the market.

In Britain, a strong liberal tradition is modified both by alegacy of conservative statism and by a strong labourmovement, whose integration into the system of power in the1940s shifted Britain in the direction of liberal. Britain,moreover, has no written constitution, and the doctrine ofparliamentary sovereignty is central to its legal framework,so freedom of the press remains an important culturaltradition but not the privileged legal principle it is inthe U.S. The press sector remains essentially liberal incharacter, with neither subsidies nor significant regulatoryintervention, though the threat of such intervention didinduce the formation of the Press Complaints Commission--andit continues to be discussed, as many argue that the PCC isineffective. Important manifestation of the Britain's strongstate tradition include the D-notice system, which restrictsreporting of information that affects "national security,"and the Official Secrets Act, under which both journalistsand public officials can be punished for "leaking"privileged information.

It is in the sphere of broadcasting, however, that thedifferences between the U.S. and Britain have been mostmarked, with Britain building a strong public servicebroadcasting system. In 1954 Britain became the first majorEuropean country to introduce commercial broadcasting; eventhen, however, its broadcasting system retained a strongpublic service orientation. The BBC and ITV competed foraudiences but not for revenue, with the BBC relying on thelicense fee and ITV on advertising. And the IndependentBroadcasting Authority which regulated commercialbroadcasting until the Broadcasting Act of 1990 was a fardifferent, far stronger institution than the American FCC.Like the rest of Europe, British broadcasting, including the

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BBC, is increasingly affected by market logic, though thepublic service system remains stronger in Britain than inmuch of Europe.

In Ireland concerns about national culture have modified thelogic of the Liberal model. Ireland is a post-colonialstate, and also a small country proximate to a larger onewith the same language. Its political culture combines atradition of liberalism with a strong official ideology ofnationalism. It also has a history of economic dependencyand weak development of domestic capital, which like otherpost-colonial societies--Greece, for example--has resultedin a post-independence tradition of an interventionist state(Bell 1985). Public broadcasting has therefore been stronglydominant in Ireland, with free-to-air commercial televisionintroduced only in 1998, although Irish public broadcastinghas a high level of commercial funding, 66% in 1998. UnlikeCanada, Ireland has not protected its print industry. About20% of daily newspaper circulation today represents Britishtitles. The Censorship of Publications Act, which lasteduntil 1967, resulted from the political conflicts of thecivil war of the 1920s, and Ireland, like Britain, hasrestrictions on media related to the conflict in NorthernIreland.

Conclusion

The early consolidation of liberal institutions in Britainand its former colonies, together with a cluster of socialand political characteristics related to this history--earlyindustrialization, limited government, strong rational-legalauthority, moderate and individualized pluralism andmajoritarianism, are connected with a distinctive pattern ofmedia-system characteristics. These include the strongdevelopment of a commercial press and its dominance overother forms of press organization, early development ofcommercial broadcasting, relatively strongprofessionalisation of journalism, the development of a

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strong tradition of "fact-centred" reporting, and thestrength of the objectivity norm. Media have beeninstitutionally separate from political parties and otherorganized social groups, for the most part, since the latenineteenth century. And state intervention in the mediasector has been limited by comparison with the DemocraticCorporatist or Polarized Pluralist systems.

We have also seen that there are important differences amongthe four countries, enough that we should be careful aboutthrowing around the notion of an "Anglo-American" mediamodel too easily. The British and to a lesser extent theIrish and Canadian systems share important characteristicsin common with continental European systems--particularlythose of the Democratic Corporatist countries--both in theirpolitical institutions and cultures and in their mediasystems. This is manifested most obviously in the strengthof public broadcasting and in the persistence of party-pressparallelism in the British press. The latter also suggeststhat the common assumption that commercializationautomatically leads to the development of politicallyneutral media is incorrect.

There are, finally, many tensions or contradictions in theLiberal media systems: there is a tension between the factof private ownership and the expectation that the media willserve the public good and a closely related tension betweenthe ethics of journalistic professionalism and the pressuresof commercialism; there is also a tension between theliberal tradition of press freedom and the pressures ofgovernment control in societies where the "national securitystate" is strong.

References

Altick, R. (1957) The English Common Reader: A social History of theMass Reading Public, 1800-1900. Columbus: Ohio State UniversityPress.

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Bell, D. (1985) Proclaiming the Republic: BroadcastingPolicy and the Corporate State in Ireland, West European Politics8(2): 26-49

Chalaby, J. (1996) Journalism as an Anglo-AmericanInvention: A Comparison of the Development of French andAnglo-American Journalism, 1830-1920s, European Journal ofCommunication 11(3): 303-26

Donsbach, W. (1995) Lapdogs, Watchdogs and Junkyard Dogs,Media Studies Journal 9(4): 17-31

Henningham, J & A. Delano (1998) British Journalists, inD.H. Weaver, ed., The Global Journalist: News People Around the World,pp. 143-60. Cresskill, NJ: Hampton Press

Humphreys, P. (1996) Mass Media and Media Policy in Western Europe,Manchester: Manchester University Press

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The Mediterranean Media Model

By Stylianos Papathanassopoulos is a Professor at the Faculty of Communicationand Media Studies, National & Kapodistrian University of Athens

The media systems of Spain, Italy, France, Greece, Portugal,Turkey, Malta and Cyprus represent what Daniel Hallin andPaolo Mancini propose as the Mediterranean or PolarisedPluralistic model. This is because the media systems inSouthern Europe share a number of characteristics whichdistinguish them from the rest of the Central, Western andNorthern Europe. According to Hallin and Mancini (2004: 89)the mass media in the Southern European countries wereintimately involved in the political conflicts that mark thehistory of this region, and there is a strong tradition ofregarding them as means of ideological expression andpolitical mobilization. The location of France with theMediterranean model is recognized as problematic, accordingto several key dimensions (p. 90). At the same time, thedevelopment of commercial media markets was relatively weak,leaving the media often dependent on the state, politicalparties, the Church, or wealthy private patrons, andinhibiting professionalisation and the development of themedia as autonomous institutions.

Cultural and Political Heritage

Political, social and economic conditions, population andcultural traits, physical and geographical characteristicsusually influence the development of the media in specificcountries, and give their particular characteristics(Gallimore, 1983: 53-62; Hiebert, Ungurait and Bohn: 1982: 33-55). An additional factor, which may need to be consideredfor a better understanding of media structures, is that ofmedia consumption and the size of a market. Across Europethere are some significant differences between countrieswhen it comes to the penetration and consumption of thetraditional media, such as the press and television.Although some other factors may play a part, it seems that

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economic conditions, religion, political freedom and cultureare the conditions that mainly influence the development andthe structure of most media systems.

Industrialism and the market were developed rather late inmost Southern European countries, while cultural life wasdominated by religion and its institutions. As Hallin andMancini (2004:128) mote “the late, uneven and conflictualdevelopment of liberal institutions in Southern Europe isfundamental to understanding the development of the media inthis region”.

Moreover, the lack of market development in relation to thecounter-enlightenment tradition discouraged the developmentof literacy, which affected the development of masscirculation press. On the other hand, most countries havewitnessed a political instability and repression in theirhistory.

Another characteristic which these seven countries obviouslyhave in common is a late transition to democracy. Liberalinstitutions were only consolidated in Italy after World WarII, in Greece, Spain and Portugal from about 1975-1985,while Turkey have witnessed three military coups (1960,1971, 1980). This is of profound importance to under-standing the media systems in the region. The transition todemocracy is of course a complex process. It involves thetransformation of many political institutions--including themass media--and of the relationships among political, socialand economic institutions. These transformations are oftenslow and uneven, and for that reason knowledge of politicalhistory is crucial to understanding current institutions. Itis not a coincidence that the development of the media inthe region has been deeply affected by influenced by thepolitical patterns of polarized pluralism, and the havehistorically served and participated in this process ofbargaining. Even though the media operate in a marketframework they offer information, analysis and commentsproduced by a few elite groups, which address other

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political, cultural and economic elites in order to sendmessages and start up negotiations. This pattern has beenmost characteristic of Italy and Greece, but is seems toapply to the other Mediterranean countries too. Last but notleast, since the state due to the atrophied civil societyhas played a central role in most aspects of social andeconomic aspects of society, it has also affected thedevelopment of the printed and electronic media, eitherthough heavy subsidies (in the case of the press) or throughtight control and heavy interference (in the case of public/state electronic media).

The Main Characteristics

According to Hallin and Mancini (2004) and Hallin andPapathanassopoulos (2000) the media in Southern Europe sharesome major characteristics: low levels of newspapercirculation, a tradition of advocacy reporting,instrumentalization of privately-owned media, politicizationof public broadcasting and broadcast regulation, and limiteddevelopment of journalism as an autonomous profession.

Low Levels of Newspaper Circulation

The most obvious distinction between the media of the eightMediterranean countries and those of the rest of WesternEurope is their low level of newspaper circulation (and acorresponding importance of electronic media). Masscirculation newspapers did not develop in any of thecountries of Southern Europe. In effect, as Hallin andMancini (2004: 91) note “a true mass circulation press neverfully emerged in any of the Mediterranean countries”. On theother hand, the church has played a significant role indevelopment of the media, while tabloid or sensationalistpopular newspapers have never really development in theregion. The only true mass media of Southern Europe areelectronic media, and their importance for the formation ofmass public opinion is therefore particularly great. Arecent development is the advent of several free newspapers

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in Spain, Portugal, Italy and Greece posing a new problemfor the conventional newspapers.

Political Parallelism

As Hallin and Mancini point out “the media in the SouthernEuropean countries are relatively strongly politicized, andpolitical parallelism is relatively high. The style ofjournalism tends to give substantial emphasis to commentary.Newspapers tend to represent distinct political tendencies,and this is reflected in the differing political attitudesof their readerships; at times they play an activist role,mobilizing those readers to support political causes.Public broadcasting tends to be party-politicized. Bothjournalists and media owners often have political ties oralliances” (2004: 98).

In effect, most of the countries covered have traditions ofadvocacy journalism. In contrast with the Anglo-Americanmodel of professional neutrality, journalism in SouthernEurope tends to emphasize commentary from a distinctpolitical perspective. There is some variation in thischaracteristic. It is stronger in Greece and in Italy, forexample, where strong and highly polarized political partieshave existed for all or much of the post World War IIperiod, than in countries like Spain, Portugal, where longperiods of dictatorship suppressed the development ofpolitical parties.

Advocacy traditions have been modified both by diffusion ofthe Anglo-American model of journalism and by traditions ofpassive reporting that developed during periods ofdictatorship. But in general journalism in these countriestends to emphasize opinion and commentary and newspapers torepresent distinct political tendencies. Thischaracteristic, however, is not distinct to southern Europe,but is also characteristic of most of continental Europe,though over the last decade or so the movement away from

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advocacy journalism has probably been faster in northernthan southern Europe.

On the other hand, the paternalism of the state in mostMediterranean European countries has remained one of themost important features of the state electronic media.Public broadcasting systems in the Mediterranean countriespresent a symbiotic relationship with the politicalcontroversies of their countries. Both radio and televisionhave been regarded as “arms of the state” and in many casesthe debate about the electronic state media was focused ongovernmental control and interference in television TV,principally news, programs. This condition became part ofpost-war ritualised politics in France during the De Gaulleadministrations as well as in Greece, Portugal and Spainafter the restoration of their democracies. The case ofRAI’s lottizazzione by the Italian leading political parties isanother manifestation of the heavy use of the media by thepolitical parties. In Turkey TRT has heavily being used bythe military and the government of the day.

Instrumentalization of Media

There is a strong tendency in all countries for media to becontrolled by private interests with political alliances andambitions who seek to use their media properties forpolitical ends. In Italy, for example, the old mediacompanies such as Mondadori, Rizzoli and Rusconi are nowcontrolled by non media businesses, such as Berlusconi(soccer, insurance, commercial television) and Fiat(automobile). Carlo DeBenedetti of Olivetti controls LaRepubblica and L'Espresso; Agnelli familly of Fiat controls LaStampa and though RCS, with Benetton (apparel) and DeallaValle (shoes) the largest Italian daily Corriere della Sera; theCaltagirone Group (construction) daily Il Messaggero, while IlCiornale is owned by Paolo Berlusconi, bother of SilvioBerlusconi, and the Italian Manufacturers' Association(Confindustria) publishes the best-selling financialnewspaper, Il Sole 24 Ore. Private television, meanwhile, is

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dominated by Silvio Berlusconi, who is also a party leaderand former Prime Minister.

In Turkey, all the major media groups, Doğan, Merkez,Çukurova, İhlas, Doğuş, etc, are large conglomerates andtheir activities expand to other sectors of the economy(tourism, finance, car industry, construction and banking).And it seems that they use their media outlets to protecttheir interests in the other sectors of the economy, whilethere seems to be no efficient way to control theconcentration of the media ownership.

In Greece industrialists with interests in shipping, travel,construction, telecommunication and oil industries dominatemedia ownership, and a long tradition of using media as ameans of pressure on politicians continues. In Spain themedia are increasingly dominated, not by industrialists withtheir primary interests outside the media, but by two broadmultimedia conglomerates which, however, do have strongpolitical alliances. For many years the dominant companywas PRISA, whose interests include El País, SER radio and cableand satellite television, and whose owner was close toSocialist President Felipe González. A rival media empire isnow emerging around the former state telecommunicationsmonopoly, Telefónica de España, which was privatized underthe conservative Partido Popular government. Thisconglomerate includes the private television company, Antena3, the newspaper El Mundo, which made its name breaking thenews of a number of major scandals involving the PSOEgovernment, the radio network Onda Zero and a satellitetelevision platform. The two media empires have becomeintense rivals, as much in the political as in thecommercial world. The conservative newspaper ABC and theCatholic Church's radio network COPE were also aligned withTelefónica in this conflict. Major banks also have ties tothese conglomerates, and Spanish journalists and mediaanalysts often describe them as major power behind thescenes, though their role is very difficult to document.

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In Portugal the transition to democracy began with a two-year period of revolutionary upheaval during which the mediawere for the most part taken over by radicalized journalistswho conceived them as instruments of class struggle.Ownership of much of the media passed to the state when thebanks were nationalized, and by the early eighties,effective control had to a significant extent passed to thepolitical parties. In the late eighties state-owned mediawere privatized. One of the principal media conglomerates,Impresa, is owned by F. Pinto Balsamão, a former PrimeMinister and leader of the (conservative) Social DemocraticParty, though instrumentalization of the media in Portugalis perhaps less intense today than in the other countries ofSouthern Europe.

Politicization of Public Broadcasting and BroadcastRegulation

All public broadcasting systems are to some degree subjectto political and disputes over the independence of publicbroadcasting are general to the history of European media.Most countries in Western Europe, however, have succeeded indeveloping institutions which separate public broadcastingfrom the direct control of the political majority. Thecountries of Southern Europe, however, have not moved as farin this direction. Italy has moved the furthest. TheItalian public broadcasting company RAI was essentiallyunder the control of the ruling Christian Democratic partyin the 1950s and 60s, but in the seventies, when a broadercoalition was formed and the "historic compromise" allowedthe Partido Comunista to share in the lottizzazione--thedivision of political power and benefits--control of RAI wasdivided among the parties, with the Christian Democratsretaining control of one channel, the "secular parties" thesecond and the Communists the third. In recent years theboard of directors of RAI has been reduced in size, makingproportional representation impossible, a move which islikely to require a degree of depoliticisation ofappointments to the board. In Malta, the state, the

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political parties, the Church and the University own radioand TV stations. TRT in Turkey has been always under thetight state control and its audience fell dramatically afterthe advent of private channels.

Spain and Greece, meanwhile, are the two countries remainingin Western Europe in which the ruling party directlycontrols public broadcasting. In both countries themanagement of the news divisions of public televisionchanges with a change in government, and the news is atimportant moments mobilized to support the governmentpolitically. In Greece, news and editorial judgments areexpected to be in close agreement with, if not identical togovernment announcements across a whole range of policiesand decisions. It should be noted that Spain and Greece areessentially majoritarian systems, unlike Italy which is aconsensus system. A governing board appointed by parliamentaccording to proportional representation therefore resultsin government control in the former, while it results inpower-sharing in the latter. Portugal similarly has had apublic broadcasting system in which the government majorityhad effective control.

In most countries politicization of regulatory bodiescoexists with relatively weak regulation of privatebroadcasters in the sense that few public serviceobligations and few restrictions on commercialism areimposed, and many regulations are laxly enforced.

"Savage Deregulation"

Across Europe, broadcasting has been in ferment, asgovernments of every political persuasion try to cope withthe stress and upheavals caused by the deregulation.However, in Mediterranean countries, broadcasting andpolitics seem to form an inextricable relationship. Theimminent deregulation of broadcasting in most SouthernEuropean countries has been associated with politics andeventually led by a haphazard reaction of the politics of

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the time, rather than a coherent plan. In short, thederegulation of Southern European broadcasting systems hasled to an unregulated environment as market logic has inrecent years been allowed to develop essentially unchecked.The dominance of private television as well as thedowngrading of public broadcasters has increasing forcedpoliticians to have good relations with the media owners. InItaly commercial television monopolies were allowed todevelop without government intervention. In Greece,meanwhile, license applications are not adjudicated andlarge numbers of radio and TV stations continue for years inlegal limbo. In Spain, as in Greece and Portugal, it couldbe said that public service broadcasting in the full senseof the word never really existed. As Hallin and Mancini(2004: 126) note “It is probably significant that democracywas restored in Spain, Portugal and Greece at a time whenthe welfare state was on the defensive in Europe, and globalforces of neoliberalism were strong; these countries missedthe historical period when social democracy was at itsstrongest”.

Limited Professionalisation

The instrumentalization of the news media by oligarchs,industrialists, parties or the state implies thatjournalistic autonomy will be limited. Journalists will attimes have to defer to their political masters. As Hallinand Mancini (2004: 110) note “journalism originated in theSouthern European countries as an extension of the worlds ofliterature and politics”. However, as they argue “thishistory of journalistic professionalisation is closelyparallel to what occurred in the Liberal and DemocraticCorporatist countries” (p. 111). The process did notdevelop as strongly in the Mediterranean countries, however,as in the north. The political and literary roots ofjournalism were deeper, and the political connectionspersisted much longer. Limited development of mediamarkets meant that newspapers were smaller, and less likely

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to be self-sustaining. And state intervention, particularlyin periods of dictatorship, interrupted the development ofjournalism as a profession. The level ofprofessionalisation thus remains lower in the Mediterraneancountries, though it increased in important ways in the lastcouple of decades of the twentieth century”.

This, however, does not mean that the level ofprofessionalisation is lower. For example, journalists inthe Mediterranean countries are not less educated thanelsewhere –in Italy and Greece, for example, famous writersand intellectuals have often been journalists. On the otherhand, the close connection of journalism with the politicaland literary worlds and the orientation of newspapers toeducated elites have meant that journalism has in some sensebeen a more elite occupation in Southern Europe than inother regions. Limited professionalisation is alsomanifested in a limited development of institutions ofjournalistic self-regulation, like the press councils whichexist in much of northern Europe (Hallin and Mancini, 2004:112).

The Media and the State

The interplay between the state and the media has largelyarisen from the tensions in most Southern Europeansocieties. These tensions, combined with the absence of astrong civil society, have made the state an autonomous anddominant factor. The over-extended character of the statehas coincided, as noted above, with the underdevelopment ofcapitalism. This makes the Southern European systems lessself-regulatory than developed capitalist systems such as inLiberal model. The lack of self-regulation is alsonoticeable at the level of politico-ideologicalsuperstructure, because with a weak civil society, even theeconomically dominant classes do not manage to form well-organized and cohesive pressure groups. As Hallin andMancini (2004//) note: “the state's grasp often exceeds itsreach: the capacity of the state to intervene effectively is

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often limited by lack of resources, lack of politicalconsensus, and clientelist relationships which diminish thecapacity of the state for unified action”.

In the case of the media, the state’s intervention can beseen in various aspects (Hallin and Mancini, 2004: 119-121).First, the state has played the role of censor. The directauthoritarian control of the years of dictatorship ispresumably a thing of the past, but some remnants havecarried over into the democratic period. Second, the statehas also played an important role as an owner of mediaenterprises. The electronic media have traditionally beenunder the total and tight control of the state, but apartfrom the state-owned electronic media, the state has alsohad significant ownership in commercial media in theMediterranean countries, including in the print press (forexample, the Franco regime in Spain often had state-ownednewspapers) and of course in news agencies (Agence FrancePresse, the Italian Agency AGI, EFE in Spain, ANA in Greece,Anadolu Ajansi in Turkey, Agência Lusa in Portugal).Publicly-funded news agencies function both to maintain thepresence of the national press on the world scene and as asubsidy to domestic news media which use the service.Thirdly, in a more indirect but more effective way, thestate acts to support its policies on ownership as well asto enforce the unwritten rules of power politics by using awide range of means of intervention which are at itsdisposal. These means include sizable financial aid to thepress, on which individual enterprises become dependentbecause they cannot cover their production costs. Forexample, as Hallin and Mancini (2004: 121) note extensiveindirect subsidies have been provided to the press as awhole in the form of tax breaks, reduced utility rates andthe like. For example, in France direct subsidies in 2005amounted to 249,2 millions euro, while the non directsubsidies were far higher.

By and large, state subsidies to the media, especially thepress take the form of "soft" loans, subsidies both overt

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and covert, and state jobs and other subsidies offered tomany journalists. Finally, the central role of the state inMediterranean media systems has no doubt limited thetendency of the media to play the "watchdog" role so widelyvalued in the prevailing liberal media theory. Thefinancial dependence of media on the state and thepersistence of restrictive rules on privacy and thepublication of official information have combined with theintertwining of media and political elites and--especiallyin the French case--with a highly centralized state notprone to the kind of "leaks" of information thatcharacterize the American system, to produce a journalisticculture which has historically been cautious about reportinginformation which would be embarrassing to state officials. Clientelism and Rational/Legal Authority

Clientelism refers to a pattern of social organization inwhich access to social resources is controlled by patronsand delivered to clients in exchange for deference andvarious kinds of support. It is a particularistic andasymmetrical form of social organization, and is typicallycontrasted with forms of citizenship in which access toresources is based on universalistic criteria and formalequality before the law. Clientelistic relationships havebeen central to the social and political organization inmost Southern European countries (Hallin &Papathanassopoulos 2000).The greater prevalence ofclientelism in Southern than Northern Europe is intimatelyconnected with the late development of democracy. Bothare rooted historically in the fact that autocratic,patrimonial institutions were strongest in the South. Theemergence of clientelism represented not simply apersistence of traditional hierarchical social structures,but a response to their breakdown, in a social context inwhich individuals were isolated, without independentaccess to the political and economic centre, e.g. throughmarkets, representative political institutions or auniversalistic legal system, and in which "social capital"

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was lacking (see also: Eisenstadt and Roniger, 1984;Gellner and Waterbury, 1977; Kourvetaris and Dobratz,1999; Mouzelis, 1980; Roniger and Günes-Ayata, 1994;Putnam,1993; Katzenstein, 1985) . Clientelism affects thedevelopment of the news media in many ways.

First, it encourages the instrumentalization of the newsmedia. The politicization of business is a result not onlyof the important role the state plays in the economy, but ofthe nature of the political process. In northern Europeclientelist relationships have been displaced to a largeextent by rational-legal forms of authority and, especiallyin the smaller continental European countries, by democraticcorporatist politics, both of which decrease the need foreconomic elites to exert particularistic pressures and formpartisan alliances. In countries with a history ofclientelism rational-legal authority is less stronglydeveloped. The judiciary and administrative apparatus aremore party-politicized and there is often a tradition ofevasion of the law. The persistence of a culture in whichevasion of the law is relatively common means thatopportunities for particularistic pressures also are common:governments can exercise pressure by enforcing the lawselectively, and news media can do so by threateningselectively to expose wrongdoing. Legal proceedings againstmedia owners are fairly common in many Southern Europeancountries.

Second, it makes the media systems less self-regulatory andthe regulatory bodies less independent compared to theircounterparts in liberal countries like the U.S. and Britainand in democratic corporatist countries. In Southern Europe,the regulatory institutions tend to be more party-politicized, and weaker in their ability to enforceregulations.

Third, clientelism has also affected the content of themedia, especially newspapers, as means of negotiation amongconflicting elites rather than means for the information of

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the public and therefore mass circulation. It forces thelogic of journalism to merge with other social logics--ofparty politics and family privilege, for instance. And itbreaks down the horizontal solidarity of journalists as itdoes of other social groups. Thus, the journalistic cultureof the Northern, corporatist countries which is manifestedboth in relatively strong journalistic autonomy and inhighly developed systems of ethical self-regulation isabsent in countries with a stronger history of clientelismbecause of the overriding importance of political interests.A sense of a public interest transcending particularinterests has been more difficult to achieve in societieswhere political clientelism is historically strong, and thiscontributes to the difficulty of developing a culture ofjournalistic professionalism.

Development Trends

In the eight countries covered in this section, significantsocial forces have undermined the development of the mediasimilar to North America or Western Europe. Although thedevelopments in the media sector may not entirely respond tothe needs of their industry, yet, their media systems havebeen surprisingly adaptable and flexible in the face of newdevelopments. To understand this, one must remember thatmost of the media systems of Southern Europe have workedunder Western democratic rule for only 30 years now, andthis has had suddenly to face all the upheavals that otherWestern media systems have taken years to deal with.

The commercialization of their media systems may have led toa de-politicization of their content, the politicalaffiliation of the media, especially newspapers, is alwaysmanifest in periods of intense political contention. This isalso due to the fact, that political parties still play animportant role in most Southern European countries. It istherefore, as Hallin and Mancini (2004: 140) note: “notsurprising either that parties would have considerable

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influence on the media, nor that the media should focus to asignificant degree on their activities”.

However, the logic of media markets may under certaincircumstances undermine these relationships. It can makemedia organizations less dependent on political subsidies,substitute marketing for political criteria in the making ofnews decisions, and discourage identification withparticular political positions. It may also make mediaenterprises too expensive for most politicians to afford, oreven for most industrialists to buy purely for politicalmotives.

Finally "globalization" may under certain circumstancesundermine the close relationship between media and thepolitical world. One particularly obvious instance is theeffect of the common legal framework of the European Union.The “Europeanisation” of the EU countries could be seen asan incremental process that re-orientates the direction andshape of politics to the degree that EU political andeconomic dynamics become part of the organizational logic ofdomestic politics and policymaking (Harcourt, 2002;Radaelli, 1997). The EU “Europeanization” process willcertainly affect their media systems as well. At present,however, we believe that in order to understand thecomplexities and particularities of media systems inSouthern Europe, the concept of Hallin and Mancini’s modelremains crucial.

Bibliography

Eisenstadt, S.N. and Roniger, L. (1984) Patrons, Clients andFriends: Interpersonal Relations and the Structure of Trust in Society.Cambridge: Cambridge University Press.

Gallimore, T. (1983) “Barriers to Media Development. In Merril,J.C. (ed) Global Journalism, White Plains, New York: LongmanPublishers, 1983.

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Gellner, E. and Waterbury, J. (1977) (eds.) Patrons andClients in Mediterranean Societies, London: Gerald Duckworthand Co.

Hallin, C.D and Mancini, P. (2004) Comparing Media Systems; Three Modelsof Media and Politics. Cambridge: Cambridge University Press.

Hallin, D. and Papathanassopoulos, S. (2000) “PoliticalClientelism and the Media: Southern Europe and Latin Americain Comparative Perspective”, Media, Culture & Society, Vol 24. No.2: 175-195

Harcourt. A. (2002) “Engineering Europeanization: the roleof the European institutions in shaping national mediaregulation”, Journal of European Public Policy Vol 9, No. 5:736–755

Hiebert, R. E., Ungurait, D.F. and Bohn, T.W. (1982) Mass MediaIII, London: Longman.

Katzenstein, P.J. (1985) Small States in World Markets: IndustrialPolicy in Europe. Ithaca, NY: Cornell University Press.

Kourvetaris, G. and Dobratz, B. A. (1999) «PoliticalClientelism in Athens, Greece: A Three ParadigmApproach», pp. 237-262. In G. Kourvetaris (ed.) Studieson Modern Greek Society and Politics. Boulder, CO: EastEuropean Monographs.

Mouzelis, N. (1980) «Capitalism and the Development of theGreek State”. In R. Scase, Ed. The State in Western Europe.London: Croom Helm.

Putnam, R.D. (1993) Making Democracy Work: Civic Traditions inModern Italy. Princeton: Princeton University Press.

Radaelli, C. (1997) ‘How does Europeanization producedomestic policy change?’, Comparative Political Studies, Vol.30, No. 5: 553–75.

Roniger, Luis and Günes-Ayata, A, (1994) (Eds.) Democracy,Clientelism and Civil Society. Boulder, CO: Lynne Rienner.

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Media Systems in Post-Communist European Countries

By Karol Jakubowicz, until recently Director, Strategic Planning and AnalysisDepartment, National Broadcasting Council of Poland, the broadcastingregulatory authority. His academic pursuits have included a teaching post at theUniversity of Warsaw and Visiting Professorships at the University of Dortmundand the University of Amsterdam.

Introduction

The collapse of the Communist system led to a debate amongmedia policy-makers and scholars as to the direction andexpected final outcome of that process. Some assumedstraight transplantation of generalized “Western” models.Others argued that media change was an open-ended processand that the “idealized Western European model” had eithervanished or become inaccessible (Sukosd and Bajomi-Lazar,2003; Mungiu-Pippidi; 2003).

Had Hallin and Mancini’s (2004) book come out earlier, itwould have been clearer that though the process may be open-ended, the range of options is not limitless. Hallin andMancini confirm that media systems are shaped by the socio-political and cultural features of their countries,including notably the degree of democratic consolidation andthe level of actual or potential societal conflict. In otherwords, they display a high degree of what we may call“systemic parallelism”. We will take this as our point ofdeparture in the following analysis. The goal is to seewhether Central and Eastern European media systems can becompared to any of Hallin and Mancini’s systems.

The term “post-Communist countries” covers nations in thefollowing regions: Central Europe (Poland, the CzechRepublic, Slovakia, Hungary, Slovenia and the Baltic States– Estonia, Lithuania and Latvia); Eastern Balkans (Romania,Bulgaria); Western Balkans (Croatia, Bosnia-Herzegovina,Serbia, Montenegro, Macedonia and Albania); European CIS

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countries: Russia, Ukraine, Belarus, Moldova); SouthCaucasus countries: (Armenia, Azerbaijan, Georgia); CentralAsia (Kazakhstan, Kyrgyzstan, Tajikistan, Turkmenistan andUzbekistan) and Mongolia. They differ widely in manyrespects (history, culture, religion, level of development)and practically the only thing many of them have in commonis the legacy of the Communist system.

Some of these countries have few prospects of progresstowards a democratic system (see Carothers, 2002; Krastev,2006). However, there are also examples of relativelyencouraging post-Communist democratization, though what hasbeen achieved so far are hybrid forms of democracy,including formal democracy; elite democracy; partitocrazia;or a system of a tyrannical majority (Cichosz, 2006). Inthese cases, parallels with systems identified by Hallin andMancini may perhaps be sought, given that they identifyprecisely political system development as the main factoraffecting the shape of the media system, includingespecially the fact of early or late democratization (and bythe same token the degree of consolidation of democracyachieved in a particular country).

Sitter (2005) discusses two approaches to comparativeanalysis of political systems in Western and Eastern Europe:

Looking at similarities with earlier developments inWestern Europe. Perhaps the most obvious comparison,says Sitter, is to the Mediterranean transitions todemocracy in the 1970s, or even post-war democratisationin Germany and Italy;

“East European exceptionalism”.

We would agree with Sitter that developments in the regionsince 1989 have been less “exceptional” than is sometimesargued. Also with Dryzek and Holmes (2002: 256) who statethat “differences between at least the more democratized CEEstates and the West look to be of degree rather than kind”(see also Sukosd and Bajomi-Lazar, 2003).

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Sitter’s suggestion that comparison of the situation inpost-Communist countries with the Mediterranean ones ispotentially most fruitful seems to be supported bySplichal’s (1994, 2004) use of the phrase “Italianization ofthe media” to describe the process of media change in post-Communist countries.

Like the countries with the “Mediterranean” media system,post-Communist countries: late democratization arecharacterized by incomplete, or (in some cases) littleadvanced modernization and weak rational-legal authoritycombined in many cases with a dirigiste State (for analysesof the situation in Mediterranean countries, also in termsof their media systems, see e.g. Statham, 1996; Marletti andRoncaloro; 2000; Papatheodorou, Machin, 2003; Mancini, 2000;Hallin, Papathanassopoulos, 2002). Like their SouthernEuropean counterparts, they also display features of “Statepaternalism” or indeed “political clientelism”, as well aspanpoliticismo, i.e. a situation when politics pervades andinfluences many social systems, economics, the judicialsystem, and indeed the media; the development of liberalinstitutions is delayed; and there is a political culturefavouring a strong role of the State and control of themedia by political elites.

Another shared feature is highly tumultuous political life.Discontinuous social change (rapid change, broad in scale)generally has pathological consequences, generatingespecially intense conflicts (Eckstein, 2001). This cannotbut affect the media system.

Theorists of post-Communist transformation often call it an“imitative” or “mimetic” process. It can be seen to containtwo forms of imitation:

Deliberate copying of Western European arrangements, Natural repetition or replication of the same processes

in comparable circumstances, when more or less the same

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factors and forces impact on the situation as in othercountries.

Where post-Communist countries sought to approximate Westernarrangements, many policy or legislative measures in themedia field represented the first form of imitation. Later,as the new political systems and market forces began toaffect media systems, imitation increasingly began to takethe second form.

The Newspaper Industry

Change in the print media after 1989 involved three mainprocess: the increase in the number of titles, growth in thenumber of companies and the emergence of new market segments(Gulyás, 1999). In most post-Communist countries,demonopolization of the media was followed by a veritableflood of new print media, many of them published by newpolitical parties. Demand for party newspapers proved to benon-existent, however, and soon this category began todisappear.

With time, consolidation of the market, much of it foreign-controlled in many post-Communist countries, went hand inhand with its segmentation, especially the appearance ofsegments which had previously been underdeveloped ornonexistent, such as tabloid newspapers, hobby magazines,women’s and fashion magazines, and so on. At the same time,democratization of the market also meant that local andcommunity newspapers, NGO publications and minoritynewspapers made their appearance.

Chorazki (1999) has identified the following sequence ofevents with reference to local and sub-local dailies andperiodicals in Poland:

1988-1991 - a heroic period of civic and public serviceinvolved in spearheading the process of change;

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1992-1993 - a period of party political involvement, asthe media scene is politicized and new political partieswin control of many media;

From 1994 onward - a period of market-driven changes andconsolidation (with two main trends observable since 1997:on the one hand, the influx of foreign capital into thelocal and sub-local media market, and on the other - theconsolidation of strong Polish publishers of regionalchains of dailies and periodicals of this nature).

Similar processes have taken place in the newspaperindustries in all the countries under consideration in thisvolume. Tabloidisation, falling circulations and thesurvival of only limited numbers of quality newspaper nowappear to be the norm in all of them.

Political Parallelism

Immature democracies produce either “politics-over-broadcasting” or “politics-in-broadcasting” systems. This isvery much the case in post-Communist countries. Politicalparallelism is high in their media systems, especially inpublic service broadcasting. This is reflected first of allin the manner of appointing members of broadcastingregulatory authorities. Two methods are most prevalent:

Appointment by legislative: “the Central Europeanmodel” (Slovenia, Slovakia, Bulgaria, Czech Republic,Estonia);

Appointment by both executive and legislative: “theFrench model,” adopted in Poland, Romania, Bulgaria andthe Ukraine.

In both cases, care is usually taken to ensure directreflection of the balance of political forces in Parliamentin the composition of the regulatory body.

Another area where political parallelism is evident is thecomposition of governing bodies of public service

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broadcasters. Irrespective of the method of theirappointment, these bodies are usually an extension of theruling party or coalition of the day. True, in Poland therehave been examples of “cohabitation” between governments andleaderships of public service television of differentpolitical persuasions, but the change of the broadcastinglaw in 2005 – eliminating staggered terms for members of theNational Broadcasting Council (the regulatory body) – willseriously reduce the likelihood of this happening again. Itis the Council which appoints the Supervisory Councils ofthe 19 public service broadcasters that in their turnappoint Boards of Management. In 2006, this ensured directpolitical parallelism between the composition of Parliament,the National Broadcasting Council and supervisory andgoverning bodies of public service broadcasters, setting intrain changes in managerial positions according to the sameprinciple.

Croatia and Slovenia provide other examples of regressioninto political parallelism from legal and institutionalsolutions which were originally designed to counteract it.In Croatia, the 2001 law on Croatian Radio-Television, thepublic service broadcasting (which provided for itsBroadcasting Council to be made up mostly of peopledesignated directly by civil society organizations) wasreplaced with a new law in 2003 in which the BroadcastingCouncil is appointed directly by Parliament. In 2004,Croatian public television HRT selected new televisionleadership from among politically unaffiliatedprofessionals. This is good news, but the possibility ofreversion to political appointments always remains. TheSlovenian broadcasting law was amended in 2005, so that theProgramme Council of Radio-Television Slovenia would beappointed by Parliament and would have the power to appointall top and middle-level managers, down to the heads ofeditorial departments.

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Surprisingly, Estonia – where the authorities have refrainedfrom interfering with the media – is reported here to beproceeding with a similar change of the broadcasting law.

In Hungary, the Presidential Bodies of the Boards ofTrustees of public service broadcasters are to have an equalnumber of members from both the ruling coalition and theopposition, so as to prevent any political party fromexercising control. However, opposition parties have oftendeclined to fill “their” seats, leaving public service radioand television in the hands of the ruling majority – as itis the Boards of Trustees which appoint the DirectorsGeneral of the two broadcasters.

As reported in this volume, political partisanship extendsalso to commercial media, both broadcast and print, bothcaused by profound divisions and high political tensionwithin Hungarian society and tending to exacerbate thosedivisions.

Another example of this situation is Poland, where highlydivisive policies of the post-2005 government haveencouraged many media outlets to take a stand either for oragainst them and to join the political fray as playersrather than observers.

Media partisanship also seems to prevail in Latvia.

The State and the Media

Leaving aside the autocratic post-Communist regimes, theState’s presence in the media has usually taken the form of:

1. Gaining indirect control of the media through proxies(e.g. oligarchs known to be friendly to the government,as in Russia or Ukraine);

2. Privatization strategies designed to prevent mediaoutlets falling into foreign hands;

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3. Attempts to promote the emergence of politicallyfriendly media, sometimes with the use of Statecompanies or funds;

4. Attempts to delay transformation of State broadcastersinto public service ones, and later heavy involvementin the appointment of their governing and managerialbodies;

5. Operation of subsidies for the media.

Estonia is one of very few countries where stateinterference into the media is reportedly not a real issue.

In Slovenia, a strategy of press privatization was designedto prevent the Hungarian experience of an almost immediatetake-over of the press by foreign publishers. As a result,the incumbent newspapers and magazines evolved, with a fewexceptions, into (limited) stock companies owned by (a)their many current and former employees (typically holdingmore than 50% of the stock); (b) two state-controlled funds,holding each 10% (the Retribution Fund and the PensionFund); and (c) various investment companies that managed thecitizens' “ownership certificates.” Very seldom did themedia companies capitalize by selling their stock on themarket.

As reported in the present volume, this can have directpolitical effects as when after the change of the governmentafter the parliamentary elections in November 2004, theeditors-in-chief and managers at three daily newspapers(Delo, Primorske novice and Večer) were replaced with peoplechosen by the new government.

In Slovenia, but also in Hungary and Poland, (mostly right-wing) governments have tried, using public funds or throughthe intermediary of state enterprises, to promote theestablishment of "politically friendly" media outlets,whether newspapers, or – as in Poland in the late 1990s – atelevision station into which state companies wereencouraged to invest. In Hungary, this was officially

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sanctioned as an effort to create a “Media Equilibrium” as away of countering what the Fidesz government of the late1990s perceived as “hegemony of the leftist-liberal press”.The Fidesz government also introduced the concept of “loyaljournalism”. The job of the loyal journalist was describedas reporting events from the government’s perspective,protecting its position and promoting the government’sinterests.

As reported in the present volume, the Croatian governmentcontrols approximately 40 percent of radio stations. Inparticular through local politicians, it influences boththeir editors and the editorial policies.

It is also common practice for governments and the powerelite in general to support friendly media by discriminatingin their favour in placing (sometimes quite unnecessary)advertisements in them, while denying this source of incometo opposition or independent media.

Assistance and support schemes are in operation in variouscountries to promote greater diversity of content bysubsidising cultural, youth, children, minority andscientific media outlets. They are sometimes used to assistmedia friendly to the government of the day. The Broadcast Industry

Two main trends have been the demonopolization ofbroadcasting and licensing of private (mostly commercial)stations, and the transformation of state into publicservice broadcasting. One exception is Bulgaria where, asreported in the present volume, licensing of new commercialbroadcasters has been suspended for years. Of late,introduction of digital technologies has spurred thedevelopment of new platforms and new television servicesusing them.

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The imitative orientation of media policy, combined withconsiderable pressure exerted on particular governments bythe European Union, the Council of Europe and otherinternational organizations, has led to widespreadintroduction of what is described as PSB in the region. Asalready noted, however, where modernization andconsolidation of democracy are incomplete, only hybridpolitical systems can emerge. As a consequence, also PSBstations in the more advanced post-Communist democracies arein reality hybrid constructs, combining disparate (publicservice; political elite mouthpiece; political battlefield;commercial) elements within one organization. That is not afeature of post-Communist countries alone: many PSBorganizations in older democracies are also hybridconstructs, combining these and/or other elements in variousdegrees.

In general, public-service broadcasting is so far generallyseen as failing to deliver on its promise of independenceand political impartiality, as well as of serving as amainstay of the public sphere, and of delivering diverse andpluralistic content of high quality. Many of the stationsare heavily in debt and their audience share is falling,especially in countries where national commercial radio andtelevision stations have been licensed. Many are facingenormous managerial, financial and programming challenges.These outward manifestations of crisis are accompanied byproblems of a far more fundamental nature: lack of socialembededness of the idea of public service broadcasting andlack of a social constituency willing and able to supportpublic service broadcasters and buttress its autonomy andindependence.

As noted above, political parallelism is rife in PSB systemsin post-Communist countries.

In some countries (Bulgaria, Croatia, Poland) public servicetelevision still has the largest following. Elsewhere (Czech

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Republic, Estonia, Latvia, Romania etc.) is has fallenbehind commercial competitors.

Public service radio has almost universally lost the ratingsbattle to national commercial stations.

The more advanced countries are seeing the development ofmany thematic and niche satellite channels, extending therange of content. With digital technologies spreading,digital satellite platforms abound everywhere, and the mostadvanced countries are witness to the emergence of IPTV andother services (Czech Republic, Estonia, Hungary, Lithuania,Slovakia, Slovenia) (see Screen Digest Ltd, CMS HascheSigle, Goldmedia Gmbh, Rightscom Ltd., 2006)

Plans to introduce digital terrestrial broadcasting arebeing developed everywhere, but the process is largely indisarray and is often approached from a telecommunications,rather than a broadcasting perspective.

Professionalisation

There are different ways of classifying media andjournalistic roles. One speaks of three types ofjournalists: watchdogs, lapdogs and hunting dogs (the lastcase applying mainly to tabloid journalism, see Lauk, Harro,2003). Another view names three models of media: market,trustee, or advocacy (Schudson, 2003, cited in McQuail,2006). McQuail (2006) lists the following roles ofjournalism:

Monitorial: finding, processing and publishing objectiveand reliable news accounts; setting an agenda;

Facilitative: aiding democratic activity in the widerpublic sphere of civil society;

Collaborative: the wider needs of a society takeprecedence over profit or journalistic purpose and requirecooperation of the media with other external agencies,sometime even the government;

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Radical or critical: an adversarial stance in relation toauthority, on clearly motivated normative grounds. Oftenthere is a fundamental challenge to the society and itseconomic and power structure.

Professionalization of broadcasters and journalists ingeneral has been seen as an important element of the processof media change. Journalists, it was assumed, must ridthemselves of the role of propaganda tools and adopt adifferent professional identity, generally summed up underthe concept of the watchdog of the powerful. The trusteemodel, as well as monitorial and facilitative roles wouldprobably best describe what was expected of journalists inthe new situation.

At the same time, as we have seen, the authorities in manycountries expected them to adopt a collaborative role.

In reality, journalists often originally appeared either aslapdogs of the powerful, or have applied the advocacy model.By throwing themselves with relish into what had previouslybeen strictly forbidden, i.e. often merciless criticism(whether justified or not) of their new governments andpolitical elites, they turned the establishment againstthemselves, with disastrous consequences for government-media relations.

This not to say there has not been a great deal of finejournalism in post-Communist countries and that themonitorial function has been neglected. However, journalistshave found it very difficult to aspire to the classicalideal of impartiality and aloof professionalism.

There are deep-seated reasons why the watchdog role wasoriginally often rejected. Hungarian writer Janos Horvathpoints out that the traditions of Central and EasternEuropean journalism have led media practitioners to seekleadership and perhaps also hegemony roles:

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Common in Europe is the concept of the active orparticipant journalist, the journalist who sees himselfas someone who wants to influence politics andaudiences according to his political beliefs. Thissense is even stronger in Eastern Europe, wherejournalists are closer to artists and writers, and manypoets and writers contribute regularly to dailypublications. Together with the journalists, they feela sort of messianic vocation. They want to become amouthpiece for the people (Janos Horvat, “The EastEuropean Journalist,” cited in Gross, 1996, p. 111)

By subordinating their work to promoting social andpolitical change, journalists must necessarily opt for apartisan, advocacy-oriented and campaigning style ofwriting, bordering at times on propaganda. In addition toany paternalism inherent in the traditional Central andEastern European role of the intelligentsia, this issometimes sincerely meant as a sense of responsibility forone’s country and a way of executing what journalists feltwas their “civic responsibility” (Żakowski, 1996).

Another set of reasons for inadequate journalisticperformance has had to do with the fact that mediapractitioners - who still have vivid and painful memories ofcensorship and what used to be called “manual steering” ofthe media by the authorities, and who are today underconsiderable pressure from politicians and publicauthorities - usually reject any talk of responsibility outof hand. “Professionalism” took on the form of a defensiveoccupational ideology based on rejection of anybody's claimto influence the performance of journalists.Two processes have affected this initial state of affairs.One is the growing foreign control of many media outlets andthe other is the related process of their tabloidisation.Many (though not all) foreign owners tend to steer away fromdirect involvement of their media outlets in politicalconfrontations, imposing on them some degree of impartiality(one exception is Axel Springer which established

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“Dziennik”, a quality daily in Poland, which promptly becamea mouthpiece of centre-right forces). Tabloidisation (a verypowerful trend, as evidenced by many reports from Centraland Eastern Europe in this volume) produces sensationalism,a concentration on exposing the real or imagined crimes ortransgressions of the mighty. In fact, as Lauk and Harro(2003: 157) point out in relation to Estonia: “at the end ofthe 1990s, when capital has become the main forceinfluencing the media, a tendency to hunt down scandals andpublic figures in order to gain more attention for apublication or channels tends to fend off seriousinvestigative journalism”.

Systems of professional journalistic accountability exist inmany Central and Eastern European countries, including codesof conduct, or ethical codes, journalistic courts, etc.Nevertheless, the fact that journalistic unions are weak anddivided, as well as the general disintegration of valuesystems due to fast social change and the incompleteinstitutionalization of new socio-political regimes withtheir corresponding cultural and axiological systems meansthat these efforts are less effective than they should be.

Development Trends

Hallin and Mancini (2004: 305) believe that “The DemocraticCorporatist model, we suspect, will have particularly strongrelevance for the analysis of those parts of Eastern andCentral Europe that share much of the same historicaldevelopment, like Poland, Hungary, the Czech Republic, andthe Baltic States”. At the same time, they suspect thatscholars working in Eastern Europe will find much that isrelevant in their analysis of Southern Europe, including therole of clientelism, the strong role of the state, the roleof the media as an instrument of political struggle, withlimited development of the mass circulation press, and therelative weakness of common professional norms.

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How to reconcile these statements? Probably they should betaken to mean that had the countries listed by Hallin andMancini been able to develop and consolidate theirdemocracies, they would now have a Democratic Corporatistmedia system, instead of the “Mediterranean” one. Shouldthis be taken as prediction that with time and withsuccessful consolidation of democracy, they will move inthat direction?

It is this potential dynamic aspect of the media systemtypology developed by Hallin and Mancini (which otherwiseappears quite static) that interests scholars from EasternEurope most, as they try to discern what is ahead for theirmedia systems. These systems are affected by all the sameprocesses of change as their Western European counterparts,including strong neo-liberal tendencies. Given all thepolitical and cultural baggage, any thought of leapfrogginginto the Liberal system should be seen as pure fantasy.“Advancement” into the Democratic Corporatist model is moreof a realistic proposition, but can hardly be expected anytime soon.

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CONCLUSIONS: CONVERGING MEDIA GOVERNANCE ARRANGEMENTS IN EUROPE

By Johannes Bardoel who is a Professor of Media Policy, working with theDepartments of Communication at the University of Amsterdam and theRadboud University Nijmegen, the Netherlands. At present he also is thechairman of the Media Commission of the Council for Culture, the officialadvisory body for the Minister of Education, Culture and Sciences.

In this final chapter I will attempt to give, first, anevaluation of the current media governance arrangements thatexist all over Europe and subsequently I will try to drawsome conclusions to see to what extent there is aconvergence of media governance arrangements across Europe.Governance according to EU consists of the “rules, processesand behaviour that affect the way in which powers areexercised, particularly as regards openness, participation,accountability, effectiveness and coherence” (EuropeanCommission, 2001 ). The also fairly new concept of ‘mediagovernance’ seems an appropriate term to cover – even‘avant-la-lettre’ – the pluricentric power relations andvarious regulatory regimes that altogether shape the mediaperformance. This situation does not result from recentinsights on the subject matter but is, first and foremost, aproduct of a long and strong tradition of freedom ofexpression in most European countries. This tradition hasprevented most governments to really intervene in the presssector ever since the abolition of the press stamp. Incommunication sectors where governments did not have thechoice not to intervene, such as broadcasting andtelecommunication, authorities were usually eager to keep adistance, and not to interfere directly with contentmatters. These different policy practices have resulted inmedia governance arrangements that grew incrementally,varying considerably from medium to medium (cf. press versusbroadcasting policies) and lacking a clear common legitimacyor logic. Even the notion that the media have a strong senseof social responsibility is not uncontested in the media

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sector. Social responsibility is interpreted in terms ofboth ‘responsibility’, indicating the media’s responsibilitywith regards to society, and ‘responsiveness’, indicatingthe manner in which the media listen to and consider thepublic. McQuail (2000) defines media responsibility as the‘obligations and expectations’ that society has regardingthe media. He distinguishes between four types ofresponsibility: assigned, contracted, self-assigned, anddenied responsibilities. According to Hodges (1986)‘responsibility’ has to do with defining proper conduct, and‘accountability’ with compelling it. To put it differently:responsibility is the theory, and accountability itspractice. In the last decade, we note a clear shift amongcommunication specialists from more general and abstractthinking about media responsibility to more practical andconcrete interpretations of these concepts (fromresponsibility to accountability), in which the emphasis isshifting from a negative approach (liability) to a positiveone (answerability). In line with McQuail (2000) and Lange &Woldt (1995), I (Bardoel, 2001, 2003) distinguish fouraccountability mechanisms for the media: 1) political; 2)market; 3) professional and 4) public. To varying degreesall these mechanisms have been used to organize therelationship between the media and society and all havetheir (dis)advantages in realizing social responsibility inthe media (Bardoel, 2003). That may be the reason why inmedia governance regimes in most countries these mechanismsare combined.

I. Current media governance arrangements in Europe

Market accountability Inarguably, the market is the oldest vehicle for ensuringthe social accountability of the media. Although nowadaysnot everyone immediately associates the market with securingfreedom and responsibility, in past centuries it has shownitself to be a reliable tool for evading the grasp of theestablished powers of church and state. Today as well,market activity is usually an effective mechanism for

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organising the free exchange of goods and services,including those of a symbolic nature. As McQuail (2000, 185)argues, the market is extremely flexible, which allows it toserve people quickly and without prejudice. Thus in manyrespects, the media market encourages openness and equalityand is usually not coercive. In the United States, thetheory and practice of media policy – for both the press andbroadcasting – are largely based on the concept of the ‘freemarketplace of ideas’ (Napoli, 1999). Also in the othercountries that belong to the North Atlantic or Liberal model(Hallin & Mancini, 2004) the market dominates in the mediasector, although countries like Britain and Ireland alsohave a strong public broadcasting system. At the same timeBritain was the first country, by the 1950’s already, toopen up its broadcasting system for private competitors.Countries with a large private sector and an earlydevelopment of capitalism usually have a long tradition ofpress freedom and an established position of liberalinstitutions. They were also the first to liberalise theirmedia and telecommunications policies starting in the early1980’s, but at the same time tried to control thederegulation by organising independent supervisionauthorities. At the same time we notice that in countrieswith weaker markets and later capitalist development thederegulation of media markets often developed in a ratherunregulated way, also because of alliances between politicsand the private sector, politicisation of regulatoryauthorities and, more in general, the lack of liberalinstitutions.

Besides the advantages of market driven media, however, wehave also witnessed the drawbacks of the market in recentdecades. There is always a looming danger of concentrationand monopolization; markets show a preference for mainstreamcontent and audiences and in the end, citizens are alwaystreated as consumers, based on their purchasing power. Theseaspects of the market detract from any pretences of freedomof choice and unhindered competition. Market accountabilityis primarily aimed at the owners and shareholders of media

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companies, but it also refers to serving audiences andtarget groups, for which market research and marketing playan important role (‘consumer sovereignty’). Such activitiesmake it possible to determine and meet a variety ofpreferences and tastes, specifically with reference topopular culture, which in a public system are widelyignored. In addition, as a result of competition, marketactivity claims to handle the resources available moreefficiently. For this reason, quasi-market relations havebeen introduced within many public media organizations (cf.the BBC’s ‘Producer Choice’). The nature of marketaccountability is, however, free of obligations and non-binding; the trend of ‘corporate governance’, in whichcompanies hold themselves accountable to society for non-economic transactions as well (‘people, profit and planet’),seems largely to have passed the (commercial) media world bythus far.

At the same time, it has to be noted that the ‘socialresponsibility theory of the press’ has existed for sixtyyears now (Hutchins Commission, 1947). This theory definesthe press, and indeed the media, as being not only acommodity, but also a ‘public trust’ that was formulatedmore than half a century ago in the United States in answerto rising commercialization and monopolization. In the post-war period this theory has also found wide resonance allover Europe, not so much because of commercialization but asa result of the propagandistic role mass media had playedbefore and during World War II. In many European countries,due to the tradition of social, not-for-profit mediaorganizations, many press companies functioned more as apublic trust though than as a commercial media enterprise,but in the current, competitive media market there seemscontinually less room for such an approach.

Professional accountability The first and most important supplement to and correction ofthe market model in the media has come from the journalisticprofession. From the moment journalism became an independent

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profession in the nineteenth century, freeing itself fromprinters, publishers and newspaper owners, Anthony Smith(1980) writes that journalists began to develop their own,more moral connection with the public. In order to be ableto properly fulfil their social obligations, journalistsbegan to claim a freer, more independent position forthemselves. These days, journalists are part of an openprofessional group in which acting responsibly is part ofits professionalism. Journalistic professionalisation hasits earliest and deepest roots in liberal countries, whereasin countries with a stronger role for the state professionalautonomy only got the change to develop later. In thistradition journalism in liberal countries considered itselfas the watchdog of democracy and has chosen an informationaland fact-oriented style of writing. Journalists in countrieswith a more political and partisan press tradition were moregeared towards advocacy journalism and a commentary writingstyle.

When it comes to giving account of the professionalactivities of journalists, print media have shown a clearpreference for self-regulation above any form of imposedregulation or government intervention. Most professionalassociations have conformed to the well-known ‘Code ofBordeaux’ (1954, completed and adopted in 1986) as aninternational standard for professional conduct. In additionto this, in many countries additional national codes areintroduced, often initiated to enforce self-regulation andto prevent possible government intervention. In addition tosuch ‘paper’ codes, editors have developed active rules (ofplay) to dictate how to react to commercial pressure, suchas editorial statutes and ethical guidelines. This not onlyfulfils an internal need for the editorial offices, whichhave gotten bigger and have consequently seen a drop in theeffectiveness of informal rules and social control bycolleagues, but it is also a reaction to regular incidentsand increasing external pressure. Many countries also havepress councils, which primarily function to set standardsand usually only pass judgement without penalty. Also here

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we see that liberal and corporatist countries, in this rankorder, have the longest and strongest traditions in thisrespect, while in the countries in the south and the eastthe arrangements for securing journalistic autonomy arestill relatively weak.Despite its limited professional institutionalization,journalism ranks as an important public service for carryingout the media’s social responsibilities. It is also,however, a public service which is traditionally based oninformal practices, its own editorial culture and self-regulation. At the same time, this means that the freedomand responsibility of journalists is institutionallyguaranteed to a limited extent only, which makes it veryvulnerable, especially in the increasingly cold, commercialclimate that has emerged in the media world in recentdecades (‘market driven journalism’).

Political accountability Government intervention is an important but from ahistorical viewpoint relatively recent tool for organizingthe media’s social responsibility and accountability.Strictly speaking, government intervention is old news,having existed since the 1920s and 30s, when publicmonopolies were formed in both the telephone andbroadcasting systems. However, these interventions wereprimarily evoked by a scarcity of distribution means, due towhich the government felt itself forced to intervene. VanCuilenburg and McQuail (2003, 186) call this pre-war periodthe phase of rising industrial communications policy, inwhich the media are mainly regulated in line with theirtechnical and national-strategic significance. A moredeliberate, active and content-oriented media policy – VanCuilenburg & McQuail call this the period of public servicemedia policy - only came into existence after World War II,in parallel with the rise of the welfare state. But alsohere, there are considerable differences between countries.The liberal countries attributed a limited role to thestate, while in the corporatist countries the state hastaken an ever more important role in the post-war period,

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also to substitute the eroding political parallelism and agrowing market orientation in the media. In theMediterranean and post-Communist model the state remained toplay a much more dominant role, even to the extent thatseveral authors speak about ‘state paternalism’. Notsurprisingly, public service broadcasting has the strongestposition and is organised at ‘arms length’ in the liberaland corporatist countries, and a much weaker, morepoliticised position in the latter countries where it oftenis effectively in the hands of the political majority of theday. Notions of general interest and public service have ashorter tradition here. In the liberal and corporatistcountries State authority has a much stronger rational-legalbase, and therefore the public trust in politicalinstitutions, and also in public broadcasting, is relativelyhigh in these countries. More in general, public trust is animportant prerequisite for proper media performance.

Despite the often very pretentious aims of media policysince the 1970’s in practice state intervention has remainedrather modest in many countries for two reasons: one the onehand, the basic principle of the freedom of expression onlyallows a limited space for government interference; and onthe other hand, in media affairs, the ideological visions ofthe ruling political parties involved usually differ to suchan extent that, especially in countries with coalitiongovernments, it is very difficult to come to terms in mediamatters. Consequently, government policy with reference tomedia is often ‘incremental’, occurring in small steps(Bardoel, 1994). According to McQuail (2000, 19-20),political accountability through legislation and regulationdoes offer the advantage that it establishes the public willin a clear and binding manner. In practice, however, suchpolicy is usually aimed at accommodating existing actors(Krasnow & Longley 1978, 102) and thus takes more account ofthe interests of media institutions than it does serve theneeds of media users. Another shortcoming of the currentpolitical accountability of the media is its limited scope.In most countries media policy is primarily aimed at the

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public broadcasting system and much less so at commercialbroadcasting, the press and new media. Consequently, it isnot possible to develop a full-fledged media policy thatstimulates a pluralist media offer, that fights theconcentration of media ownership and predominant opinionpower, and that protects media consumers across the board.Even in the domain where political accountability isstrongest, public broadcasting, the scope of politicalaccountability is rather limited. Despite the fact that thelegal obligations imposed on the public broadcasting systemseem firm, in practice they are hardly feasible due toincompatibility with the freedom of communication (whichdiscourages interference with regards to content) andproblems to operationalise them properly. This supports thegeneral observation that media policy lends itself tointerference on a structural level, but that it is much moredifficult to apply to content-related issues. Altogether,this implies that the steering power of politics and thegovernment in relation to the media should not beoverestimated.

Public accountability Public accountability is a relatively new phenomenon andprimarily directed at strengthening the relationship withcitizens and civil society more directly. It has become anattractive policy option mainly in public broadcasting butalso the press. In the broadcasting domain, the advent ofprivate broadcasters has opened alternative options andpartnerships for politicians and governments, also since newentrants often promised to be less critical and cynicaltowards politics than PSB journalism deemed necessary. Partof the explanation for this recently more critical anddistant attitude between politics and PSB probably lies inthe forced tango that national politics and publicbroadcasters have danced for many decades, simply because ofthe lack of other, private partners. Moreover, publicbroadcasters in many continental European countries havegained independence in recent decades, due to a decline in‘political parallelism’ and a rise in the professionalism

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and autonomy of journalists, especially in countries with acorporatist tradition. More in general, the liberalisationof policies has caused a distancing on both sides and asearch for new policy instruments for public broadcasters tobecome less dependent of politics and the government of theday. Especially since the 1990s, after the introduction ofcommercial broadcasting companies in many Europeancountries, did ‘public’ broadcasting companies feelthemselves forced to go back to worrying about theirlegitimacy and roots in civil society (Bardoel & Brants2003). Once they did, they came up with new accountabilityinstruments in order to give the citizens more involvementin PSB-policies. As it happens, as Sondergaard has pointedout, this phenomenon has come up in public broadcastingcorporations throughout Europe: ‘Competition has above allforced public service media to be more responsive to theiraudiences than previously in the sense that viewers andlisteners’ wishes and desires now carry more weight thansociety’s desires regarding cultural or social functions.The dissolution of the monopolies meant the death of thekind of paternalism previously associated with publicservice media.’ (Sondergaard 1996, 24).

Although the European Commission (2001) explicitly andcorrectly includes ‘professional associations’ in itsdefinition of civil society, journalists and theirprofessional organisations were often part of thispaternalistic complex, sharing the same pedagogical, top-down approach. These new forms of public accountabilitytough, such as organising interaction platforms, publichearings and better complaints procedures, are aimed more atestablishing a direct dialogue and interaction with theindividual citizen, and have been developed in recent yearsby public broadcasters in liberal and corporatist countries,partially in imitation of the active accountability policypracticed by the BBC (Woldt 2002) and other publicbroadcasting companies in Europe. This new focus on publicaccountability can also be seen as an attempt to compensatefor public broadcasting’s unilateral political dependence

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(through political appointments and following the publicfunding of TV licensing fees – cf. the experiences of theBBC under Thatcher). In the press sector, publicaccountability is used to improve the relationship with thereader (examples: more discussion pages, ombudsmen, reader’seditors, etcetera), as well as to parry criticism of theintroverted journalistic system and to halt the drop innewspaper circulation. Additionally, following theparticipative journalism movement in the 1970s, starting inthe 1990s there were once again movements to make journalismmore ‘citizen-oriented’ -through ‘public’ or ‘civiljournalism’, especially strong in the US (Carey 1999). Ofcourse these new practises presuppose a favourable socialcontext, i.e. the presence of a vital civil society and aspirit of public service among both media professionals andthe public, which is of course absent in countries whereclientelism still prevails over citizenship.

Figure 1 offers an overview of the main socialresponsibility mechanisms as described in this paragraph(see at the end).

II. Convergence of media governance arrangements in Europe

In the previous paragraph we have seen that the market isclearly the oldest media governance arrangement, and that itinitially had a primarily emancipatory function. Over time,this was supplemented by the professional accountability ofjournalists and publishers, who started to see themselves asbelonging to a respected public tradition. As a result ofthe increasing concentration of press sector in the post-warperiod, the commercialization of the press sector slowly butsurely increased, allowing less room for the ‘public spirit’of publishers and the professional autonomy of journalists.Though it would be possible to say that commercialpublishers were ‘socially responsible entrepreneurs’ evenbefore the term existed, they still have hardly taken up thetrend of corporate governance, which is currently

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fashionable in other business sectors. The same applies tocommercial broadcasting that has, as we have seen, hardlyestablished an accountability system of its own.

Professional accountability has gradually gained ground, inparallel with the establishment and(semi-)professionalization of journalism. A delayed, lateprofessionalization occurred in many corporatist countries,which only gained the upper hand since the 1960s and 1970sthrough the erosion of political parallelism and the shiftfrom a vertical orientation, built around politicalaffiliation, to a more horizontal orientation, focused onjournalistic peer review. With this background of lateindependence in many countries, journalism is still quitewary of new forms of (public) accountability. In themeantime, however, the profession is being subjected toincreasing pressure and criticism. Journalism is beingreproached for its questionable quality and transparency, aswell as for not being able to sufficiently counterbalancecommercial public relations or political spin doctoring.

As has been said, political accountability in the form ofmedia-related government policy has only relatively recentlyarrived on the scene, due in part to friction with thefreedom of the press. Such policy is primarily directed at(public) broadcasting. In relation to the press, governmentpolicy has always remained discrete, resulting in a limitedrange of intervention. From the 1980s, governments onceagain made motions to step back (the deregulation andprivatization of the broadcasting and telecommunicationssectors). Currently, the movement away from government andtoward the market seems to have passed its peak, andpoliticians are seeking a new policy paradigm.

Every media system and all media governance arrangements arethe product of a given society, as this book clearlyillustrates. Resulting from a comparison of media andpolitical systems in several Western countries, Hallin andMancini (2004) have developed three ‘ideal types’ that, as

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you will have noticed, also constitute the structure of thisbook: 1) the ‘liberal model’, mainly to be found in GreatBritain and the former British colonies (United States,Ireland, and Canada); 2) the ‘polarised pluralist model’with considerable levels of politicisation, Stateintervention and clientelism in the Mediterranean countries;and 3) the ‘democratic corporatist model’ in theScandinavian countries, the Netherlands, Austria,Switzerland, Belgium and Germany strongly relying on therole of organised social groups in society, against a moreindividualistic concept of representation in the liberalmodel. This book introduces a forth category that can,according to Jacubowicz in his introduction, most adequatelybe called the ‘post-Communist model’. The country studies inthis book clearly show, in my view, both the conceptual andanalytical value of this relatively new typology as well asthe great variation of national media governancearrangements, within and between the four models.

Assessing the analogies and differences of these models inrelation to the actual national policy practises presentedin this book I am inclined to the conclusion that instead offour models we can also think of two main clusters that havemuch in common and are quite different from one another: theliberal and the corporatist model in one cluster, and theMediterranean and post-Communist model in the other cluster.The decisive distinction here is the difference between oldand young democracies, with a strong versus a weak formal-legislative authority and the presence or absence of a well-developed public sphere and civil society. Looking at thehistory of the respective countries we further notice adifference between, roughly speaking, the protestantcultures of north-western Europe with strong Enlightenmentroots and individualistic reading traditions as opposed tothe catholic cultures of southern and eastern Europe withroots in the Counter Reformation and more collectivecultures and stronger image cultures and viewing habits.

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In their recent study ‘Broadcasters and Citizens in Europe;trends in media accountability and viewer participation’Baldi and Hasebrink (2007) make a distinction between (1)‘most-advanced countries’, being the UK, Ireland, Germany,Scandinavian countries and the Netherlands, (2) ‘less-advanced countries’ like France, Italy, Spain and Greece,and (3) ‘under construction countries’ comprising all thepost-Communist countries. This divide shows a considerableoverlap with both Hallin & Mancini’s typology and thestructure of this book, and it also introduces a rank orderin terms of advancement or progress. Several other authorssee similarities between the Mediterranean and the easternEuropean model, and Jacobowicz also poses the question towhat extent the difference between these both models is of afundamental or rather of a gradual c.q. temporal nature.

Recent regulatory changes at both national and, first andforemost, EU level undoubtedly show a tendency to stimulatea market-orientated approach (Steemers, 2003; Murdock andGolding, 1999) and consequently favor a convergence towardsthe liberal model. Based on the EU-policy driven imperativeto separate policy and supervision, administrativeaccountability via independent supervisors has risen sharplysince the 1990s. Such relatively independent supervision,disassociated from the government policy of the day, isintended to ensure an equal level playing field for publicand commercial players in the ‘dual’ media landscape. Inpractice, it undoubtedly stimulates more open andtransparent conduct from and playing rules for mediacompanies. In the same line, the European Commission hasstipulated in its Communication on the application of Stateaid rules to public service broadcasting (2001) that thedefinition of the public service mandate should be asprecise as possible. Moreover, on the basis of‘subsidiarity’ the European Commission leaves it to theMember States to formulate the task – broad or small – ofpublic service broadcasting, while at the same time makingit clear that as far as the Commission is concerned thismandate cannot be concrete enough. Also this emphasis on

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harmonization of regulation on the basis of explicit andprecise rules in order to create equal rules of play for allpublic and partners involved in effect favors the formal-legislative authority that goes with the liberal model anddisfavors the incremental working procedures that arepredominant in corporatist and clientelist cultures. Thesame holds for the EU Commissions preference for transparentdivisions between public and private financing that favorsthe BBC model of separate bookkeeping and disfavors themixed income model of dual funding systems – public andadvertising money – that characterise most PSB’s on theEuropean continent. At the same time we have to realizethat, as Williams (2005) points out, EU media policy remainsa constant power struggle between liberals and dirigistes,between economic and cultural objectives and between thedevelopment of a pan-European culture and the protection ofnational cultures, where the first have indeed the upperhand in the policy making process, but where at the sametime the recognition of the latter interests seems toincrease. Kevin Williams concludes his book with theinteresting observation that “it is possible to argue thatEU media policy is bringing about the opposite to what itstates it is trying to achieve. Rather than promotingEuropeanness, the strategy of liberalization is creatingmore commercial channels, which are dependent on Americanprogramming. Americanization may be the unintendedconsequence of television without frontiers in Europe”(Williams, 2005: 149).

Next to, and even more than, EU policies, other major trendsin the media and in society at large - like modernization,globalisation and commercialization - have enabled, whatHallin and Mancini (2004, 251) call, the homogenization ofmedia systems and the triumph of the liberal model. In factall these trends go hand in hand and it is not easy todetermine what is the chicken and what the egg. In generalit means that the patterns of political communication havechanged considerably, from party centered patterns withstrong relations to collectively organized social groups to

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more media centered patterns where politics is personalizedand the support of the electorate of individual citizens isincreasingly organized via political marketing (Hallin &Mancini, 2005: 252-253). Hallin & Mancini call thisincreasing separation or ‘differentiation’ between media andpolitical institutions a principal characteristic of theliberal model, in which a distinctive ‘media logic’ comes toprevail over the ‘political logic’ that dominated the mediascene in Europe for such a long time. The media’s ever-larger role in political communications can also beexplained as a result of major changes amongst citizens orwithin the general public. According to Bardoel (2003, 12),“deinstitutionalization and individualization are the keywords to describe the evolutions that have taken placewithin the public arena over the last few decades. Thisgrowing individualization goes along with self-reinforcingphenomena such as increased education, income and mobility,which have weakened the power and influence of older,collective vehicles for self-improvement in favour of thecitizens’ individual ability to choose to improve their owndestiny. In Giddens’ words, ‘emancipatory politics’ loses out to‘life politics’ (Giddens 1991, 210; ff; Faulks 1999, 169). Thishas resulted in smaller families, limited participation intraditional church, political party and trade unionactivities, and on average less of a connection with thevalues of a group to which one belongs. As such, the old,institutionally-anchored system of external pluralism hasfallen away, making room for shifting public preferencesbased on age, level of education and ‘lifestyle’.” In thiscontext, some authors even speak of the emancipation orliberation of the public (Bardoel 1997, 190; Mazzoleni &Schulz 1999, 253). All this means that the role of organizedsocial groups in society, which is characteristic for thedemocratic corporatist model, has given gay to a moreindividualistic conception of representation that is centralto the liberal model.

We have seen the many different media governancearrangements that have arisen from the tension between

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freedom and responsibility of the media in variousgeographical and historical contexts. At the same time, thebasic principle of freedom of expression does not make iteasier either to develop effective governance arrangementsfor the media in future. In my opinion, as I have statedearlier (Bardoel 2003), in the future there must be abalanced intervention mix of governance arrangements toensure the public interest.

There seems to be a growing consensus that the increasing‘power’ or, better, ‘influence’ of the media has to becounterbalanced by greater media transparency andaccountability. However, there is no consensus on how thelatter should be achieved. Governments are often consideredas the classic guarantee for a sound media system, but theyhave proven to be quite ineffective in preventing mediamonopolies in the press or broadcasting industries and instimulating the plurality of media content. They experiencealso problems with the organization of public broadcasting‘at arms length.’ More in general, media regulation provesto be rather ineffective in the management of content. Inthe 1980s and 1990s, media markets were seen as a new panaceafor the problems of public and/or government-controlledmedia: inefficiency, inflexibility and bureaucratization,paternalism and lack of interest for popular taste andculture, lack of innovation, et cetera. Over the lastdecade, the dark side of market-driven media is getting moreattention again: its mainstream orientation, its interest inconsumers (not citizens), the influence of advertisers andsponsors, et cetera.

The trend of ‘less government’ and ‘more market’ also shedsnew light on the position of the media professionals: they havebecome the ‘guardians’ of the quality of media output, whileat the same time the public spirit of and the public spacefor professional journalists and other creative people tendto diminish. Media professionals want to work ‘for thepeople,’ but not seldom see accountability to the public andto society as no less threatening than the forces of the

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market or the state. More than ever in the past, the citizenbecomes an active part of the (mass) communication process,due to the potential of new technologies, more competitionbetween media and, last but not least, a more self-consciousand better educated citizenry. Involvement of citizens andcivil society can also provide a ‘fourth’ way to organizesocial responsibility in the media, next to the primacy ofeither the market, the state and/or the professional. Thereis, in other words, a growing awareness that an adequatemedia and communications ‘ecology’ can best be organized,not by exclusively relying on one of these parties ormechanisms, but by way of interrelated and multileveled‘governance’ arrangements in the media system. This alsocorresponds with new approaches in the reflection on publicpolicies and business strategies.

In political science several new concepts have emerged thatimply a change of, and not an end to, state responsibilityfor the public domain (cf. Hoffmann-Riem et al., 2000; WRR,2005). These and other authors (cf. Schulz & Held, 2004)make a distinction between state regulation, co-regulationand self-regulation and demonstrate that, both in theliterature and in the policy practice, many alternativeforms of regulation on the continuum between state andmarket and based on collaborative arrangements betweenpublic and private partners have been elaborated recently.The idea that market forces can simply replace governmentregulation has proven to be naïve. Instead of deregulation,we should speak about reregulation. Also the EuropeanCommission (2001) has been reflecting on new forms ofregulation and governance: Its aforementioned White Paper‘European Governance’ emphasizes that co-regulation will bemore and more put in practice. Consequently, in the mediaand telecommunications sector a transformation of statehoodis taking place that can be traced by trends such as achange from protectionism to promotion of competition, theseparation of political and operative tasks (i.e.independent regulatory authorities), the shift from vertical(sector-specific) to horizontal regulation, the transition

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from national to supra- and international regulation and thechange from state to self- and co-regulation in whichprivate and societal partners are becoming more activelyinvolved in regulation. Looking at the future of mediapolicy in Europe it is interesting, as we have tried to do,to assess the analogies and differences between media policymodels and to address the question if there is a convergenceof these models, but in my view it is much more important tolook for new governance arrangements that include a properbalance of market, state, profession and, last but notleast, the public.

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ORGANISATION OF SOCIAL RESPONSIBILITY OF THE MEDIA

MECHANISM Principle Decision Participation Instrument

MARKET Competition,

companies

Demand and

supply

Purchasing

power, money

Market

share,

market

research

POLITICS Hierarchy,

bureaucracy

Law and

regulation

Authority,

force

Budget,

annual

review,

contract /

charter

PROFESSION Professionalis

m, ethics

Self-

regulation

Education,

‘peer review’

Reflection,

code,

Council for

Journalism

PUBLIC Voluntarism,

associations,

pressure

groups

Discussion,

dialogue

Commitment Openness,

feedback:

hearings,

ombudsmen

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Reference: Bardoel (2003)

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