# PUBLIC MEDIA AND POLITICAL INDEPENDENCE: Lessons for the Future of Journalism from Around the World

By Rodney Benson and Matthew Powers
New York University
Department of Media, Culture and Communication

## EXECUTIVE SUMMARY

We live in paradoxical times. The core institutions and systems that have supported journalism in America for decades are weathering a perfect storm of challenges that have undercut our country’s longstanding information infrastructure. At the same time, a new generation of news and journalism organizations are driving a renaissance in local reporting and reinvigorating our media system. This shifting media landscape has inspired a range of important reports and initiatives designed to help chart a course toward stronger journalism and media in America.
A diverse set of stakeholders – policymakers, academics, foundations, nonprofits, and former and current journalists – have weighed what the future of journalism might look like and what it might take to get there. In report after report, America’s public and noncommercial media sector has been held up as a core component to the future of hard-hitting, accountability journalism. All of the major reports released in 2009 and 2010 agreed that there is a vital role for public and noncommercial media to play, and that the federal government must work to strengthen and expand funding for it.1 Together, these reports sparked inquiries at both the Federal Communications Commission and the Federal Trade Commission.
However, too often the moderate proposals for federal funding and public media run into a wave of protest and knee-jerk reactions against any and all government action. In fact, government has always and will always influence how our media system functions, from the early newspaper postal subsidies to handing out broadcast licenses and subsidizing broadband deployment. The question is not if government should be involved, but how, and that is a question that demands an in-depth conversation, not a shouting match.
Those concerned about government involvement in journalism have legitimate concerns about the ways federal funding can open the door to undue political pressure. While there is broad agreement that the current situation in American journalism is a classic case of market failure, remedial action has been stymied by the fear that any public policy cure would be worse than the disease. The proper response to these concerns, however, should be to identify how best to insulate journalists and newsrooms from political pressure, not to throw the baby out with the bathwater.
Although U.S. public broadcasting has accomplished much in the 40 years since its founding, today there is a growing sense that we can and must do better. In the global context, our public media system’s independent civic mission is woefully underfunded: U.S. per capita public spending is less than $4, far less than the $30 to $134 per capita for the 14 countries examined in this study. And as the recent efforts by politicians to punish NPR for its firing of Juan Williams suggest, public media in America possess little autonomy from direct political pressure. How can public media be adequately funded and adequately protected from partisan political meddling? These decisions do not need to be made in a vacuum. The lessons of other democratic nations, many of whose public media systems have been around long before American public broadcasting, are instructive.
In this report, we survey the concrete ways that a cross-section of democratic nation-states around the world fund and protect the autonomy of public media. Countries examined in this report are: Australia, Belgium, Canada, Denmark, Finland, France, Germany, Ireland, Japan, The Netherlands, New Zealand, Norway, Sweden and the United Kingdom. Most of our focus will be on television and radio public service broadcasters, increasingly reaching citizens via online platforms, though where appropriate we will also document public support for newspapers (in Belgium, Finland, France, the Netherlands, Norway and Sweden).
In the 14 nations examined in this study, public media independence and democratic functioning are promoted through a variety of means.
* First, in several countries, funding is established for multiyear periods, thus lessening the capacity of the government to directly link funding to either approval or disapproval of programming.
* Second, public media seem to be strongest when citizens feel that media are responsive to them rather than to politicians or advertisers (i.e., when they are truly “public”). Funding structures and oversight organizations that create a direct link between public media and their audiences foster citizen engagement, involvement and accountability.
* Third, the legal and administrative charters establishing public broadcasters work to assure that public funds are spent in the public interest — providing diverse, high-quality news and other content. At the same time, these charters and related media laws restrict the capacity of governments to exert influence over content in a partisan direction.
* Fourth, public agencies, administrative boards, and/or trusts of one type or another exist in all countries to serve as a buffer between the broadcasters and the government in power. The independence of such agencies, boards, and trusts is bolstered through a variety of means and by creating an “arms-length” institutional relationship between the public broadcaster and partisan political interference or meddling.
As a result of these policies, not only have public broadcasters continued to provide high-quality, diverse programming, they have also been responsible for airing critical investigations of government performance. According to a growing body of scholarly research, public broadcasters across western Europe and other democracies examined in this study provide more and higher quality public affairs programming and a greater diversity of genres and unique perspectives than their commercial counterparts. Publicly subsidized newspapers are just as or more critical of government than their advertising-subsidized competitors.
Today, democratic public media systems in Europe, North America and elsewhere face challenges on a number of fronts. European scholars and journalists we consulted for this study emphasized the threat to public broadcasters posed by increasing commercial pressures, and, in general, the increasing difficulty of balancing demands to simultaneously appeal to large audiences and to uphold public service values such as high-quality programming across multiple genres, in-depth information, promotion of democratic citizenship, and representation of diverse voices and viewpoints.
Some public broadcasters are better funded and operated than others. Our survey highlights the notable strengths of public media systems in the U.K., Germany and Scandinavian countries. In contrast, due to erosion in either the amount of funding or procedures for assuring arms-length autonomy from direct governmental control, public media have arguably been weakened in recent years in Australia, Canada, France, The Netherlands and New Zealand.
Likewise, in the transition to digital and Internet platforms, countries with public service broadcasting are adopting a variety of approaches to maintain or increase public funding, some more conducive than others to maintaining an important role for public service media. While advertising or online merchandising might seem to offer an additional means of funding online expansion, public media are facing stiff opposition from commercial media, as well as from the European Commission, which are raising the specter of unfair state-sponsored competition against market actors (a criticism, it should be noted, that commercial channels, many of them privatized in the 1980s, have been making since their inception).
In sum, even as public media face new challenges and difficulties, this report establishes the continuing international viability, indeed vitality, of the public service model and provides a range of positive policy prescriptions, from funding mechanisms to citizen engagement and governance structures, for the United States as it considers needed expansions of its own very modest public media system. While it is unlikely that the United States would adopt any of these models directly, the report quite clearly demonstrates that public service broadcasters play an important civic role in overseas markets, remedying the classic market failure in the production of quality, independent, commercial-free journalism. The models herein should be considered a starting point for discussion, acknowledging that each would have to be modified for the American media and political context.

## PART I: PUBLIC MEDIA AROUND THE WORLD

America is unique among western democracies in its nearly complete reliance on commercial media to present comprehensive information about government and politics, to hold political and business elites to account through critical commentary and investigative reporting, and to provide a forum for a broad range of voices and viewpoints. At its best, this system has produced Pulitzer Prize-winning investigative reporting and in-depth, long form journalism. But for much of the time and for most media outlets and their audiences, entertainment, crime and disaster news, and light, human-interest stories have been the dominant tendency. PBS and NPR, created in the early 1970s, were a very modest attempt to add a little more public affairs to the media content balance. In recent years, of course, cable television and the Internet have provided additional outlets for public affairs content. But few of these outlets, whether privately or publicly funded, reach a broad public audience.
In contrast to the highly fragmented and mostly commercial American media, the media in virtually every other western democratic nation-state are a mix of private and public. And in many cases public media are the leading media, both in terms of audience size and in terms of quality and independence, as numerous comparative studies have shown:
* In a comparative study of election news coverage by national private and public television channels in Germany, England and France, and national private channels in the United States, Zurich-based scholar Frank Esser (2008: 412, 416, 422-425) found “more extensive [election] coverage on public than commercial channels” in all of the European countries. He also reports that French public channel France 2’s coverage was the most likely to focus on policy substance, and that “the toughest candidate interviews aired on the British channels,” including the public BBC.
* Recent research comparing publicly and privately owned television news in Denmark, Finland, the United Kingdom and the United States by scholars James Curran, Shanto Iyengar, Anker Brink Lund and Inka Salovaara-Moring (2009) shows that “public service television gives greater attention to public affairs and international news, and thereby fosters greater [public] knowledge in these areas, than the market model.” In this sophisticated study, which combines content analysis with survey research, Curran and colleagues also found that public service television “encourages higher levels of news consumption and contributes to a smaller within-nation gap between the advantaged and disadvantaged.”
* Research has also shown that publicly subsidized newspapers in Sweden, Norway and France (Strömbäck and Dimitrova 2006; Skogerbø 1997; Benson and Hallin 2007; Benson 2009b, 2010) tend to provide more original, critical, in-depth and multiperspectival coverage than their advertising-dependent counterparts (either in their own countries, or in the United States).
How is it possible that publicly funded media can perform just as well or better than commercial media? For starters, it needs to be kept in mind that the alternative to government-facilitated public support for media is not a blank check providing no-strings-attached “independence,” but rather alternative forms of dependence. Advertising support, generally from large business corporations, can be just as or more problematic as state funding. Research has documented the ways in which advertising funding tends to dampen, to say the least, critical reporting of business (Collins 1992; Baker 1994; Davis 2002; Hamilton 2004). But given that businesses also want to assure good relations with government and diverse consumer publics, they also tend to push (subtly or not so subtly) for news that will avoid causing offense or disturbing the status quo. For this reason, paradoxically, publicly funded media such as the BBC are often more willing to take risks than commercial media. During the Iraq war, which involved significant British involvement, the “BBC was more likely to be accused of being an enemy of the state than a patriotic cheerleader” (Robertson 2003).
What matters for both public and private media are the procedures and policies in place to assure both adequate funding and independence from any single owner, funder or regulator. Inside corporate-owned newsrooms, as profit pressures have increased, informal “walls” protecting the editorial side from business interference have crumbled. In contrast, the walls protecting public media are often made of firmer stuff such as independent oversight boards and multiyear advance funding to assure that no publicly funded media outlet will suffer from political pressure or funding loss because of critical news coverage.

### RESEARCH QUESTIONS AND METHODOLOGY

This report documents the precise mechanisms for funding and protecting the journalistic autonomy of public media in leading western European democracies, as well as Canada, Australia, New Zealand and Japan. Our aim is to survey a range of democratic solutions to the common challenges posed by public media: How can they be adequately funded? And how can they maintain their independence from undue governmental interference or partisan political meddling?
In Part II of this report, countries are listed alphabetically for ease of reading and reference purposes. Broadly, though, the countries follow three primary funding models: license fee only or primarily2 (Denmark, Finland, Japan, Norway, Sweden, and the United Kingdom),mixed license fee and advertising funding (France, Germany, Ireland), and mixed public funding and advertising (Australia, Belgium, Canada, The Netherlands, New Zealand). License fees refer to fees assessed to television-owning households and set aside only for the purpose of public media, generally television and radio. Public funding means that public broadcasters compete directly with all other general tax supported programs in the national (or regional) government’s budget.
For each country, we document: 1) basic background information about the major public broadcasters; 2) the amount, means, mechanisms and duration of funding (all funding amounts are expressed in U.S. dollars, converted using Oanda Currency Converter, http://www.oanda.com/currency/converter, at the rate of July 1 for the year reported); 3) the “external” government branches and agencies and “internal” media boards which oversee public media and help insulate them from political pressure, as well as procedures and laws governing appointments and purview; 4) new policy issues arising out of the transition to Internet platforms; 5) information about newspaper subsidies for those countries where they are offered; and 6) when available, content analysis research comparing the form and content of public media programming, especially news, with its commercial competitors.
Our focus in this report is on audio-visual media, particularly television. In most countries, provisions for television and radio are closely linked. We also document procedures for public funding for newspapers, an important additional type of public media funding in France, Belgium, the Netherlands, and most Scandinavian countries. Our findings are based on original source documents (including annual reports and websites), the latest scholarly research, and personal e-mail communications with more than 30 journalists, scholars, media executives, and government regulators with expertise on public media in the 14 countries examined in this report.
In Part III, Table 1 provides up-to-date data on precise amounts and types of funding for public service broadcasting media in all countries studied, as well as for the United States. Table 2 provides a short summary for each country of funding sources, funding approvers, funding renewal process, legal protections of independence, and administrative buffers.
It may be tempting to quickly dismiss European ways as products of vastly different civilizations: It may work in Europe, so this common argument goes, but it could never work here. Certainly, America will adopt its own unique policies, just as approaches vary across European and other democracies. Decisions about the role of the state and the market, however, are unavoidable. The history of American media, as numerous historians (see, e.g., McChesney 1993, Starr 2004) have shown, has been shaped by political struggles (not predetermined by “culture”) to decide how and under what conditions media should be oriented toward serving civic or commercial needs. And the truth is that American media — TV, radio, newspapers, magazines, and Internet — have and continue to receive significant public subsidies (Cook 1998, Cowan and Westphal 2010): The question is whether this public support is sufficient and whether it is being used as effectively as it could be to support democratic civic ends.
Is the role of the government and media policy moot in the age of the Internet? While it is surely true that the social organization of news media and their relations with diverse publics are complicated by the Internet, it is highly debatable whether this has led to a disintegration or dispersal of power, as some philosophers have argued. And while the Internet enables new forms of democratic public engagement, there is already considerable empirical evidence that old commercial media patterns are reappearing or even being accentuated on the Web, such as the continued dominance of a handful of large media conglomerates, homogeneous or ideologically narrow news coverage, and scoop-driven sensationalism. The title of one recent study (Fenton 2010) of the Internet’s effects on journalism sums up an all-too-frequent outcome: “New Media, Old News.” As noted, however, the Internet clearly poses new challenges for public media, and we will document the various ways in which these are being addressed.
Finally, we want to be clear about the purpose of our report. Even given the demonstrated virtues of European public media, we are not suggesting that public media can or should replace private enterprises. Commercial and public media each have their blind spots. That’s why it’s important to have both. This report simply shows a range of concrete, workable ways that public media can be a stronger part of the mix.

### KEY FINDINGS

Public media, whether TV, radio or newspapers, attract sizeable audiences and are the market leaders in many countries. Without exception, the western European public broadcasting channels examined in this survey attract one-third or more of the national television audience. In contrast, audiences for public service channels in Canada, Australia and New Zealand, as well as the United States, tend to be significantly smaller.
Public media are funded by a variety of sources, including license fees (assessed only to television set owners with revenues reserved for the media organization), direct government funding (general tax revenues), taxes on commercial media or telecommunications companies, advertising, and other commercial sources. The best funded public broadcasters, such as the U.K.’s BBC, Germany’s ARD/ZDF, and the various Scandinavian public broadcasters, tend to receive the lion’s share of their funding from license fees. In the Netherlands, the license fee was replaced with direct government appropriations beginning in 2000, with one result being a gradual decline of funding in subsequent years (Papathanassopoulos 2007: 155-156).
The license fee itself is defended by many as a guarantee of autonomy and the means to provide a direct link between broadcasters and the public. As Papathanassopoulos (2007: 156) argues, in contrast to the license fee, “Direct public or government funding may, in one way or another, seriously affect public broadcasters’ independence, or in the best case, the public perception of their independence.” In addition to establishing a buffer against dramatic changes in governmental funding, the license fee also has historically had “a social dimension,” in that “by contributing to their national public broadcaster, citizens felt that it was more accountable to them than to the politicians.” (ibid.: 156). In the American context, public broadcasters have long argued that direct charitable contributions from local citizens to local stations serve a similar role. The question then is how public policy can help strengthen that connection without implementing a license-fee model. Public service media’s professional autonomy and optimal democratic functioning are promoted through a variety of means:
* First, in several countries, including Australia, the U.K., Denmark, and Germany, funding is established for multiyear periods, thus lessening the capacity of the government to directly link funding to either approval or disapproval of programming.
* Second, public media seem to be strongest when citizens feel that media are responsive to them rather than to politicians or advertisers (i.e., when they are truly “public”). Funding structures and oversight organizations that create a direct link between public media and their audiences, such as in Denmark, Germany, the Netherlands, and the U.K., foster citizen engagement, involvement and accountability.
* Third, the legal and administrative charters establishing public broadcasters almost uniformly emphasize mandates to provide diverse, high-quality programming, and inclusion of a wide variety of voices and viewpoints. At the same time, in many cases, these charters and related media laws have strictly restricted the capacity of governments to attempt to influence programming in a partisan direction, or even to determine funding except according to very narrow technical criteria (as in Germany). In the United Kingdom, the BBC “Trust” oversees the BBC; the government has its most significant power during the negotiations over the BBC’s 10-year Royal Charter. However, between charter negotiations, the BBC Trust and by extension the BBC have significant autonomy from governmental interference.3 The Swedish public broadcaster, SVT, is likewise governed by a multiyear charter (in this case, three years) and owned by an independent foundation, Förvaltningsstiftelsen för Sveriges Radio AB, specifically designed to insulate SVT from both state and market pressures.
* Fourth, oversight agencies and/or administrative boards of one type or another exist in all countries to serve as a buffer between the public broadcasters and the government in power. The independence of such agencies or boards is bolstered through a variety of means: through staggered terms, limiting the capacity of a new government to immediately control all appointments (Canada, France); through dispersal of authority to make appointments; and through multiple layers of “external” and “internal” oversight, creating an “arms-length” relationship between the public broadcaster and partisan political interference or meddling (in all countries, but especially in the U.K., Germany, and the Scandinavian countries). In all the countries in our study, governments and oversight agencies are prohibited, by law and by custom, from engaging in any pre-broadcasting censorship.
As a result of these policies, not only have public service broadcasters continued to provide high quality, diverse programming, they have also been responsible for airing critical investigations of government performance (notably in Denmark, Canada and the U.K.). Likewise, subsidized newspapers in Sweden, Norway and France have provided consistently high-quality, in-depth, and often critical news coverage of government and the leading political parties.4 Numerous scholarly content analyses demonstrating the democratic virtues of public over commercial media and many examples of outstanding critical news coverage by public media are presented in the individual country profiles.
In the United States, public media are funded through direct government annual appropriations, which have been and will continue to be problematic. While we acknowledge that the license fee model will likely never gain a foothold in the United States, nor do we think a regressive tax is the right answer, we do need to look for new ways of more deeply connecting citizens to their public media system. If we seek to create strong public media — as free as possible from both political and commercial influences, yet deeply committed to a democratic civic mission — then a sustainable, long-term trust fund is perhaps the best model. This approach could build upon the experiences of trust ownership forms developed in the United Kingdom and Sweden.
Today, democratic public media systems in Europe, North America, and elsewhere face challenges on a number of fronts. Far more than partisan political meddling (though this has occurred in some cases, notably in France), European scholars and journalists we consulted for this study emphasized the threat to public broadcasters posed by increasing commercial pressures, and, in general, the increasing difficulty of balancing the need to appeal to a broad audience (to justify the license fee) and to uphold public service values such as high-quality programming across multiple genres, in-depth information, promotion of democratic citizenship, and provision of “access to and reflection of society in diverse or proportional ways” (McQuail 2003: 27; Blumler 2010, personal communication).
Public media face increasing competition from commercial channels, which in turn see public media’s access to both public funds and advertising (in some cases), as well as unfettered access to the Internet, as unfair competition. Commercial television owners argue for the obsolescence of public service television in the age of cable television and the Internet, even though research has shown that public broadcasters continue to offer programming (news, educational and children’s programs, and programs appealing to diverse minorities) generally not offered by commercial stations. At the same time, increases in license fees or direct government appropriations have often failed to keep pace with increasing costs, forcing a dilution of programming quality.
Some public broadcasters are better funded and operated than others. Our survey highlights the notable strengths of public media systems in the U.K., Germany and Scandinavian countries. In contrast, due to erosion in both the amount of funding and procedures for assuring “arms-length” autonomy from direct governmental control (shift from license fee to direct government funding, shift from multiyear to annual funding, etc.), public media have arguably been weakened in recent years in the Netherlands, Canada, New Zealand, and Australia.
Likewise, in the transition to digital and Internet platforms, countries with public service broadcasting are adopting a variety of approaches to maintain or increase public funding, some more conducive than others to maintaining an important role for public service media. Historically, license fees were determined simply by the presence or absence of a television in the home (as is still the case in the U.K., Germany and Finland). Recently, though, countries such as Denmark have altered this definition somewhat to include any device that can display television content (e.g., computers). Other Scandinavian countries are discussing a shift from the narrowly conceived television license fee to a more general media fee (Finland) or replacing it with direct government funding (Norway). While advertising or online merchandising might seem to offer an additional means of funding public media’s online expansion, public service broadcasters already are facing stiff opposition from commercial media, as well as from the European Commission, which are raising the specter of unfair state-sponsored competition against market actors.5
In sum, even as public media face new challenges and difficulties, this report establishes the continuing international viability, indeed vitality, of the public service model and provides a range of positive policy prescriptions for the United States as it considers needed expansions of its own public media.
NOTES
1 See Leonard Downie, Jr. and Michael Schudson, “The Reconstruction of American Journalism,” Columbia Journalism Review, published online October 19, 2009. This report was endorsed in a CJR editorial, “A Helping Hand: The case for (smart) government support of journalism,” Columbia Journalism Review (November / December 2009). For other positive evaluations of targeted government support of U.S. journalism, see Geneva Overholser and Geoffrey Cowan, “Free press, with profits,” Los Angeles Times, January 19, 2009; Bree Nordenson, “The Uncle Sam Solution,” Columbia Journalism Review (September/October 2007); Victor Pickard, Josh Stearns, and Craig Aaron, “Saving the News: Toward a National Journalism Strategy,” Free Press Policy Report, Washington, D.C., 2009; The Knight Commission on the Information Needs of Communities in a Democracy, “Informing Communities: Sustaining Democracy in the Digital Age,” The Aspen Institute, 2009; and David Westphal and Geoffrey Cowan, “Public Policy and Funding the News,” USC Annenberg School of Communications and Journalism, 2010.
2 A few of the countries in this category also receive small amounts of sponsorships or other commercial revenues, but these typically account for less than 5 percent of total revenues. BBC receives about 20 percent of its total revenues from the commercial operations of BBC World or direct government grants. However, domestic BBC is entirely funded by the license fee.
3 Remarks of BBC Director-General Mark Thompson, Conference on “Public Media in a Digital Age,” sponsored by The New America Foundation and Free Press, Washington, D.C., October 5, 2010.
4 For another survey of research demonstrating the critical, in-depth, and ideologically diverse character of public media, both audio-visual and print, see Benson (2011, in press).
5 As detailed in this report, much of European public service broadcasters’ transition to online has involved the adjudication of the European Commission. Commercial broadcasters in several member countries (Netherlands, Denmark, Germany and the U.K.) have questioned the legality of funding public broadcasters online. Questions focus on whether and how public broadcasters may be permitted to expand online services. Broadly, the European Commission has tended to favor a solution known as “public value tests.” To introduce a new online service, public broadcasters must submit a plan to their national regulatory authority that demonstrates a social need for the service and the estimated effect such a service will have on commercial competitors. These tests must be carried out prior to the approval of any new service. See, e.g., Aslama and Syvertsen (2007), Donders and Pauwels (2008) and Open Society Institute (2005).
For the full report, including country profiles and bibliography, please go to: http://www.freepress.net/sites/default/files/resources/public-media-and-political-independence.pdf