Copyright 2008. No quotation or citation without attribution.
IR/PS CSR Case #08-08

How the Parents Television Council(PTC) Protects American Children:
Promoting Social Responsibilities in
the Broadcasting Industry
By: Vici Lihardo

GRADUATE SCHOOL OF INTERNATIONAL RELATIONS AND PACIFIC STUDIESUNIVERSITY OF CALIFORNIA, SAN DIEGO

Prepared for Professor Peter Gourevitch
Edited by Kristen Parks
Corporate Social Responsibility
Fall 2008

Copyright 2008. No quotation or citation without attribution.

2

Table of Contents
I. INTRODUCTION ..................................................................................................................... 3
II. OFFICIAL TV PROGRAM RATING SYSTEM (TV-PG)................................................. 5
II.1. FCC and Regulating the Content of TV Programs.............................................................. 5
II.2.The Problems of TV-PG ....................................................................................................... 7
III. THE ORGANIZATION OF PTC......................................................................................... 8
III.1.The Establishment and the Mission of PTC ........................................................................ 8
III.2. Promoting a “Standard” of Family Friendly TV-Program ............................................... 9
III.3. Monitoring the Industry: What the PTC has done ........................................................... 10
III.4. Expanded Issues and Market Driven Approach............................................................... 13
III.5.The Advisors and Funding ................................................................................................ 16
IV. ANALYSIS............................................................................................................................ 17
IV.1. Credibility......................................................................................................................... 17
IV.2. Accountability................................................................................................................... 21
IV.3. Sanction ............................................................................................................................ 22
V. CRITICISM AND CHALLENGES ..................................................................................... 23VII. CONCLUSION ................................................................................................................... 27
VIII. QUESTIONS FOR FURTHER DISCUSSION .............................................................. 28
VIII.

REFERENCES ............................................................................................................... 29

Appendix 1: Total Media Exposure and Total Media Use for 8 to 18 year Olds, by Age,
Gender, Race and Parent Education and Income.................................................................... 31
Appendix 2. : TV-PG Rating System ........................................................................................ 32
Appendix 3: PTC the Family Guide to Prime Time Television rating system) .................... 33
Appendix 4: This year's 2005-2006 Advertiser Seal of Approval winners are: .................... 35
Appendix 5: The Entertainment Software Rating Board ....................................................... 36
Appendix 6: PTC Advisory Board ............................................................................................ 37
Appendix 7: Top Ten Best and Worst Advertisers................................................................. 38
Appendix 8: ................................................................................................................................. 39
Hall of Fame and Shame ............................................................................................................ 39

Copyright 2008. No quotation or citation without attribution.

3“Children in the United States are, on average, exposed to an
estimated 8,000 murders and 100,000 acts of violence on television by
the time the child completes elementary school”(Telecommunications Act of 1996 Sec. 551 [5])I. INTRODUCTION
The rapid evolution of information technology (IT) has significantly affected a lot of aspects ofAmerican society. This advanced technology has also attracted an increasingly high amount ofinvestment in certain industries, such as wireless technology, entertainment and media industries(TV, Radio and Network Broadcasting industries). The development in the broadcasting
industry, for example, not only increases profits for broadcasting-related business, but also
serves the needs of society for a wide array of information and entertainment. However, various
groups in society have been concerned about the social consequences of this massive flow of
information, particularly the TV programs that are perceived as inappropriate for children.
The data collected by Roberts and colleagues in 2005 reveals that American children aged 8 to
18 spend an average of 3 hours and 4 minutes per day to watch TV.1 Younger kids under the ageof 6 spend on average two hours a day with screen media. This is around three times as muchtime as they spend reading or being read to. 77% of these kids turn on the TV by themselves and
62% use the remote to change channels.2 (See Appendix 1: Total Media Exposure and Total MediaUse for 8 to 18 year Olds)

1
2

George Comstock and Erica Scharrer, Media and the American Child, (Academic Press, Elsevier, 2007), p . 13
PBS Parents, Children and Media http://www.pbs.org/parents/childrenandmedia/article-faq.html

Copyright 2008. No quotation or citation without attribution.

4

While TV programs have long been perceived as a source of information, entertainment, and tosome extent, as a means of education, massive study and research on the issues, such as thecontents of the programs or the impact of the habits of watching TV among children conclude
that the media can contribute to aggressive behavior, anxiety, and obesity in young children.3
Various research projects and experiments demonstrate that the exposure to violent portrayals
leads to increased aggressiveness (Bandura, Ross & Ross 1963a; Berkowitz & Rawlings, 1963,
Steuer, Applefield and Smith, 1971; Josephson, 1987 and Paik and Comstock, 1994). In the
speech on the signing of the broadcast decency Enforcement Act of 2005, President Bush stated:4“In recent years, broadcast programming has too often pushed the bounds ofdecency. One study found that during the hours between 8:00 p.m. and 9:00 p.m. - that's the time when most families are watching television -- the use of profanity
on television shows increased vulgar language by 95 percent, from '88 to -- from1988 to 2002. In other words, the language is becoming coarser during the times
when it's more likely children will be watching television. It's a bad trend, a badsign. Since 2000, the number of indecency complaints received by the FCC has
increased from just hundreds per year to hundreds of thousands”
In order to help American parents to protect their children, the Parents Television Council (PTC),
since 1995, has acted as an advocating organization whose objective is to provide information
for parents to help them to protect their children from certain television program and othermedia. To achieve this goal, PTC has developed its own rating system as a standard for decent

3

The Center on Media and Child Health, Children’s Hospital Boston; Issue Brief: The Effects of Electronic Mediaon Children Ages Zero to Six: A History of Research (Kaiser Family Foundation, January 2005)
http://www.kff.org/entmedia/upload/The-Effects-of-Electronic-Media-on-Children-Ages-Zero-to-Six-A-History-ofResearch-Issue-Brief.pdf
4
http://www.whitehouse.gov/news/releases/2006/06/print/20060615-1.html

Copyright 2008. No quotation or citation without attribution.

5

TV programs, its own TV program monitoring mechanism and various methods to promotesocial responsibility in the broadcast industry. This paper will analyze how PTC conducts theirmonitoring and evaluating activities, and what makes this organization accountable and credible.

II. OFFICIAL TV PROGRAM RATING SYSTEM (TV-PG)
II.1. FCC and Regulating the Content of TV Programs
Realizing the increasing amount of TV shows and other products of business companies in the
broadcast industry, (TV series, reality shows, video clips, song clips, advertisement, etc) inwhich some of them contain materials that are not appropriate for children, and have a potential
negative impact on the kids who watch these programs, the government has mandated that theFederal Communication Commission (FCC) regulate the industry. In order to fulfill its
responsibility, the FCC has monitored TV programs and is ready to pose certain amounts of fines
on those who violate the rules. However, in addition to technical and logistical problems, theFCC has faced significant legal challenges, which include the difficulties in determining theviolation of decency rules in order to prevent the accusation of breaching the first amendment of
the constitution.
The enactment of the 1996 Communication Act provided the FCC with a new policy instrument
for regulating the industry. In one of the chapters, the 1996 Act stipulates the rule that prohibits
the industry from displaying programs that contains sex, violence and profanity materials. The
act also rules that Congress “calls on the industry to establish a voluntary system to provide
parents with information concerning programming that contains sexual, violent, or other indecent
materials about which parents should be informed.” As a federal regulator, the Act mandated theCopyright 2008. No quotation or citation without attribution.

6

FCC to oversee the efforts of the industry to set a standard guideline for the products of TV andbroadcasting industry (within a year after the act was enacted).
To follow up this call, in 1997, the Industry led by three organizations: the National Associationof Broadcasters (NAB), the National Cable Television Association (NCTA) and the Motion
Picture Association of America (MPAA – the organization who set the rating system for themovie industry) submitted a proposal of voluntary TV Rating System, known as The TV
Parental Guidelines (TV-PG). In January, 1997, the FCC accepted and adopted the TV Parental
Guidelines as the official TV rating system for the broadcast industry in the US, and regulated
that these guidelines should be implemented by television broadcasters and networks, cable
networks and systems, and television program producers.5 In July 1997, this age-based TV
Parental Guidelines was expanded with one new rating code and 4 additional letter codes (S, V,
L and D) of the specific content of the programs.6 As a consequence, the industry rates the
programs that contain sexual, violent or other material that parents may deem inappropriate andare committed to voluntarily broadcasting signals containing these ratings. These ratings are
displayed on the television screen for the first 15 seconds of rated programming. (See appendix 2
for the list of TV Parental Guidelines Rating Codes)

To strengthen the application of the rating system, the broadcasting industry also developed VChip technology that enables parents to block programming with a certain rating to be watchedin their homes. The industry also provided another solution called cable (lockbox) and set-top
boxes which parents can use to control the TV programs. In addition, the industry also

56

http://www.tvguidelines.org
http://www.cnn.com/US/9707/10/tv.ratings/

Copyright 2008. No quotation or citation without attribution.

7

established the TV Parental Guidelines Monitoring Board, which is responsible for daily
monitoring and consultation on the compliance of the industry to the Guidelines.
II.2.The Problems of TV-PG
The adoption of the official rating system and the compliance of the broadcast industry to thisnew self-imposed practice were not effective at protecting American children. At least, it was noteffective enough according to the PTC. The PTC argues that this rating system has several flaws,
namely:-The rating system allows the broadcasting industry to continue broadcasting the shows,some of which are not appropriate for kids to watch. By doing its part by displaying therating code sign, it is now the responsibility of the parents to control which shows areallowed to be watched. In another words, even though The PTC agrees that parents havethe greatest responsibility for monitoring and controlling the viewing habits of theirchildren, the rating system fails to secure the serious commitment of the broadcasting
industry in preventing the negative impact of the shows on children.

-

A lack of or no strong incentive for the industry to apply a consistent rating system,
especially if they perceive that the rating will affect the sponsorship or the advertisers
who see that the rating does not serve their best interests.

-

Because the code is a voluntary rating system, there has been inconsistency in rating the
program, either inter-network or even intra-network. Because of this inconsistency of therating, the V-Chip technology, which operates based on the coding of the TV-PG, will
not always be effective at controlling the objectionable programs. Moreover, the study
shows other problems related to TV-PG, such the preference for a content-based rather

Copyright 2008. No quotation or citation without attribution.

8

than age-based rating system, and the low use of V-Chip technology among the families
who are aware that C-Chip technology exists.7-

The Monitoring Board is established by the industry, the same party that set the rating
system. Therefore, the Board has a vested interest in monitoring the compliance to therating system by the industry. In addition, by putting the burden of monitoring on the
public by simply asking people to contact the Board through email or telephone if they
have complaints regarding certain TV programs, the Board appears to be failing torepresent the public interests well.

III. THE ORGANIZATION OF PTC
III.1.The Establishment and the Mission of PTC
Founded in 1995, the Parents Television Council™ (www.parentstv.org®) is claimed to be anon-partisan education organization advocating responsible entertainment. Since its inception,
the founders and early members of this NGO agree on the PTC mission that is "to promote andrestore responsibility to the entertainment industry" and “to ensure that children are notconstantly assaulted by sex, violence and profanity on television and in other media”. Today, thePTC has been developed into a national grassroots organization with more than 1.2 million

7

The Kaiser Foundation, Rating Sex and Violence in the Media, Media Ratings and Proposal for Reform
http://www.kff.org/entmedia/loader.cfm?url=/commonspot/security/getfile.cfm&PageID=14094

Copyright 2008. No quotation or citation without attribution.
members working in 48 chapters across the United States (2007).8 Bozell was the president of
the organization from 1995 to 2007, after which he was succeeded by Tim Winter.
In its website, the PTC's primary mission is “to promote and restore responsibility and decency
to the entertainment industry in answer to America's demand for positive, family-oriented
television programming”. To realize this goal, the PTC seeks to foster changes in TV
programming in at least the early hours of prime time TV to be family-friendly and suitable forviewers of all ages. In other words, the PTC founders and members, who believe that TV has
pervasive and powerful influence on children’s upbringing and behavior, seek to discourage thestakeholders in the industry from aggressively displaying graphic sexual themes and dialogue,
depictions of gratuitous violence, and profane/obscene language in TV programming. Hence,
the PTC perceives that it is reasonable to concentrate on broadcast television because they use
the public airwaves to enter every home with a television set, as well as expanded basic cable,
which millions of households rely on for their TV programming.
III.2. Promoting a “Standard” of Family Friendly TV-Program
As it was stated above, the PTC found that the FCC approved official rating system (TV-PG)
was not effective. The ineffectiveness is shown by the inaccuracy of the ratings and theinconsistency of the industry in rating the programs. In addition, a study also shows that only asmall number of American parents use the V-chip technology to block the programming. In his
remark before the Media Institute last June, Jonathan S. Adelstein, a Commissioner at theFederal Communications Commission stated that:9

8

Parents Television Council 2007 Annual Report 2007

9

Jonathan S. Adelstein, Commissioner, Federal Communications Commission:

9

Copyright 2008. No quotation or citation without attribution.

10… even parents who are aware of the V-Chip technology find the TV Parental
Guidelines, which were approved by the Commission, to be confusing andunhelpful. It requires a doctorate in cinematography to understand the differences
between “TV-PG” -- which means that parental guidance is suggested and thatthe show may be unsuitable for younger children -- and “TV-14” -- which meansthat the show may be unsuitable for children under 14.
As a result, the PTC claims that American TV programming is still airing a lot of programs that
display a lot of materials containing sex, violence and profanity.
Armed with this concern, the PTC created a set of guidelines that will assist parents in exercising
responsibility for their children's viewing habits. The guidelines, called

The Family Guide

to Prime Time Television, soon became a trademark of the PTC. This Guide simply uses
indicators similar to a traffic-light system, which are the red, yellow, and green color dots, for
rating the TV program. Each of these colored dots rates the program based on the amount of sex,
foul language and violence in each series. This ratings system is also accompanied by clear
descriptions of every prime time show, which enables parents to make fully informed decisions
about the programs that they and their families wish to view. (see appendix 3 for the descriptionof the Family Guide to Prime Time Television rating system)
III.3. Monitoring the Industry: What the PTC has done
Based on the feedback received directly from the members of the PTC, general public and fromits independent research and studies on the broadcast industry, the PTC finds that parents often
complain that the objectionable programming that comes through broadcast television or“Stuck in the Mud: Time to Move an Agenda to Protect America’s Children”, Remarks Before the Media Institute,
Washington, DC June 11, 2008

Copyright 2008. No quotation or citation without attribution.

11

expanded basic cable is often virtually unavoidable. This condition puts a tremendous burden onthem to monitor their children's viewing 24/7. Therefore, the PTC has customarily focused its
monitoring activities on broadcast television programs particularly during prime time andespecially during the "Family Hour" which is the earliest hour of network television each
evening. However, the PTC also monitors the shows in other time slots and on expanded basic
cable channels.
How does the PTC monitor hundreds of hours TV programs aired by various broadcasting
companies in the US? To begin with, due to the legal constraints, the PTC only monitors the
programs which are available for free, so it does not include the paid TV programs, such as ones
provided by HBO, Playboy TV, etc. In monitoring these programming, the PTC relies on its own
designed technology, known as the Entertainment Tracking System (ETS). With this system,
the PTC is able to scientifically track broadcasts and selected cable network programs for sex,
violence, and profanity.
The ETS monitoring mechanism is conducted by combining the work of a set of recording
machines and a team of full time analysts employed by the PTC. Every evening, the machines
record every prime-time series on ABC, CBS, Fox, NBC, the CW, Ion, and My Network TV, aswell as original programming on basic cable, including MTV. On the following day, a group of
analysts reviews the records from the previous evening and transcribes every offensive word,
every instance of sexual innuendo and every act of violence in detail. At the end of the day, thesereports are fed into the PTC’s custom-designed computerized database. Using this database of
the assessed programs, the PTC is able to generate reports and later use the reports as the sourceof comprehensive studies, e-mail alerts, television recommendations and newsletters.

Copyright 2008. No quotation or citation without attribution.

12

With this hard evidence backed by a set of information, reports and studies, the PTC hasenhanced its monitoring activities to a higher-level cause, which is educating and advocating,mobilizing the pressure and legal campaigning.
-

Educating and Advocatingo Providing free information regarding the programs that are considered beneficial
or harmful to the development of children. This information is made available tothe members and the public, including the stakeholders of the TV programs(producing companies, sponsoring companies, advertisers and the government(FCC). This information has been disseminated on its website and through suchprinted publications. Some examples of important studies are “The Alarming
Family Hour”, “No Place for Children: A Content Analysis of Sex, Foul
Language” and “The Ratings Sham: TV Executives Hiding Behind a System
That Doesn’t Work”.
o By providing the contacts of stake holders in the broadcasting industry, the PTC
is further channeling the people who wish to express their concerns to thestakeholders and their local elected legislators.

-

Campaigning:o Launching the campaigns in response to perceived indecency on television
programs by directly writing the media or campaigns that have also involved
filing complaints with the FCC.

Copyright 2008. No quotation or citation without attribution.

13

o Launching Campaigns to allow subscribers to select and pay for only the cablechannels that they prefer to watch. Today, the US has no law that requires cable
companies to offer channels or programs on an “a la carte” basis.10-

Mobilizing Consumer Pressureso Publish the information that holds the companies accountable for the television
programs that they sponsor or in which they advertise. In doing so, The Parents
Television Council released its ranking of the “Top Ten Best and Worst
Advertisers” on television. This annual report ranks advertisers according to how
frequently they sponsor wholesome, family-oriented television shows or thosecontaining sexually graphic, violent or profane material on broadcast television.
This release is expected to educate consumers on the behavior of such companies,
and in return will vote with the money they spent to buy or not to buy the
products of those mentioned companies.

III.4. Expanded Issues and Market Driven Approach
By trying to mobilize the pressure on the companies who sponsor the broadcasted TV programs,
not only has the PTC expanded the issues from its long time focus on decency, but it also has
incorporated the market driven approach in influencing the social responsibility of the broadcast
industry. By bringing up the issues of advertisers accountability, the PTC has made a statementthat television sponsors contribute to television culture by choosing to support programs with
their advertising dollars. With the publication of the list of the Top Ten Best Advertisers, the10

FCC, http://www.fcc.gov/cgb/consumerfacts/cablerates.html

Copyright 2008. No quotation or citation without attribution.

14

PTC awarded companies such as Disney and Hallmark, who choose to be responsible sponsors.
On the contrary, the Worst List put the companies who have sponsored some of the mostheinous content on broadcast television in the spotlight. Furthermore, with this statement, thePTC calls on its members and all concerned parents to consider whether their dollars will go
toward a company that supports family friendly shows or toward a company that only cares fortheir own benefits. In this list, the PTC only reviews the companies who purchased at least 25
ads on prime time broadcast programs. Applying its standard traffic light rating system, the PTC
decides that the companies with the most ads on the PTC-rated green-lighted shows were ranked
the best and on those with the most ads on PTC-rated red-lighted shows were ranked the worst.
The PTC’s market driven approach has also been strengthened by publishing awards known as
the PTC Seal of Approval. This award is given to worthy television programs, made-for-TV
movies, motion pictures, home products, and advertisers that help parents by providing orsponsoring entertainment suitable for the entire family. The PTC Seal of Approval gives
consumers the information and confidence they need to make the best choices. Right now, thePTC presents two Seals of Approval, which are the Entertainment Seal of Approval and theAdvertiser Seal of Approval. Last year, the PTC named Coca-Cola as an Advertiser Seal of
Approval recipient for 2005-2006. (See appendix 4 of this year's 2005-2006 Advertiser Seal of
Approval winners)

PTC also expands the issues that are considered to showcase the concerns of people, both as
consumers who care about how to spend their money effectively, and the parents who care about
the negative impact of the industry. Other expanded issues respectively, are the issues of thecable options and violent video games.

Copyright 2008. No quotation or citation without attribution.

15

Many parents welcome expanded basic cable to access family-friendly programming such as theDisney channel, Nickelodeon, ABC Family Channel, the Discovery Channel, and more. But fora long time, the cable TV providers have only offered the channel packages which are perceived
by many as not only forcing them to pay for channels they don't want, but actually also making
their job as a parent much more difficult. The TV cable companies have been allowed tomaintain this practice because the federal law does not regulate or require them to offer channels
a la carte. For both reasons, the PTC has been facilitating avenues for the members and the
public to express their concerns, and also directly as an organization by trying to lobby local
lawmakers and the FCC to review this regulation. In its lawsuit, the PTC directly confronts thecompanies that they call committed to the cable cartel’s anti-competitive and anti-consumer
product bundling practices.
Regarding the violent video games, the PTC has been concerned with the fact that under thecurrent laws, retailers are not obligated to impose restrictions on the sale of video games tominors. Today, a ten-year-old can purchase an Adult Only (AO rated) video game. Criticized bymany as anti art and artists, the PTC argues thatallowing higher rated video games to only be sold to adults will have no affect on the ability ofthis industry to pursue its profit and its "art" amongst adult consumers. Believing the scientificproof of the potential for irrevocable damage when children play violent video games, the PTC
has been campaigning to enforce the standards that the video game industry itself has said are
prudent and necessary. To do so, the PTC is pushing for legislation to enforce the ratings guides
for purchase of games, and endorse significant financial penalties for those who do not follow
the law. (see appendix 5 for The Entertainment Software Rating Board)Copyright 2008. No quotation or citation without attribution.

16

III.5.The Advisors and Funding
Since its inception, until 2007, the PTC was led by its founder L. Brent Bozell III, who was alongtime conservative activist and former President of the National Conservative Political Action
Committee. In January 2007, Bozell was succeeded by Timothy F. Winter, a registered
Democrat and former media executive who worked for Metro-Goldwyn-Mayer and NBC.
The President of the PTC has been supported by a Board of Directors consisting of the
Honorable Leon J. Weil (Chairman of the Board), L. Brent Bozell III (Founder), the Honorable
Robert D. Stuart (former Chairman and CEO, Quaker Oats), Pat Boone (Entertainer) and Phillip
Friedmann (Co-Founder Recycled Paper Greetings, Inc). In addition, there is also an Advisory
Board consisting of prominent figures from various backgrounds of expertise and affiliation,
politicians and entertainers, such as former football player Mel Renfro, Sen. Blanche Lambert
Lincoln (D-Arkansas), actor Coleman Luck, country musician Billy Ray Cyrus, Senator andformer 2008 presidential election candidate Sam Brownback (R-Kansas), film critic Michael
Medved, actress Susan Howard, and ION Television producer Gary Johnson (See appendix 6:
for the list of Advisory Board).
To cover all the expenses of its activities, the PTC has to mobilize revenues from various
sources. Today, the PTC relied on its funding from contribution, members fee, the revenues fromits online commercial business and the income from its partnerships with business entities suchas Wal-Mart and Amazon. In the PTC Financial Report 2006-2007, the PTC’s total revenue
decreased from $5,381,057 to $4,886,792, while the total expenses increased from $4,761,220

Copyright 2008. No quotation or citation without attribution.

17

into $5,440,856.11 As an NGO, the largest portion of its revenues is derived from contributions.
In December 2007, more than $4.6 million from total revenue comes from contributions. Today,in addition to regular donators, the PTC has received significant contributions from corporate orfoundation and individual contributors known as the Founders Club, whose annual contributions
are $5,000 and higher, and from the Leader’s Circle with donations varying from $1,000 to$4,999 annually.
IV. ANALYSIS
IV.1. Credibility
In order to achieve its missions, the PTC has encouraged high quality, family friendly
programming at all hours of the day, and particularly when young viewers are likely to bepresent. By focusing on family friendly quality, the PTC has educated and advocated for theissues that specifically and only are related to the contents that are perceived to have negative
effects on children by seeking to discourage the depictions of extreme and gratuitous violence,graphic sexual themes and dialogue, and profane language in entertainment programming. The
pursuance of these goals has been conducted through a combination of efforts, including
research, public education and support for community-based advocacy, as well as direct
engagement with regulators and decision makers in the entertainment, advertising and broadcast
industries. Through this coordinated set of strategies, the PTC has become an influential andeffective actor in promoting and addressing these issues. How can we assess these claims?

11

PTC Form 990 are available at http://www.guidestar.org/FinDocuments/2006/954/819/2006-9548190710363fbe6-9.pdf and PTC website

Copyright 2008. No quotation or citation without attribution.

18

In 2007, The PTC reached a national membership of over one million that support the agendasof the PTC through 46 local chapters across the states. In 2005 alone, the PTC provided printed
information to over 250,000 persons, and issued email alerts to over 100,000 subscribers to thisservice. The receivers of E-Alerts get information which feature updates on current projects, ongoing research, and news on advocacy opportunities. Through its website, the PTC serves over
16,000 different users per day. The success of the PTC in garnering the support has been the
fruit of its authentic efforts to invest in high cost technology of ETS and the supports of theanalysts. Since 1989, over 110,000 hours of this material have been recorded, analyzed andarchived.
Those numbers above reflect the achievement of the PTC in providing reliable information
which enables the organization to not only educate but also mobilize hundreds of thousands ofcitizens, generating support for improved content in entertainment programs, and supporting
governmental action to affect the behavior of the industry. In addition, with its research andstudies on the broadcasting patterns, the organization has been able to advocate both that theindustry be more responsible in airing the programs and that the government shape theregulations on decency in broadcasting. One example of achievement in advocating the law
making process was the signing of the Broadcast Decency Enforcement Act of 2005 by
President Bush in June, 2006, in which the PTC has been fighting for.12 This piece of legislation
cannot be separated from the PTC’s efforts in both facilitating the members and regular parents
to intensively file complaints to the FCC, and institutionally pressuring the FCC to hold thebroadcasting industry accountable, and to enforce indecency laws. In relations with advocating12

http://www.whitehouse.gov/news/releases/2006/06/print/20060615-1.html

Copyright 2008. No quotation or citation without attribution.

19

and pressuring for regulating the behavior of the broadcasting industry, the PTC has became areliable provider for TV content analysis for the FCC.
In addition, the PTC’s efforts to facilitate and to directly express the concerns to advertisers andsponsors of the aired programs have resulted in tens of advertisers withdrawing theirsponsorship of the most offensive programming. BMW, Carrier, Epson, Mercedes, Cadbury
Adams, Michelin, Nissan, Suzuki, DQ Shares, Choice Hotels and Verizon are some of thecompanies that are reportedly withdrawing their sponsorship or have contacted the PTC toclarify the situation or to apologize for the errors and promise either to solve the problems or tostop the sponsorships immediately. On a state level, the local chapter in Chicago was successfulat convincing the Toyota dealership to withdraw its sponsorship for FX’s raunchy drama Rescue
Me.
The success of the PTC - as reflected by the decision of the FCC to fine the companies forbreaking the law or the decisions of sponsoring and advertising companies to withdraw theirsupport for certain programs - have made a difference in which it discourages the airing ofindecent content in the future
Regarding the campaign on the cable choice, the PTC's Cable Choice campaign has generated
strong support among the public, and within the FCC and Congress. In fact, in mid 2008, theU.S. District Court in Los Angeles has allowed a case raised to move forward the demand that achallenge to the lack of consumers; freedom to chose the cable program they seek to view. In
one of its reports, the FCC stated two issues that have been promoted by the PTC, namely the
ineffectiveness of the TV-PG related V-Chip programming blocking technology and that cable
companies “could provide consumers greater choices in how they purchase their programming sothat they could avoid violent programming.

Copyright 2008. No quotation or citation without attribution.

20

The PTC’s involvement in monitoring the social responsibility of the industry was also
strengthened in 2007 when the PTC agreed to appoint Dan Isett, one of the Directors at the PTC
to be a commissioner in the FCC’s Consumer Advisory Committee. To maintain the PTC’s
strong role in advocating the law, in 2007, PTC President Tim Winter continued to provide
testimonies at two major Senate committee hearings.
The composition of the PTC Advisory Board can also be perceived as another factor that isstrengthening the credibility of the organization. Right now, The PTC’s Advisory Board consistsof several figures that represent national public policy and entertainment leaders across theideological spectrum. United by the common goal of helping the PTC restore social
responsibility to the entertainment industry, actors, writers, producers, and directors; talk-show
hosts and authors; elected representatives from both political parties and heads of public policy
organizations closely supervise the PTC in pursuing its goals.
The PTC relies on the FCC in shaping the regulations to ensure the decency of the TV programs.
In many cases the two organizations have shown close and good relations and cooperation in
shaping the regulations for the broadcasting industry. This situation has often resulted in
criticism, especially from the industry that the PTC has acted as a sub-organization of the FCC.
However, as many studies of the PTC and the testimonies of the PTC executives before theCongress hearings have shown, the PTC has proved its standpoint by objectively applauding theachievements of the FCC and harshly criticizing the slow response of the FCC in dealing withpublic demands.13

13

PTC: Dereliction Of Duty, How The Federal Communications Commission Has Failed The Public,
http://www.parentstv.org/PTC/publications/reports/fccwhitepaper/main.aspCopyright 2008. No quotation or citation without attribution.

21

The achievements in accomplishing the tasks in researching, educating, advocating andcampaigning have laid the foundation for the credibility of the PTC. However, in its activities
PTC has reviewed TV programming by applying its self-imposed standard and completely
ignore the official TV-PG rating that has been used by the broadcasting companies in rating theirprogram. As it will be discussed in part V, this situation poses a significant challenge to thecredibility of the PTC.
IV.2. Accountability
The foundation of almost all the information and arguments that have been used by the PTC in
educating the society and the stakeholders in the broadcasting industry is based on its genuine
archives generated by the Entertainment Tracking System (ETS). The PTC does not create,
modify or manipulate the evidence that they present in their publications. For its own part, thePTC only applies its own imposed standard (The Family Guide to Prime Time Television) tointerpret and analyze the content of the TV programs. Moreover, in reviewing the programs,
PTC analysts only focus on the decency aspect of the shows, and do not meddle with thephilosophy, the political orientation or the aesthetic and the artistic consideration of the
programs. In this sense, the PTC has appeared to be able maintain the accountability of its
activities in accomplishing its missions.
As it has maintained the transparency of its operations, the PTC has also been transparent in its
funding. Just like for profit entities, the PTC always has its financial reports audited by anindependent third party, such as Holthouse Carlin & Van Trigt LLP. PTC also makes all this

Copyright 2008. No quotation or citation without attribution.

22

report available for the public. In the annual and financial reports, the PTC mentions that thelargest part of its funding comes from the contribution of corporate, foundation and regularcontributors who committed to support the organization every year. Except for those donators
who wish not to be published, the PTC always lists the donors who annually contribute morethan $1000.
IV.3. Sanction
The PTC has not only been about the success stories. This organization has listed many cases
where the FCC has denied the pressures of PTC in raising the cases of violations to decency lawsby the companies. Moreover, both the credibility and the accountability of the PTC wereseriously at stake when the PTC was sued by a company that rejected the statement of the
President of the PTC regarding its televised show. In 2001, the PTC mobilized mass concerns
over the impact of the professional wrestling television program WWF SmackDown. It wasreported that the PTC claimed that the program caused the deaths of young children who theyfelt were influenced by watching the program. Because of this, WWE later sued the PTC for
using false and misleading statements and facts in their campaign, such as the withdrawal ofcertain advertisers from the show. As a result, in July 2002, WWE received $3.5 million and apersonal letter of apology from Mr. Bozell (Founder and President of the PTC).14

14

WWE Press Release: World Wrestling Entertainment Settles Lawsuit With Parents TelevisionCouncil Founder Brent Bozell Issues Apology, July 8, 2002
http://corporate.wwe.com/news/2002/2002_07_08.jsp

Copyright 2008. No quotation or citation without attribution.

23

The big sum of money that the PTC paid to WWE is a clear example of the penalty of
misleading and lying to the public. On one hand, this case shows that the PTC has dealt with asubject that is substantially serious and hence worth of millions of dollars of settlement fees.
The PTC learned a hard lesson that the assessments and statements of the PTC are verifiable andcan bring in good results (such as pressuring the government to take legal actions on certain
issues), but also drawbacks or penalties in terms of finance or credibility. However, on the other
hand, assuming that the PTC had learned the hard way, the public might perceive that the PTC
has become more prudent and more accurate in its analysis: providing materials for educating,advocating and campaigning and making a statement on certain issues. Therefore, sanctions to
the PTC have improved its credibility and proved the accountability of the PTC.
V. CRITICISM AND CHALLENGES
The PTC’s efforts to reduce indecent programming have been criticized by many, especiallyfrom the broadcast industry. The industry argues that the PTC’s approach to increase theregulations in the American broadcasting industry will limit the creativity and might eveninfringe upon the freedom of speech as it is guaranteed by the first amendment. On the contrary
to PTC’s approach, the industry argues that the concerns over the impact of TV programs for
American children should be addressed through promoting parental control. To do so, theindustry believes that parents are able to control and monitor the programs that are allowed to bewatched in their family by taking advantage of V-Chip technology and control box devices forcable TV.
Moreover, the industry has also put a lot of effort into providing the information to the parents
regarding the ratings of all TV programs using the FCC approved TV-PG. According to TV

Copyright 2008. No quotation or citation without attribution.

24

Watch, a TV industry-funded group, the aggressiveness of the PTC in criticizing the TV
programs and many companies in the industry are often conducted based on the study that isusing “faulty analysis and biased methodology and suspect omissions to influence the debate
and raise money.”15 In addition, the PTC is also often described as a self-appointed moral
guardian supported a by a group of conservative and religious activists.
Apart from criticism of the organization and the activities of the PTC, from the perspective of theeffort to improve the social responsibility of the broadcasting industry, there are three major
challenges that the PTC has to overcome to achieve its mission:a. Self-posed standard
In spite that the PTC has been using the traffic light system of The Family Guide to Prime
Time Television as measure to rate the programs, this guideline is in principal a self-posed
standard. Therefore, the industry has no legal obligation to comply with this standard. The
existence of both TV-PG and PTC’s The Family Guide to Prime Time Television are in factcaused by long time difficulties in legally defining the violation of decency. As an example,
even though the US Supreme Court decided that obscene material is not protected by the First
Amendment and cannot be broadcast at any time, it has to meet three criteria for TV programs
to be considered obscene, namely:

15-

An average person, applying contemporary community standards, must find that thematerial, as a whole, appeals to the prurient (arousing lustful feelings) interest;-

The material must depict or describe, in a patently offensive way, sexual conduct
specifically defined by applicable law; andMediaweek: Updated: PTC: Nets Peddling Too Much Sex; TV Watch Responds,
http://www.mediaweek.com/mw/content_display/esearch/e3i1e5a2e8d39dee108b680b014d2cc970e?imw=Y

Copyright 2008. No quotation or citation without attribution.
-

25

The material, taken as a whole, must lack serious literary, artistic, political, or scientificvalue.

Looking at the first criterion, the clause applying contemporary community standards will bereasonably difficult to apply to the entire population with various races and cultural backgrounds.
Similarly, there is also a certain level of vagueness in the second and the third criterion. As aresult, since it is difficult to apply even only one criterion to the real case of an accused violation,
it will surely be more difficult to apply all of these criteria in certain acts in the program. This is
why it is difficult for the FCC to always accept the case of violating the decency law that israised by the PTC. As it is for obscenity, there are also difficulties to legally define the violationof regulations in terms of violence and profanity. Unlike many other monitoring organizations
that monitor the compliance of parties based on commonly or at least mutually acceptable
standards, the PTC has been monitoring other parties based on the standards that they neveracknowledge.
b. Legal Limitation
Because of the problem in standard setting, the PTC is left with two choices: either trying to set amore widely accepted standard (trying to be a standard setter) or continuing its activities in whatmany perceive as policing the industry based on its own “law”. To do so, the PTC has topersuade or work together with the industry to reform the current official standard or to
predominantly influence the FCC to strengthen the regulations on decency that align more withthe standards of the PTC. By looking at the distant relationships between the PTC and theindustry, the first option does not seem feasible in the near future. In other words, the PTC could
only continue its activities by relying on its self-posed standards in which it will remain as themain obstacle for the credibility of the PTC, especially before the industry.

Copyright 2008. No quotation or citation without attribution.

26

The above vicious cycle will not be broken unless the industry is willing to reform its TV-PG or
decency is regulated with an amendment to the constitution. Since neither of these is probably
going to happen in the near future, judging the credibility of the PTC based on the use of its own
standards appears irrelevant. Instead, the existence of competing standards supposed to beconsidered as given. As a result, the analysis of credibility of the PTC should only focus on its
activities in educating, advocating and campaigning in order to pressure the FCC to improve theregulation or to enforce the existing law on decency.
c. Regulation Making or Market Approach
However, the end result of the PTC’s activities does not stop at pressuring the FCC but to affector to change the behavior of the industry. Because of the problem of the standard rating systemand competing efforts of industry and the PTC in influencing the FCC, there is another questionthat is worth asking: Is the PTC’s approach to change the behavior of the industry by increasing
the regulation more effective than its market driven approach? In recent years the PTC has used
the market driven approach to affect the industry by convincing the sponsoring companies toselectively choose the program in which they seek place the ads or to support. However,sponsorship and advertisements have never been the only source of revenue for a television
program. Often programs are sold to other networks either in the US or throughout the world.
Some programs earn their revenues in syndication and others can be further promoted to themarket as DVDs. The only production that relies on its rating and advertising are programs thatare produced solely for television. 16

16Howard J.Blumenthal and Oliver R. Goodenough, This Business of TV: The Economics of Programming and
Production, (New York, Billboard Books, 2006), p.112

Copyright 2008. No quotation or citation without attribution.

27

VII. CONCLUSION
Realizing the increase of obscenity in American television, the Parents Television Council wasestablished in 1995 to protect American children from the impact of TV programs that often
display materials that contains sex, violence and profanity. With this goal, the PTC has been
trying to improve the social responsibility of the American broadcasting industry by reducing theamount of indecent materials from their TV productions.
In achieving its mission PTC mainly relies on the pressuring the FCC to improve the regulations
or to enforce existing regulation on decency to affect the behavior of the industry. Based on its
approach, PTC appears to be credible in conducting its activities in educating advocating andcampaigning. This credibility derives from potential efficiency in pressuring the government toenforce law or to even consider to produce new regulations. PTC also hold up to its
accountability due to the transparency in its organization and its activities and also the significant
risk it takes for making mistakes.

Copyright 2008. No quotation or citation without attribution.

28

VIII. QUESTIONS FOR FURTHER DISCUSSION
1. How does the PTC determine that certain actions that are taken by the FCC are based on theinfluence of the PTC and not because of other factors?
2. What is the basis for the claim of the PTC that advertising companies withdraw or stop theirsponsorship or ads because of the pressures of the PTC?
3. How does the FCC decide on the case raised by the PTC given that the standards that havebeen used by the PTC and the industry are different?
4. Which approach is more effective: an approach to strengthen the regulations on decency ormarket driven approach that will affect the production process of certain program?

Copyright 2008. No quotation or citation without attribution.

29

VIII. REFERENCES
Adelstein, Jonathan S, Commissioner, Federal Communications Commission:“Stuck in the Mud: Time to Move an Agenda to Protect America’s Children”, Remarks
Before the Media Institute, Washington, DC June 11, 2008
Blumenthal, Howard J.and Oliver R. Goodenough, This Business of TV: The
Economics of Programming and Production, (New York, Billboard Books, 2006)
Comstock, George and Erica Scharrer, Media and the American Child, (Academic
Press, Elsevier, 2007)
Parents Television Council 2007 Annual Report 2007

Online Source
FCC, http://www.fcc.gov/cgb/consumerfacts/cablerates.html
Mediaweek: Updated: PTC: Nets Peddling Too Much Sex; TV Watch Responds,
http://www.mediaweek.com/mw/content_display/esearch/e3i1e5a2e8d39dee108b680b01
4d2cc970e?imw=Y
PBS Parents, Children and Media
http://www.pbs.org/parents/childrenandmedia/article-faq.html
PTC: Dereliction of Duty, How the Federal Communications Commission Has Failed
The Public, http://www.parentstv.org/PTC/publications/reports/fccwhitepaper/main.asp
The Center on Media and Child Health, Children’s Hospital Boston; Issue Brief: The
Effects of Electronic Media on Children Ages Zero to Six: A History of Research (Kaiser
Family Foundation, January 2005) http://www.kff.org/entmedia/upload/The-Effects-ofElectronic-Media-on-Children-Ages-Zero-to-Six-A-History-of-Research-Issue-Brief.pdf
The Kaiser Foundation, Rating Sex and Violence in the Media, Media Ratings andProposal for Reform
http://www.kff.org/entmedia/loader.cfm?url=/commonspot/security/getfile.cfm&PageID=14094
WWE Press Release: World Wrestling Entertainment Settles Lawsuit with Parents
Television Council Founder Brent Bozell Issues Apology, July 8, 2002
http://corporate.wwe.com/news/2002/2002_07_08.jsp

Copyright 2008. No quotation or citation without attribution.
http://www.whitehouse.gov/news/releases/2006/06/print/20060615-1.html
http://www.tvguidelines.org
http://www.cnn.com/US/9707/10/tv.ratings/
http://www.guidestar.org/FinDocuments/2006/954/819/2006-954819071-0363fbe6-9.pdf
http://www.whitehouse.gov/news/releases/2006/06/print/20060615-1.html.

30

Copyright 2008. No quotation or citation without attribution.
Appendix 1: Total Media Exposure and Total Media Use for 8 to 18 year Olds,
by Age, Gender, Race and Parent Education and Income17

TOTAL EXPOSURE

TOTAL USE

8:33

6:21

8 to 10

8:05

5:52

11 to 14

8:41

6:33

15 to 18

8:44

6:31

Boys

8:38

6:21

Girls

8:27

6:19

White (Non-Latino)

7:58

6:15

(Black (Non-Latino)

10:10

6:30

Latino

8:52

6:30

High School or less

8:30

5:54

Some College

8:02

6:26

College Graduate

8:55

6:42

Under $ 35,000

8:40

5:02

$35,000 – $50,000

8:28

6:25

Over $50,000

8:34

6:44

Overall
Age

GenderRace

Parent Education

IncomeAdapted from Robert, D.F., Foehr, U.G & Rideout, V (2005)

17

George Comstock and Erica Scharrer,

31

Copyright 2008. No quotation or citation without attribution.

32

Appendix 2. : TV-PG Rating System
Directed
to Olderprogramis designed
forforchildrenage 7 andabove.animatedIt may be
All Children.
This Children.
program isThis
designed
to beappropriate
all children.
Whetheror moreliveappropriate
forchildrenwho
have
acquiredthedevelopmental
skillsneededtodistinguishbetweenaction, the themes and elements in this program are specifically designed for a very young audience,
make-believe
and reality.
Themesand program
elementsisinnot
thisprogramtomay
includemild children.
physical or comedic
includingchildrenfrom ages
2-6. This
expectedfrightenyoungerviolence, or may frighten children under the age of 7. Parents may wish to consider the suitability of thisprogram for their very young children.

General Audience. Most parents would find this program suitable for all ages. Although this rating
does not signify a program designed specifically for children, most parents may let younger children
watch this program unattended. It contains little or no violence, no strong language and little or no
sexual dialogue or situations.

Parental Guidance Suggested. This program may contain some material that some parents wouldfind unsuitable for younger children. Parents may want to watch it with their younger children. The
theme itself may call for parental guidance. The program may contain infrequent coarse language,
limited violence, suggestive sexual dialogue and situations.

Parents Strongly Cautioned. This program may contain some material that many parents would findunsuitable for children under 14 years of age. Parents are strongly urged to exercise greater care inmonitoring this program and are cautioned against letting children under the age of 14 watch
unattended. This program may contain sophisticated themes, sexual content, strong language and more
intense violence.

Mature Audience Only. This program is specially designed to be viewed by adults and therefore may
be unsuitable for children under 17. This program may contain mature themes, profane language,graphic violence and explicit sexual content.

Copyright 2008. No quotation or citation without attribution.

33

Appendix 3: PTC the Family Guide to Prime Time Television rating system)SEX

FREQUENCY LANGUAGE FREQUENCY VIOLENCE

References
condoning
pornography or
masturbation,
strippers,
incest, nudityand partial
nudity, oral
sex,
prostitution,
sexualviolence,
etc…sexdepicted

shit, dick,prick, fuck,asshole, cock,
Goddamn,
profaning
Jesus Christ

sadism, death
depicted,
sexualviolence,occultviolence,graphic
depiction or
description,
rape, viscera,
decapitation,
visibledismembermentsexualinnuendo,
marital sex,
If any of these ass, screw,
sex implied,bitch, bastard,
subtopics
If used morehomosexuality,
appear more euphemisms
weapons, guns,
than 5 times
pre-coitalfor fuck,
than three
explosion,per ½ hour,
and/or postblows, bite,times perblood, medical
bump up to acoital,sonofaprocedure
three-weekred
responsible
period, bump bitch,
discussion ofJackass, piss
up to Red
pornographyormasturbation
less than 3veiled or mild occurrences
less than 5 uses
threat, fight,
innuendo
per ½ hour, if
per ½ hour, if
impliedcrap,
hell,
responsible
more than 5,
more than 3,
damn
violence, death
discussion of bump up to abump up to a
impliedsexual issues yellow-lightyellow-light

RATINGS LEGENDGreen: Appropriate for all ages

FREQUENCY

If used morethan 3 times
per ½ hour,bump up to redless than two
per ½ hour, if
more than 3,bump up to ayellow-lightCopyright 2008. No quotation or citation without attribution.

34

Yellow: Program would be unsuitable for children under the age of 14, and parents of teens may
want to preview before allowing their child to watch.
Red: Appropriate for adult audiences only