public-media-and-political-independence.pdf

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
FEBRUARY 2011

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PUBLIC MEDIA AND POLITICAL INDEPENDENCE: Lessons for the Future of Journalism from Around the World
ABOUT THE AUTHORS
Rodney Benson is associate professor and director of graduate studies in the Department
of Media, Culture and Communication at New York University.
Matthew Powers is a Ph.D. student in NYU’s Department of Media, Culture and
Communication.
NYU Ph.D. student Beza Merid also conducted research for this report.
The authors would like to gratefully acknowledge the close readings and helpful editing
of this text by Josh Stearns, S. Derek Turner and Craig Aaron of Free Press, and by our
academic and journalistic colleagues around the globe (listed at the end of this report).
The conclusions of this study, and any factual errors, are our own.
ABOUT FREE PRESS
Free Press is a national, nonpartisan, nonprofit organization working to reform the media.
Through education, organizing and advocacy, we promote diverse and independent
media ownership, strong public media, quality journalism, and universal access to
communications.
www.freepress.net
Supported by a grant from the Foundation to Promote Open Society.

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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
1
See Leonard Downie, Jr. and Michael Schudson,“The Reconstruction of American Journalism,”Columbia Journal-
ism 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 Commis-
sion 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.

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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

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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

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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.

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TABLE OF CONTENTS
PART I: PUBLIC MEDIA AROUND THE WORLD 8
Research Questions and Methodology 9
Key Findings 11
PART II: COUNTRY PROFILES 15
Australia15
Belgium17
Canada20
Denmark25
Finland28
France30
Germany35
Ireland39
Japan40
The Netherlands 42
New Zealand 45
Norway48
Sweden51
United Kingdom 54
PART III: TABLES 61
Table 1: Funding Public Media in the U.S. and 14 Leading Democracies 61
Table 2: Types of Funding and Firewalls in 14 Leading Democracies 62
PART IV: SUPPORTING DOCUMENTS 67
United Kingdom, The Royal Charter of 2006 67
Canada, Broadcasting Act of 1991 67
Denmark, Radio and Television Broadcasting Act of 2010 67
Norway, NRK’s Articles of Association 67
PART V: SOURCES OF INFORMATION 68
List of Personal E-Mail Communications 68
Bibliography 72

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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.”

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• 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),
2
A few of the countries in this category also receive small amounts of sponsorships or other commercial revenues,

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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
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.

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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).

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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.
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.

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• 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).
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).

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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.
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 ser-
vice 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).

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PART II: COUNTRY PROFILES
AUSTRALIA
Overview
Australia has two public service broadcasters: the Australian Broadcasting Corporation
(ABC) and the Special Broadcasting Service (SBS). ABC is modeled after the BBC and aims
to provide traditional public service content on TV and radio; SBS aims to provide a more
specialized service of multicultural and multilingual programming (Hitchens 2006: 24).
ABC (all channels included) has an audience share of 14 percent; SBS reaches 5 percent
of the total audience (OzTAM 2010). Due to ABC’s status as the major public broadcaster,
we focus primarily below on its funding and oversight. Australia is also notable for its
Community Broadcasting Association which coordinates nonprofit community radio
stations (CBAA 2010).
Funding
ABC receives nearly all its funding directly from the government via legislative
appropriations, and is prohibited by law from airing commercial advertising on domestic
television and radio services (although it does have the capacity to earn additional revenue
via merchandising). Early in its history, ABC was funded by a license fee, though this
was abolished in 1973 when the Labor government argued that the near-universality of
television and radio meant that direct public funding was a more equitable method of
providing revenue (Inglis 2006). In 2008, ABC received $728.9 million (A$858.4 million)
directly from the government (ABC 2009). SBS, by contrast, receives less funding from the
government ($183.6 million, A$191 million in 2008), though it is permitted to carry some
advertising (five minutes per hour of advertising and sponsorships)(SBS 2010; Hawkins
2010: 289). Funding now occurs triennially. The public service broadcasters initiate the
process by preparing a three-year budget proposal, which is then submitted to the federal
government. The government then determines whether to accept or revise those figures
in that year’s annual budget. This budget is then brought before Parliament for approval
(Department of Broadband, Communications and the Digital Economy 2010).

16
Protections of Autonomy and Accountability
Both ABC and SBS are statutory authorities functioning as independent corporations with
their own legislation and charters. ABC is governed by the Australian Broadcasting Act of
1983, while SBS is regulated according to the Special Broadcasting Service Act of 1991. Both
acts set forth a variety of legal protocols to ensure editorial independence (Hitchens 2006).
The Australian Communications and Media Authority is an independent agency with
regulatory oversight over all broadcasting, radio, and telecommunications. It is governed
by a board of seven members.
ABC is presided over by a board of directors with eight members: seven are appointed
by the governor-general on the recommendation of the government in power, and
the eighth is the managing director appointed by the board who serves for five years.
In 2007, Labor announced a plan for a new system to appoint board members
“assessed on merit” through a nomination panel ”established at arm’s length from
government.” The government would then be required to either select a candidate from
the panel’s recommendation or to explain in detail its alternative choice. As of July
2010, six appointments had been made using this process (Department of Broadband,
Communications and the Digital Economy 2010).
Transition to the Internet
In October 2008, the government released a discussion paper entitled, “ABC and SBS:
Towards a Digital Future,” in which it sought comments regarding how to deal with the
online transition. The report broadly posed two questions: What sort of content should
public service broadcasters be expected to provide? And how should this be funded?
The report drew 2,431 comments from both groups and individuals and led to the
development of a new online strategy, titled “Strengthening our National Broadcasters”
(Department of Broadband, Communications and the Digital Economy 2009). “The
importance of the ABC’s information services was particularly prominent in submissions
to the review, with over 1,600 respondents stating that public broadcasters should
provide credible, independent news and current affairs programming” (OECD 2009:
77). This report included both major funding increases for ABC and SBS as well as a
significant policy statement regarding expectations for the public service broadcasters. The
government promised an additional $178.2 million (A$185.3) over three years to expand
the range of programming, including a new television channel and website dedicated to
commercial-free children’s programming and a Continuous News Centre designed to help
ABC create 24-hour news across digital and broadcast platforms.
Comments to the initial government inquiry overwhelmingly supported the continuation
of commercial-free services. SBS’s mixed model received criticism for allowing advertising
during programming and, while the report acknowledged such criticisms, it stated that
due to the economic recession, a new restriction on “in-program advertising would

17
substantially reduce the amount of funding available to SBS to support the provision
of high quality diverse programming” (ibid.: 17) and concluded that the current model
should be left as is for the moment.
Why It Matters: News Content and Public Knowledge
Both ABC and SBS enjoy broad public support. Additionally, viewers of public service
broadcasters in Australia have higher levels of political knowledge than consumers of
commercial news. Jones and Pusey (2010), for instance, find positive correlations between
respondents who watch ABC or SBS regularly and are able to provide correct answers to
basic questions concerning the Australian political system and current events. Conversely,
those responding incorrectly to these questions were correlated with a preference for
commercial sources, leading the authors to write: “the high correlation between reliance
on commercial television for news and information and lack of political knowledge is
remarkable” (p. 465).
Survey research (ABC 2009) has shown that 89 percent of respondents believe that ABC
provides quality programming and 83 percent believe ABC provides “fair and impartial
reporting” of news and current affairs. In the government’s recent policy statement about
the future of public broadcasters, the level of positive response in the public commenting
period led the report authors to note “clear evidence of the esteem in which the two
organizations [ABC and SBS] are held by Australians” (ibid.: 2).
BELGIUM
Overview
The television industry in Belgium is linguistically split, primarily between Flemish and
French-speaking communities with a relatively small German-language sector. The primary
focus here will be on the Flemish and French broadcasters. Within the Flemish-language
market, the public broadcaster, VRT (1930), captures the largest audience share (32 percent
in 2008), followed by the lead commercial broadcaster, VTM (1989, 21 percent). A second
public channel, Ketnet (also run by VRT) receives 9 percent, while a smattering of niche
channels, typically originating either in the Netherlands or Britain receive the remainder
of the audience.6
The French market is led by commercial broadcaster RTL (1989) with
19 percent of the 2008 audience. France’s TF-1 ranks second, with 17 percent, and the
public broadcaster, RTBF (1930) takes third with 15 percent (De Bens 2004; European
Audiovisual Observatory 2009).
6
All audience share data are from European Audiovisual Observatory (2009), unless otherwise noted. All figures
are from the latest year available, which may vary across countries.

18
Funding
Each of the language markets has its own public service broadcaster. In the Flemish
sector, total VRT revenues in 2008 were $560.9 million (€457.9 million), of which 74
percent comes from a government grant. The remaining $145.8 million (26 percent) is
secured through advertising. In the French-speaking sector, RTBF’s total revenues for 2008
amounted to $474 million, with $390 million (82 percent) coming from government
grants and the remaining $84 million (18 percent) from advertising and sponsorships.
BRF, the German-language public broadcaster, operates with a comparatively modest $7.3
million (2006 figure, breakdown between public and commercial funding not provided)
(European Audiovisual Observatory 2009; for background, see De Bens 2004).
The primary form of funding for both the Flemish and French-language public
broadcasters is government appropriations that are established between the broadcaster
and ruling government via a “management contract.” These contracts (created every five
years) set forth funding levels for the length of the contract and tie that funding to a
variety of performance criteria (D’Haenens et al. 2009). Objectives are established in four
broad areas — services (e.g. reach and appreciation), innovation, staff policy and financial
management; annual funding increases are contingent upon meeting these criteria. Annual
reports are required to establish whether these objectives have been met; a representative
of the public broadcaster must then present this report to Parliament.
These contracts are themselves relatively recent inventions in Belgium’s media policy
process (Coppens and Saeys 2006). Prior to their creation in 1997, a license-fee system
was used. Critics claimed that this left public service broadcasters both underfunded
and unaccountable. Since the implementation of these contracts, audience shares have
increased for public service broadcasters (De Bens 2004; d’Haenens and Saeys 2001).
Scholars have questioned the general transparency involved in this process: whereas laws
need to go through lengthy parliamentary processes, contracts are formed between a single
department within the ruling government and the public service broadcasters (Coppens
and Saeys 2006).
Public service broadcasters are mandated to “reach a maximum number of viewers and
listeners with a range of programmes which excite and satisfy the interest of viewers and
audiences” (VRT 2010). Both Flemish and French-language broadcasters must produce
relevant national programming designed for intended audiences. This is an issue due to
the high level of cable penetration in the country and the dominance of international
programming from other European countries. Mandates are put forth in “media decrees”
passed by Parliament and then specified under management contracts established between
the ruling government and the public broadcaster (Donders 2010).

19
There are two primary types of external buffers. First, there are national regulatory
authorities — for the Flemish community this is the Vlaamse Regulator voor de Media
(VRM), for the French it is the Conseil Superieur de l’Audiovisuel (CSA). Both agencies are
intended to ensure that the public service broadcasters carry out the objectives set forth
in their contracts. They have no legal authority to intervene in programming decisions.
VRM is led by a five-person general board: by law, this must include a chairman, a judge
and three media professionals. These appointments are made by the Flemish government
and do not require parliamentary approval (Machet 2002). CSA consists of a four-person
council. One member is appointed by the government, and three are appointed by the
lower chamber of the legislature (Machet 2002).
The other buffer is the Media Council (Sectoral Council for the Media). This council is an
independent advisory body composed of industry professionals and academics. Legally, they
have no binding authority and they are not part of the contract creation process. They make
non-binding recommendations to the government whether new services should be enacted,
based on proposals put forth by the public service broadcasters (Donders 2010: 52).
A 12-person Board of Governors oversees the public service broadcasters (VRT 2010).
These individuals are appointed by the ruling government and serve for a period of five
years. Their tasks include: approval of the management contract, oversight of finances,
and the hiring and firing of executive committee members. This executive committee
consists of four individuals: managing director, and three general managers, in charge of
media, production and general affairs, respectively. The three general managers assist the
managing director in the daily management of VRT. The four-person Executive Committee
tends to all matters not explicitly delegated to the Board of Governors and the General
Shareholders Meeting.
VRT online content is funded through the same mixture of public money and advertising
revenues as television and radio. In annual reports, VRT describes itself at a moment of
transition from a “traditional radio and television broadcaster” to a “digital broadcaster,
focusing on radio, televisual, internet and mobile applications” (VRT 2010). To this end,
it has introduced a “digital media factory” project that seeks to have all broadcast content
available online, both for a broad public audience and more narrowly focused niches.
There is some debate about how funding for new VRT services (especially online ones)
will be arranged. In March 2009, the Flemish parliament passed a decree stating that any
new services from VRT must be approved by the Flemish government before actually being
produced; approval would be contingent on the recommendation of the Sectoral Council
for the Media. Some scholars see this move as consistent with the adoption of “public
value tests” (as in the U.K.), whose proponents in Belgium see as crucial to preventing
VRT from gaining an unfair competitive advantage online. Public broadcasting advocates
counter that public media are in no position to threaten commercial competitors and

20
that public value tests are thus a waste of time and money. At the moment, it appears
there is little consensus on the issue and that it is unlikely such a test will be implemented
(Donders 2010).
Newspaper subsidies
Since 1974, Belgium has provided indirect (preferential postal rates, reduced rates for
rail transport, and lower VAT sales taxes) aid to all newspapers and direct subsidies to
newspapers with low circulations and advertising revenues. As of 1989, aid to the press
became the responsibility of the separate French and Flemish communities (Blanchart
2006: 94-95). In 1999, the Flemish government ended direct subsidies but continued
indirect support (de Bens 2010). The French community revised its press aid in 2004 to
create a “Centre for Aid to the Written Press” supported by general government revenues
and a tax on television advertising revenues at the inflation-indexed level of $7.6 million
(€6.2 million). Programs include: 1) support for the creation of new daily newspapers
during their first three years of operation, 2) aid to newspapers linked to the “absolute
number of employed professional journalists” in order to promote high “editorial quality,”
3) initiatives to distribute daily newspapers in educational institutions and to “generate
press awareness among pupils,” and 4) continuation of programs to “ensure the greatest
possible diversity within the daily press” by aiding those newspapers that are “the least
profitable” (Blanchart 2006: 96-97).
RTBF was found in one analysis to offer “more and longer newscasts” than the
commercial competitors, which tend to import much of their content from abroad
(D’Haenens et al. 2009).
CANADA
Overview
The Canadian television industry is linguistically split between French and English
speaking segments. Within the English-language market, the public broadcaster CBC
(Canadian Broadcasting Corporation, founded in 1936) captured 9 percent of the
audience in 2008. Two commercial broadcasters capture larger audience shares: CTV
(founded in 1961, originally the Canadian Television Network) had a 33 percent audience
share, followed by CanWest’s Global TV (1974) with 19 percent. Shaw Communications
(1966) had a 9 percent audience share. Rogers (1931), which also provides cable and
Internet services, owns CityTV, which accounts for 5 percent audience share. The French
language market is more consolidated. Télévision de Radio-Canada (the French language
version of the CBC) had a 17 percent audience share in 2008. Quebecor Media captured
58 percent and Cogeco (1957) had 25 percent (Winseck 2008: 31; Canadian Broadcasting
Corporation 2009).

21
Funding
Total CBC revenues in 2008 were $1.6 billion (1.7 billion CDN), of which 64 percent
came from government appropriations. This total figure is for all of the CBC, including
television and radio, as well as both CBC in English and Télévision de Radio Canada
in French. The remaining revenues, $579.7 million, came from advertising and other
commercial services, such as licensing and service provisions. CBC Radio has not carried
advertising since 1974, except when required by law (e.g. during federal elections, it
must carry advertising for political parties). On the other hand, limits on the amount of
television advertising were abolished in 2009 (Canadian Radio and Television Council
2010). However, advertising on both public television and online services tend to be “less
pervasive” (no precise figures provided) than advertising on commercial media (Sparks et
al. 2006).
The CBC is funded through a direct annual parliamentary appropriation. Under the
Broadcasting Act of 1991, the CBC is established as a government department reporting
to the Ministry of Heritage (responsible for arts, culture, media, and sports programs and
policies) with a duty to submit an annual budget for approval by the current government.
Some scholars have criticized the annual appropriation process as designed to keep the
CBC “on a short leash” by “making long term planning difficult” (see Skinner 2008: 16).
Likewise, critics have suggested the process submits the CBC to a greater degree of partisan
upheaval than the British model of finance via license fees (Trudel and Abran 1996). In
March 2008, the Conservative Party-controlled House of Commons’ Standing Committee
on Canadian Heritage released a report on the role of the CBC in the 21st
century, calling
for the establishment of a seven-year memorandum of understanding that would set
forth expectations for the CBC and create funding commitments from the government. In
June 2008, the ruling Conservative government announced that it would not support the
conclusions in the report (Canadian Broadcasting Corporation 2009).
The CBC’s mandate is set forth by Parliament in the Broadcasting Act of 1991: to “provide
radio and television services incorporating a wide range of programming that informs,
enlightens and entertains.” Programming is required to be “predominantly Canadian”
and available both in English and French to “contribute to shared national consciousness
and identity.” Independence from government interference is also established in the Act,
Section 46(5): “The Corporation shall, in the pursuit of its objects and in the exercise
of its powers, enjoy freedom of expression and journalistic, creative and programming
independence.”
While the overall mandate is spelled out by Parliament, oversight and enforcement is done
by a separate agency: the Canadian Radio-Television and Telecommunication Commission
(CRTC, created in 1968 through a previous broadcasting act), which regulates all
broadcasting and telecommunications activity in Canada. Mendel (2000) writes that

22
oversight tends to focus more on achieving the principles set forth in the mandate than
on interfering in the day-to-day operations of the CBC. The CRTC has no power to
censor CBC programs. Mendel notes that Perrin Beatty, a former cabinet minister in the
Conservative government of Brian Mulroney, continued to serve as president of the CBC
through two terms of Liberal leadership at the federal level.
The CRTC reports to the Canadian Parliament through the Ministry of Canadian Heritage.
It operates at an “arms-length from government” (Mendel 2000) and while the executive
has legal authority to override CRTC decisions, in the Broadcasting Act it is stated that this
can only happen when the decision taken by the CRTC distracts from attaining the policy
objectives as set out in the Act.
The prime minister appoints individuals to the CRTC, which is composed of a chairman,
two vice-chairmen and 10 commissioners. All positions are appointed to five-year terms
and are staggered. No specific criteria for CRTC appointments are contained in the
broadcasting legislation. One analysis (Gates 1998) noted: “All prime ministers except
[Pierre] Trudeau [1968-1984] and [Louis] St. Laurant [1948-1957] have shown some
willingness to appoint individuals of a differing political affiliation. Every government
has appointed some known non-partisans.” Typically, appointees have experience either
in broadcasting, law or business. Since 1984, CRTC appointees have received salaries and
been employed full-time.
As stipulated in the Broadcasting Act, a 12-person Board of Directors is responsible for the
management of the CBC. The prime minister makes all appointments; all terms last five
years. From 1936-1998, 90 percent of appointees were part time and received a per diem
rather than a salary (Gates 1998).
The transition to online takes place within two broad discussions about (1) the
transformation of CBC/Radio Canada into a multiplatform “content company” rather
than a broadcaster with “separate and discrete media lines” (Canadian Broadcasting
Corporation 2009) and (2) the financial funding necessary for such a set-up. Because
“online” is not treated as a separate channel, funding for it comes from existing television
and radio production budgets and is not broken down separately in annual financial
reports (it has been this way since the launch of Web services was reported in the 1999-
2000 annual report). With 4.8 million unique monthly visitors, CBC.ca is Canada’s most
popular English language news site online. Podcasts prove popular as well, with audiences
downloading more than 2 million podcasts monthly (ibid.: 18).
The second issue of financing the CBC in a digital age is a continuation of long-standing
funding issues for the corporation. Broadly, there are two main issues, and concerns/
initiatives stem from one or the other. First, the CBC is partially dependent on advertising
revenues and is therefore subject to general market fluctuations and more specific

23
transformations in the allocation of advertising dollars. In the 2008-2009 budget,
advertising revenues were off $65 million against budget estimates; estimated shortfalls
against the budget for 2009-2010 are $171 million (Canadian Broadcasting Corporation
2009). Second, the CBC’s primary source of revenue — government appropriations —
is set annually. This arrangement makes long-term financial planning difficult for the
corporation, and it has lobbied repeatedly to institute a multiyear agreement. As noted, the
House of Commons’ Committee on Canadian Heritage released a report in 2008 with this
suggestion — a seven year memorandum of understanding that would set forth funding
commitments — but was not supported by the ruling Conservative government.
Short of broad changes to these two above-mentioned features, the CBC is left to seek
funding initiatives within this structure. One new revenue stream is a CRTC proposal
for value-to-signal models, which would permit conventional television broadcasters to
negotiate compensation from cable and satellite companies for the value of their signals,
which these services (cable and satellite) provide without compensation. This proposal
puts CBC together with other traditional broadcasters (e.g. CTV and Global) in demanding
payments from cable and satellite providers (e.g. Bell, Rogers, and Shaw).
On the side of government appropriations, in March 2009 the Ministry of Canadian
Heritage announced the consolidation of the Canadian Television Fund into a new
Canadian Media Fund whose purpose is to finance original Canadian productions on
a variety of platforms. In the past, 37 percent (roughly $100 million Canadian) of the
CTF was dedicated to the CBC (the rest was competed for by broadcasters and individual
producers). The new CMF broadens the distribution reach beyond television (requiring
recipients to make the work available on a minimum of two distribution platforms),
though it is not clear whether a certain percentage will be set aside solely for the CBC, a
move the corporation prefers.
A variety of analyses demonstrate that the CBC provides greater, in-depth news coverage,
especially with regards to original “Canadian” programming7
and international news, than
its commercial competitors. Hoskins et al. (2001) find that the CBC shows a much higher
percentage of Canadian programming than private broadcasters. CBC English Television is
81 percent Canadian throughout the day, with the percentage rising to 91 percent during
prime time. In contrast, commercial broadcasters hover consistently around the 50 percent
level required by the CRTC. On international coverage, the CBC employs more reporters
and operates more foreign bureaus than CTV or any other commercial broadcaster.
One analysis (Morrison 1998) finds CBC coverage to be more informational and less
sensational, with “more in-depth reporting” than commercial counterparts.
7
Concerns regarding the amount of available Canadian programming are a perennial issue in Canadian broadcast
policy. Due to the relatively cheap and accessible programming available from the United States, a primary reason
for creating a public broadcaster was to assure that programming produced by Canadians and for Canadians would
be available. At times, this has led to strategic equivalence between“national”programming and“public”program-
ming to the protest of French-speaking Québécois (Raboy 1990).

24
Within the CBC, producers have generally been free of constraints from management (e.g.
boards of directors), just as the CBC as an institution has generally been free of constraints
imposed by government (Raboy 1990: 167). Occasional examples to the contrary are
generally seen as proving the rule. In the 1960s, a popular (and entertaining) public affairs
show, “This Hour Has Seven Days,” was taken off the air amidst a crisis of national unity
for highlighting divisions between English- and French-speaking Canadians (Raboy and
Koch 1986). More indicative of the contemporary relationship between CBC producers and
the state was the airing on CBC News of three documentary films in March and April 1992
about Canadian involvement in World War II. Media scholar David Taras (1995: 725) writes
that the films “aggressively challenged the conventional wisdom that Canadian servicemen
had performed magnificently and with great chivalry in a cause unblemished by the stain of
dishonor. Though the documentary emphasized the dignity and bravery of ordinary soldiers
in a graphic and powerful way, it delivered a seething indictment of what it depicted as the
immorality and incompetence of senior Canadian and British commanders.”
The CBC enjoys broad public support. A 2008 poll by Friends of Canadian Public
Broadcasting found that, nationwide, about 76 percent of respondents either favored the
CBC’s current funding levels or wanted them increased. Only 14 percent said they favored
cutting the CBC budget (Cobb 2008).
The CBC has garnered prestigious national awards (the Michener Award) for journalistic
excellence. In 2008, it shared honors with the Canadian Press Agency for bringing to light
the widespread use of taser guns by the RCMP (national police). In 1999, CBC radio was
honored for its coverage of a vote-splitting scheme (in which independent candidates
were encouraged and funded to run for office by the Conservative Party in an attempt to
“split” the left-of-center votes away from the New Democratic Party) in the province of
Manitoba. The CBC has also provided crucial investigative coverage in recent political
scandals, both foreign (the case of the Afghan detainee scandal) and domestic (the Liberal
Party sponsorship scandal). In the case of the Afghan detainees (which involved Canadian
forces transferring prisoners to Afghan security forces who in turn tortured the prisoners),
the CBC acquired and reported on crucial government documents implicating the national
government in the scandal. In the case of the Liberal sponsorship scandal (Kozolanka
2006), which entailed the funneling of public funds to the province of Quebec (for pro-
Canada sponsorship at public events) back into the coffers of the Liberal Party, CBC
reporters were crucial in uncovering and broadcasting evidence of the issue. The event was
key in leading to the subsequent electoral defeat of the Liberal Party, which had been in
power for over a decade. Thus, while often accused of a “liberal” bias, the CBC has been
considered by some a key actor in bringing down the Liberal Party.8
8
In Canada, ruling governments can be forced to hold a new election when the opposition parties refuse to pass
the budget. This happened in the case described above. Canada’s Liberal Party is a center-left party that is generally
leftist on social issues (e.g. environment, health care, same-sex marriage) while championing balanced budgets and
strong economic growth. In many ways it can be seen as comparable to the U.S. Democratic Party. Further to the
left is the National Democratic Party, which has never controlled the executive but remains a key minority player in
parliamentary politics, as Conservatives and Liberals need to consult with them in order to pass budgets.

25
DENMARK
Overview
Public broadcasters are central players in Danish television, accounting for 69 percent of
the total daily viewing audience (and 76 percent of the prime time audience). The older
of the two primary public broadcasters, the Danish Broadcasting Corporation (DR), was
founded in 1925, and in 2008 its two channels captured 29 percent of the total daily
viewing audience. The newer public broadcaster, TV2, was founded in 1988: its seven
channels had 40 percent of the 2008 audience share. Danish private channels (chiefly
Kanals 4 and 5) account for only a slim portion of the total audience (1.5 percent); the
bulk of the competition for public media comes from foreign channels, which account for
30 percent of the total audience.
Funding
In 2008, total revenues for DR were $787.9 million (€499.4 million), of which 91 percent
came from the license fee. The remaining 9 percent derives from licensing and service
provisions; there are no revenues from advertising. TV2 is also publicly owned; however,
it is financed almost entirely by advertising and other commercial sources (some regional
services of TV2 receive public funding). Total TV2 revenues in 2008 were $473.2 million
(€299.9 million). While TV2 captures the largest audience share, it is in poor financial
health and faces an uncertain legal future, as the Danish government has sought to
privatize it, so far without success, since 2003 (European Audiovisual Observatory 2009).
The focus of the analysis to follow is on DR.
In 2010, the license fee was $389 per year. The fee is paid per household on the basis of
owning a television or any other media device that can receive television broadcasters
(e.g. personal computers with Internet access, mobile phones, etc.). DR itself collects the
fee biannually, through an administrative arm known as DR Licens. Parliament sets the
license fee every four years, as stipulated in the Radio and Television Act. DR’s executive
board sets the budget for its activities annually. This budget is submitted for approval to
both the Ministry of Culture and the Danish Parliament (Denmark Radio and Television
Broadcasting Act 2010).
Every four years, DR and the Ministry of Culture enter into a contract that sets forth the
tasks DR is expected to perform in that period. The contract defines DR’s public service
purposes, including: strengthening citizens’ capacity for democratic self-governance,
reflecting the diversity of Denmark, stimulating creativity and culture, and promoting
interest in a wide range of knowledge. Specific obligations include broadcasting a

26
minimum of 560 hours of original news programming a year between the hours of 5 p.m.
and midnight; providing online news in the languages most commonly used by Danes
and resident immigrants; and increasing the time devoted to Danish-produced drama by
10 percent over the average output in the previous four-year contract (Danish Ministry of
Culture 2007).
Enforcement and oversight of that contract fall to the Radio and Television Board (RTB),
an independent regulatory authority established in 2001. The RTB monitors both public
and private broadcasters to ensure they are fulfilling their legal obligations (in DR’s
case, this means fulfilling its public service function as set forth in the contract). As with
many independent authorities in the realm of Danish cultural production, RTB is based
on an “arm’s length principle,” the idea that while the Ministry of Culture may operate
as the “architect” of cultural policy, it cannot intervene in the actual process of cultural
production (Duelund and Valtysson 2010). It consists of eight members, seven appointed
by the Ministry of Culture (i.e. neither parliamentary approval nor proportionality are
required) (Fievé 2010, personal communication) and coming from backgrounds in law,
finance, administration, business and media/cultural policy (Jauert and Sondergaard
2007), and one nominated by the Cooperative Forum for Danish Listeners and Viewers
Association (Denmark Radio and Television Broadcasting Act 2010). All members serve
four-year terms (Herzog 2004). While all members are appointed at the same time, there
are no term limits on reappointments; since establishment in 2001, there have been
several members who continued from one four-year term to the next (Fievé 2010, personal
communication). The RTB replaced the Broadcasting Councils, which were often referred
to as “mini-parliaments” because the appointments were largely based on political
affiliations (Humphreys 1996: 156) as opposed to the professional backgrounds that
are necessary for appointments today. RTB was thus created to be a regulatory authority
characterized more by professionalism and less by political partisanship.
Internally, the Executive Board, made up of 11 members elected for four-year terms,
provides a buffer between the public broadcasters and the government in power. The
Ministry of Culture appoints three members, including the chairman; six are appointed
by parliament, and two are selected by the employees of DR (DR Executive Board 2010).
Parliamentary appointments are made proportionally, so that all of the major political
parties can put forward their own appointee (Radio and Television Board of Denmark
2004). The primacy of political affiliations is tempered somewhat by the requirement that
Executive Board members be drawn from the realm of media and arts, as well as from
politics, business, and management (Jauert, Poulsen and Sondergaard 2007; Radio and
Television Board of Denmark 2004). Executive Board terms are not staggered, though
board members can be re-appointed and frequently are. Since the model was introduced
in 1988, it has never been the case that all members left at the same time. Typically, after
an election some of the members appointed by the previous parliament will leave and if a
new government takes power, the three members appointed by the previous minister will
leave (Jauert 2010, personal communication).

27
The Executive Board maintains responsibility for the financial management of DR and
conducts internal “value tests” to ensure that programming services meet the “cultural,
democratic and social needs of society” (Danish Ministry of Culture 2007). The Executive
Board, in turn, appoints members of the Management Board, which oversees day-to-day
operations (especially programming decisions) of DR broadcasting. In sum, as Hallin
and Mancini (2004: 169-170) note, Danish public broadcasters “shade more towards the
parliamentary model [e.g. proportional representation in oversight divided among the
relevant social and political groups], though still with a high level of autonomy.”
DR Online is the largest Danish online news provider and has 24-hour staffing for its site
(Danish Broadcasting Corporation 2008). Recent initiatives include a portal with health
information, a portal that provides personal advice for young people, and a new delivery
system that provides news content to screen at bus and train stations. Currently, the public
broadcaster is free to develop online initiatives at it sees fit. There is a formal process
wherein it submits plans to the RTB, which in turn provides “comments” on the proposed
services. These comments are non-binding, though positive comments are typically seen
as approval. It is expected that the board is “likely to have formal decision making powers
[over online, just as it does for radio and television] in the near future” (Bron 2010: 49)
Several content analyses demonstrate that Danish public broadcasters provide more
hard news coverage than their domestic commercial competitors and U.S. commercial
television. Curran et al. (2009) find 71 percent of all DR evening news programming to
be “hard news,” while only 63 percent could be similarly classified in the United States.
Public broadcasters are also found to do a more complete job of exposing the entire
citizenry to public affairs news content. Whereas only 34 percent of low education (up
to high school diploma) persons in the United States watch national television news, 72
percent of similarly low educated citizens do so in Denmark. Another content analysis
(Lund and Berg 2009) shows news and current affairs accounting for 49 percent of all
programming content on the public broadcaster (DR) versus only 2 percent of all content
on the leading domestic commercial channels (Kanals 4 and 5, combined). A recent
study examining election news coverage of both DR and TV2 in 1994, 1998, 2001, 2005
and 2007 found that the public channels “were not biased” and “were professionally
balanced,” providing proportional coverage to all of the political parties according to their
electoral strength (Hopmann 2009).
In 2007, DR purchased, aired and defended a lengthy television documentary (“Den
Hemmelige Krig”), which found the Danish government’s involvement in the Afghanistan
War to have been established on a dubious legal basis in violation of the Geneva
conventions. It also demonstrated the Danish government’s (a center-right coalition
at the time) complicity in handing over prisoners to the American government, with

28
the knowledge that they, too, broke the conventions. The documentary was subject to
harsh criticism from the prime minister, the minister of defense and several newspapers
sympathetic to the center-right government. DR defended both the documentary and
the decision to broadcast it. Eventually, it was subject to review by a group of experts at
a journalism school and found to be a credible work of journalism (Kleis Nielsen 2010,
personal communication; Bondbjerg 2009).
FINLAND
Overview
In Finland, the public broadcaster, YLE (Yleisradio Oy), captures 41 percent of the daily
audience share. That figure is spread out between its two channels, TV1 (the main news
channel), which has 24 percent audience share and TV2, with 17 percent. The leading
private channels are MTV3, Nelonen, and SubTV.
Funding
YLE’s total 2007 revenues were $553.7 million (€409.1 million), with 95 percent derived
from license fees. The remaining portion was generated through private broadcasters’
licensing fees (a separate fee paid by commercial broadcasters for broadcast rights) and
service provisions (e.g. sales of programs). Under current law, YLE may not generate
additional income through advertising (Bron 2010). The fee is set annually by the Ministry
of Transport and Communications and collected by the television fee office, a department of
the ministry. The current license fee (2010), paid by all households with a television, is $295.
The Finnish Communications Regulatory Authority (FICORA) is an independent
regulatory authority (operating under the Ministry of Transport and Communications)
of both private and public broadcasters. The agency’s duties include collecting the license
fee and monitoring content and advertising amounts of television and radio programs.
It has no legal authority to intervene in programming decisions prior to broadcast. It is
headed by a Board of Directors, including a director-general (appointed by the Ministry
of Transport and Communication) who serves for five years and may be reappointed. The
other seven directors are appointed by the director-general (Lappalainen 2010, personal
communication).
YLE is overseen internally by a 21-member Administrative Council. Members are elected
by parliament during the first parliamentary session and continue to serve until the end
of the session (which normally lasts four years); they may be re-elected. Two additional
representatives are appointed by YLE personnel and are entitled to attend and speak at
the meetings of the Council (though they hold no voting power) (Prakke et al. 2004:
219). Members of the YLE Administrative Council are elected by members of the different
political parties and their political affiliations are listed on the annual reports. As of

29
2009, seven members belonged to the Centre Party, six to the Coalition Party, five to the
Social Democratic Party9
and one each to the Swedish People’s Party, Green Party and Left
Alliance. While members of the Administrative Council are political appointees, they are
required by law (in the Act on Yleisradio Oy) to “comprise people familiar with science,
art, educational work and business and economic life, and who represent different social
and language groups” (Ministry of Transport and Communications in Finland 2005:
2). The Council is charged with monitoring the administration of YLE and assuring that
finances are properly spent.10
In turn, the Administrative Council elects annually the Board of Directors, which
comprises a minimum of five and a maximum of eight members. By law, Board members
are not allowed to be members of the Administrative Council, nor belong to YLE’s senior
management and should represent “diverse expertise.” By law, the Board’s task is to decide
on the budget for the following year, to provide an annual report on finances and to elect
and/or fire the public broadcaster’s managing director and to set his/her salary. It also
hires and fires other members of the senior management. Finally, the Management Group
is charged with day-to-day management of YLE: positions include the director-general,
program areas directors (e.g. children’s TV, news, entertainment), etc.
Since 2004, the number of citizens paying the license fee has fallen. In 2009, a
parliamentary working group issued a report recommending the replacement of the
license fee with a tax or “media fee” to be levied on all citizens, regardless of ownership
of a transmission device, beginning in 2011. The idea is to reduce the annual contribution
per citizen, increase the total funding for YLE, and avoid direct government funding to
maintain YLE’s political independence (Nieminen 2010: 11). YLE has been very pro-active
in making its news programs available through the internet, with plans to extend its
regional services online as well (Nieminen 2010: 4), and it has also been expanding its
multi-cultural programming both online and on television for linguistic minorities as well
as new immigrant populations (Horsti 2010).
Newspaper subsidies
Public funding has been used since the early 1970s to support Finnish newspapers
affiliated with political parties to promote “political discourse,” to support non-
newspaper publications “devoted to political and social opinion,” and to selectively aid
those newspapers in financial distress. In 1999, these subsidies were $16 million (80
million FIM) (Picard and Gronlund 2003: 112). Additional small subsidies are provided
to newspapers and electronic publishing in the Swedish, Samí and Romani languages.
Subsidies have helped keep alive politically oriented newspapers and viewpoints that
would be marginalized if left only to market forces. In 2008, however, subsidies to party-
9
On the political spectrum, the Social Democrats are left, Coalition Party is right and Centre falls between the two.
10
The information in this section was also verified by Horsti (2010, personal communication).

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affiliated newspapers were ended, and by 2009 only direct subsidies to minority language
publications ($0.7 million) and cultural and opinion journals ($1.4 million), shared by
about 150 publications, remained (Nieminen 2010: 63). However, all newspapers continue
to receive significant tax breaks (0 percent VAT sales tax) and delivery subsidies, which
together amount to more than $400 million per year (ibid.).
Curran et al. (2009: 13) find Finnish public television to be “more hard news oriented and
outward looking than American commercial television,” with 83 percent of all evening
news programming on YLE classified as hard news, compared with 63 percent in the
United States. Further, public service television is found to expose a greater diversity of
individuals to the news. Whereas only 34 percent of low education (up to a high school
diploma) persons in the United States watch national television news, 73 percent of
similarly low educated persons do so in Finland; and whereas only 30 percent of low
income ($24,999 or less annually) watch national news in the United States, 82 percent
do so in Finland. Building on a study of French and U.S. newspapers (Benson and Hallin
2007), Väliverronen and Kunelius (2008) show that Finnish newspapers are more likely to
incorporate civil society viewpoints and provide background historical information than
the U.S. press.
FRANCE
Overview
The French public broadcaster, France Télévisions (FTV), operates two primary channels,
France 2, the national public television station and France 3, the network of regional
television services.11
Together, the two channels capture 17 percent and 13 percent of
the viewing audience, respectively (2008 figures). The French-German state-funded
cultural channel Arte, which offers evening programming only, including a short
newscast, also competes for a small audience share. The single most watched channel
is TF1, with 27 percent audience share. Formerly a public station, TF1 was privatized
in 1987. M6 (launched in 1987) is privately held and captured 13 percent of the 2008
viewing audience. Canal+ (founded in 1984) operates as a premium channel (with some
programming only available to subscribers) and had a 3 percent audience share in 2008.
11
France Télévisions also operates several smaller channels, including the digital-only France 4, France 5 (which
shares half of the broadcasting day with Arte, the French-German cultural channel), and RFO/Reseau France Outre-
Mer, a network of television and radio channels for overseas French departments. The French public broadcaster
also has a financial interest in several thematic digital channels. Other publicly-funded media include France 24
(television) and Radio France Internationale (RFI), internationally-oriented news channels available in both French
and English, as well as a host of domestic radio channels including France Inter, France Culture, and France Mu-
sique.

31
Funding
Total funding for public broadcasting (including both radio and television) amounted
to $4.3 billion (€2.75 billion) in 2008. Of that amount, 74 percent is generated through
public funding and the remainder from commercial advertisements.
Public funding is provided through a license fee (known as the contribution à l’audiovisuel
public) and is paid annually with the residence tax (known as the taxe d’habitation) based
on possession of a television set. Thus, the license fee covers all family members residing
under the same roof. At present, the license fee amounts to $158 (121€) annually (Bron
2010; Open Society Institute 2005).
The overall process of funding public service broadcasting begins in July each year, when
the budgets for France Télévisions and France Radio are drafted by the government in
power via both the Ministry of Culture and Communication and the Ministry of Finance.
The prime minister sets the budget and then, generally in November, sends it on to the
National Assembly and Senate (Sénat), which approve the final budget and license fee.
In 2008, President Nicholas Sarkozy announced his intention to end commercial
advertising as a funding source for France Télévisions. In March 2009, legislation was
passed that removed advertising from public service television between the hours of 8
p.m. and 6 a.m. The legislation called for further discussions in 2011 to decide whether
to extend the ban to hours prior to 8 p.m.; because of political and judicial opposition
(including from the Conseil d’Etat, as well as complaints filed before the European
Commission), a “moratorium” on any action to ban daytime advertising has been put in
place for five years (Berretta 2010; see also Levy 2010). Jean-François Copé, the leader of
the UMP majority party in the National Assembly and the chair of the commission that
proposed the specific funding and other changes (see more below), recently stated: “On
a personal level, I think that this moratorium of five years should be renewed eternally”
(Berretta 2010; see also Levy 2010).
Ironically, the ban on advertising was a goal long sought by the left in France as a way to
make FTV more like the BBC, providing a clear public service alternative to the commercial
TF1. For example, the Copé commission report notes: “For the new public television,
[attracting] audiences must be an ambition and not an obsession. New audience measures
will take into account the quality of the programs as well as audience satisfaction” (Copé
2008: 7). Sarkozy’s reforms, however, have been generally interpreted as driven by different
kinds of motivations, notably the desire to strengthen TF1, owned by a close political ally
of the president, and to weaken public service television by simultaneously cutting its
budget and increasing its dependence on the state (Levy 2010: 8). Sarkozy nevertheless
guaranteed to replace public television’s lost advertising funding “euro for euro” with new
public funding.

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While it is not clear yet that this goal has been accomplished, several new fees and taxes
are being enacted to at least partially meet the shortfall: 1) a small license fee increase
(€3), 2) a turnover tax on telecommunications companies and Internet providers initially
planned at 0.9 percent of turnover but cut in half after intensive industry lobbying against
it, and 3) a yearly tax of €80 million “on those commercial television companies which it
was expected would benefit by the end of advertising in peak time on FTV” (Levy 2010: 7).
French public television has had a long, hard road from being under the thumb of the
state (as during the de Gaulle years in the 1960s) to achieving a certain measure of
independence in recent years. By broad consensus, this gradually won autonomy has been
weakened by unilateral measures taken by President Nicolas Sarkozy beginning in 2008.
There remains a High Council for Broadcasting, or CSA (Conseil superieur de l’audiovisuel),
which serves in principle as the chief buffer between the government in power and the
public service broadcasters. Established in 1989, the CSA is led by nine commissioners.
Three of the commissioners, including the chair, are appointed by the president, three
by the Senate president, and three by the president of the National Assembly (based on
the model of the French Supreme Court). While there are no legal prohibitions per se to
prevent a “packing” of the CSA in the case where a single party controls the presidency,
Senate, and National Assembly, the actual practice has been to nominate commissioners
without strong partisan attachments and who possessed needed expertise (Méon 2010,
personal communication; see also Méon 2003). CSA commissioners serve six-year
terms with mandates staggered so that one third of the Council leave every two years.
Additionally, commissioners are legally required to refrain from making public comments
on positions before the Conseil (CSA 2010).
The CSA has no authority to set funding levels and is charged primarily with monitoring
television programming to see that it fulfills its public service obligations, as well as
providing “youth ratings” for programs similar to the U.S. film ratings (Méon 2003). Prior
to the Iraq war, the CSA advised journalists to correctly identify sources of information;
during the war, it issued recommendations regarding the portrayal of prisoners. Similarly,
the CSA monitors and reports its findings about the amount of news coverage accorded
to the various political parties to assure a degree of “pluralism and equity” in their
treatment, especially of the opposition parties in relation to “the executive and the parties
of the governing majority” (Kuhn 2010b: 11). All recommendations, it should be noted,
are issued after the broadcast, and the CSA is not legally capable of censoring broadcast
materials (Open Society Institute 2005; Kuhn 2010a).
In the past, the CSA has appointed the directors of France Télévisions and France Radio.
These are crucial positions in that the directors have a great deal of discretion in hiring
personnel and in choosing and scheduling programs. As French media scholar Raymond
Kuhn (2010b: 11) sums up: “Prior to the start of the Sarkozy presidency the Council has

33
survived alterations in government between left and right over an eighteen year period …
its existence had constrained the freedom of maneuver of president and government to
interfere directly in the management of public television.”
In addition, an Administrative Board is responsible for more direct oversight of France
Télévisions. The primary task of the board is to oversee the long-term financial planning
for France Télévisions; an independent external evaluation concluded that the board is
“hardly involved in daily management” (Open Society Institute 2005: 673). The board has
14 members, each serving five-year terms, and is composed of two members of parliament
(one appointed by the National Assembly, the other by the Senate); five civil servants
appointed by the government in power; five members appointed by the CSA who must be
“qualified” to serve in the capacity of broadcast regulation; and two members appointed
by the staff of France Télévisions.
Similar to the Charter Review process in the United Kingdom, FTV periodically negotiates
“contracts” with the government over its public service rights and responsibilities. In 2007,
a new contract was agreed upon (Levy 2010: 2). This contractual process has also been
undermined by President Sarkozy’s recent interventions. Less than a year after the 2007
contract was finalized, Sarkozy effectively nullified it, calling for the end of all advertising
on public television and other reforms he deemed necessary (no prior notice had been
given to CSA or other television officials). He launched a commission, chaired by Copé,
to undertake a wide-ranging review of FTV. Recommendations of the commission (whose
opposition party members had quit in protest midway through the process) led to new
legislation passed in March 2009. In addition to dramatic changes in funding, by far the
most important additional “reform” is shifting the power to name the director of FTV
and France Radio. Previously, as noted, the CSA held this prerogative; henceforth, the
president will make these five-year appointments (coinciding with the president’s term
of office) directly, with consultation with the CSA and in agreement with parliamentary
commissions (requiring a 3/5 majority). However, “most commentators saw these
[limitations] as little more than window dressings in a futile attempt to mask a dramatic
increase in presidential direct control of FTV” (Levy 2010: 8). In general, the CSA was
sidelined and did not play a major role during the Copé commission proceedings.
Resistance on the part of French public television has not disappeared entirely. Sarkozy’s
push to eliminate all advertising for France Télévisions has been delayed in part because of
the opposition of FTV staff and administration, including former CEO/director Patrick de
Carolis, who as a result was not reappointed to the post (Psenny 2010).

34
According to several observers, French public service broadcasters’ “online presence is
underdeveloped compared to that of the BBC” (Kuhn 2010b: 1; see also Levy 2010: 3).
Given the current French preoccupation with questions of control, direction, and funding
of public television, questions of how it will adapt to the online environment have not
been central.
Notably, however, the French government justified its tax on telecommunications
companies to help make up the shortfall in decreased advertising funding for FTV by
arguing that “convergence means a wider range of operators benefit from, and hence
should contribute to, the costs of public service content” (Levy 2010: 12). The Copé
commission report (Copé 2008: 40) also explicitly exempted the FTV Internet sites from
any ban on advertising.
Newspaper subsidies
Press subsidies now make up about 13 percent of total French newspaper revenues,
reportedly the highest percentage in Western Europe (Mathien 2003: 146). At first, general
subsidies were made available to all newspapers in the form of reduced postal rates,
distribution aid, and preferential tax rates to journalists as individuals (Charon 2005).
Beginning in the early 1970s, additional small direct subsidies were provided to politically
oriented newspapers with low advertising receipts and circulation that provide “ideological
diversity.” These subsidies are content neutral and have been granted to newspapers
from the far-right to the far-left, including the Front National-linked Présent, left-leaning
Libération, the Catholic La Croix, and the communist L’Humanité (Albert 2004: 105).
Press subsidies have been paid for at least in part by “a national tax on public and private
television advertising revenue” (Dennis 2004: 11).
After a lengthy process of consultation with publishers, journalists, and concerned publics
(“Etats généraux de la presse écrite “) during the fall of 2008, the French government
announced additional measures totaling $946.7 million (€600 million) over three years
beginning in 2009 to help newspapers during the current economic crisis, including: a
“ninefold” increase in funding for home delivery of newspapers (from €8 million to €70
million, about $100 million), reductions in taxes, free weekly newspaper subscriptions
to 18-24 year olds (given by publishers, with the state paying for delivery), and grants
(€20 million, or $28.2 million) to support online-only news operations as well as to help
newspapers improve and expand their websites (Wauters 2009; see also Etats généraux de
la presse écrite 2009 and Pirot 2009).

35
Research on French media shows that public service broadcasters provide a wide range of
coverage addressing issues of public relevance. Public channels, for instance, regularly air
political shows that cannot be found on the channels of commercial broadcasters. These
have included 100 minutes pour convaincre (100 minutes to convince) on France 2 and
France Europe Express on France 3 (Open Society Institute 2005). Holtz-Bacha et al. (1994)
show that broadcast election coverage in France tends to focus more on logical appeals,
whereas comparable U.S. election coverage focused more heavily on emotional appeals.
In a comparative study of election news coverage by national private and public television
channels in Germany, U.K., and France, and national private channels in the United States,
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.
Leidenberger (2010) compares public and commercial television news in Germany and
France and finds that the public news in both countries is more focused on politics than
the commercial channels. He also reports, however, that French public (France 2) and
commercial (TF1) news are very similar on a number of dimensions, including their focus
on sensational news (catastrophes, disasters, and delinquency, etc.), which he attributes
to France 2’s reliance on advertising and market pressures to imitate its commercial
competitor. Presumably, in the future, a less-advertising-reliant France 2 might differentiate
itself to a greater degree from TF1. Benson’s (2009a) case study of immigration news
coverage likewise found France 2 and TF1 to be similar in many respects (length of
news segments and sound bites, diversity of voices and viewpoints, proportion of news
generated by the political field, etc.), but showed that France 2 — as well as the German-
French entirely publicly funded Arte — was more likely to be critical of the government
and the majority party than TF1.
Research comparing French and U.S. newspapers both offline (Benson and Hallin 2007;
Benson 2009b, 2010) and online (Benson, Orsten, Powers, Willig, and Vera 2010) has
found the French press to be both more internally and externally pluralist, just as or more
critical of the major political parties and government, and more likely to make room
for in-depth debate and analysis of issues. French newspapers receiving direct subsidies
such as La Croix or L’Humanité were just as ideologically diverse and critical as American
newspapers as well as other French newspapers (Benson 2009b, 2010).
GERMANY
Overview
German public broadcasting comprises two basic elements. The older ARD was created
in 1950 as a network of regional broadcasters and today captures 27 percent of the total

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