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Extracts from Submissions to the 2nd and 3rd Phases of the Broadcast Commission of Ireland's consultation process

Phase 2 Submission

Broadcast media, especially television have many very positive attributes that can be tested, measured and demonstrated. One thinks especially of the areas of relaxation, entertainment and education in all their forms.

There are issues of taste on which every individual may have a differing opinion. Issues of taste are by their nature subjective, and while there are often strongly held differences of opinion there is no objective way to measure what is best.

It is also possible that broadcast media may have some harmful side effects.

If harmful side effects do exist, then they should be measurable and stand up to objective analysis.

Harmful side effects which are measurable, and which stand up scientific analysis, should not be confused with issues of taste or opinion.

Cigarette smoke may be “offensive or harmful”. The recent legislative changes covering smoking in the workplace addressed the “harmful” element of smoking. It is still up to each person to decide if they find smoking “offensive”.

The same argument applies to broadcast media, especially television. This distinction between “harmful” and “offensive” appears to have been overlooked in the discussion document as the phrase “harmful or offensive” is repeated frequently in the text. This implies that the author(s) considered that there was a similarity in meaning between the two words.

The remainder of this submission is based on the premise that there is sufficient evidence available to demonstrate that the widespread use of violence and especially violent death as entertainment has some measurable negative side effects on viewers.

Public awareness of these effects is essential if the average viewer is to make informed decisions about his or her viewing choices.

Experience gained from talking to senior executives in the television industry, over a number of years, has shown that television stations are unwilling to acknowledge the possibility that there may be any undesirable side effects relating to any of their programme content.

This is despite the large volumes of research data that are available. For example, Professor Joanne Cantor’s address to the US Senate commerce committee in 2003 is a compelling summary of the research available at that time. It lists the three main effects of watching violence as desensitising viewers to violence, creating a greater feeling of personal insecurity and confirms that there is a link between watching violence and becoming more violent.

The current attitude adopted by most television stations reminds one of to the stance of the cigarette industry when initially asked to acknowledge that there may be some undesirable side effects associated with smoking.

It is worth recording that BBC, RTE, UTV, Sky and TV3 all decided that they were unable to commit to omitting violent death for entertainment purposes from their schedules on 21st September this year. TG4 was the only station transmitting on the island of Ireland that readily agreed to observe the day. TG4 say that they wish to support and encourage a greater understanding of media.

That we are influenced to some extent by what we see on television is beyond dispute. All those hardnosed business people who, with research at their fingertips, spend millions of euro advertising their products and services on the medium adequately demonstrate this.

Is it credible that our behaviour can only be influenced by advertisements but not by other things we see repeatedly on Television?

Children must be influenced by the 8,000 violent deaths that they see in their entertainment programmes before reaching secondary school age. How they deal with this influence is the question of concern.

Response to individual questions

Question 1: Are the key objectives appropriate?

Yes in as far as they go

Question 2: Are there other objectives which should be taken into account?

Yes, two additional objectives are suggested.

1) To inform viewers of both the positive and negative effects of television, and to encourage informed viewer decision making on programme selection. Information should be based on the findings of objective independent research.

2) To educate viewers to differentiate between what they consider offensive and what is known to be harmful.

Question 3: Are there types of sexual content or violence you believe should receive particular attention in the code?

Violent death as entertainment should receive special attention.

Most violence is subjective and individual opinions may well vary as to what constitutes violence.

However, violent deaths are definite events. It is possible to count them. No debate or ambiguity is possible.

It would even be possible to use the number of violent deaths to rate programmes in advance

Examples No violent deaths

Less than 5

Less than 20

Less than 100

Over 100

Question 4: Which if any of the following areas do you consider appropriate to include in the Code of Programme Standards.

The list given is comprehensive

It is suggested that the number of programmes that may foster an imitative lack of respect for oneself or for others be minimised.

Question 5: Are there other areas/issues that you believe should be included in the code?

Stations, especially those with a public service duty, should be tasked to transmit a minimum amount of television media awareness material at peak times each year. There is a responsibility to inform viewers of both the positive and negative impact of the medium.

Would the Broadcasting Commission consider formalising the 21st Sept as one day each year when no violent death is shown for entertainment purposes?

(TV3 have formally stated that they would only observe this day if “forced to do so by the by the regulator”)

Question 6: Does the time at which a programme is broadcast influence whether the material on that programme could be seen as offensive or harmful.

As indicated above “offensive” and “harmful” are completely different concepts.

It is generally patronising to assume that something, which is harmful to children, may have no adverse effect on adults. Do the 15,000 violent deaths seen by the well adjusted adult viewer have no effect?

Also can something be offensive to children and not be offensive to adults? Or does this just mean that adults have become desensitised and are no longer offended.

The “water-shed” is a useful mechanism to help compartmentalise the viewing day so that there is an expectation that certain types of material will not be shown before that time. The concept of context is most appropriate. However a lot of the material shown after the water-shed is of a sexual nature which may be considered as offensive but is generally not harmful (unless violence is involved). However violence, which is known to be harmful, is shown with impunity before the water-shed. (Lethal Weapon 3 on RTE Christmas Day 2003)

Question 7 Are there differences between radio and television in this regard?

No opinion on this issue.

Question 8 Does time of broadcast become a less important consideration for channels that are subscription or encrypted?

For channels that provide “General Entertainment” the time of broadcast is important. There is probably no difference between subscription or encrypted channels and mass transmission television in this regard.

For clearly identified specialist ”Special Interest” porn, horror or violence channels where the programme content can be anticipated then time of transmission is probably not relevant.

Question 9 In considering whether programme material is offensive should consideration be to the type of programme in which it features?

Yes. Predictability of the type of material to be shown allows viewers to make decisions of what they wish to be watched. Unexpected content type could cause embarrassment or offence.

Question 10 In determining whether programme material is offensive should the type of channel/service on which it appears be taken into account?

Yes. Again the issue is predictability. One expects to find porn on a cable porn channel, or religion on the religion channel.

However, I suspect that all Irish transmissions would classify themselves as “General Entertainment” suitable for general family viewing. Consequently the type of channel is important.

Question 11 Should a differentiation be made between free to air and subscription channels?

No. A differentiation should be made between “General Entertainment” channels and “Special interest” channels. These can be spread across both free to air and subscription channels.

Question 12 Should the existence of a prior warning be taken into account in assessing whether material is harmful or offensive?

If the material is measurably harmful then a prior warning may have the effect of reducing the number of viewers that see the programme but the material remains unchanged and is still harmful.

If the material may be considered offensive and a prior warning is given then viewers will not be confronted with unexpected material and there is much less likelihood of causing offence.

Question 13 In assessing whether programme material is offensive or harmful should consideration be given as to whether the material is justified from an editorial point of view?

Yes, for offensive material.

Harmful material should not be shown unless the public are adequately informed to deal with the probable harm

Question 14 Should the likely size and composition of the audience be considered in assessing whether the material is offensive?

If the audience composition can be clearly identified then the assessment can be made with a degree of confidence. I,e the audience for a sex channel will have self selected.

For “General Entertainment” channels there is less predictability as to audience composition, and the watershed approach is probably appropriate. The size of the audience should not be a factor. Is it considered appropriate to offend a very small number of Jews for instance?

Question 15 Are there other factors that you believe should be included that could influence how the viewer or listener perceives a programme and as a result should be included in the definition of context?

Submission to 3rd Phase Consultation

Draft BCI Code of Programme Standards.

Dear Sirs,

This submission to the phase 3 consultation is focused on the single issue of the portrayal of violence and violent death as entertainment on television.

In previous submissions I have stressed the difference between the objective and measurable harm that can be caused by excessive exposure to violence and the subjective issues of taste that fuel the debate on sex and bad language.

It is noted that the Phase 3 Draft does acknowledge that some television material may be harmful. This suggests that the BCI accepts the concept that viewers of any age may be exposed to harmful material. Yet the BCI Draft does not insist on either a “health warning” or mandatory media education to ensure that viewers are made aware of the harm that could be caused by the material that they or their children are watching. This ommission could be labelled as reckless endangerment.

This submission is informed by many hours of research on published material on the effects of media violence. The most comprehensive and balanced document uncovered is the US “National Television Violence Study” Some elements of the Executive Summary are quoted below. This submission is attempting to ensure that the findings of this comprehensive piece of research are used to inform the Irish Code of Programme Standards.

A simple directive by the BCI in setting aside a single day each year when no violent death is shown for entertainment purposes on Irish television would effectively provide a focus for media education and effectively alert parents and guardians of the harmful effects of television and other media violence.

It is suggested that Ireland’s Health and Safety approach to banning smoking in Pubs and Restaurants set a headline which is now gaining international momentum. Similarly, a directive by BCI would be both beneficial to the health of the nation and would also set an international standard which would be noted by international film and programme makers.

September 21^st, United Nations World Peace Day is suggested as a suitable date.

I trust that the weighting system that you use to evaluate submissions will take account of Health and Safety issues, the depth of background work etc, and does not simply relate to the number of submissions on each area.

I would be very pleased to discuss any aspect of this submission, should this be considered helpful.

Yours Sincerely

Terry Gillespie

National Television Violence Study

Volume 3

Executive Summary

CENTER FOR COMMUNICATION AND SOCIAL POLICY

UNIVERSITY OF CALIFORNIA, SANTA BARBARA

“This volume summarizes the final report of the National Television Violence Study. The report represents the efforts of more than 300 people, involving the videotaping of nearly 10,000 hours of television programming over a three-year period, and the participation of more than 1,600 individuals as study participants in five separate experiments. The project is a landmark in the history of television research in that its analysis of TV content is based on the most representative sample of the television landscape ever collected.

Project Overview

Violence on television has been the subject of national debate for decades. In the last few years, public concern over this issue has intensified in response to overwhelming scientific evidence that TV violence has harmful effects on society. Due to this public concern, policymakers called on the entertainment industry to more closely examine the way in which violence is shown on television. As a result the National Television Violence Study (NTVS) was commissioned.

Initiated in 1994, the National Television Violence Study is a three-year effort to assess violence on television. The project is funded by the National Cable Television Association (NCTA). The National Television Violence Study involves the efforts of media researchers at four universities, an oversight Council of representatives from national policy organizations, and project administration and coordination.

Researchers at the University of California, Santa Barbara, have assessed violence in entertainment programming such as drama, comedy, movies, children's shows, and music videos. Researchers at the University of Texas at Austin have examined violence in a particular type of programming — reality-based shows such as tabloid news, talk shows, police shows, and documentaries. Researchers at the University of Wisconsin, Madison, have studied violence ratings and advisories used on television, including their impact on the viewing decisions of parents and children. Researchers at the University of North Carolina, Chapel Hill, examined the effectiveness of anti-violence public service announcements.

The project also involves the efforts of an oversight Council, whose role has been to safeguard the integrity and independence of the study, provide advice and counsel to the researchers, ensure the scientific validity of the study, and identify implications from the findings. The Council is comprised of representatives from 17 national organizations that are concerned with the impact of television on society. These organizations represent the fields of education, medicine, law, violence prevention, psychology, sociology and communication. In addition, one third of the Council members represent the entertainment industry.

The administration and coordination of the study has been conducted by the Center for Communication and Social Policy at the University of California, Santa Barbara. This responsibility includes managing the videotaping of more than 3,000 programs each year for content analysis, convening the NTVS Council, coordinating the research efforts among the four university sites, and releasing the study's report and Findings. The initial phases of this project, including the taping of the Year 2 sample, were coordinated and administered by Mediascope, a nonprofit organization, before moving to UCSB in June 1996.

In very many ways, the study as a whole has been a collaborative effort. Though their studies were conducted separately, the researchers from the four universities met together frequently, particularly during the design phase of the project. In addition, the Council and researchers met together a total of six times during the course of the study, reviewing and vetting its design, results and recommendations.

Risks of Exposure to TV Violence

Prior to this study, it had already been well established that television influences many kinds of attitudes and behaviors by modeling them as appropriate and/or desirable. A highly successful multi-billion dollar advertising industry is built on that premise. More specifically, violence on television has been shown in hundreds of studies to have an influence on aggressive behavior. Over the past 20 years, numerous respected academic and public health organizations and agencies — including the American Psychological Association, the American Medical Association, the U.S. Surgeon General, and the National Institute of Mental Health — have reviewed the existing bodv of evidence in this area and have unanimously-affirmed the validity of that conclusion.

Three main effects of viewing Television violence have been noted in the literature: learning aggressive attitudes and behaviors, desensitization to violence, and increased fear of becoming victimized by violence.

Scientific evidence has also established that the portrayal of violence on television need not lead to the reinforcement of aggressive attitudes and behaviors. If the consequences of violence are demonstrated, if violence is shown to be regretted or punished, if its perpetrators are not glamorized, if the act of violence is not seen as justifiable, if in general violence is shown in a negative light, then the portrayal of violence may not create undesirable consequences. But if violence is glamorized, sanitized or made to seem routine, then the message is that it is an acceptable, and perhaps even desirable, course of action. Television can be a powerful influence on social mores concerning violence and aggression, for good or for ill.

The crucial question then becomes: in which of these ways does television currently portray violence? Does television today encourage or discourage the learning of aggression? Does it increase the risk of desensitization or fear in viewers? These are the central questions addressed by the National Television Violence Study.

The study does not exaggerate the importance of television violence among the myriad contributors to violence in society. It recognises that the causes of violence are manifold, and include biological and psychological factors as well as broader social and cultural ones. It also recognizes that televised violence does not have a uniform effect on viewers. The relationship between viewing violence and subsequent behavior depends both on the nature of the depiction and the makeup of the audience. In some cases, the same portrayal of violence may have different effects on different audiences. For example, graphically portrayed violence may elicit fear in some viewers and aggression in others. Peer influences, family role models, social and economic status, educational level, and the availability of weapons can each significantly alter the likelihood of a particular reaction to viewing violence on television.”

INTRODUCTION 8

“Violent acts may be shown close-up or at a distance. There are also differences in the types of characters who commit violence and their reasons for doing so. And there are differences in the outcomes of violence—some depictions focus on the pain and suffering of victims, whereas others avoid showing the negative consequences of physical aggression. Simply put, not all portrayals of violence are the same. Their context can vary in many important ways. Studies show that the way in which violence is presented helps to determine whether a portrayal might be harmful to viewers. Some features of violence increase the risk of a harmful effect, whereas others decrease that risk. In order to evaluate violence on television, then, we must look at the contextual features of different portrayals.

Based on an extensive review of all the studies in this area, we identified a range of contextual features that influence how audiences will respond to television violence. Below we describe each of these features and indicate whether it increases or decreases the risk of harmful effects.

ATTRACTIVE PERPETRATOR

Different types of characters use violence on television. Studies show that viewers of all ages are more likely to emulate and learn from characters who are perceived as attractive. Thus, heroes and "good guys" who act violently pose more risk to the audience than do villains.

ATTRACTIVE VICTIM

Just as the perpetrator is an important contextual feature of violence, so is the victim. The nature of the victim is most likely to influence audience fear rather than learning. Studies show that viewers empathize with good characters more so than with bad ones, so violence against victims who are perceived as attractive can heighten audience fear.

JUSTIFIED VIOLENCE

Viewers interpret an act of violence differently depending on a character's motives for engaging in such behavior. Certain motives like self-defense or protecting a loved one can make physical aggression seem justified. Studies show that justified violence increases the chance that viewers will learn aggression; such portrayals legitimize such behavior. In contrast, violence that is undeserved or purely malicious decreases the risk of imitation or learning of aggression.

CONVENTIONAL WEAPONS

Characters can use their own physical strength to enact violence against a victim or they can use some type of weapon. Conventional weapons like guns and knives can increase viewer aggression because such devices often trigger the memory of past violent events and behaviors. This type of priming effect is less likely to occur with novel or

unconventional weapons such as a chair or a frying pan.

EXTENSIVE/GRAPHIC VIOLENCE

Television programs and especially movies vary widely in the extent and graphicness of the violence they contain. A violent incident between a perpetrator and a victim can last only a few seconds and be shot from a distance or it can persist for several minutes and involve many close-up views of the action. Research indicates that extensive or repeated violence can increase desensitization, learning, and fear in viewers.”

The remainder of this submission is based on answering the questions raised in the 3^rd phase consultation bearing the research above in mind.

Comments on

1 Objectives of the BCI code of Programme Standards (p6)

The first objective includes the phrase “and harm is reduced”.

If material is known to be harmful then it is irresponsible to broadcast it unless viewers can be expected to recognise and be aware of the potential harm. To knowingly expose people, young and old, to a harm that they do not recognise is reckless endangerment.

The third objective is to inform viewer and listener choice. How can this be achieved without sponsoring media education, especially creating a widespread understanding of the negative effects of violence and violent death as entertainment. The simple action of designating one day each year when no violent death is shown for entertainment purposes would provide a focus for media education on the topic.

2 Content Principles

2.1 General community standards

Add the phrase” programmes must not be harmful”

2.2 Audience information and guidance

Add “A health warning is to be provided on violent material which is known to be harmful”

2.3 Due care

Add “Particular care must be taken when scheduling programmes in which the hero figure uses violence without remorse or punishment”

2.4 Protection for Children

The BCI Codes of Programming standards recognises that broadcasters share a responsibility with parents and guardians in protecting children i.e. those under 18 years of age , from exposure to inappropriate and harmful programme material.

To this end broadcasters must have due regard to the protection of children by providing adequate information to parents and guardians to inform them of the potential harm associated with some programme material and when scheduling such material.

Add

“iv When showing material in which the hero figure kills without remorse or punishment”

3 Content Rules.

Add under 3.1.2

The inclusion of the following violent programme material must be justifiable in the context of the development of the narrative and/or characters, or have strong editorial justification.

“

· Violence being glamorised or sanitised by a hero figure

· Violence without punishment effect or remorse”

3.2 Sexual Conduct

Add

3.2.2 Programs which show violent sex or rape should also include consequent punishment or remorse

3.8 Imitative behaviour

Add

“i.e. The hero kills or commits violent acts without receiving punishment of suffering remorse”