Transcription 2007

Finding Yourself on the Map: Sometimes More Difficult Than You Think

            In case you were wondering what maps had in common with public service broadcasting, let me recall the well-known truth that a socio-centric approach to the media is by far preferable to a media-centric approach in media studies. To understand what is happening with PSB in post-Communist countries, one needs to understand what is happening with those countries themselves.

The issue with maps is that what is known as “Eastern Europe” has suffered from an identity crisis, reflected in the various names it has invented for itself, including “East Central Europe”, “Central and Eastern Europe”,“East of West”, and other fanciful names, designed primarily to avoid exclusive association with “the East”.

            After 1989, the desire to “rejoin Europe” has been translated into a westward movement, in geopolitical terms, though the Baltic States are really looking northward, towards Scandinavia, and some countries, like Belarus, are still determined to move to the East, rather than the West. In some cases, as in that of Poland, this westward movement has developed such momentum – given strong ties with the U.S. – that the country may be said to have gone beyond Western Europe and to be suspended in mid-air over mid-Atlantic. Let us hope that this exercise of sitting on two stools – the EU and the US – will not end with the country crashing into the Atlantic with a big splash and an even bigger tsunami to follow.

            Another aspect of this effort to find oneself on the map relates to the three media systems identified by Hallin and Mancini (2004) in their well-known book Comparing Media Systems. They left “Eastern Europe” largely out of their analysis and media scholars from the region have been trying to establish which of the three media systems fits best what they know in their own countries.

            If one were to try to show where post-Communist countries are, or should be, going, one would really have to identify two directions. In geopolitical terms, the movement is westward. In terms of democratic standards, it should be northward. In this second case, we need to ask ourselves two questions. First, what is the starting point of this quest for a particular country: is it from the level of Italy, or is it perhaps in some cases from the level of Libya, or similar Northern African countries? And secondly, how long before we can hope to approximate Northern European standards of democracy: is it a matter of decades, or centuries? And there is yet another question to consider: are some post-Communist countries moving up, or down, on this axis of democratic standards? Or is it perhaps both, in cases of backsliding, where hard-won gains of democratic development are jeopardized, due to the triumph of populist or more autocratic political parties?


PSB and Media Policy Orientations in post-Communist Countries

When post-Communist countries set about developing a media policy, they first had to settle on a model of the media system, with underlying normative media theory(ies) and concepts of the role of the media and journalism in society (see Jakubowicz, 2007). Three main media policy orientations emerged in response to this:

        Idealistic (a radical vision of direct, participatory communicative democracy);

        Mimetic (straight transplantation of the generalized Western media system with a free press and a dual broadcasting system), promoted in a spirit of “no more experiments” and a “return to Europe”, and

        Atavistic (the unwillingness of new power elites to give up all control of, or ability to influence, the media).

The idealistic media policy orientation, rooted in concepts of a future media system originally developed by the dissidents still under the Communist system, was rejected immediately. One can call it a victim of the two other orientations: first, it would have been a noble experiment and no-one had any taste for that any more. Second, it would have deprived the power elite of any control of the media, and that is something they certainly did not want to see. What remained, therefore, was a combination of the mimetic and “atavistic” media policy orientations.  

What has happened in post-Communist countries has indeed been called “mimetic” or “imitative” transformation (see Jakubowicz, 2007; Splichal, 2000, 2001). The mimetic orientation, both home-grown (some of it is due to market forces reproducing features of Western media systems) and resulting from considerable pressure (or “leverage”, as Vachudova, 2005, prefers to call it) exerted on particular governments by the European Union, the Council of Europe and other international organizations, has – as shown in  Table 1 –  produced a significant result in terms of the legal and institutional introduction of what is described as PSB in the region (see also Richter, Golovanov, 2006).


Table 1.  Presence of PSB (*) in Post-Communist Countries


political regimes

War-torn regimes


Noncompetitive political regimes

Czech Republic *

Slovenia *

Hungary *

Poland *

Lithuania *

Estonia *

Latvia *


Slovak Republic * Bulgaria *

Romania *



Croatia *

Moldova *

Kyrgyz Republic *

Mongolia *

Armenia *

Albania *

Georgia *

Macedonia, FYR *

Azerbaijan *


Bosnia-Herzegovina *






 The World Bank (2002) assigned particular countries to one of the categories on the basis of the situation in 1999. Some countries have evolved since then and have moved, or are moving towards other categories. Introduction of PSB could be an indicator of this change of status.

             So, on the face of it, one could say “mission (almost) accomplished”. And yet, Mihaly Galik, a Hungarian media scholar and himself a broadcaster after 1989, has said with regard to the Hungarian situation that “the introduction of public service broadcasting has failed”. He cites the unwillingness of politicians to refrain from seeking to control public service broadcasting, their deliberate misapplication of the law to prevent PSB from emerging in the form designed in the Broadcasting Act of 1995, and the weakness of civil society, as the reasons for this assessment. Many other scholars from the region (see Hrvatin, 2002; Jakubowicz, 1995, 2003, 2007; Mungiu-Pippidi, 2003; Ociepka, 2003) have broadly concurred with that assessment.

            To understand the reasons for this sense of disappointment, we need to put the situation of PSB in post-Communist countries in the context of the history of public service broadcasting.


Introduction of PSB in Different Social and Historical Contexts

We can  identify three main models of the creation of public service broadcasting, or of the transformation of State broadcasting into public service broadcasting:

 1.      Paternalistic – as in the UK, where PSB was originally born in 1926 in the form of the BBC, an independent public corporation with a public-service remit, understood in part as promoting public enlightenment, playing a clearly normative role in the country’s cultural, moral and political life, and as promoting ‘‘the development of the majority in ways thought desirable by the minority’’ (Williams, 1968: 117);

2.      Democratic and emancipatory – as in some other Western European countries, where erstwhile state broadcasting organisations began to be transformed into public service broadcasters in the 1960s and 1970s, a time when State (government) control of the then monopoly broadcasters could no longer be justified or claim legitimacy, and a way was sought to associate them more closely with the civil society and turn them into autonomous PSB organisations;

3.      Systemic – as in West Germany after World War II, Spain, Portugal and Greece in the 1970s, and in Central and Eastern Europe after 1989, when change of the broadcasting system was part and parcel of broader political change, typically transition to democracy after an authoritarian or totalitarian system.

As I will seek to show, more than one model may, over time, operate in one country. One example of that is the evolution of PSB systems in response to broader change in society, leading e.g. to democratic and emancipatory change in an existing paternalistic (or State-dominated and politicized) PSB system.

In the group of countries representing the systemic model of PSB introduction, we may additionally distinguish cases where the system of public service broadcasting has been imposed by outside forces. This includes Germany as well as, to some extent, Japan.

The United States and New Zealand offer another special case of PSB being created (or, as in the latter case, recreated; see e.g. Comrie, Fountaine, 2006) for reasons other than the progress of democratization (as in the democratic and emancipatory model) or loss of legitimacy of State media (as in the democratic and emancipatory or systemic models). Here, we have to do with a clinical case of the market failure rationale for PSB: a conviction that commercial broadcasting alone is not enough, as it fails to meet all the needs of society.

The three main models of PSB introduction obviously emerged in different socio-political circumstances, arising out of the history of political development of particular countries. There is clear interdependence between this process and the level of democratic consolidation in a particular society. Accordingly, this might perhaps suggest a strong correlation between particular models and the three “waves of democratization” identified by Huntington (1995): 

         The years 1828-1926 which saw the democratization of Australia, Canada, Finland, Iceland, Ireland, New Zealand, Sweden, the United States, Switzerland, Great Britain, Austria, Belgium, Denmark, France, the Netherlands, Norway (as well as others, which, however, reverted to non-democratic rule);

        The years 1943-1964, when Allied occupation helped impose democracy on some countries (Germany, Japan, Italy, Austria, South Korea); when other countries (Greece, Turkey, Brazil, Argentina, Peru, Ecuador, Venezuela and Columbia) advanced to democracy; and when the beginnings of decolonization also promoted the process;

        The years after 1974, when the fall of the Soviet Union and the final phase of decolonization were the prime movers of the process;

And yet, despite some chronological parallels, Hungtington’s three “waves of democratization” are not a sufficient guide to prospects for PSB emergence and development.  This is because Huntington accepts the Schumpeterian formal and procedural definition of democracy and that is not in itself enough to create propitious conditions for PSB independence.

Another framework of analysis is provided by the typology of media systems developed by Hallin and Mancini (2004) (see Table 2).


Table 2. The Three Models: Main Political and Media System Characteristics


Polarized pluralist model

Democratic Corporatist model

Liberal model

Political system

Political history: conflict vs.


Late democratization, polarized pluralism Early democratization, moderate pluralism, Early democratization, moderate pluralism
Consensus or majoritarian govt.


Predominantly consensus Predominantly majoritarian
Individual vs.
organized pluralism
Organized pluralism Organized, democratic corporatism Individual representation
Role of State


Strong welfare state Liberalism
Rational Legal Authority

Weak, clientelism



Media system

Political parallelism



External pluralism,
politics-in-broadcasting with substantial autonomy
Internal pluralism (external in the UK), professional broadcast governance, formally autonomous system



Role of State in Media


Strong, but freedom of media protected Market-dominated (but strong PSB in UK and Ireland)

This shows that the media display “systemic parallelism” in the sense that they are shaped by the socio-political and cultural features of the countries in which they operate, including notably the level of actual or potential societal conflict and the degree of democratic consolidation.

An indication of what “systemic parallelism” may mean in practice is provided by a report on PSB in Western Europe (Conseil Supėrieur d’Audiovisuel, 1998), which identifies two main models of public service broadcasting in the five countries under consideration:   

    The “Anglo-Saxon” model (the UK and Germany) involves considerable independence of PSB broadcasters, rooted in tradition in the UK and in the Constitution in Germany. Moreover, in both countries PSB broadcasters have long received sufficient funding and were thus able to avoid being drawn into direct competition with commercial broadcasters. That allowed them to retain their distinctiveness and to remain the point of reference in the broadcasting landscape. Still, the application of the proporz-system in both Germany (and Austria) has long meant that also in those countries political parity between main parties had to be preserved in the appointment of top and middle management of public service broadcasting organizations.

    The “Latin” model (France, Italy and Spain), where PSB had long been under political tutelage. The funding of PSB in countries representing this model has long been insufficient, resulting in the permanent destabilisation of the public sector, once commercial broadcasting appeared. “Chronic underfinancing of the public sector has turned it [in the three countries] into a ward of the State – says the CSA –  and one must ask whether in some cases this has not made it possible to preserve the old tutelage”.

Table 3 provides a schematic and simplified depiction of the interrelationships between waves of democratization, models of PSB introduction and media systems.


Table 3. Systemic parallelism” and public service media

Waves of  democratization 

Models of PSB introduction

Media systems



Paternalistic, followed in some cases by democratic-emancipatory

Liberal or Democratic-corporatist



Systemic, possibly followed by democratic-emancipatory



Polarized pluralist

In  Huntington’s first-wave countries, PSB was usually introduced in line with the paternalistic model. Later, however, things got more complicated. The democratic and emancipatory model emerged primarily in first-wave countries, but before and during of the third wave of democratization. Those countries were already democracies, but only at that time did consolidation of liberal democracy make serious gains and socio-political conditions emerged, allowing either the introduction of PSB or the weaning of existing PSB organizations away from government control.

The systemic model has been most conspicuous in third-wave countries (which is not to say that PSB is now present in all those countries), but was equally evident in other countries, where – as in Germany for example –democratization was followed by reversion to totalitarian/authoritarian rule and only its subsequent collapse paved the way to transforming State into public service media. Depending on the strength of democratic tradition in a particular country, or on the pace of democratic consolidation, while it typically produced a polarized pluralist model, it did also, in some cases (e.g. Germany), lead to the democratic-corporatist model.

Simple correlations are equally elusive in the case of waves of democratization and media systems as classified by Hallin and Mancini (2004).

What Hallin and Mancini call the liberal system is to be found exclusively in the first-wave countries (the United States, the UK, Canada and Ireland). However, other first-wave countries (Austria, Belgium, Denmark, France, the Netherlands, Norway, Switzerland etc.) developed the democratic-corporatist system. The obvious reason for this is that their socio-political systems, traditions, cultural and religious divisions required the accommodation of various group interests.

In turn, third-wave countries have so far, as a rule, developed “Mediterranean systems” (polarized pluralism). In Hallin and Mancini’s analysis they are Greece, Spain and Portugal, but in addition also France and Italy.

The fact that polarized-pluralist and democratic corporatist media systems often operate in the context of consensual (consociational) systems of government is a manifestation of the “systemic parallelism” we mentioned above. Consociationalism is essentially a strategy for conflict management and the choice of a majoritarian or consociational form of government is predicated i.e. on the level of actual or potential conflict within society (e.g. due to divisions of various nature within society). Where there is a high level of actual or potential conflict, PSB organizations will be affected by the political and institutional solutions designed to cope with it, i.e. involving politicized and pluralistic governing bodies of PSB (“politics-in-broadcasting”), serving as an arena for the negotiation and resolution of such conflicts.

Incidentally, the concept of systemic ”parallelism” would suggest that a future wave of democratization should bring about the emergence of PSB organizations in new countries. This could perhaps be the logical conclusion, especially as concerns countries and regions oriented to imitating European models, though we need to note that while some authors do look forward to a ”fourth wave” (Diamond, 1997), others expect only a ”fourth trickle” (Bunce, 2002), and still others are saying that the next wave is already happening and is producing ”illiberal democracies” (Zakaria, 1997). Illiberal democracies are certainly not a natural habitat for PSB.

            The establishment of PSB organizations has been announced in Thailand (Article 19, 2007) and Brazil. in countries such as Afghanistan, Cambodia, Malawi, Panama, Sri Lanka and Indonesia steps towards the gradual transformation of existing or new broadcasters into public service organizations are being taken, thanks to the efforts of UNESCO (see Stiles, Weeks, 2006). All this could be seen as evidence that the process of dissemination of PSB is continuing, though with many difficulties. Let us, however, also note a different view: “Neither domestic democracy groups nor foreign donors have prioritized PSB as an option for Africa. PSB has not been assessed as a challenge, but rather as an institution belonging to the past” (Kivikuru, 2006: 7).


Riviera on the Mediterranean: PSB in polarized pluralist systems

Sitter (2005) discusses different approaches to comparative analysis of political systems in Western and Eastern Europe and says that one of them consists in looking at similarities with earlier developments in Western Europe: “Perhaps the most obvious comparison was to the Mediterranean transitions to democracy in the 1970s…” Another indication that this might be the right frame of reference is Splichal’s (1994) concept of ”Italianization of the media” as a phrase to describe the process of media change in those countries.

Let us therefore take a brief look at these countries in order to develop a comparative perspective for our discussion of PSB in post-Communist countries. Papatheodorou, Machin (2003) point to similarities in historical experience, level of economic development and political culture between Spain, Greece, Portugal and, occasionally, Italy. Greece and Spain, they say, were – due to delayed and uneven economic development – sites of intense social conflict and upheaval during a large part of the 20th century. Social and ideological divisions culminated in civil strife. After several decades of authoritarian rule, stable democratic institutions were only established in the last quarter of the 20th century.

         Statham (1996) says that Italy is a case of an unfinished process of modernization. Marletti and Roncaloro (2000) add that in Italy the elite-led nation and state-building process has not succeeded in bringing about a unitary civic culture, but rather has created a gap between the political cultures of the masses and the elites, accentuated by the centralism of the state. Italy remains a fragmented and pluralistic country, with various territorial identities and political subcultures, in which state centralism is only a heavy superstructure. The First Republic (the period which goes up to the Tangentopoli scandals and the disappearance of the traditional party structures at the beginning of the 1990s) was characterized by a sort of panpoliticismo, i.e. a situation when politics pervades and influences many social systems, economics, the judicial system, and so on (see also Mancini, 2000).    

In these circumstances, it is no surprise that, as – Papatheodorou and Machin (2003) put it – the political elite and the media are joined by a “umbilical cord” that remained in place (as in Portugal, Spain and Greece) even after the overthrow of dictatorship and subsequent political change. Despite efforts towards political and economic modernization, patronage channels have remained. Even after the downfall of dictatorial governments, and despite the extensive renovation of political personnel, the persistence of social incoherence and of traditional political practices imposed limitations on the establishment of mass political parties in the West European fashion. As a result political parties in government have always relied heavily on the resources of the state in order to consolidate their power. Patronage has thus remained a crucial means for mobilizing and maintaining political support.

Papatheodorou and Machin conclude that the central role of the state in South European societies, the organizational weakness of political parties and the insecurity caused by the fluidity of their electoral base, are a key to understanding both the pattern of development of media institutions and their place within the overall configuration of power.

As a result, Southern European countries display features of “State paternalism” (Papatheodorou, Machin, 2003) or indeed ”political clientelism” defined as ”a pattern of social organization in which access to resources is controlled by patrons and delivered to clients in exchange for deference and various kinds of support. It is a particularistic and asymmetric form of social organization, and is typically contrasted with forms of citizenship in which access to resources is based on universalistic criteria and formal equality before the law” (Hallin, Papathanassopoulos, 2002: 184-185). Cases of clientelism can be found anywhere, but in some countries – and this applies to Southern Europe – it is described as the dominant feature of the social order.

Hallin & Papathanassopoulos (2002) associate certain features of the media system with political clientelism:

               A tradition of advocacy reporting (see also Mancini, 2000);

               Instrumentalization of privately-owned media;

               Politicization of public broadcasting and broadcast regulation;

               And limited development of journalism as an autonomous profession. 

This explains the situation of public service broadcasting in Southern Europe.

 The Italian story is well known. After decades of Christian Democratic party hold on society and RAI, an attempt to democratize public service broadcasting and free it from government control led in the 1970s to the introduction of the lottizzazione, turning a system of “party domination” into one of “party partition” (Cavazza, 1979), a paragon of “political parallelism”. After the collapse of the Christian Democrats and the Socialists (two of the three parties which had held RAI in their grip) in the Tangentopoli scandal in 1992, the old lottizzazione system was replaced by “individual lottizzazione” (Hibberd, 2001), with political appointees placed in the management of RAI to promote party interests. The many years of Berlusconi rule in reality meant the return of “party domination” over RAI: “Berlusconi and his coalition allies … adopted majoritarian, winner-take-all policies in appointing directors and overseers of the RAI broadcasting empire” (Marletti, Roncarolo, 2000:197).

With regard to Spain, which The Wall Street Journal recently called “a young and fragile democracy”, Gunther, Montero and Wert (2000: 47) make the point that media liberalization after the end of the franquist period “did not include a reform of the structural relationship between the government and TVE”. Also Bustamante (1989) has pointed out that the formal democratization of State television showed a curious delay in relation to other institutions in the country, with TVE remaining the centre and basic arena of political struggle. The “heavy legacy of Franco’s television model” continued to exert its influence long after the demise of Franco’s system of government, despite repeated (but perhaps only half-hearted) attempts to introduce institutional arrangements guaranteeing greater independence for TVE (all the while, however, the Director General of RTVE was still appointed directly by government).

Thus, Bustamante (1989) concluded, the transition to democracy partially, and belatedly, reformed that model without breaking from the traditional concepts of broadcasting, generically identified with authoritarianism. But, above all, he said, Spanish television joined the wave of commercialization, but without having previously consolidated a public service stage.

A strikingly similar process can be observed in Portugal. Writing in 1996, Sousa had this to say about Portugal’s public service broadcasters: “RTP has never had a balanced and impartial political output, it has been financed mainly (and now almost totally) by advertising revenue; thus, it has never had a high degree of financial and political independence. Finally, its statutory requirement to educate, inform and entertain has not been taken seriously. In general terms, the Portuguese PSB has been controlled by the government and operates like the other commercial channel”.  She went on to say that both RDP and RTP had been under the control of successive governments, with the result that between 1974 and 1986 the eleven seats on the board of governors and the 20 directors posts at RTP and RDP has been held by 80 and 130 different people respectively, whose qualifications for the job were considered less important than their party membership cards.


Students of public service broadcasting in post-Communist countries may find it instructive that it was only nearly 30 years after the collapse of the authoritarian regime and the “systemic” model of PSB introduction, that “democratic and emancipatory” changes were initiated in Portugal. Spain and perhaps in Italy. 


In Portugal, the process with the adoption of the 2003 Television Broadcasting Act. It  has a special section on access to air time on public television, guaranteeing political parties, the Government, trade unions, professional organisations and those representing economic activities and environmental and consumer protection associations the right to broadcast time on the public television service, in accordance with strictly calculated quotas. Moreover, a variety of the now-defunct American Fairness Doctrine was introduced, with opposition parliamentary parties enjoying the right to refute, in the same programme service, to the political declarations made by the Government on the public television service which affected them directly. A sign of the new approach is that one of the two national public service television channels will from now on include partnerships with civil institutions such as universities, foundations, museums and associations, for the cession of their archives or copyrights, sponsoring and other forms of contributing for the production of programmes.


 Another new departure is the fact that the law calls for the appointment of “the Listener Ombudsman” and “the Viewer Ombudsman” who are to represent the public, its complaints and grievances   vis-à-vis the management of public radio and public television. Their annual reports are to be considered by the regulatory authority.


In Spain, the plan launched by the Zapatero government was to promote the  “degovernmentalization of RTVE” (Caffarel, de Castro, 2006) and to put an end to the political control within the public broadcaster. To this end, a new RTVE Corporation has been formed, autonomous with regard to its management, acting independently of the government and under the control of Parliament, with a new Administrative Council formed by highly qualified professionals, appointed by Parliament for 6 years (longer, therefore, than the life of a legislature). A key aspect is participation of the citizens, with the new law calling for the creation of an Advisory Council made up of thirteen members appointed by social organizations, the Social Economic Council, consumer and user organizations, and associations of various types, professional and civic.

By contrast, Italy is still waiting for its “democratic and emancipatory” process of change in RAI, the public service broadcaster.  In January 2007 it was reported that according to the Prodi government’s plans, RAI would be controlled by a Foundation ”in order to avoid direct control by the Italian government” (Pekic, 2007). The Foundation is to guarantee autonomy of government, represent the citizens-viewers, defend the company’s independence, define the statutes of RAI and nominate the top management. It is proposed that the Foundation’s Board of Directors be composed of seven members, with candidates screened by Parliament. The Board is to have a six-year mandate, a third being renewed every two years. Another idea is that the Board will be appointed by other institutions as well, such as Regions, Universities, and trade unions: in that case the number of members would be bigger. Following a public consultation, a government bill providing for these changes was to be submitted to Parliament.

It remains to be seen whether this will mean a democratic-emancipatory turn in Italy’s policies vis-à-vis PSB, reducing what is now full political control of the broadcasting organization.

Spain, Portugal and to some extent Italy are all examples of the “systemic model” of PSB introduction. The subsequent experience of these PSB organizations and their relationships with the power elite, hopefully leading to greater independence as a result of democratic consolidation, suggests that the process which media (and perhaps other) institutions go through when transplanted into an environment where they did not emerge naturally, could be compared to that of “ontogenesis”. In common parlance, we usually speak of “teething problems”, but there is more to it than that. The concept of ontogenesis in developmental biology captures “individual development of a living thing, all sequence of its transformations.” In other words, ontogenesis means that every specimen of the species repeats in the course of its development all the stages of evolution that the entire species had gone through in the process of its phylogenesis.

So, when you transplant an institution into a new environment, you are in reality launching a process that could retrace the stages of evolution that ultimately led to that institution’s successful development elsewhere. This is especially so if you transplant that institution into a “disabling” rather than “enabling” environment – as has happened with PSB in Mediterranean countries. The best you can hope for is that the institution and its social and political environment will repeat—albeit probably in an accelerated form—the experience (and all the mistakes) that other countries went through before they were able to achieve something close to the desired results: in this case, a strong and independent PSB with a true public service ethos. However, it is also possible that you may end up with an empty shell, an institution designed in theory to become a public service broadcaster, but prevented from becoming one by external circumstances.

It is clear that where modernization and consolidation of democracy are incomplete, only a hybrid political system can emerge. As a consequence, PSB organizations in Mediterranean countries are in reality hybrid constructs, combining disparate elements within one organization: public service; political elite mouthpiece; political battlefield; a commercial enterprise. In fact, many PSB organizations in established democracies are also hybrid constructs, combining these and other elements in various degrees.


An Enabling Environment for PSB

 After this extensive and lengthy detour, we are now ready to return to public service broadcasting in post-Communist countries. We must begin with the lessons that we can draw from the fate of PSB in polarized pluralist media systems as concerns prerequisites for its successful development.

There is no question that it requires the context of a mature liberal democracy and high democratic political culture to exist and flourish. However, simple consolidation of democracy is not enough for PSB properly so called to flourish. After all, Linz and Stepan (1996) regard Southern European democracies as consolidated, and yet – as have seen – PSB is facing major difficulties in those countries. What is needed is a stable, mature liberal democracy. However, even that in itself is not enough, if you consider the fact that the United States is such a democracy and yet has a very weak system of PSB. What is also required is a tradition of concern for the public interest and of a strong role for the State and the public sector in meeting society’s needs. McQuail (2005: 239-241) has identified three phases of media policy development in Europe, including a public service phase, lasting from the 1920s to the 1970s and – not coincidentally – largely overlapping with a long period of social democratic rule in many of those countries. That was the period when PSB emerged and developed. The triumph of neoliberalism in the 1980s, again not coincidentally overlapping with a new phase if the evolution of media policy, has shaken PSB and raised doubts as to its future.

Linz and Stepan’s (1996) concept of consolidated democracy helps portray the systemic interdependencies between the five arenas of democracy (political, civil and economic societies, state administration and the rule of law) needed for (representative) democracy both to operate properly, and to create propitious conditions for media freedom and autonomy, including that of PSB.

As a minimum, these conditions must include:

1.      Sufficient separation of all these arenas (which is not to deny their interdependence) so that proper separation of powers is achieved, all the countervailing forces operate properly, and the economy (and PSB) is outside direct political control;

2.      The existence of a strong civil society which, as Linz and Stepan put it “helps monitor the state apparatus and economic society”, resisting the expansionist tendencies of political society and state apparatus which always, when given a chance, seek to control more and more of social and public life. If this condition is met, an independent public sphere outside the control of politicians and/or state apparatus may emerge as the social space where independent media, operating as emanations of civil society, rather than political society, may develop;

3.      The effective operation of the economy and economic society and markets, so that the media can be sustained by the market and financially successful, as a prerequisite of their independence and development;

4.      Effective rule of law, so that the legal framework designed to protect media autonomy and proper performance is respected, both by the media as well as political society and state apparatus.

While this is all true, we must be conscious of the fact that these conditions can never be met fully. The experience of Western European countries and of the United States suggests that “clinical” separation of political and civil society, or political and economic society, can hardly be expected. Hence the need for a strong, aware and engaged civil society, as the only countervailing force capable of bringing influence to bear on the other arenas of democracy so as to prevent take-over of the democratic process.

      Even less is this likely in a young democracy, where the political class is the strongest (in some cases together with the economic class, taking the form of oligarchs), and can dominate all the other arenas of democracy. This is certainly the case in post-Communist countries.

            Another aspect of advanced consolidation of democracy that is needed for PSB to flourish is explained by Diamond (1997: 4):  

Consolidation [of democracy – K.J.] involves not just agreement on the rules for competing for power but fundamental and self-enforcing restraints on the exercise of power. This, in turn, requires a mutual commitment among elites, through the “coordinating” mechanism of a constitution, related political institutions, and often an elite pact or settlement as well, to enforce limits on state authority, no matter which party or faction may control the state at any given time. … This … involves not just tactical calculations of long-term benefit in a repeated game but, again, a normative shift as well (emphases added – K.J.).

Restraints on the exercise of power are hardly likely to be accepted, unless there is  long-term stability of a polity and the satisfactory resolution of fundamental societal issues. A recurrence of conflicts or the reappearance of profound divisions within society may potentially lead to rejection of these restraints. Nevertheless, there is little doubt that elite acceptance of restraints on the exercise of power and of limits on state and political authority is indispensable for the successful introduction and operation of PSB as an independent broadcaster. Otherwise, as shown by countless examples, a nominal PSB organization will become, in one way or another, an extension of the State, or of the power establishment.

          This points to the crucial importance of cultural factors, as shown in table 4.


Table 4. Processes of Media Change as Influenced by Key Areas of Society in Post-communist Countries


Depending onpolitical factors, the media can:


Politics, economy determine whether the media can:


Economy, market, technology favour or hinder:


Cultural conditions and “cultural change” are required for:

Be deregulated anddemonopolized

Become pluralistic and open

Be covered by a democratic legal framework

Enjoy an enabling  and effective policy for digitalization

Gain autonomy


Diversify in content

Address minority groups


professionalization of journalists

True removal of  media monopoly





Development of ICTs and convergence


Non-existence or resolution of national and ethnic conflicts

Resolution of major societal conflicts

Depoliticization of media

Rule of law

Ability to define and serve the public interest

Role for public opinion

The media to serve as impartial watchdogs

            In this table, column IV identifies some of the cultural prerequisites of media independence and autonomy, including successful introduction of PSB. However, as pointed out by Offe (1997) with regard to post-Communist countries, transformation by imitation or transplantation means that:

the cultural foundations of the new institutions […] will have to be supplied after the fact and in the course of the actual operations of the new institutions … . As long as the appropriate spirit and supporting political and economic culture is not yet in place, there is little that can immunize these new democracies and market systems against the dangers of opportunism, defection, erosion, and opportunist subversion of the newly introduced rules. […] If institutions are seen to fail or to yield less than what was expected of them, the only thing that can ensure their continued validity and recognition is a firmly entrenched system of beliefs that supports them – not for the reason (at least for the time being) that they are useful, but because they are “right” and hence intrinsically deserving of support.

            This process of developing the cultural foundations of the new institutional order after the fact is precisely an element of the process of their ontogenesis discussed above. Politicians, civil society and media practitioners need time
– measured in decades – to institutionalize the values and standards of consolidated democracy and to use transplanted patterns of public service broadcasting in the proper way.


Riviera on the Baltic? PSB in Post-Communist Countries

             Post-Communist countries share some of the features of Southern European countries: late democratization, insufficient economic development, weak rational-legal authority combined with a dirigiste State. Their modernization is also incomplete, or (in some cases) little advanced. In other words, they are not yet able to create a truly enabling environment for PSB.

Post-Communist countries break down into several groups in terms of their democratic development. Vachudova (2005) simplifies this by distinguishing liberal and illiberal democracies, though of course some of these countries are not democracies at all.

In the liberal ones, partitocratic systems, together with the politicisation of all spheres of public life (the post-Communist version of panpoliticismo) and the political culture of post-Communism, have favoured control of the media by political elites. In the illiberal democracies, autocratic systems of government, involving the power of state administration or the oligarchs over the media and an underdeveloped civil society, largely undermined prospects for media freedom, turning them into the voice either of the state, or of political or other vested interests.

As for consolidation of democracy, one assessment argues that “no doubt, prospects for successful consolidation can be found in the countries which were admitted to the EU in 2004, and those that are to join in 2007, i.e. Romania and Bulgaria. As for the others, we can rather speak of the beginnings of  democratic transformation (Ukraine, Croatia, Serbia and Montenegro), or of attempts to consolidate some hybrid forms (Russia, Albania), or of an authoritarian system (Belarus)” (Cichosz, 2006: 66).

Cichosz goes on to say that most post-Communist countries have developed hybrid forms of democracy: 

  1. Formal democracy – no counter-elites to oppose those in power, low level of political competition (Russia, Ukraine before 2004, Serbia before 2000);
  2. Elite democracy – competing oligarchies with low political participation of the citizens (Romania before 1996; Albania, Bulgaria);
  3. Partitocrazia – monopolization of public life by political parties which exclude other social actors from decision-making processes; rule by political oligarchs often connected to economic pressure groups. This amounts to political party capture of the state, corruption and low legitimacy of the system (just about everywhere in post-Communist countries);
  4. Tyrannical majority – forces returned to power disregard the political views and interests of other political or social forces; display no willingness to compromise and accept no restraints on their power. This type of hybrid democracy is promoted by “leaders convinced of their ‘historic and moral mission’, consisting in imposing a direction of the country’s development on the rest of society” (Cichosz, 2006: 64). Examples include Hungary in 1990-1994, Slovakia under Meciar, Croatia under Tudjman, Slovenia after 2004; Poland 2005-2007).

 It can be no surprise, therefore, that public service broadcasting in post-Communist countries is so far generally seen as failing to deliver on its promise of independence and political impartiality, as well as of serving as a mainstay of the public sphere, and of delivering diverse and pluralistic content of high quality. Many of the stations are heavily in debt and their audience share is falling, especially in countries where national commercial radio and television stations have been licensed. Many are facing enormous challenges caused by, among other things:

1.      Traditional and badly designed organizational and management structures, involving many collective bodies divided along party lines, incapable of fast decision-making and mainly concentrating on blocking each other’s actions;

2.      Heavy political control, resulting both from the politicization of the process of appointing top governing authorities, and from the desire of the journalists and programme-makers themselves to support or promote the political party of their choice;

3.      Frequent management and leadership crises and changes of top management, resulting from political interference;

4.      Lack of funds and programming know-how required to compete with commercial broadcasters, sometimes coupled with exaggerated insistence on non-commercialism which additionally weakens those stations’ ability to hold their own in the face of aggressive competition by commercial broadcasters;

5.      Self-censorship of journalists and programme-makers who can expect little protection from their superiors when they run afoul of politicians or some influential organization.

These outward manifestations of crisis are accompanied by problems of a far more fundamental nature: lack of social embededness of the idea of public service broadcasting and lack of a social constituency willing and able to support public service broadcasters and buttress its autonomy and independence. Transplanted into post-Communist countries in the process of “transformation by imitation,” they have not, generally speaking, been able to win support and a constituency in civil society.

Splichal (2001: 9-10) goes so far as to call the introduction of PSB in post-Communist countries a case of “re-nationalization”: 

In almost all countries in the region, the new governments – regardless of their specific political orientation – did not hesitate to imitate regulations and strategies of the former regimes to retain control over national broadcasting, either directly by appointments of boards, directors and editors, or in a more indirect way through budgetary and other economic instruments (e.g. state advertising). […]  Although some new forms of broadcasting regulation are deemed to imitate West-European systems, access to the “public” broadcasting is … still severely limited to political elites in most countries of the region (see also Price, Raboy, 2001). 

As a result

1.      Civil society perceives PSB as a pawn of the politicians (in some countries public service broadcasters enjoy relatively high credibility and are treated as the main source of news, but general awareness of political control over them prevents civil society from identifying with them); it may rouse itself into active protest in extreme situations, but on a day-to-day basis displays cynicism and lack of confidence in prospects for PSB properly so called to emerge;

2.      Political society views it as an instrument in the hands of the government of the day, control over it being a prize to be achieved on winning a general or local government election;

3.      Rule of law is inadequate to ensure general respect for the legal framework which may, on paper, define public service broadcasting properly and create the right institutional arrangements for it to exist;

4.      The state apparatus considers public service broadcasting as an instrument in its own hands, or – if it proves too independent – as an enemy;

5.      Economic society perceives public service broadcasting as an impediment to full control of the broadcasting market by commercial operators and in many countries actively campaigns for its marginalization. 

This is a fundamental problem. In Western European countries, PSB had a long time to become entrenched, and for the ethos of public service in broadcasting to become established, before these organizations began to face commercial competition and a less favorable political climate due to the triumph of neoliberalism. In post-Communist countries, the ideas of public service broadcasting have, on the whole, been honored more in the breach than in the observance from Day 1.

Another challenge is the lack of a tradition of impartiality among the journalists themselves. Hungarian writer Janos Horvath points out that the traditions of  Central and Eastern European journalism also lead media practicioners to seek leadership, guardianship/ stewardship and perhaps also hegemony roles:

Common in Europe is the concept of  the active or participant journalist, the journalist who sees himself as someone who wants to influence politics and audiences according to his political beliefs. This sense is even stronger in Eastern Europe, where journalists are closer to artists and writers, and many poets and writers contribute regularly to daily publications. Together with the journalists, they feel a sort of messianic vocation. (Janos Horvat, “The East European Journalist”, cited in Gross, 1996: 111). 

The willingness of some journalists to align themselves with political parties and their views contributes to a situation whereby PSB in post-Communist countries is described as “parliamentary broadcasting”, because of the strong influence parliamentary parties can bring to bear on those institutions. This has produced something that could be called “parliamentary-term pluralism”, with PSB media reflecting the orientation of the government of the day. If you live long enough, you will – over many terms of parliament – be exposed to many orientations, but only one dominant one at a time. This is almost like serial monogamy – many spouses, but only one at a time.

Meanwhile, a coalition of local and international commercial broadcasters seek to use their political clout to marginalize public broadcasters and to influence legislation to this effect.


PSB in Poland

There are 19 PSB organizations in Poland: 2 at the national level (public television – TVP, and public radio – PR), and 17 regional public radio stations at the regional level. Each has a Supervisory Board, a Board of Management and a Programme Council (a non-executive advisory body, consisting of 10 people representing parliamentary parties and 5 others – all formally appointed by the NBC). There are also Programme Councils attached to the 16 regional television stations that form part of TVP.

Despite their formal status as state companies, public service broadcasters are not really controlled by the either parliament or government. Under the Broadcasting Act, “State authorities may take decisions concerning the functioning of public radio and television broadcasting organizations only in circumstances specified in the existing legislation”. This removes the danger of any arbitrary action. The general meeting of shareholders (i.e. the Minister of the State Treasury) is legally prohibited from affecting the contents of programming. The Minister may not unilaterally change the statute of any PSB organization, but must obtain the consent of the National Broadcasting Council for that. Also, the State Treasury is not entitled to any dividend from PSB organizations. License fee revenue is deposited with the National Broadcasting Council which is legally bound to transfer this money immediately to PSB organizations.

Different terms of office for the National Broadcasting Council (6 years), supervisory councils (3 years) and boards of management (4 years) were designed to dissociate those terms from that of Parliament. Staggered terms for NBC members (before they were abolished in 2005) were also designed to prevent “political parallelism”, i.e. reproduction within the NBC and the governing  bodies of PSB organizations of the political composition of the Parliament of the day.

In addition, supervisory council members may not be dismissed. Appointment and possible dismissal of the whole board of management, or of one or more of its members, requires a qualified majority of two-thirds, with at least three-fourths of supervisory council members present and voting. The supervisory council may, however, suspend a Board of Management member by simple majority. Still, refusal by the general meeting of shareholders (the Minister of State Treasury) to accept of the annual report and accounts of each PSB company, need not legally be followed by the dismissal of the board of management.

      In short, the Broadcasting Act and verdicts of the Constitutional Tribunal (rulings that NBC members and members of supervisory councils may not be dismissed, and that the chairperson of the NBC should be elected by the members themselves, rather than appointed by the President) contain an extensive array of safeguards of the formal independence of PSB organizations.

      Once the governing bodies of PSB organizations have been appointed, political influence is either a matter of internal decision-making, or – in case of external influences – usually of an informal nature.

      There is usually no direct, formal or institutional impact of political bodies or the authorities on any PSB activities, except of course for the appointment of Supervisory Councils and by extension of Boards of Management. Supervisory Boards are appointed by the National Broadcasting Council, with the exception of 1 person who is appointed by the Minister of the Treasury. It is these Boards which then appoint the Boards of Management of PSB organizations.

      Poland has just gone through two years of a populist, right-wing government, determined to centralize power in the hands of the then ruling Law and Justice Party.

A report on the state of democracy in Poland, issued in 2007 by a civil society organization (Konwersatorium Doświadczenie i Przyszłość, 2007) contains the following general assessment of the then government’s policy: “After the elections of 2005 we can observe attempts to dismantle the mechanisms of the division of powers in the name of creating a ‘strong State’, which in practice amounts to imposing the superiority of the government and the parliamentary majority.”

            Part of this process has been what can only be described as “capture of public service media” by the then ruling coalition.

To this end, one of the first legislative initiatives of the new government in December 2005 concerned amending the broadcasting law. As far as the National Broadcasting Council is concerned, the amendments provided for the following:

1.                  The term of office of serving NBC members was terminated;

2.                  The number of NBC members was reduced to 5 (2 appointed by the Diet, 1 by the Senate, 2 by the President);

3.                  Staggered terms of office for NBC members were eliminated;

4.                  The NBC Chairperson was to be appointed by the President (previously the Chairperson was elected from among the members) – later rejected by the Constitutional Tribunal;

5.                  The NBC was given the competence to ”initiate and undertake actions in the field of protecting journalistic ethics” (later rejected by the Constitutional Tribunal).

As a result, new members of the NBC were appointed according to a straight party ticket (3 designated by the Law and Justice Party or the President; 1 each designated by the coalition parties – Self-Defence and the League of Polish Families). The consequence of this was that the governing coalition took direct political control of the National Broadcasting. The new NBC proceeded to appoint Supervisory Boards according to a straight party ticket, with a pre-determined distribution of seats between candidates designated by the three governing parties. The same principle applied to the distribution of seats on Boards of Management which – upon their appointment – proceeded to replace personnel, bringing in new people especially to run news and current affairs programming. Incidentally, the same principle applied to the Polish Press Agency, a state-owned company.

      That turned public service media into a direct mouthpiece of the government. In 2006, a foundation conducted monitoring of selected news programmes of TVP and concluded that in the main evening news Law and Justice appeared twice as often as the leading opposition party, the Civic Platform, and three times as often as any other political parties. The sound-bites of its representatives last twice as long as those of the opposition, and the fact that those representatives will appear is announced beforehand much more often (Fundacja im. Batorego, 2006).

During the general election of September 2007, OSCE election observers also noted a lack of balance in the presentation of different political parties in the programming of Polish Television, with the Law and Justice Party enjoying a clear advantage.

Some journalists have been sidelined or fired from public service media in Poland in 2005-2007 (and indeed previously) for refusing to toe the political line, testifying to the fact that the public service spirit has not been totally extinguished yet.

The new government, elected in September 2007, is liberal in orientation, so it may take the neoliberal approach. There is talk of eliminating the license fee, of privatizing public television, and so on.

            Generally speaking, one could say that Polish public service media face six major crises:

         Dual State Policy vis-à-vis public service media

         A Crisis of Identity

         A crisis of legitimacy

         Management crisis

         Funding crisis

         Delayed technological transformation and change of relations with the public

Dual State policy takes the form of, on the one hand, properly defining the goals of PSB, and designing a system of protecting its formal independence, and, on the other, trying to turn PSB organizations into “ideological state apparatuses”, when possible, and by doing nothing to prevent far-reaching commercialization, especially of public television.

      A crisis of identity on the part of PSB organizations and their staff is a natural result of their hybrid nature, creating a conflict between an unavoidably weak public service ethos, political bias and commercial values resulting from heavy dependence – especially in public television – on advertising revenue. All this produces a cognitive dissonance which deprives the staff of certainty as to what it should really do.

As can be seen in figure 1, Polish Television has a higher share of entertainment in its programming than many other PSB TVs. This contributes to this crisis of identity. 


Figure 1. Break-down by genre of selected PSB TV programme services (2004) 

Data taken from the European Audiovisual Observatory. 

That leads directly to a crisis of legitimacy, as PSB organizations cannot deliver on the promise of political impartiality, ambitious programming of high quality, and cultural and educational content.

      Management crisis results from the political method of appointing governing bodies, meaning that the organizations are usually run by amateurs with little experience either of broadcasting, or of management.

      Crisis of funding concerns not so much lack of money, as the fact that license fee evasion is high and Polish Television depends on advertising for around 70% of its revenues. This results in growing programme convergence between PSB and commercial media, exacerbating the identity and legitimacy crises. 


Table 5. Revenue of public TV in Poland – break-down by source (%)






















    Licence fees







    Financial operations














The crisis of delayed technological transformation and change of relations with the public concerns the fact that Polish PSB organizations are still primarily traditional broadcasting organizations with little activity online or on other platforms. So, while studio and other equipment can be up-to-date, little of the migration to new platforms undertaken by other PSB organizations has yet happened. Equally, there has been little effort to use the new technologies to establish a “New Partnership” with the public, which is needed in the digital era (see Jakubowicz, forthcoming).



            After all this gloom-and-doom talk, my conclusion will be quite positive. On the strength of my comparative analysis, we could say that disappointment with PSB performance in post-Communist countries is one more reflection of the great, but also  to some extent unrealistic expectations created by the process of post-Communist transformation, especially as concerns the pace of change and the success of transformation.

Given that the creation of PSB is one of the hardest tests of the success of the general process of political and media change, it is doubtful whether, realistically, more could have been achieved since 1989.

            Of course, there is a price to be paid for disappointed expectations. Much of the mimetic strategy of transformation was based on a hope that, with time, the cultural and axiological underpinnings of transplanted institutions could be added to enable those institutions to operate as intended. As we saw on the example of Spain or Portugal, change in media, especially public service media, may lag behind a more general process of democratization. So, this soon becomes a race against quickly growing disillusionment with the way the institution operates. Such disillusionment may prove dangerous, as public opinion may not be prepared to accept the existence of a flawed institution, failing to bring the expected benefits. That may deepen the frustration on the part of civil society and cynicism about the concept of public service broadcasting, turning into an unending vicious circle.

            Yet, Central and Eastern Europe has seen many instances of civil society willing to defend free media. This includes a famous strike of public television personnel against government intervention in the Czech Republic (2000); similar recent developments in Slovakia; street protests against the persecution of the  Rustavi-2 TV station in Georgia (October 2001), street protests in Moscow against the elimination of NTV, an independent TV station (2001); a campaign against changes in PSB law, threatening its political subordination in  Slovenia (2005); protests in Poland in 2006 and 2007 against pressure being put on public and independent media, and against ultimately unsuccessful attempts to vet journalists for possible history of collaboration with Communist-time secret police, with the threat that they would be banned from the journalistic profession for 10 years if they refused to submit to this.

Spain, Portugal, Italy and France have been the scene of this vicious circle for many years. It can be broken through. It can also persevere. Let us hope that in post-Communist countries it will be broken through.

Of course, all this depends on whether there will be enough time for that. In other words, on the survival of PSB as such. If because of neoliberal tendencies in Western countries, the continued existence of PSB is threatened, it will be dismantled in post-Communist countries like a shot. Our politicians can only be shamed into grudgingly accepting the existence of PSB if it is seen to perform well elsewhere. So, if you wish us well, defend PSB in Canada – for your sake and ours.



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