A RESPONSE BY THE ASSOCIATION OF ADVERTISING AGENCIES
DRAFT POSITION PAPER
THE MEDIA DEVELOPMENT AND DIVERSITY AGENCY


The AAA response to the draft Position Paper on the MDDA will address the principle of media diversity and accessibility, and how to achieve media development and diversity, by asking two key questions: whether market forces have failed to establish media-pluralism in South Africa; and whether extra market-forces (such as the MDDA) are required to ensure media diversity. Where appropriate, arguments will refer directly to the relevant numbered sections in the draft Position Paper.

THE PRINCIPLE: MEDIA DIVERSITY AND ACCESSIBILITY

The AAA is fully in agreement with the principle of promoting access to media by marginalised groups and to enhance media pluralism. Communication scientists all over the world have realised since the early 1980’s that the 4 key information trends which go hand-in-hand with the communications explosion viz. information overload, alienation and resistance, the information paradox and the information elite, will require the emergence of smaller-scale media to satisfy the more localised and interpersonal needs of the smaller community and subculture. The trend was also clearly predicted by Toffler in "The Third Wave" (1980) in which he described the succession of what he called the paper blizzard and the reign of the mass media, by the demassifying influences of the rising number of

local papers, radio and television networks. In marketing terms this trend has become known as stronger segmentation or niche marketing. In sociological terms, this has been called a shift from the "we thinking" to the "me thinking" syndrome, and in media terms it is called a resistance against the "melting pot" function. Respected communication theories at the heart of the matter are the uses-and-gratification theory and the knowledge-gap hypothesis. In terms of the uses and gratification theory the emphasis is no longer on what media do to people, but what people do with the media in terms of their own uses and needs for them. The knowledge gap hypothesis states that mass communication might actually increase the difference in knowledge between members of different social classes. Information is generated, used and communicated within an ever shrinking

 

-2-

information "elite" with the consequence that ever fewer people are able to check the information on which important decisions affecting their daily lives, is based.

At the basis of this issue is, therefore, nothing less than the very idea of a democratic society with a diversity of media, in which at least the main social, cultural and political groupings can express their views.

It makes infinite sense for a country like South Africa, especially, that a workable media development and diversity policy is established, particularly because it is such a heterogeneous, complex and multicultural mix of an information rich and information poor society.

ACHIEVING MEDIA DEVELOPMENT AND DIVERSITY

From a marketing point of view, the obvious approach would be that communications must become more market-orientated, which would require great market expertise and ethical responsibilities of the communication practitioner in order to satisfy audience needs and maintain the credibility of the media.

The first question would be whether all of this can not be naturally achieved through market forces alone, in which a diversity of private media can service the different information needs of a large number of cultural, political and socio-economic groupings of the population.

The marketplace ideology, inspired by Lockean principles of natural law, would only tolerate government’s intervention in matters such as these on the grounds of market failure (or national security). This is typical of the US (whilst some other Western European countries are more tolerant of government intervention and more vigilant about private power).

Have market forces failed to establish media pluralism in South Africa? And if so, what role should government play? We would like to return to the first question in the next section.

To answer the second question, consideration of all the political angles which may underlie the principle becomes unavoidable. It is ironical that a media diversity and developmental policy (including deregulation and privatisation of the electronic media) has been desperately advocated in the mid – 1980’s by journalists, academics and critics of Government, exactly to break the then Government’s hold on the SABC, the Afrikaans press, the clampdown on the alternative media and the government’s then newly created watchdog the Directorate of Media Relations in 1987.

Today, grave concerns are expressed that the proposed MDDA will be just a front to create mouthpieces for government due to its perceived inability to take criticism. Unfortunately, recent statements from government spokespersons criticising "systematic hostility" of the media, ownership of which is concentrated in the hands of the few, add fuel to such concerns and perceptions. (Business Day, Beeld 7 February 2001.)

The point is that inasmuch as it is a dangerous situation that information is generated and communicated within a select few, it is as dangerous for any government to be part of that select few.

Have market forces failed to establish media-pluralism in South Africa?

In answering the above question the following points deserve careful consideration:

 

-3-

1. To begin with, the AAA would like to point out a glaring omission in the draft position paper. This was very clearly brought to the attention of GCIS during its discussions with the AAA in April 2000 regarding the MDDA, and more information regarding this point was subsequently requested by GCIS from the AAA, which was provided together with a table on media growth slowdown for 1998 – 1999.

This information will be repeated again, by providing data on share of Adspend by media type over a 4 year period, which shows clearly that advertising expenditure in measured media has grown more slowly than it has done for years.

Share of adspend by media type

(Also see Annexure 1 which includes 2000 adspend figures only released

after submission on 28 February)

1996

1997

1998

1999

 

Rm

Share

Rm

Share

Growth

Rm

Share

Growth

Rm

Share

Growth

 

 

%

 

%

%

 

%

%

 

%

%

Print

2338,0

45,6

2760,0

44,9

18,0

3167,2

43,7

14,8

3422,1

42,8

8,0

TV

1937,8

37,8

2397,8

39,0

23,7

2938,8

40,5

22,6

3274,9

40,9

11,4

Radio

658,1

12,8

725,7

11,8

10,3

795,3

11,1

9,6

925,7

11,6

16,4

Outdoor

148,8

2,9

195,3

3,2

31,2

210,9

2,9

8,0

250,4

3,1

18,7

Cinema

47,0

0,9

69,9

1,1

48,6

76,8

1,1

9,9

666,1

0,8

-14,0

TOTAL*

5129,8

100,0

6148,6

100,0

19,9

7189,0

 

16,9

7939,2

 

10,4

Knock & Drop

 

 

 

 

 

59,2

0,8

 

60,9

0,8

2,9

TOTAL**

5129,8

100,0

6148,6

100,0

19,9

7248,2

100,0

 

8000,1

100,0

10,4

*Excl Knock & Drop, ** Incl Knock & Drop SOURCE: MEDIA SHOP, ADINDEX

While the rate of growth in measured adspend is declining, non-traditional or below-the-line marketing (which includes such activities as sponsorship, direct marketing, promotions, taxi-advertising, traffic hoardings, industrial theatre, back-of-airline tickets, toilet doors and cafe floors) continues to grow significantly and is estimated to account for at least half of marketing expenditure. If this growth continues, their share of the total value will exceed that of advertising very soon. (This is also incidentally confirmed by the dramatic growth of specialist agencies during the past years)

The implications of this ongoing trend are twofold:

1.1) Does this not signify a natural development of alternative, economically viable vehicles to communicate with diverse audiences?

1.2) Even if this trend is seen as not a strong enough market force not to warrant the proposed MDDA, would reliance on the MIT levy as a source of funding for the MDDA, for instance, not prove too risky? (See section 10.3)

2. There is a debate amongst communications scientists as to whether too much diversity (or too narrow a segmentation policy) may not be premature in a country like South Africa which is still undergoing a transition. They point out that the media’s (often vilified) melting pot function is not necessarily negative. The mass media contributes to integration and to the creation of middle class values, and

-4-

symbols of upward mobilisation and aspiration which may not be necessarily undesirable in South Africa.

3. There are those who argue that media diversity is not possible without cross ownership. Media convergence is as much a reality as is cross media ownership. Yes, there could and should be more disseminators and gatherers of news, but it is an expensive undertaking. Surely if news is gathered in one medium, it makes good economic sense to amortise the cost of gathering this news over a number of media types. It’s up to the individual to decide whether he/she requires their news digitally, over the airwaves, in printed format, etc. Should the onus, at this stage, in some way or another, not fall more heavily on those who can afford to make media accessible to marginalised audiences?

4. Instead of extra-market measures, should the hands of those who have already launched their own worthy initiatives not be substantially strengthened? For instance, in line with its Transformation Charter, the AAA as a stakeholder would not be opposed for the industry to give consideration to either an increase of the MIT levy or alternatively, a contribution in terms of fixed fees from industry members, in order to fund voluntary industry initiatives such as PMSA’s Print Development Agency (see 3.2.2), emerging black advertising agencies/marketers, or bursaries for talented disadvantaged individuals studying in media – , advertising – or market-related fields.

Are extra market forces (such as the MDDA) necessary to ensure media pluralism?

According to the position paper, media diversity cannot be left entirely to market forces. Even in a fully transformed society, it states, extra market measures will be required to reach poorer communities (section 2.4.2).

The AAA can accept this argument, only if it is convinced that sufficient consideration has been given to points 1 – 4 in the previous section. It is our contention that natural market developments and options are underestimated and underexplored at present.

Even if the AAA is convinced of the necessity of extra market intervention, such as the proposed MDDA, it would still question the following:

1. The extent of such intervention, in terms of the proposed size, structure, functions and funding requirements of the MDDA.

2. Whether the MDDA will in fact operate at arms length from Government.

3. Whether there is not an unnecessary overlap of functions between the proposed MDDA and Icasa, as well as the MAPPP SETA. For instance, it is not at all clear whether Icasa and its predecessor the IBA, which was established to achieve a vibrant, diverse broadcasting sector, could not fulfil its mandate due to reasons given under section 2.2.1, or due to other problems, i.e. funding. Also, the proposed involvement of the MDDA with training and skills development seems very similar to the mandate which MAPPP SETA already has to fulfil (see section 6.8).

In essence, it seems that there already exist extra market mechanisms (such as Icasa and the MAPPP SETA) which already fulfils (or should fulfil) some of the functions of the proposed MDDA. Unnecessary duplication of costs should be of prime concern here.

-5-

4. In section 8.3 of the Position Paper it is stated that the MDDA "will work closely with Icasa to ensure that broadcasting licences are issued according to principles of media development and diversity " and " will empower committees and individuals to apply for and receive broadcasting licences from Icasa". Does this imply that preferential treatment will be given to such applications by Icasa?

In view of the above, we believe consideration of the proposed funding of the MDDA via, amongst others, the MIT levy is premature at this stage. As already pointed out however, the AAA is in principle not opposed to a voluntary industry contribution to empower worthy industry initiatives to advance media pluralism. In fact, AAA members could only benefit from improved media penetration of diverse audiences.

Conclusion

In summary, the AAA agrees in principle with the intention to enhance media development and diversity, but is not convinced that natural market forces have been fully explored and acted upon. It is willing to give its 100% co-operation and contribution in developing viable market mechanisms to make media accessible to marginalised audiences. If extra market forces are proved unavoidable, the AAA will accept this. However, the extent of such intervention (as currently proposed), are seriously questioned, as well as the perceived overlap between the functions of the MDDA and other regulatory bodies with the same objectives. For these reasons, we believe consideration of the proposed financing of the MDDA is premature.

As an industry we are vigilant of government intervention, but are most willing to build a constructive partnership with Government on an issue as important as this. We remain committed to the realisation of the national agenda and are most willing to pursue all possible avenues in search of a solution to the challenge of offering diversified independent media to smaller and marginalised audiences.

 

 

 

DR. NINA DE KLERK

EXECUTIVE DIRECTOR

(On behalf of the AAA)

26 February 2001