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Unformatted text preview: LeonieRutherford,DeanBironandHelenSkouteris CHILDREN’S CONTENT REGULATION AND THE‘OBESITYEPIDEMIC’ Abstract Some30yearsago,AustraliaintroducedtheChildren’sTelevisionStandards(CTS) with the twin goals of providing children with high quality local programs and offering some protection from the perceived harms of television. The most recent reviewofthe CTSoccurredinthecontextofadecadeofincreasinginternational concernatrisinglevelsofoverweightandobesity,especiallyinveryyoungchildren. Overlapping regulatory jurisdictions and co regulatory frameworks complicate the process of addressing pressing issues of child health, while rapid changes to the media ecology have both extended the amount of programming for children and increased the economic challenges for producers. Our article begins with an overview of the conceptual shifts in priorities articulated in the CTS over time. Using the 2007–09 Review of the CTS as a case study, it then examines the role ofresearchandstakeholderdiscoursesinthe CTSreviewprocessandcritiquesthe effectiveness of existing regulatory regimes, both in providing access to dedicated children’s content and in addressing the problem of escalating obesity levels in the population. Increasingly,Australianmediacontentandmarketingcommunicationmoregenerallyhave been linked by public health researchers to an alarming rise in childhood obesity. One question raised by this growing anxiety is the ability of existingAustralian regulation to deal with the scope of this so called ‘obesity epidemic’. In the last two to three years, a raft of reviews of media policy settings and other areas of regulation have attempted to dealwithkeypublicconcernsaboutprotectingchildren’shealthandwell being,together withtheirrightstodedicatedscreenmediacontent.Thesereviewsarecouchedwithinan economiccontextframedbyincreasingcoststoterrestrialbroadcastersmarketfragmentation, digitisation and multi channelling. In 2009, the Australian Communications and Media (CTS)afteratwo yearprocessofconsultationandreview thefederalgovernmentallocated budgetresourcestofundtheAustralianBroadcastingCorporation’snewdigitalchildren’s channel,ABC3, to provide commercial free, dedicated children’s programming  and the multi channel services, including Nine’s GO!, targeting a ‘youth’ demographic (14–39 years). Provision of content for children and youth is clearly at a high point. However, the limited remit of the ACMA hinders its ability to address fully controversial issues that cross other regulatory jurisdictions and multiple media platforms. Despite an unexpected surge in TV advertising revenue in July 2010, the consensus view is that the free to air television business model is under threat.This view informed amuch criticiseddecisiononthepartoftheDepartmentofBroadband,Communications andtheDigitalEconomy(DBCDE)torebateathirdofcommercialtelevisionbroadcaster No.140—August2011 47 licencefees.During2010,concernfortheeconomicviabilityofthetelevisionbroadcasters, oftenframedintermsofprotectingAustraliancontent,continuedtodominateoutcomesof reviews of proposed reform.In this policyenvironment,itis not surprising thatboththe HealthTaskforce(AustralianGovernment2010)bothrejectanyincreasesinlimitationson advertisingofenergy denseandnutrition poor(EDNP)foodsduringtimeswhenchildren constitute a large part of the viewing audience.1 dedicatedcontentwithinthechildren’stelevisionenvironmenthasbeenshapedintwoways. First,Australianpolicyhascreatedinstitutionsthatfosteraculturalandpublicserviceethos inchildren’scontentprovision.TheAustralianChildren’sTelevisionFoundation(ACTF), for example, has functioned as a developer of dedicated children’s production within an increasingly funding starved global ecology. The Australian Broadcasting Corporation (ABC),whileproducingverylittlecontentinhousesincetheearly1980s,hascontinued to broadcast children’s and educational programming in an advertising free environment. the inception ofABC3, is celebrated as one prong of the government’s response to the publicdiscourseandexpectationssuchthatthewidercommunity,andevenmanyelements withincommercialstakeholderorganisations,nowsupportprovisionofdedicatedchildren’s content. The second regulatory support lies in the imposition of quotas on commercial licensees, mandating the provision of children’s andAustralian content.Various industry codes of practice that contribute to a co regulatory partnership with government address issues of harms associated with the broadcast of television content. One question raised by increasing anxiety over rising rates of childhood obesity is whether the existing frameworks are robust enough to deal with pressing issues concerning children’s health. The major regulatory document over the last three decades has been the Children’s TelevisionStandards.TheCTShaveevolvedfromprimarilyaculturalpolicytoonemore consciousofcommunityconcernsaboutissuesofchildhealth,culminatingintheresearch anddiscoursesurroundingthe2009reviewconductedbytheAustralianCommunications and Media Authority (ACMA). The CTS Review Issues Paper (ACMA, 2007a) raised policyamendmentsforconsideration,suchasa‘TradableObligations’scheme,thatpoint to a reduced role for the CTS in the shaping of children’s content provision across new televisionchannels.ThispolicysuggestionwasreintroducedbyaDepartmentofBroadband, CommunicationsandtheDigitalEconomyreviewannouncedinlateDecember2009,and framed in the context of digital switchover regulation (see DBCDE, 2010). In addition, in considering further limitations of ‘junk’ food advertising in both dedicated children’s programmingbandsandmoreextendedtimeperiods,the2007IssuesPaper(ACMA,2007a) and subsequent reports marshalled research that traversed other regulatory jurisdictions (such as health and food policy). Given the complexity of the obesity problem, and the challenges posed to regulators, this article argues that the continued reliance on the CTS and the ACMA more generally as a ‘Nanny Regulator’ – bearing the brunt of public expectations about child protection and well being – needs to be rethought. In primarily framing its discussion around the wider problem of childhood obesity and the marketing ofso called‘junk’foodandbeverageproducts,ourdiscussionwillscrutinisetherelevance A brief history of the Children’s Television Standards TheChildren’sTelevisionStandardsweretheunlikelyoffspringofaninquiryintoindustry self regulation,duringaneracharacterisedbyincreasingreluctanceonthepartofregulators to act in opposition to the interests of commercial broadcasters (Hawke, 1995  Flew, 2006). The Australian Broadcasting Tribunal’s 1978 Self Regulation Inquiry introduced MediaInternationalAustralia 48 Committee(CPC),whosebriefincludedtheformulationofstandardsrelatingtochildren’s television productions. In essence, the Standards proposed reforms aimed at increasing the amount of dedicated,Australian produced children’s programming screened on free to air commercial television. Predictably, such reforms were hotly contested by industry disciplinary expertise of academics and child welfare professionals.The discourse of the CTSemphasisedissuesofchildren’scognitivedevelopment,andmobilisedpublic interest argumentsforservicetochildren.Theserationaleswerealsodominantinthe1987review of the CTS (ABT, 1991: 281). Mandated Australian children’s programming was – and arguably remains – the keystone of the CTS. The ‘discovery’ of the children’s market (McNeal, 1999  Kenway and Bullen, 2001) and the exponential rise of marketing communications directed to children (Jones, 2007  Schor, 2004) was yet to cause concern for child advocates. In her 2006memoir,DamePatriciaEdgarnotesthatsincetherewere‘noprograms,programming itselfwasanareawherechangecouldsucceed’,suggestingthattheindustrymemberson theChildren’sProgrammingCommitteemorejealouslypolicedanyguidelinesrestricting development of children’ and ‘is appropriate for Australian children, not assuming too much of the culture, dialect or environment of some other country’ (ABT, 1991: 312). The1984CTSwere,however,notrestrictedtoissuesofprogramming.Criteriadelimiting thescreeningofadvertisementsduringCtimewerealsoset.Suchcriteriaweredominated by three concerns: (1) the separation of advertising and program material  (2) perceived truthinadvertising and(3)childwelfareandsafety.Harm minimisationclausesfocused primarily on preventing children from being misled or deceived by advertisements, and protecting them from unsafe toys and games. Health and nutrition were not addressed inanupdatedCTStakingeffectfromJanuary1990.Thisreviewattractedahighlevelof advertisements during dedicated children’s television shows. Submissions to the inquiry from organisations such as the Department of Community Services and Health, as well as from concerned individuals, drew attention to the general issue of nutrition and its impact on child health. The subsequent document included a new directive (CTS 19.6) to the effect that ‘an advertisement for a food product may not contain any misleading or incorrect information about the nutritional value of that product’ (ABT, 1989: 28). More recent work in cultural and consumer studies, of course, emphasises ‘branding’ and associated ‘affect’ as the mechanism driving consumer choice, rather than ‘factual’ presentation of a product’s merits. T he 2007–09 C T S Review The most recent review of the CTS occurred in the context of a decade of increasing international concern on the part of paediatricians and health economists at rising levels of overweight and obesity, especially in very young children – the so called obesity ‘epidemic’ (US Department of Health and Human Services, 2001  National Preventative HealthTaskforce, 2009: 9). Pressure was mounted on regulators in other jurisdictions to introducelegislationreducingchildren’sexposuretofoodpromotion,particularlytelevision advertising.In2004,OFCOM,theUnitedKingdom’s‘super’regulator,publisheditsown researchonchildhoodobesityandfoodpromotion.2Evidencefromthisresearchresulted in policy changes to partially restrict television advertising of ‘junk’ food in children’s No.140—August2011 49 viewing periods, though this limitation fell short of the total ban prior to the 9.00 p.m. ‘watershed’ sought by the Food StandardsAgency (FSA) and other health advocates. WhentheCTSReviewwasannouncedinMarch2007,theresearchagendasofvarious Australian state and federal Health Departments had already turned to the concept of preventative health.While still in opposition, inAugust 2007 theAustralian Labor Party (ALP) signalled that if elected it intended to make health promotion a key strategy for Roxon, 2007). One of three major inquiries into the health system commissioned by the Rudd government, the National Preventative Health Taskforce, amassed research and outlined a comprehensive strategy in its discussion papers and report, Australia: The Healthiest Country by 2020, including numerous recommendations focusing particularly onobesity,andontobaccoandalcoholuse(NationalPreventativeHealthTaskforce,2008, 2009 CommonwealthofAustralia,2009,2010).Theconceptofinterventionwasclearly on the public policy agenda. Notwithstandingthe2007electioncommitmentstohealthandeducation,prioritiesfor the Department of Health and Ageing (DOHA) exist in competition with agendas and initiatives under the aegis of other regulatory jurisdictions. It has widely been accepted mediasectors.3AsmanysubmissionstotheCTSandtheDBCDE’sMultichannel(Content ‘the right policy mix for the rapidly developing digital media environment’. Most in the content aggregation business are keenly aware that, until usage patterns across a range ofnewandprojecteddeliveryplatformsandservicesstabilise,certaintyabouttheability to monetise will not emerge. Less debated in media policy circles is the fact that such fragmentation means that marketers are already targeting much of their spend (and their campaigns to promote consumer behaviours) across media not protected by standards such as the CTS. Research and the CTS review process ACMA released its Issues Paper in June 2007 (ACMA, 2007a), together with a trio of research sources thus discursively prioritised as background evidence. These were: the Children’sTelevisionProductionProject(Aisbett,2007),asmall scalequalitativeresearch projectevaluatingtheeconomicsupportsofchildren’stelevisionproduction theChildren’s ViewingPatternsonCommercial,Free to airandSubscriptionTelevision(ACMA,2007b), ananalysisofratingsdatafor2001,2005and2006 andtheBrandReviewoftheliterature Broadcasting ServicesAct including Australian programming’. The third report addresses the additional objective ‘to provide for the protection of children from possible harmful effects of television’ (ACMA, 2007a: section 1.1.1). Cultural identity and diversity criteria largely rest on the foundation of provision ofAustralian content, while the protection from harmful effects centres around the threat posed by food advertising. Australian media policy scholars such as Terry Flew have argued that supervisory authorities are subject to what Robert Horwitz calls ‘regulatory capture’ (Horwitz, 1989, citedinFlew,2006:289)–thatis,thatregulatingagenciesintimecometosystematically favourtheprivateinterestsofthebodiestheyregulateoverquestionsofthepublicinterest. Arguably,bothACMAandsectionswithintheindependentproductionindustryhavecome to associate the continuance of the children’s production sector and the availability of MediaInternationalAustralia 50 locallyproducedchildren’sprogrammingwiththeinterestsofthefree to aircommercial broadcasters. This is problematic for ACMA’s second cultural objective – protecting children from food marketing – since the revenue base of the broadcasters is dependent on such advertising. ACMA is often seemingly placed in the position of a ‘nanny regulator’, charged with protecting children’s physical and mental well being on issues such as childhood obesity, which clearly fall under the co jurisdiction of other institutions, including the variousTrade andTrade Practices Departments, and Health Departments, at both federal and state levels. Furthermore, it must do this in a governance climate where its ability to act strategically is hindered by long standing neo liberal ideologies and practices.As the Issues Paper explains: ACMA’sroleistoworkwithindustrytomanageaneffectiveregulatoryenvironment  within the industry  is supportive of technological advancement  and enables industry to meet the needs of the community. (ACMA, 2007a: section 1.1.4) ‘Command and control’ regulatory interventions, such as a ban on EDNP food advertising, are an unlikely result of such a whole of government approach. Clearly the commercial free to air broadcasters as they gear up for digital multichannelling. The Issues Paper overtly recognises that the power of the CTS to provide visible, accessibleandaffordableAustralianchildren’scontentisunlikelytosurviveintheeraof digitalplenitude.Itmorecoylyskirtstheissueoftheeconomiclogicthatlinkspromotion of EDNP foods to children to that very affordability. The Issues Paper references, and gives policy prominence to, advertising industry Codes of Practice, such as that of the Australian Association of National Advertisers (AANA), which mandate that marketing communicationstochildrenshouldnot‘promoteaninactivelifestyleorunhealthyeatingor drinkinghabits’(AANA,2008),whileimplyingadistributedresponsibilityforregulatory action: TheadvertisingprovisionsoftheCTSoperatewithinamulti layeredframeworkof foodandbeverageregulationthatincludesgovernmentregulation,co regulationwith industryandvoluntaryindustrycodes.Thisbroaderframeworkcoversadvertising andmarketingoffoodsandbeveragesacrossarangeofmedia,aswellasproduct packaging and labeling. (ACMA, 2007a: section 9) Children’s Television Production Project TheChildren’sTelevisionProductionProject(Aisbett,2007)canvassestheeconomicsof children’s television production inAustralia, particularly the role of the CTS in ensuring theviabilityofthelocalindependentproductionindustry,withdramaproducersespecially viewingtheproductionquotasmandatedbytheCTSasthemainsupportfortheirindustry. The Children’s Television Production Project also provides an ecology of the industry, c.2007, tracing the intersections of regulation, government and non government funding regimes, together with international market ecologies that impact on available funding for,andcontentof,‘Australian’children’smediaproduction.Examinationofthereport’s of the marketing communication industries within this children’s media ecology has a bearing on the argument presented here. Aswiththe Children’sViewingPatternsonCommercial,Free to airandSubscription Televisionreport(ACMA,2007b),theChildren’sTelevisionProductionProjectaddresses the question of the diminishing audience for free to air children’s television (putatively No.140—August2011 51 it remains economically viable for advertisers to target children during the ghettoised Cperiodsnominatedbybroadcasters(generallybetween4.00and5.00p.m.).Theprime time audience is larger (including more children) and this timeslot is therefore more lucrative in terms of the advertising revenue it attracts for broadcasters. Neither the children’s televisionproducersnorthenetworkexecutivesinterviewedbytheresearchersadvocated any lifting of the volume of advertising during C programs, largely due to a supreme lackofadvertiserinterest.Aisbettcitesviewsofsomefree to airtelevisionexecutivesto theeffectthatsubscriptionchildren’schannels‘hadanunfairadvantageovercommercial networks because they do not have to comply with advertising restrictions’ (2007: 30). However,sheconcludesthattheextenttowhichthisadvertiserdisinclinationresultsfrom the requirements of the CTS, which prohibit certain kinds of marketing practices (such as host or program character endorsement), is unclear. ProducersofP(preschool)programsinterviewedweremorereadytocallforincreased sponsorship and relaxing of the rules concerning merchandising to children during dedicated C and P periods. Preschool programs are often sold to networks for very low licencefeesbecausereturnstoproducersaredrivenbymerchandising,DVDsalesandlive concerts (Aisbett, 2007: 20). Some of the producers interviewed suggested that the strict application of CTS 22 (2005) – which prohibits promotion of a product or service by a program’s character during or immediately adjacent to a C or P program – reduced the revenuestreamfromspin offmerchandising(Aisbett,2007:30).Nevertheless,children’s (andadults’)loyaltytotelevisionprogramcharacters(orcelebrities)formsacrucialpart of the cross promotional circuit known within the advertising industry as ‘360 degree marketing’. The Food Marketing to Children in Australia study commissioned by the Cancer Council contends that: Foodmarketingtochildrenoccursinavarietyofguisesacrossdifferentformsof media,includingTV,internet,magazines,in schoolmarketing,sponsorship,product placement and point of sale promotions. (Centre for Health Initiatives, 2007: 6) WeciteasymptomaticcasestudyfromtheCancerCouncilreport,nottosuggestthat all advertising is necessarily a bad thing but to examine the extent to which TV centric regulation fails to ‘catch up’ with campaigns that traverse media platforms. Many of thesecampaignsuselong standingstrategiesforthechildmarket–promotionsemploying cartoonprogramcharacters,premiumoffersandtheco optionofchildren’sgameplayas ‘invisible’ advertising. The Kelloggs children’s cereal brands case study detailed in the Cancer Council report maps the intersection of TV program properties with other forms of media and marketing. Each of the children’s cereal brands has its own long standing cartoon character (e.g. Coco the monkey for Coco Pops). However, during the research period, the Nickelodeon program character Spongebob Squarepants was also used to promotetheKelloggsmueslibarrange.Children’scerealboxeshistoricallyhaveincluded marketingpromotionssuchasgive awaysandcompetitions.Contemporarypackagingnow directschildrentotheproductwebsitewheregamesolutionscanbefound,togetherwith othergamesandinteractivematerialthatinviteusersofthesitetoregister,andtoprovide contact details such as email addresses, which can then facilitate direct company to user communication(CentreforHealthInitiatives,2007:16–19).Popularchildren’smagazines (print)arelinkedtosubscriptiontelevisionchannelssuchasNickelodeonandDisney,and these not only heavily promote EDNP foods (Centre for Health Initiatives, 2007  Schor, 2004  Kelly et al., 2007) but are also central to the cross promotional strategy. Many of these media fall within ACMA’s regulatory remit (e.g. free to air and subscription TV marketingtochildren(andadults)4rendersthepoweroflimitedtelevision basedregulation of advertising such as the CTS problematic, if not totally ineffective. MediaInternationalAustralia 52 Television advertising to children ACMA has been reluctant to commission research pertaining to media that it does not regulate (such as print). The terms of reference of the Brand Review limit its scope to television advertising, thus also limiting its usefulness as an evidence base to inform nationalcross platformpolicy.TheresearchquestionsintheBrandReviewthataremost pertinent to the CTS include developmental issues around children’s understanding of persuasiveintent(RQ1),repetitioneffects(RQ2),effectsofcharacter andcelebrity based marketing(RQ3)andresponsetopremiumoffers,suchastheMcDonald’s‘HappyMeal’/ toy combination (RQ4). Two additional research briefs pertinent to the CTS target the evidence base on the effects of advertising on behaviours such as ‘pester power’ (RQ5) andtherelationshipbetweenchildren’sadvertisingexposureandtheirfoodandbeverage preferences(RQ6).Itisfairtosaythatthisisapieceofsolidresearch,butonethatneeds tobereadinitsentirety:theexecutivesummarygivesasomewhatconfusingimpressionof foodrequests,Brandandcolleaguesconcludethatthereisa‘fairlyclearassociativelink between advertising and pester power’ (2007: 30), and that: Empiricalresearchshowscorrelationsbutnotcausalrelationshipsbetweenchildren’s exposure to advertising and … preferences as indicated by requests (but not necessarily consumption) of advertised foods. (2007: 42) most of the reviewed studies (apart from a few key experiments), although it should be stressedthattherearemanystudiesinthemarketingandtradeliteratures,andintheBrand review itself, showing increased short term consumption (purchase) of foods following marketing campaigns, especially cross media promotions. However, this conclusion is symptomatic of a crucial difference between the analytic frames employed by media regulatory discourse and by that of epidemiology and public health. The latter rely on anythinglessthat‘causation’tobeanunsoundbasisforinterventioninindustrystructures.5 Responses to the I ssues P aper of June 2007 These oppositional paradigms are deployed in many of the submissions in response to the Issues Paper of 2007. The commercial broadcasters and content aggregators share a commonsetofpositionswiththebodiesrepresentingtheadvertisingindustries.Manyof thesepositions–suchasafocusonmedialiteracyandpromotionofexerciseandhealthy lifestyles–ratherthanlimitsonadvertisingalsoformcentralstrandsofself regulatorycodes, suchasthatoftheAustralianAssociationofNationalAdvertisers(AANA).Nickelodeon Australia,forexample,stressesitssupportofDOHA’s‘“Gofor2+5”campaign,designed topromotetheconsumptionof2servesoffruitand+5servesofvegetableseachday’,as wellastheAANA’s‘EatWell,PlayWell,LiveWell’initiative,arguingthat‘thecampaign representedtheindustry’scommitmentandobservancetotheAANACodeforAdvertising to Children’ (Southron, 2007: 2).6 Both broadcaster and advertising bodies ally around to address the ethical concerns around ‘responsible’ advertising to children.Also crucial to this paradigm is the position that the causal link between advertising and childhood obesity (rather than advertising and food preferences) is not supported by research: TheACMA issues paper references the extensive research that has been done in relationtothecausesofobesityandacknowledgesthereisawiderangeoflifestyle, heredity, social and cultural factors that contribute to the problem [and that] no directlinkhasbeenestablishedbetweenadvertisingandobesity.(AFA,2007:12) No.140—August2011 53 Conversely,themanyearlysubmissionsfromresearchorganisationsadvocatingaban weight to the evidence of a link between advertising and childhood obesity predicated onthe mechanism orpathwayofconsumptionbehaviours.Forexample,theAustralasian SocietyfortheStudyofObesityreferencesthe‘compellingevidenceofan“association” between food advertising and behaviours contributing to childhood obesity’, while the World Health Organisation Collaborating Centre for Obesity Prevention goes further, contending that literature reviews, such as that of Brand, miss the enormous volume of proprietary research that provides a causal link between the ‘marketing of obesogenic foods and beverages to sales of those products’ (2007: 4). Producerandcontentcreativeassociations’submissionstookalessconsistentposition onadvertising,generallybeingmorefocusedontheroleoftheCTSquotasortherange of genres supported by existing regulation. The Media Entertainment Arts Alliance (MEAA) (2007: 8) was critical of self regulation of advertising, suggesting that a more restricted advertising regime such as the one imposed in the United Kingdom would be oflittleeconomicconsequencetobroadcasters,whiletheScreenProducersAssociationof AustraliaandAustralianWriters’Guild(2007:6)restrictedtheirinteresttothepositionthat ‘[a]dvertisingandtheCTSquotarequirementsmustbeconsideredinisolationfromeach other’. TheAustralian Children’s Television Foundation (ACTF) – whose submission is primarilyinvestedinthecampaignforadedicateddigitalchildren’schannel–acknowledged that the submissions of other interested parties were founded on specialist expertise in the areas of childhood health and nutrition, and the impact of advertising upon children. However, the ACTF distanced itself from the controversy surrounding food promotion. Instead, it argued that above allACMA must ‘ensure that the debate over advertising to children does not impact in any way on the quality, local children’s programs that run between the ad breaks’. Whose economics? WhenACMAreleaseditsdraftupdatedCTSinAugust2008,thosecallingforrestrictions reacted with predictable dismay at the complete absence of any amendment to Part 3 of thestandardswithrespecttotheadvertisementoffoodstuffsandbeverages.TheAustralian MedicalAssociation (AMA), for example, argued thatACMA had based its decision on an‘overlynarrowconceptionofwhatis“harmful”’,focusingtoocloselyontheabsence predictably,thoserepresentingtheadvertisingandfoodandbeverageindustriesregistered their overwhelming agreement with the draft decision not to impose further restrictions. Nonetheless, such organisations at the same time sought to demonstrate their awareness of the high level of community concern surrounding this issue. In a clearly pre emptive move (Jones, 2007), both the Australian Food and Grocery Council and the Australian QuickServiceRestaurantIndustryformulatedtheirownresponsiblemarketinginitiatives, whichACMA undertook to monitor over the immediate post CTS amendment period. Perhapsthestrangestadditiontotheevidencebasebroughtintothecontroversialdebate at this point was the regulator’s own economic modelling study, The Economic Impact of Restrictions on Television Food and BeverageAdvertising (ACMA, 2008). Unlike the Australian Bureau of Statistics or Treasury, economic modelling is not generally an in house responsibility of ACMA. Bringing additional research to the table along with its releaseofthedraftCTSdemonstratesACMA’ssensitivitytotheconcernofpeakmedical bodies around this issue. ACMA’s Economic Impact Study balances the cost of lost advertising revenue on commercialfree to airbroadcastersagainsttheannualcostofobesitysourcedfromAccess estimateusedinACMA’smodelling(NationalPreventativeHealthTaskforce,2009).More MediaInternationalAustralia 54 terms, ACMA uses the concept of audience ‘share’ – that is, it measures the impact of hundreds of thousands) likely to be in the audience for a certain number of repetitions ofthecommercial.Ontheotherhand,acompetingtheoreticalmodelpreparedbyateam of health economists (Haby et al., 2006  Magnus et al., 2009) assessing cost effective obesityinterventionsusestheideaof‘reach’,aconceptthatassumesallAustralianchildren Allsuchstudiesaresimplypredictions,andallcontainmarginsoferror.However,given thatpromotionalstrategies(foracertainHappyMealtoycombo,ortherecentMcDonald’s ‘Angus’burgercampaign)ofteninvolvecross mediasaturationforalimitedperiodoftime, the concept of ‘reach’ would seem to be a better theoretical model. More critically, the economicpriorities–impactoflostannualrevenueonbroadcastersintheACMAstudy, versus the impact of obesity related disease over a child’s life course in the ‘Assessing Cost Effectiveness in Obesity’ studies – bring the highly polarised values mobilised in this debate into sharp focus. Manyofthe2007and2008submissionstotheCTSreviewdrewattentiontoACMA’s lackofexpertiseinthejurisdictionandscienceofhealth.Negotiation(evenhandballing) ofresponsibilitiesbetweenportfoliosistracedinboththeFinalReportoftheCTSreview and DOHA’s response to the issue of preventative health (DOHA, 2010). Noting the tablingoftheHouseofRepresentativesStandingCommitteeonHealthandAgeingreport on obesity,ACMA stresses the mutual commitment of both government departments to In relation to advertising, the Committee supported the argument that marketing unhealthy products to children should be restricted and/or decreased. However, it considered that industry self regulation may prove to be successful through the reduction of advertisements for unhealthy food products on television during children’s prime viewing times. (ACMA, 2009a: 8) T he C T S  2009 and beyond: Converging solutions? Predictably, the CTS 2009 are little altered from those of 2005, with ACMA deciding not to impose any ‘additional requirements on industry in relation to food and beverage advertising’,oranychangestothequotasforchildren’sprogramming.ThenewStandards slightly restrict the number of popular characters or personalities that can be used to endorse or promote commercial products or services. Oddly enough, the submissions to the review generated a strange consensus.While most agreed that the CTS had failed to addressadequatelyeitherthemandatetoprotectcontentproductionandaccessinthenew mediaenvironmentortheobesityepidemic,therewasgeneralagreementthattheStandards should be retained in the interim for whatever limited protection they might provide. Tradeable obligations and (public service) children’s channels However,itisworthrevisitingthoseareasofpolicyinnovationthattheCTSReviewraised, or at least forwarded. Proposals such as ‘tradable obligations’ and dedicated children’s channelsand‘blocks’intersectwithotherculturalpolicyobjectives,andhavebeendeployed in more recent policy documents in the context of preventative child health. As argued above, the primary rationale for the CTS is to ensure that policy settings continue to imposesomekindofobligationoncommercialbroadcasterstoprovidededicated(largely Australian) children’s content in the multi channel environment. Institutions representing theproductionindustries,thepublicbroadcastersandtheproductiondevelopmentagencies (includingScreenAustraliaandtheAustralianChildren’sTelevisionFoundation)converge in their interests around this cultural policy objective. No.140—August2011 55 Research in international markets showed that aggregating children’s content into channels or blocks was the most successful strategy for ensuring audience accessibility, and thus broadcaster viability, in the digital multi channel landscape (Steemers, 2010  ACMA, 2007a: section 14  Buckland and Dalton, 2008). The success of a commercial children’s channel model (largely minus Australian quota requirements) had been demonstratedbypayTV.ASTRA’ssubmissiontotheCTSreviewcontends,forexample, thattherelativetakeuppercentageofsubscriptiontelevisionamongfamilieswithchildren is high, indicating that the children’s channels were a subscription driver for pay TV providers. Conversely, commercial free to air licensees maintain an interest in ensuring thatchildren’sandAustraliancontentrequirementsarenotextendedtotheirdigitalmulti channels. The interim reform proposed by ACMA took the form of the proposal for a Tradable Obligations scheme. This idea was proposed as early as 2002, in the context of the Australian Content StandardReview.Theschemewouldallowacommercialbroadcastlicenseetoenterinto aformalarrangementtotradeaportion,orall,ofitscompulsorychildren’sprogramming and facilitate more ‘innovative approaches to programming and scheduling’ that might address accessibility issues for children (ACMA, 2007a). Clearly foreshadowed here is theideaofadedicatedchildren’schannelora‘branded’children’sbloconacommercial broadcaster.An undertaking to establish theACTF/ABC digital children’s channel, were the Howard government re elected, had been given by Senator Helen Coonan, the then CommunicationsMinister,in2007.ACMAregretfullysurrenderedthetradableobligations scheme as an outcome of the CTS review, although it resurfaced in December 2009 in the DBCDE’s Content and Access Review. Following on from the establishment of ABC3,therewasageneralconsensusamongthesmallnumberofsubmissions(including reservationsfromtheABC itself)thatifsuchaschemewereintroduced,thebroadcaster in effect being paid by the commercial licensees to relieve them of their obligation to showchildren’sprogramsshouldideally notbethenationalbroadcaster(DBCDE,2010). Nevertheless,theestablishmentofABC3isoneinterimpolicyinterventionthatappears to be doing double duty as a stop gap measure for both DOHA (obesity prevention) and DBCDE (content and access). The new funding to the ABC reversed several years of declineunderthepreviousCoalitiongovernment,andallowedABCChildren’stoquickly become a major commissioner of new Australian content, as well as a destination for the 30 year bounty of the CTS (Buckland and Dalton, 2008). More recently, DOHA’s response to the National Preventative Health Taskforce’s recommendation (5.1) to ‘phase out the marketing of EDNP food and beverage products onfree to airandpayTVbefore9.00p.m.withinfouryears’,aswellastheuseofcertain kinds of marketing across all media sources, also cites the government’s commitment to theABCchildren’schannelasapreventativehealthinitiative,‘givingparentsacommercial freechoicefortheirchildren’(DOHA,2010:46).Ironically,thesolutionproposedalongside ‘voluntary industry initiatives’ such as theAdvertiser Codes of Practice promoted in the CTS review is public service media.ABC3 broadcasts up until the 9.00 p.m. watershed originally proposed by both obesity researchers and public health activists. Conclusion Increasedgovernmentfundingforpublicbroadcastingmaybeawelcomepolicysettlement for many. In his 2009 address to SPAA, Kim Dalton,ABC Director of Television, also suggested (among other things) direct funding forAustralian content in the face of any increasingly fragmented and unregulated digital future (Dalton, 2009). Obesity scientists and public health economists will be less convinced by a policy intervention that places MediaInternationalAustralia 56 theresponsibilitybackontheshouldersoftheindividual–themajorityofthetelevision audience, after all, view commercial media most of the time, and are unlikely to restrict themselves toABC3 until 9.00 p.m. Theanalysisprovidedinthispaperdemonstratesthat,30yearson,theCTSandvoluntary commercial industry initiatives are unable to provide access to dedicated content at a able,intheabsenceofawhole of governmentapproachtoregulatingtheconstitutionand promotionoffoodtochildrenandadultsalike,abletoaddresstheproblemofescalating obesitylevelsinthepopulation.TheNationalPreventativeHealthTaskforce,forexample, argues for a ‘population wide focus’: A wide range of forces, some outside the control of individuals and families, interacttoshapepatternsofoverweightandobesity.Themagnitudeofthisproblem warrants a stronger population level response. (2009: 12) The Taskforce advocated a ‘staged trialling of a package of interventions’, based on the World Health Organisation recommended actions. Three of these would require multi jurisdictional ‘command and control’ legislation from government: (1) legislation to reform the contents of food products  (2) limit the marketing of food and beverages to children (3)  (tax)toencouragehealthyfoodconsumption(2009:14). Oneofthesetop downregulatorymeasureswouldnaturallyfalltoACMAtoadminister. However,asthisarticlehasargued,otherstrategiesforaddressingthe‘obesityepidemic’ lie beyond the jurisdiction and scope of the ‘Nanny Regulator’. Notes   Junk food products are often referred to as EDNP (energy dense, nutrition poor) or HFHS (high fat, high sugar) food and drink in the health and regulatory literatures, although there is considerable debate as to what products qualify for inclusion under these labels. 2   Responding to rival systematic reviews of research on effects of food promotion on childhood obesity,oneonbehalfoftheUnitedKingdom’sFoodStandardsAgency(FSA)–anindependent government watchdog department set up by an Act of Parliament in 2000 to oversee public health and consumer interests in relation to food – and a second prepared for a food industry group, OFCOM contracted Professor Sonia Livingstone of the London School of Economics to adjudicate. Livingstone, a renowned social psychologist, as well as a cultural and education theorist, has acquired international credibility for her ability to negotiate the balancing act between the ‘risk’ (effects) and ‘resilience’ (agential consumer) schools of thought concerning children’s media behaviour. 3   According to Price Waterhouse Coopers’ Global Entertainment and Media Outlook 2009–13 (citedinASTRA,2009),thepredictedcompoundannualgrowthinadvertisingrevenueforthe commercialterrestrialnetworkswas2.3 percent,with7.5 percentand12.2 percentpredicted 1 released in late July 2010 witnessed at least a temporary windfall for the free to air sector (Dyer, 2010). 4   The argument that young children are more vulnerable to the effects of advertising than older childrenandadultsunderpinsmuchregulatoryandindustrydiscourse however,thisisdisputed are affected equally by advertising, although each market segment is differentially targeted in promotional communication. 5   While it is a methodological orthodoxy that correlation does not equal causation, especially in cross sectionalstudies,someassociationsaremorelikelythanothers–forexample,acorrelation between the time teenagers spend watching television and academic achievement (measured by school test scores) may be explained either by a supposition that more TV viewing makes students less capable/motivated or that less capable or unmotivated students choose to watch No.140—August2011 57 TVratherthanstudying.However,theideathatpreference,oratendencytopesterparents,for certain food products makes a child more likely to watch advertisements is far less plausible. 6   ForahistoryandcritiqueofthestrategicdeploymentofadvertiserCodesofPracticeandEthics, see Jones (2007). 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Technical Paper 1: Obesity in Australia: ANeedforUrgentAction,www.preventativehealth.org.au/internet/preventativehealth/publishing. nsf/Content/tech obesity. Childhood Obesity: Food Advertising in Context: , www.ofcom.org.uk/research/tv/reports/food_ads. Rudd, K. and Roxon, N. 2007, New Directions for Australian Health, Taking Responsibility: Labor’s Plan for Ending the Blame Game on Health and Hospitals, policy document,August, http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p query=Id%3A”library%2Fpartypo l%2FGT1O6”. No.140—August2011 59 Schor,J.2004, BorntoBuy:TheCommercializedChildandtheNewConsumerCulture,Scribner, NewYork. Southron,K.2007,NickelodeonAustralia:SubmissiontotheChildren’sTelevisionStandardsReview, www.acma.gov.au/webwr/_assets/main/lib310132/73_nickelodeon.pdf. Steemers,J.2010, CreatingPreschoolTelevision:AStoryofCommerce,CreativityandCurriculum, Palgrave Macmillan, London. US Department of Health and Human Services 2001, The Surgeon General’s Call to Action to PreventandDecreaseOverweightandObesity,USDepartmentofHealthandHumanServices, gov/topics/obesity. World Health Organisation Collaborating Centre for Obesity Prevention, Deakin University 2007, Submission to Review of the Children’s Television Standards, www.acma.gov.au/webwr/_ assets/main/lib310132/53_who_collaborating_centre_for_obesity_prevention.pdf. LeonieRutherfordisaSeniorLecturerintheSchoolofCommunicationandCreativeArts,Deakin University.SheiscurrentlyengagedinanARCLinkageGrantfundedprojecttoevaluatetheemergence of digital literacies in very young children, and a Deakin Central Research Grant funded project examiningtheinceptionofABC3,inthecontextofeconomic,technologicalandregulatorychanges inAustralia. DeanBironisaBrisbane basedscholar.Hismajorareasofresearchinterestarechildsafetyand studies. HelenSkouterisisanAssociateProfessorinDevelopmentalPsychologyintheSchoolofPsychology, DeakinUniversity.Since2008,herresearchinterestshavefocusedpredominantlyontheprevention of childhood obesity, and maternal health and well being during pregnancy and the postpartum, includingpreventionofexcessivegestationalweightgain. MediaInternationalAustralia 60 Copyright of Media International Australia (8/1/07-current) is the property of Media International Australia (MIA) and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use. ...
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