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The "Share of Voice" Approach to Cross-Media Ownership Control
Kim Jackson
Social Policy Group
In May 1995 the UK Government published its Green Paper on Media Ownership.
This was intended to provide a more flexible basis for media ownership
regulation in order to accomodate commercial and technological change.
As part of this, the Green Paper foreshadowed a new approach to the regulation
of crossmedia ownership. This approach involved the following steps
- definition of media markets (ie.national, regional or local) and the
measurement of their overall size in terms of audience or revenue share
for all three major media sectors (ie.the press, radio and television)
- a common expression of the value of these shares for each sector (with
possible weightings for each sector based on their relative influence
or market power)
- determination of the thresholds of ownership (in terms of the total
'share of voice') for markets beyond which acquisitions would have to
be referred to the media regulator.
The Green Paper did not present final details of the scheme as it recognised
that there was significant work to be done in methods of measurement of
shares and weightings. It proposed thresholds of 10% for the national market,
and 20% for regional and sectoral markets.
The Green Paper's approach was largely derived from a submission by
the British Media Industry Group (BMIG) which advocated using consumer
usage of media to calculate the share of voice. Thus for a particular
market one would use newspaper circulation, with TV and radio ratings,
to determine the total 'share of voice' of any one proprietor. Where ownership
of a media outlet was shared between companies or proprietors, then the
'share of voice' would be allotted in proportion to the percentage of
ownership.
Professor David Flint (Chairman of the Australian Press Council) has
supported the BMIG approach and has made some tentative calculations of
the 'share of voice' for Australian media markets. For the national market
the results were as follows
National 'Share of Voice' 1994
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Murdoch 19.81%
Packer 9.17%
Black 1.55%
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Note: It has been assumed that the
latest available statistics were used
as Professor Flint did not date his sources.
On 15 December 1995 the UK Government published its Broadcasting Bill. The
Bill did not contain a mechanism for regulating total media ownership (as
proposed in the Green Paper) and the National Heritage Secretary conceded
that there was little agreement on such a concept and that the proposals
had been effectively dropped. Instead, the Bill contained amendments to
media ownership rules to allow greater crossholdings between newspapers,
television and radio companies, subject to public interest criteria being
satisfied. These are described in the Bill as including the promotion of
a plurality of ownership and diversity of sources of information, as well
as economic benefits (employment, export income) and the proper operation
of markets. It is left to the regulator to assess the possibly competing
claims of these social and economic objectives.
In February 1996 the House of Lords rejected the Bill on the basis of
a different issue: the exclusive coverage of sporting events by subscription
television.
Although the 'share of voice' approach to crossmedia regulation appears
to have been abandoned by the British Government, it is likely to be considered
by the inquiry into media ownership planned by the Australian Government.
Such a consideration would have to deal with a number of difficult issues,
namely
- whether to give different weightings to the various media sectors.
The BMIG submission argued that radio should be discounted by 50% because
of the predominance of music formats. However, in Australia the popularity
of 'talkback' radio means that the medium probably has a more extensive
coverage of public issues than TV.
- what published material to count in the 'share of voice'. While capital
city and regional daily newspapers are obvious inclusions, the position
of suburban, Sunday and ethnic newspapers (as well as magazines) is
more problematic. A system which accorded more influence to a regional
daily than to magazines such as the Bulletin or Womens Weekly could
be regarded as suspect. The inclusion of magazines and suburban newspapers
would be a sensitive issue because of the predominance of Murdoch and
Packer in these areas. In February 1996 Packer controlled 47% and Murdoch
26% of major magazine circulation, while in surburban newspapers Murdoch
controlled 49% of circulation.
- the definition of markets. Professor Flint's analysis referred to
national and State media markets, but these are notional rather than
actual markets, which in Australia are metropolitan and regional in
nature.
- a system based on circulation and ratings could have the effect of
discouraging excellence and best practice. A proprietor could be in
the position where providing what the public wants, and thus increasing
circulation or ratings, leads to a penalty.
- should the public broadcasters, the ABC and SBS, be included in the
calculation of the 'share of voice'. To do so would have the effect
of diluting the 'share' of the major proprietors.
- the trigger mechanism. Should a breach require a reduction in audience
share or divestiture of assets? In the system proposed by the Green
Paper a great deal of discretion was left to the regulator. This may
not be regarded as appropriate in the Australian situation.
- at what percentage should the thresholds be set? The UK Green Paper
'share of voice' thresholds of 10% for the national market and 20% for
regional markets would be exceeded by Murdoch in Australia. It should
also be noted that in the UK system the overall 'share of voice' threshold
did not replace, but was in addition to, the individual thresholds on
radio, TV and newspaper ownership. The Green Paper's 20% sectoral threshold
would also be breached in Australia.
- should the calculation of 'share of voice' require a definition of
control, or simply be proportional to ownership shares?
It has been argued that the 'share of voice' approach is required because
of technological developments. In fact, it fails to deal with the convergence
of broadcasting, computing and telephony into 'broadband services', but
simply measures the traditional media in a different way.
The regulation of media ownership, over and above the generic competition
regulation expressed in the Trade Practices Act, is undertaken for social
rather than economic objectives. It is generally considered that the effective
functioning of a democracy requires a diversity of sources of information.
However, a system based on circulation and ratings measures the popularity
of given sources, rather than the availability of a wide range of views.
It would be more accurate to describe such a system as designed to prevent
the acquisition of excessive influence by any one proprietor, rather than
as one aimed at ensuring a diversity of views.

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