Page 99 - Comparing Political Communication Theories, Cases, and Challenge

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Comparing Mass Communication Systems

Media Surveillance and Media Regulation
Comparison of media surveillance and regulation presents itself as
a standard area of comparative research. A similar functional necessity,
regarding the tendencies toward liberalization and the opening of the
market exists in all countries: the construction of effective supervision
structures. A comparative study on regulating the media examines li-
censing and regulation in six countries (the United States, the United
Kingdom, Germany, France, Canada, and Australia): national regula-
tion structures and their context are researched according to a partly
unified scheme. In a second step, common features are sought for, ac-
cording to the principle of “method of agreement.” The author stresses
that a change of paradigm can be observed in all of the states examined,
which can be described as “from the trustee model to the market model”
or “from cultural to economic legitimization” (Hoffmann-Riem 1996,
340–1). Attention is paid to differences as well: two groups of countries
are formed. Three countries with a long-standing privately owned me-
dia sector (the United States, Canada, and Australia) are compared with
three countries in the public service tradition (the United Kingdom,
Germany, and France). The two categories differ clearly in their results,
simultaneously describing the difference between developments within
and outside Europe while using area studies. The result is a classical type
formation,takingintoaccounttheconceptsofagreementanddifference.
Questions about regulation become apparent in the case of the In-
ternet as well, albeit in a different way. The Bertelsmann Foundation
has presented a study on this subject, which primarily pleas for self-
regulation (Waltermann and Machill 2000). One part of the study com-
prises an opinion poll of Internet users in three countries (Australia,
Germany, and the United States). It was based on identical questions
so that results could be compared. The results show that, despite “ex-
treme national differences” in the diffusion of Internet use (at least at
the time of the research in mid-1999), respondents gave similar answers.
Particularly control over abuse was seen as an important task in every
country and self-control was favored. State control was, as was to be ex-
pected, especially unpopular in the United States, while in Germany the
ban of extreme right-wing or extreme left-wing opinions was favored
more than anywhere else (Germany: 58 percent, the United States:
28 percent) (K¨ ocher 2000). These kinds of questionnaires with an explic-
itly comparative focus remain somewhat rare as they are very expensive.
It is generally true that the politics of regulation are a good example
of diffusion because of their great international significance – the first

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