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17 Jan 2008, Posted by Eric Karstens in Media Policy, 0 Comments

Risk management in media policy (4): Dealing with complexity


The search for an innovative foundation of media regulation spanning all 27 member states of the EU has recently prompted the European Commission to initiate a study on media pluralism based on the concept of risk management.

This is the fourth in a series of articles exploring the motivation for this endeavour and the practical conditions of its actual implementation. Here we will examine how existing risk management theory can contribute to the governance of media landscapes.

The science of risk management has developed viable sets of criteria and strategies to control risks, but it has so far been applied mostly in fields such as financial markets, insurance issues, technology, and life sciences. This is not surprising, since these areas are not only easily recognised by the public as prone to tangible and widely publicised risks, but also lend themselves to being quantified in spite of their inherent complexity: There are monetary values or potential health impairments involved.

More recently though, the findings of risk management have been explored from a sociological and political perspective as well, and can therefore provide a handle on the issue of media pluralism.
One of the most widely discussed concepts to be adapted to matters of society and the public sphere is that of “systemic risks”. It proceeds from the finding that such risks are often highly complex. Their management involves interdisciplinary scientific efforts and touches a variety of areas of life and business, which are correlated on multiple levels. Therefore, people and institutions face major challenges describing and evaluating systemic risks; the boundaries between cause and effect can be blurred, and the ethical assessment of risks tends to be ambiguous.

According to this approach, the impacts of systemic risks do not only stem from the direct damages as analysed by a more quantity-oriented risk management, but also depend on their social, economic, and political collateral ramifications.

Again, this can be best illustrated with an example from outside the media: Climate change. While mankind undoubtedly influences the climate with greenhouse gas emissions, construction, agriculture and other activities, natural factors come into play as well, such as solar activity, vulcanism, sea currents, and others. Reducing the debate about climate change to any one of these factors would not take the actual complexity into account and lead to dodgy conclusions. The debate becomes even more ambiguous as soon as one extends it to matters social, political or ethical. Can the West afford to deny developing countries industrialisation for reasons of pollution? Can mankind cope with the massive migration issues probably resulting from climate change? Or how do you weigh the advantages of mass travel for education, understanding among nations, and personal liberty against its adverse effects on the environment? And so on.

In the spirit of risk-based and co-regulation as discussed in the previous articles, an effective risk governance hence calls for participative risk evaluation, integrating all kinds of stakeholders such as the government, self-regulatory bodies, NGOs, other institutions of civil society, and individuals directly affected. This is in order to ensure the utmost transparency of criteria and arguments and to make an informed debate possible in the first place.

The aim of risk management is to shift the boundary between science and politics ever farther out in order to improve the ratio between actual knowledge and mere opinion. The goal is to know what science can achieve; balancing the findings in the public sphere and converting them into actions, though, remains in the political domain.

While this approach is relatively new to societal risk analysis, it is even more innovative to use it for the evaluation of the media. How conclusive and straightforward is the connection between pluralism and its empirically observable descriptors? Which amount of uncertainty remains despite all efforts? Can circumstantial and contextual influences be factored into a comprehensive framework for evaluation? And, finally, how must empirical findings be interpreted in order to reach sensible normative conclusions, i.e., laws?

In their 2003 report on Emerging Systemic Risks, the OECD has pointed out “the need for information gathering, early warning, and timely identification of vulnerabilities” for any complex risks. Media pluralism regulation therefore calls for a systematic and dependable accountability, and it is supposed to define benchmarks which are warning signs for impending constraints on pluralism.

Yet in our media societies, blame is often perceived as more detrimental to institutions and public figures than the actual damage. And pressure groups are very skilled in using “policy windows” opened by current events and/or media salience in order to push their agendas. Therefore, risk-based regulation itself runs the risk of being merely shaped out of populistic considerations, through the power logic of particular interests, or with “quick and dirty” solutions anticipated to meet the least amount of resistance or designed to cover up liability.

This is also the chief reason why risk management requires sound ethical foundations. These foundations must serve to define a set of criteria with which to identify and evaluate indicators for media pluralism from a normative point of view and thus lay the foundation of public accountability.

The fifth and final instalment of this series will try and evaluate the merits and the viability of the risk-based approach to media pluralism.