Sir, - Fintan O'Toole (October 23rd), is right to worry about what is happening in the commercial broadcasting sector at the moment, and in particular, the commitment of the Broadcasting Commission of Ireland (formerly IRTC) to "light touch" regulation in its relationship with radio and television stations.
To be fair to the BCI, it is merely following a general European trend over the past decade which has seen commercial broadcasting companies lobby very successfully for a system of regulation which is in effect as light "as angels stroking your skin with fluff from day-old ducklings", as Fintan O'Toole puts it.
"Light touch" regulation has become the mantra echoed across Europe wherever commercial broadcasters and regulators meet in conference. It was defended by the first IRTC 10 years ago as a temporary approach, to enable fledgling commercial radio stations, then TV3, to gain a foothold in the newly deregulated Irish broadcasting market.
But now that this sector is effectively owned by foreign interests, including global corporations based in Canada and the UK and healthy streams of revenue are beginning to flow outwards, surely it is time to examine how "light touch" regulation can reconcile owners' right to profits with the rights of viewers and listeners, as enshrined in recent broadcasting legislation.
The key public interest, of course, is the need for diversity of content, dramatised currently in the hunger for diversity of viewpoints on the war in Afghanistan and the very varied performance of European television channels in supplying a sufficiently rich diet of information to their various publics.
The Broadcasting Act (2001) puts the onus on the BCI to ensure that broadcasting "best serves the needs of the people of Ireland, bearing in mind their languages and traditions, and their religious, ethical and cultural diversity".
The Radio and Television Act (1988) requires the BCI to ensure diversity of content in broadcasting. The overall objective of both Acts is to ensure diversity of content in existing services and in any new radio or television channels that might be provided by digital technology.
But the question is: how is programme diversity to be provided? Will radio and television stations do this if the regulator remains silent? Not likely. There is plenty of evidence to show that the operation of market forces alone, in the absence of any public interest requirement, generates pressures which actually flatten programming down into a bland output based mainly on soaps, inexpensive American fiction and sports.
Surely now is not the time to signal to broadcasters that regulation will be minimal. Surely we owe it to all viewers and listeners to expect a more robust approach from the regulator, to find the most appropriate degree of intervention necessary to harness whatever energies market forces can generate in broadcasting, while also keeping public policy goals intact, in line with what legislators intended.
The very least we need is a regulator with the will and the means to monitor media performance and to verify if broadcasters are respecting their obligations to broadcast agreed quotas of programmes - domestically produced or European, independent productions, current affairs, documentaries - whatever has been agreed with the BCI.
Surely the power to monitor (with sanctions if necessary) is at the centre of good regulation, since commitments set down in licensing conditions would be ineffective unless it is possible to verify that they are being respected.
This would mean that TV3, for instance, would actually be regulated in accordance with broadcasting legislation, so that it could genuinely become the alternative to RT╔ that many people argued was necessary and relieve TG4 of the burden of being the only channel to provide a "s·il eile." - Yours, etc.,
Farrel Corcoran, School of Communication, Dublin City University, Glasnevin, Dublin 9.