Formal Comments to FCC on Technical Standards for the V-Chip
by Joanne Cantor, Ph.D., University of Wisconsin-Madison
December 15, 1997Office of the Secretary
Federal Communications Commission
1919 M Street, N. W.
Washington, DC 20554
ET Docket No. 97-206Dear Commissioners:
I am writing to file formal Reply Comments in the matter of Technical Requirements to Enable Blocking of Video Programming based on Program Ratings. I have already filed comments (in CS Docket No. 97-55) on the industry's original Proposal for the "TV Parental Guidelines" (April 7, 1997) and on the Revised Rating System (October 3, 1997). My views on these matters are based on my more than 20 years of research on the effects of television on children and on my research over the last four years on television ratings specifically.
In these comments, I take issue with three arguments made by the "Joint Commenters" from the entertainment industry (the National Association of Broadcasters, the National Cable Television Association, and the Motion Picture Association of America) and by the Consumer Electronics Manufacturers Association (CEMA). The first argument I dispute is that the availability of multiple ratings systems will result in "consumer frustration or confusion"(1) or "increased confusion for the parent."(2) The second is the argument by CEMA that the final ratings system, once approved by the FCC, should not be altered or changed.(3) The third is the argument by the Joint Commenters that there should be no capability in television sets to use the V-chip to block unrated television programs.(4) I address these issues in my comments below:
1. The availability of multiple ratings systems has the potential to reduce rather than increase consumer confusion by permitting parents to select a ratings system that is most consistent with their goals for protecting their children. As I stated in my previous filings, five national polls have shown that parents overwhelmingly prefer ratings that provide content information rather than those that suggest the appropriate age of the viewing audience.(5) Multiple ratings systems would give parents a choice between systems, a choice they could make when they first programmed their V-chip. An inherent benefit of the V-chip is the fact that after making an initial choice of system, parents would not have to deal with more than one system.
On the other hand, if parents are limited to the revised TV Parental Guidelines, they will be saddled with its unnecessary complication. As I stated in my previous filing, the revised TV Parental Guidelines are unduly complicated because they make unnecessary distinctions and because they uses euphemisms for certain types of content. Although parents have not requested this, the revised system distinguishes between "S" for sexual content depicted visually and "D" for sexual dialog (sex that is talked about but not shown.) In addition, intense violence that occurs in children's programming is designated not with a "V" for "Violence" but with an "FV" for "Fantasy Violence" -- whether the violence is indeed of the impossible, magical variety, or whether it is quite realistic. This designation is likely to confuse many parents. In addition, the unnecessary complication introduced by these superfluous letters may make many parents reject the system without giving it a try. Parents should be given the choice between the industry's confusing compromise and simpler systems geared more directly to the needs of families.
2. Any ratings system that is approved by the FCC must have the capability to be amended as feedback is received regarding whether it actually provides parents the information they need to block programs they consider harmful. The V-chip needs to be designed so that it is able to accommodate any necessary changes. As we ride the crest of the information age, it is strange indeed that the information industry takes the position that we should rigidly lock in place a singular system without any chance for correction or improvement.
The Revised Rating System was agreed to before any testing of its effectiveness was possible. It is unlikely that any rating system (espeicially one that is arrived at by compromise) would stand up under testing without requiring revision. Any necessary changes will need to be made without necessitating new hardware for the V-chip.
A little known aspect of the revised system is that it permits the industry to conceal the presence of violent, sexual or coarse language content in some situations. The age-based structure makes it impossible to discern information about content that exists at more than one age-level within a program. Under the current plan, for example, if a program has "strong coarse language," it will be rated TV14-L; if it has "moderate violence," it will be rated TVPG-V. But if it has both of these elements, the program will be designated simply as TV14-L. No indication will be given of the violent content. If a parent were to program her V-chip to avoid programs designated with a "V," a program designated TV14-L that contained PG-level violence would not be blocked. Theoretically under the new system, a producer could avoid disclosing that a program had moderate violence simply by adding strong coarse language to the program. Parents may find this "loophole" unacceptable. Indeed, it may well turn out that this loophole undermines the intended purpose of the V-chip. If independent research determines that this is the case, or if this loophole is abused by producers, the ratings system will need to be modified, and the V-chip will need to to be able to adapt to this change.
3. Parents should be able to block unrated programs and any programs that they have identified as harming their children. The purpose of the V-chip is "to permit parents to limit their children's exposure to video content that they consider harmful." Programs do not need to have ratings to be considered harmful by a parent; nor do they need to be rated as inappropriate for children to be harmful. A parent should be able to block a particular program that causes problems for her child without having to block all programs that have the same rating.
My fifteen years of research on television and children's fears has shown that young children often have repeated nightmares and long-term anxieties from viewing programs that are rated as appropriate for children or general audiences. These include most of the Disney animated features and "family-oriented" series like "Little House on the Prairie."(6) Moreover, research also shows that children often have intense fright reactions from the news, a category that is exempt from the ratings.(7) The Joint Commenters state that the exemption of news from ratings reflects the "unique status and public benefit of news and informational programming."(8) While I'm not arguing here that the news should be rated, parents should have the ability to shield their children from traumatic news stories when they are out of the room and unable to monitor the effects such stories might have. If some parents were to block all unrated programs to protect their children, it would not have a chilling effect on news content. It would simply mean that an unsupervised child in that home would not be subjected to news or sports or other unrated programs.
The unique status of television in the home requires a strong degree of parental empowerment. Without the V-chip, if there is a television in the home, any and all contents that producers wish to program can enter the home automatically, without being specifically requested. Parents need to have the power to keep out specific programs and unrated programs as well as programs rated in specific ways, to protect their children's mental health and well being.
In summary, the arguments advanced by the Joint Commenters and the CEMA against the capability of the V-chip to decode multiple ratings systems, against flexibility in the V-chip's circuitry to accommodate inevitably necessary changes, and against the ability to block specific programs and/or unrated programs are unconvincing. Adopting the industry's perspective on these issues would deter rather than enhance the V-chip's ability to function in the way the Telecommunications Act of 1996 intended it to function: to empower parents to protect their children.
Sincerely,
Joanne Cantor
ProfessorFootnotes:
1. Joint Comments of the National Association of Broadcasters, the National Cable Television Association, and the Motion Picture Association of America, p. 10.
2. Comments of the Consumer Electronics Manufacturers Association, p. 9 (III.A.)
3. Comments of CEMA, p. 13 (III. B).
4. Joint Comments of NAB, NCTA, and MPAA, p. 5.
5. See my comments to the FCC dated October 3, 1997.
6. See Cantor, J. (1996). Television and children's fear. In T. MacBeth (Ed.), Tuning in to young viewers: Social science perspectives on television (pp. 87-115). Thousand Oaks, CA: Sage Publications.
7. Cantor, J., & Nathanson, A. I. (1996). Children's fright reactions to television news. Journal of Communication, 46(4), 139-152.