What is "good" press freedom?

The difficulty of measuring freedom of the press worldwide


Christina Holtz-Bacha
Institut für Publizistik Johannes Gutenberg-Universität 55099 Mainz phone:+ 49 6131 3925636 fax: + 49 6131 3924586 email: christina.holtz-bacha@uni-mainz.de

Paper prepared for presentation at the 2004 conference of the International Association for Media and Communication Research (IAMCR), Porto Alegre/Brazil, July 25-30.


What is good press freedom? The difficulty of measuring freedom of the press worldwide

Freedom of the press, although generally regarded as a constituent of democracy, does not have the same meaning everywhere in the world. Differences in the understanding of press freedom exist e.g. even among the West European democracies or between Western Europe and the United States. Because press freedom refers to the system level and only international comparisons allow for assessing the 'goodness' of a country's freedom of the press, we need a measure that can be used worldwide. This paper discusses the difficulties of measuring freedom of the press in international comparison and the problems of the two existing scales and finally makes a plea for a more differentiated perspective on the concept.

If we believe the worldwide Press Freedom Index drawn up by Reporters Without Borders and published for the second in the fall of 2003, Finland, Iceland, the Netherlands and Norway are the heaven of press freedom. These four countries share the first rank on the Index which now lists 166 countries altogether. However, media experts may, for instance, immediately point to the fact that newspapers in Finland and Norway receive state subsidies and thus cast doubt on the independence of the press in these countries. Newspapers on the drip of the government? Can this really be heaven? Newspapers, dependent on government money, should have problems with their critical ability. Therefore, the question arises which criteria stand behind such an index of press freedom. What constitutes good press freedom? How does a country qualify for the first rank?

Digging further into the matter, it turns out that, although press freedom is an essential constituent of democracy and as such often taken for granted, it still remains an uncertain concept. This is not only due to the fact that constitutional norms often diverge from reality but also that press freedom is understood differently in the various parts of the world. Such differences are obvious for democracies and authoritarian regimes, but even established democracies do not interpret press freedom in exactly the same way. Against this background, it is the aim of this paper to present an overview of how press

3 freedom has been measured in the past and to discuss such measurements critically. At the same time, the arguments offered here are meant to inspire new approaches to future research in this field. Altogether, this combines with a plea for comparative research across countries.

Press Freedom according to Freedom House According to the latest Survey of Press Freedom, which is presented each year by the US organization Freedom House, Western Europe has the highest level of press freedom worldwide. In 2002, 24 of 25 countries rated free, only one West European country was classified as partly free. However, the individual scores show that considerable differences exist even among the countries that are classified as free. Table 1 lists the detailed rankings for the 15 member states of the European Union. [Table 1: Freedom House Ranking] The scale ranges from 0 to 100 with 0 being the best rating. In countries scoring 0 to 30 the media are classified as free. So, the lower the score, the better. The last row of this Table shows the overall score for each country displaying differences of up to 20 points. According to the Press Freedom Survey, Sweden ranks first with a score of 8, while Greece and Italy each received 28, thus ranking last among the EU member states and only three points above the threshold to partly free.

At present, the Press Freedom Survey is the only source regularly providing information about the situation of the media in all countries of the world. The Survey has been conducted since 1979. Thus, it not only allows for comparisons across countries but also across time. In fact, any research that studies the degree of press freedom in a given country refers to the macro level. The research unit is the political system or the state. Comparing two or more countries allows for ascertaining a higher or lower degree of press freedom. In addition, at the state level only international comparisons allow B as Gurevitch and Blumler (1990: 309) wrote B 'to render the invisible visible' and, by bringing out similarities and differences, lay open national specifics. Comparing the degree of media freedom or restrictions for the media across countries makes it possible to find out which national structures and processes affect the situation of the media. On the other hand, if we discover common features B in democracies for instance B these could allow for generalizations.


Methodological problems of international comparisons However, international comparisons have to deal with considerable methodological problems. A particular difficulty lies in the collection of adequate data. In order to be valid, cross country comparisons have to be based on comparable data for the countries included. If such data do exist at all, their availability is not guaranteed, particularly when a sensitive issue as freedom of the press is being addressed. More problems originate from language barriers and the cultural bias that each individual researcher brings along. Therefore, international comparisons are dependent on a high degree of external support which again carries the potential for inconsistencies B between data and in interpreting the data. On the other side, international cooperation of this sort offers the opportunity to overcome national idiosyncrasies.

Particularly if a large number of countries is involved, comparisons require quantitative research methods. However, the more countries are included, the coarser will be the examination of the individual country, necessarily leading to loss of detail. Therefore, the attractiveness of taking into consideration a multitude of countries is bought at the price of neglecting details that may be important for interpretation. As a consequence, the challenge is to develop a measure for press freedom to be used for international comparisons. This raises the question of what the essential factors of press freedom are and how these can be measured across continents.

As can be seen in Table 1, Freedom House uses three broad categories to assess the status of press freedom in each country: legal environment, political influence, and economic pressures. These categories are only roughly defined in the Survey Methodology. The legal environment 'encompasses an examination of the laws and regulations that could influence media content as well as the government's inclination to use these laws to restrict the ability of the press to operate' (Survey methodology, 2003:xi). To consider political influence, Freedom House evaluates 'the degree of political control over the content of news media'. Economic pressures reach from the structure of media ownership and the costs of establishing media outlets to the impact of corruption and bribery on content. The overall scores of press freedom for each country are calculated by adding the scores in the three aforementioned categories. The

5 individual scores are shown in detail for the EU member states in Table 1 and thus allow for further explanation of the individual ratings. In most countries included here, economic pressures provide for the most negative influence on the overall score.

The definitions of the categories as given in the publication of the Press Freedom Survey are very broad and do not lay open how the individual scores are actually reached. Although short text explanations are provided for each country, it is not possible to retrace which factors exactly are considered and how they are weighed in the scores. For example, in the case of Italy that shares the last rank among the EU member states with Greece, it comes as a surprise that the comparatively low ranking is due mainly to economic pressures on the media and not B at least to an equal amount B to political influence.

Moreover, when comparing the Freedom House explanations concerning methodology from 2002 and 2003, we find that they differ considerably. Again, no commentaries can be found as to whether this is only due to variations in wording or whether there have been actual changes in the evaluation process from one year to the other. The 2002 edition at least mentions changes concerning the criteria for press freedom compared to earlier years. However, this casts doubt on the comparability of rankings over time and ruins one of the great advantages of this long-term observation of press freedom in the world.

In addition to the Press Freedom Survey, not much more than a handful of other, mostly older, studies exist which also presented scales for the measurement of press freedom. The first studies date back to the late 1950s and early 1960s. These studies coincided with the emergence of modernization theory that was established by Daniel Lerner (1958). Modernization theory attributed the media an important role in the development of traditional societies. Against this theoretical background, this research tried to identify sociological or political factors that help to improve press freedom and could thus be applied for prognoses.

Mostly, these studies used rather simple indicators that in one way or the other stood for government influence on press freedom. The perspective was expanded in 1970 with

6 the presentation of the so-called PICA-Index by Ralph Lowenstein (1970, 1976). PICA stands for Press Independence and Critical Ability. For the first time, the PICA-Index went beyond the traditional equalization of press freedom with independence of government influence and added economic restrictions to the measurement of press freedom. Economic restrictions here referred to consequences of press concentration or problems arising from an unstable economic situation of newspapers. However, the PICA-Index also assigned unfavorable marks for the existence of institutions of selfregulation like a press council. Meanwhile, economic variables have also been adopted by the Freedom House index, thus providing for a broader definition of press freedom. This definition takes into account that restrictions of freedom of the press can result from other factors than government influence alone.

The Western bias The few examples mentioned here demonstrate that concepts of press freedom may differ considerably. In fact, the non-applicability of the same model all over the world had also been one of the outcomes of earlier research by David Weaver and his colleagues (1985) who tried to assess the factors helping the development of press freedom in a country. While these findings referred to differences mainly between industrialized countries and less developed regions of the world, the data presented in Table 1 hint at differences even among established democracies whose media systems are classified as free.

Although Freedom House does not offer much of an explanation for individual ratings, examples taken from the 2002 and 2003 publication will show that many problems occur when attempting to measure freedom of the media. For instance, it is noted for the Scandinavian countries that newspapers are in the hands of parties. But: Does media ownership by political parties in general have to be regarded as a threat to press freedom? Another case: Germany receives unfavorable marks for prohibiting Nazi propaganda and also for trying to prevent distribution of obscene content through the Internet and such offerings that glorify violence. Finally France: The independence of French journalism is called into question because the French press is extensively supported by the state through direct and indirect measures. It is also noted in the commentary on the situation of the French media that journalists are required to have a

7 Carte de presse and therefore have to be officially registered. Thus, it does not need a comparison of different cultures to realize the difficulties of developing a standardized instrument to measure freedom of the press which is moreover applicable across countries and continents.

Beyond Europe, a look at the United States further adds to the differences in concepts of press freedom. The Anglo-Saxon notion of press freedom shrinks from any state regulation of the media or at least tries to keep regulation by law to a minimum. For instance, it also tends to rank press freedom higher than personality rights.

In the United States, public service broadcasting is often equated with state broadcasting. Most West European countries attach great importance to public service broadcasting which they consider a safeguard for diversity. Public service broadcasting is therefore supported through financial guarantees. From the US point of view, this is understood as public service broadcasting being dependent on the government while from a European perspective, support of public stations is regarded as lying in the interest of a free and diverse media system.

In the United States, the market is seen as the best guarantor of media independence. In contrast, West European countries examine the problems that arise for the media from a free and unregulated media market much closer. The economic difficulties small markets bring about for the media and the threat for diversity, which can result from media concentration, have therefore been an ongoing issue in most West European countries. In fact, diversity as an objective has explicitly or implicitly been written into the constitutions of West European countries. In Germany for example, in addition to the usual interpretation of press freedom as a barrier against state influence, the Federal Constitutional Court has also deduced from the press freedom article of the German constitution an obligation of the state to secure the functioning of the press. This positive guarantee for the press as an institution, however, leaves the state on a tightrope walk between the obligation to keep its hands off the media and the obligation to safeguard the conditions necessary for a free and diverse press. Several other EU member states interpret their constitution in the same way as Germany and distinguish a subjective and an objective side of press freedom. Thus, their constitutions include an institutional

8 guarantee for the press that also could provide for a basis of government action. Even more, the Portuguese constitution makes it an explicit duty of the state to prevent concentration of the media. To give another example, the Spanish constitution guarantees all social and political groups access to the public media and thus explicitly secures diversity. In addition to such general constitutional guidelines, most West European countries have more specific regulations to prevent concentration, not to speak of the aforementioned well-established role of public service broadcasting which is also regarded as a means to secure a diverse media market.

Finally, to counter the problems posed for the media on small markets or as a consequence of concentration, some countries have adopted more or less extensive schemes to support the press financially. The Scandinavian countries in particular, started in the 1970s to subsidize production and distribution of newspapers or to give subsidies to secondary newspapers to preserve diversity in a given market and to prevent monopolies. France, to take another example, provides newspapers with a variety of direct and indirect aids like tax reductions, reduced tariffs for postal distribution or by prescribing equal prices for the purchase of paper for all newspapers independent of their circulation. Finally, Austria has for a long time paid money directly to all daily newspapers in addition to indirect subsidies that are given away selectively.

Both, regulations to secure diversity on the media market, either through restrictive measures to prevent concentration or through subsidies, represent state interventions on the media market. The same is true for internal press freedom. In some countries, statutes according journalists participatory rights are regarded as a safeguard for diversity. In other countries, however, participatory rights for journalists are seen as an assault on press freedom because freedom of the press is interpreted as the freedom of the private owner to determine the tendency of the newspaper.

Thus, not even the West European countries agree on whether such activities of the state in the interest of diversity are to be regarded as threatening freedom of the press. Against this background, it did not come as a surprise when the European Commission, after two internal proposals, backed out of its plan to pass a concentration directive. At the EU level, the inconsistencies on press freedom became evident again in the

9 negotiations about the Charter of Fundamental Rights of the European Union. The freedom of the press clause in Article 11, which gives everyone the right to freedom of expression and information, underwent several changes. The 1999 draft of the Charter spoke of a guarantee for freedom of the press and freedom of information with respect to transparency and pluralism. In a new version of September 2000, the wording was changed to a guarantee for freedom of the media and media pluralism. One week later the wording was changed again to the then final version which now reads: 'The freedom and pluralism of the media shall be respected'. However, there seems to be quite a difference between 'guaranteed' and 'respected'.

The Press Freedom Survey carried out by Freedom House as well as the studies that were inspired by modernization theory all come from the United States. It is obvious that the indexes used for measuring freedom of the press have a Western bias. They mirror the norms and values of the highly developed Western democracies. Even more: These scales have a US bias. Therefore, they tend to reject any kind of media policy and to evaluate any activity by the state negatively, independent of its nature. Media ownership other than private is regarded with suspicion.

The cultural bias inherent in the scales used to measure freedom of the press continues with those who are actually evaluating the individual countries. The studies mentioned here mostly worked with experts who came from the Western hemisphere or even exclusively from the US Even if they are experts on the countries and regions they are supposed to evaluate, these experts bring along their 'cultural package', that means their perspective is shaped by the experiences and values of their own culture. The Western bias is thus reinforced.

Press freedom according to Reporters Without Borders In October 2002, a new worldwide Press Freedom Index was presented, this time by Reporters Without Borders also known under its French name Reporters sans frontières. The organization, particularly well-known for defending imprisoned journalists, bases the rankings on 'local journalists or foreign correspondents living in the country, researchers, legal experts, specialists on a region and the researchers of the Reporters Without Borders International Secretariat' (Reporters sans frontières,

10 2002a). This index has a somewhat different perspective compared to the Press Freedom Survey. Particular attention is put on direct attacks on journalists, as for instance murder or imprisonment, and attacks on the media like censorship or confiscation. This includes threats by other groups than the state, as for instance armed militias or underground organizations. Reporters Without Borders also takes into account whether the state uses its resources to fight such groups that put pressure on the media. Thus, the index goes beyond state influence on freedom of the press and, to a certain extent, registers the active protection of press freedom by the state. However, it is not clear whether economic variables are considered in the index as well.

As mentioned here at the beginning, according to the Press Freedom Index Finland, Iceland, the Netherlands and Norway share the first rank in a list that now includes 166 countries. Other than the Press Freedom Survey by Freedom House, the Press Freedom Index by Reporters Without Borders does not group the countries but only lists them in the order of their achieved rank. Therefore, the rankings by Reporters Without Borders only allow for evaluation of a country's media system as more or less free compared to others while the Freedom House Index groups countries as either "free", "partly free" or "not free". Reporters Without Borders thus avoids the difficult and somewhat arbitrary task to decide about thresholds between free and not free and at the same time demonstrates that such boundaries cannot easily be defined.

As a consequence of the different criteria that are used for evaluation in the two worldwide indexes, the rankings of specific countries differ. Table 2 shows the rankings for the EU member states according to these two indexes. Because only the EU countries are considered here and other countries are left out, the numbers given to the ranks do not correspond to the real numbers in the index rankings. [Table 2: Comparison]

Why is the measurement of press freedom important? Of course, the quality of press freedom in a specific country is of great significance, because freedom of the press is a constituant of democracy. Therefore press freedom is also used as an indicator for the measurement of democracy. Thus, the evaluation of the quality of a country's freedom of the press is at the same time an evaluation of its

11 democracy. However, because press freedom is only one of several indicators that are used to determine the 'goodness' of democracies, measurement becomes even more of a problem. In scales used for the measurement of democracy that combine several indicators, press freedom is only represented by a few or even one variable only. The democracy theory of Robert Dahl was influential in this respect. He proposed seven criteria or guarantees to be used for the measurement of democracy among which were, as two separate criteria, freedom of expression and freedom of information (Dahl 1989). The operationalization of these criteria necessarily has to be economical but gives cause for criticism. In this case, the degree of freedom of expression was determined by freedom of the press, and that is where all the problems apply that were outlined here. Therefore, it still remains an open question which variable is the best indicator for good freedom of the press and suitable to stand for a free media system which can be used to measure how democratic a democracy is.

The difficulties with the measurement of freedom of the press as was demonstrated here are a challenge for further research. The problems of measurement make it necessary to discuss the general question whether freedom of the press can be and should be defined and measured in the same way everywhere and for general purpose. The advantages and the attractiveness of worldwide comparisons notwithstanding, it is the question whether a homogeneous measure to be used worldwide is at all sensible. Democracy research has also come to a point where the dissolution of democracy as a consistent concept is discussed. It had to be acknowledged that over time certain core elements of democracy have spread worldwide but then led to culture-specific adaptations, particularly in non-western cultures. As a consequence, the concept of democracy has undergone a differentiation.

This idea could be applied for research into freedom of the press as well. In the same way as is discussed for the concept of democracy, it seems to be appropriate to discuss whether we should give up the search for a consistent notion of press freedom and rather work with a differentiated concept. Such a decision would allow for consideration of national variations and cultural adaptations. For instance, it is not only discussed in less developed countries whether freedom of the press is to a certain extent linked with social responsibility. This is of course the West European concept of public service

12 broadcasting but is also made an issue in view of potentially negative consequences of media concentration or commercialization.

If freedom of the media is indeed an important indicator for the quality of democracy, it is amazing that research has made few attempts to develop a suitable and at the same time easy to handle measure for freedom of the press, particularly a measure that can be used for international comparisons. The new Press Freedom Index by Reporters Without Borders demonstrates the relevance of this research when it summarizes its 2002 enquiry with the assessment: press freedom 'is under threat everywhere' (Reporters sans frontières, 2002b).

Two things are needed. Firstly, a scale for a worldwide comparison of freedom of the press. To account for different perspectives and avoid a cultural bias, this measure should be developed in international cooperation. Until today, this seems to be best achieved by the Press Freedom Index as presented by Reporters Without Borders. In addition to the theoretical approach, the measurement of freedom of the press has practical relevance: In the same way as the quality of democracy, the quality of press freedom in a specific country can be made the basis for decisions about international cooperation and support, for instance when it comes to support for the reorganization of a media system or for journalism education. A second, much shorter scale is needed that can be included in the measurement of democracy. This could be deducted from the first scale and should include the core elements of press freedom.

In any case, in order to track down the national characteristics of a media system, for example to lay open indirect and subtle infringements of freedom of the press, it is impossible to work on a worldwide basis. That is where we need comparative studies on the basis of only a few countries which allow for in-depth analysis. It is only then that we will be able to really assess the quality of press freedom in a specific country and to find out what makes Finland, Iceland, the Netherlands and Norway the heaven of press freedom.



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Table 1: Freedom House Ranking EU Member States
A LE PI EP 11 6 6 23 B 3 1 5 9 D 2 6 7 15 DK 1 3 7 11 E 1 8 7 16 F 5 7 5 17 FIN 1 2 7 10 GR 14 6 8 28 I 8 6 14 28 IRL 5 6 5 16 L 3 3 8 14 NL 5 4 6 15 P 5 4 6 15 S 1 2 5 8 UK 6 5 7 18


LE = Legal Environment PI = Political Influence EP = Economic Pressures 3 = Total Score

Table 2: EU Member States: Comparison of Freedom House and Reporters Without Borders Rankings
S FH R 1. 6. B 2. 4. FIN 3. 1. DK 4. 3. L 5. -D 6. 5. NL 6. 1. P 6. 11. E 9. 13. IRL 9. 8. F 11. 9. UK 12. 10. A 13. 7. GR 14. 12. I 14. 14.

FH = Freedom House (2003) (2003)

R = Reporters Without Borders

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