The paper makes a set of sound (and in some cases innovative) policy proposals that are in line with arguments about the media and the public interest raised in some academic and policy circles.

All of the proposals aim to strengthen mechanisms that protect the public interest and that take into account citizens’ (rather than consumers’) needs. The core proposals about stronger cross-ownership rules are likely to spark a lot of debate and so are the proposed behavioural elements of the public interest test. There is likely to be widespread agreement about the need for mechanisms that protect editorial independence and safeguard investment in newsgathering and investigative journalism, however, making these part of the public interest test is likely to cause a lot of controversy. These proposals go against the current deregulatory and liberalizing trend and I agree with CCMR that stronger regulation is necessary in these areas and that behavioural remedies could be effective.

The extension of cross-ownership rules to all platforms is a logical (and perhaps overdue) move in updating regulation in line with the changed converging media environment. Similarly, calls for the de-politicization of the initiation of the public interest test and for greater transparency of media ownership have been made repeatedly in both academic and policy circles to no actual avail.

Ofcom and the strengthening of its competencies are central for some of the proposals, above all the de-politicization of the initiation of the public interest test and a broader understanding of plurality in competition decisions. This is indeed of key importance for assuring that the public interest test is not restricted to the narrow understanding of plurality as embedded in competition regulation.

Some of the proposals deal with extremely important issues that are not easily translated into actual policies (especially not into statutory regulation). Ongoing discussions at pan-European level (European Union as well as Council of Europe) and also at UNESCO indicate the difficulties with implementing policies that ensure that media enable a ‘range and diversity of cultural expression’. Yet, from my point of view, this is an absolutely core element of the media and the public interest as we live in societies with diverse populations and media should serve their needs better. I agree with the CCMR that Ofcom is well positioned to contribute to policy making and its implementation in this respect.

Greater transparency and more democratic procedures in media ownership considerations are important proposals and so are the ones that aim to create a greater distance between political and journalistic/media elites. While opening up procedures for the involvement of the public in media ownership considerations is a less controversial proposal, it is likely that media professionals as well as politicians will resist the proposed procedures for recording meetings, for a variety of reasons. This, however, should not prevent efforts at creating (statutory and non-statutory) policy instruments that would contribute to the critically important distancing between media and political elites.

Monika Metykova has been a lecturer in media at Northumbria University since September 2010. Prior to that appointment, she was a research associate for the Goldsmiths Leverhulme Media Research Centre. Her research has covered aspects of the transformation of media systems in former communist countries and her PhD dealt with the establishment of Czech and Slovak public service broadcasting. Monika has contributed to EU-funded research on changing journalistic cultures in these countries as well as the economic, social and cultural impact of broadband in new EU member states.