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Chapter Two

Citizenship, Media and Liberal Forms of

Government: Political and National Dimensions

This chapter begins with an overview of citizenship theory, drawing attention to

its national and cultural as well as its political dimensions. It also critically

appraises the relationship of liberal and critical media theories to citizenship

discourses, with the claim that citizenship is automatically related to public

service broadcasting being critiqued. It is argued that binary oppositions between

citizens and consumers, and public and commercial broadcasting, are neither

empirically sustainable nor intellectually productive. A detailed overview is

provided of the historical development of citizenship and its relationship to

political strategies associated with ‘governmentality’, or the management of

population through the diffusion of techniques of self-management aimed at

regulating conduct. Tensions between governmentality and citizenship are seen as

arising from three sources: the paradox of political power being exercised over

populations in the name of their own popular sovereignty; the relationship

between policy ‘failure’ and political contestation; and the relationship between

policy expertise and political sovereignty. Enhancing the scope for citizen

participation in political decisions that have an impact on their lives has often

been presented as the solution to these problems, but it presents its own issues,
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most notably around questions of representativeness and the nature of political

agency.

The second half of this chapter explores the concept of national citizenship

and its relationship to the development of national cultures, with particular

reference to the role played by print and broadcast media as cultural technologies

that can be engaged in the ‘nationing’ of populations. The capacity to distribute

broadcast media across national boundaries presents challenges to the cultural

sovereignty and territorial jurisdiction of the nation-state, analogous to those

discussed in the debates about globalisation. It is found that, just as the

globalisation literature overstates both the newness and the significance of the

phenomena it describes, debates about media globalisation need to recognise the

relationship between global, national and local forces in the circulation of

audiovisual media content, together with the important roles played by nation-

states and national cultures in the regulation of these international media flows,

and the significance of these forms of ‘communicative boundary maintenance’ to

the formation of national citizens.

The ‘Return of the Citizen’ in Media Studies

The 1990s saw the concept of citizenship put forward as providing a set of

guiding principles for media policy and media studies. Stuart Cunningham

proposed that citizenship discourses provided a direction for research and critical
 69

activity in media and cultural studies that would ‘be developed and justified

within an operational reformism that is sensitive to what is possible as much as to

what is ideal’ (Cunningham 1992b: 535). Geoff Mulgan utilised citizenship

discourse in the ‘quality debate’ about British broadcasting, to argue that a

citizenship perspective allowed television viewers to conceive of themselves as

contributors to the making of television as well as being its receivers, and got

beyond the sterile dichotomy of consumer sovereignty versus cultural elitism

(Mulgan 1990). James Curran (1991), Jo Hawke (1995) and Julianne Schultz

(1994) proposed an orientation to citizenship as essential to requiring both media

proprietors and journalists to recognise social obligations as well as private

interests, and as an alternative to policy approaches which they saw as

interpreting community well-being as being synonymous with the extension of

market relations.

Utilising T.H. Marshall’s (Marshall 1947) historical typology of civil,

political and social citizenship, Peter Golding and Graham Murdock (1989)

propose that communications policies that guaranteed citizenship rights would:

(1) maximise the access of individuals to information, advice and analysis

concerning their rights; (2) provide all sections of the community with access to

the broadest possible range of information, interpretation and debate on issues;

and (3) allow people from all sections of society to recognise themselves in the

representations offered in communications media, and to be able to contribute to

the development and shaping of these representations. The necessary conditions

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for communications and information systems to achieve such goals are maximum

possible diversity of provision, mechanisms for user feedback and participation,

and universal access to services regardless of income or place of residence.

According to Graham Murdock, ‘to meet these criteria, a communications system

needs to be both diverse and open’ (Murdock 1992: 21).

Renewed interest in citizenship in media and communications studies

coincided with developments in the 1990s which saw citizenship become ‘the

“buzz word” among political thinkers on all points of the political spectrum’

(Kymlicka and Norman 1994: 352; cf. Turner 1986; Hall and Held 1989; Hirst

1990). In political terms, citizenship is ‘a polysemic category, open to

contestation’ (Miller 1993: 12), and has been used to justify political projects as

diverse as privatisation of public assets and retention of public ownership, or both

the rights of welfare recipients and schemes requiring the unemployed to work in

order to receive welfare benefits. In current usage, citizenship has become a

‘Third Way’ concept, used to find ways forward in social and political debates

from long-standing divides between neo-liberalism and Marxian socialism

(Giddens 1998; Latham 1997).

In their discussion of the renewal of interest in citizenship in political

theory, Kymlicka and Norman point to two cautionary issues. First, they observe

that ‘the scope of a “theory of citizenship” is potentially limitless ... [as] almost

every problem in political philosophy involves relations among citizens or

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between citizens and the state’ (Kymlicka and Norman 1994: 353). Second, they

point to a need to avoid conflating ‘citizenship-as-legal-status’, involving full

membership in a particular political community independently of one’s degree of

political participation (so-called ‘passive citizenship’) with ‘citizenship-as-

desirable-activity’, or ‘active citizenship’, where ‘the extent and quality of one’s

citizenship is a function of one’s participation in that community’ (Kymlicka and

Norman 1994: 353). A third issue is the complex and sometimes contradictory

relationship between political citizenship, which can be the basis for an open,

inclusive and universalist understanding of rights, and national citizenship, with

its associated obligations to a nation-state, a ‘common culture’ and a moral

community. Employing Hindess’ (1993) definition of citizenship, the concept can

be seen to have three dimensions:

1. A legal-political dimension, based upon an egalitarian understanding of

rights and duties, including the guarantee of legal rights of independence and

equality before the law, the political rights of freedom of speech and association,

and the right of citizens to participate in decisions concerning their governance, as

part of their standing as independent persons;

2. A national dimension, or the existence of forms of exclusivity over the

granting of citizen rights within a territorially defined community, and control by

state authorities over formal admission into that community, including the right to

deny admission, as well as requirements upon citizens to participate in the affairs

of that community, including the defence of its territory;

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3. A cultural dimension entailing, on the one hand, the sustaining of some

form of moral community or ‘common culture’ among its citizens, as part of a

binding sense of membership in a political community and, on the other,

recognition and tolerance of difference, diversity and the rights of individuals to

freedoms within the ‘private’ sphere.

Media and Citizenship: Classical and Contemporary Debates

Citizenship in its modern sense has long been connected to the media of

communications. Popular media have played both a pedagogical role as cultural

technologies deployed for purposes of nation-building and citizen-formation, and

a more critical role as sites for articulation of popular discontent with the unjust or

illegitimate use of public power and authority. Philosophers of modernity such as

Immanuel Kant and G.W.F. Hegel recognised the relationship between the means

of expression of ideas and the popular imaginary. Kant defined the public use of

reason as ‘that use which anyone may make of it as a man of learning addressing

the entire reading public’ (Kant 1971: 55), while Hegel described ‘reading the

morning paper [as] a kind of realistic morning prayer’ (quoted in Donald 1998:

219). More generally, the centrality of media to modern conception of citizenship

arises from the re-emergence of classical citizenship discourses in the context of

modernity, whose features include: the large multi-ethnic nation-state;

representative democracy; commerce and capitalist industry; rational and

calculative modes of government administration; and a world of sovereign states

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(Heater 1990; Davidson 1997). The primary means of communication of modern

nation-states would not be the direct speech and face-to-face interaction of the

ancient city-states, but rather forms of ‘mediated interaction’ associated with the

development of print technology and the mass circulation of the printed word and,

later, broadcasting (Thompson 1995; Finnegan 1988).

In broad terms, two approaches to the relationship between media and

citizenship have predominated. The first has been that of liberal media theory,

which points to the role of the media in modern liberal-democratic societies as

guardians of the rights and liberties of citizens in the face of unaccountable or

irresponsible exercises of institutional power, or as the ‘Fourth Estate’. According

to liberal media theory, the principal requirement of a free media is that it must

possess ‘freedom from government controls or domination’ (Seibert 1963: 51).

Structural independence from government, and a willingness to champion popular

interests in the face of institutional power, are central parts of the rhetorical

armour of the media as the ‘Fourth Estate’. Julianne Schultz has argued that, in

the late twentieth century, this has been associated with the ‘watchdog’ role of the

media, and the assertion by journalists of ‘their idealised role as defenders of the

public interest’, in the face of challenges from the executive, parliamentary and

judicial ‘estates’ of government (Schultz 1998: 93).

The primary weakness of liberal media theory is its difficulty in

reconciling the formal equality of senders and receivers in the communications

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marketplace with substantive inequalities in access to material resources to

influence public opinion, and the concentration of ownership of the most

influential media among a small number of powerful corporate interests. Curran

(1991) describes the three principal limitations of liberal media theory as being:

its reluctance to address the implications of media concentration for diversity of

opinion; the tendency for media markets to consolidate the position of dominant

media conglomerates; and the adverse implications for diversity of opinion arising

from the tendency to pursue the largest possible media audience through limited

product differentiation. Schultz also points to the difficulty in promoting ‘Fourth

Estate’ ideals in the context of a predominantly commercial media system, in her

observation that journalism has been increasingly bound by the ‘paradox of

holding its head in politics while its feet are grounded in commerce’ (Schultz

1998: 45).

Critical media theory shares with liberal media theory a belief in the

emancipatory possibilities of media, but is concerned about the degree to which

media institutions are enmeshed with wider structures of political and economic

power. The tension between the formal equality of citizens in democratic societies,

and the structural inequalities and forms of hierarchy characteristic of capitalist

market economies, is seen as creating a situation where ‘the public sphere - this

space for a rational and universalistic politics distinct from both the economy and

the State - was destroyed by the very forces that had brought it into existence’

(Garnham, 1990: 107). This argument is most full developed in Jurgen Habermas’s
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historical-normative analysis of the public sphere, which is seen as first emerging

among the educated middle classes of Western Europe in the seventeenth and

eighteenth centuries as the bourgeois public sphere, but which has been marked by

decline in the nineteenth and twentieth centuries, due to the concentration of

corporate control over media industries, the rise of advertising and public relations

as mechanisms for control over media content, and the growing role of the state in

economic and social management through Keynesian economics and the welfare

state. As a result, for Habermas, the liberal model of the public sphere ‘cannot be

applied to the actual conditions of an industrially advanced mass democracy

organised in the form of the social welfare state’ (Habermas 1977: 200).

Drawing upon Habermas, critical media theorists such as Nicholas Garnham

(1990), James Curran (1991) and Peter Dahlgren (1995) have argued for the

significance of public broadcasting as central to the project of collective citizen

formation within nation-states. Garnham argued that public broadcasting possesses

elements of an ideal-type public sphere, such as operational principles premised

upon ‘a communally agreed structure of rules and towards communally defined

ends’, and the ‘opportunity for different classes and groups to take part in the same

public dialogue’ (Garnham 1990: 105). Curran proposed that a decentralised and

highly accountable form of public broadcasting should constitute the core of a

democratic media system, around which would operate politically - aligned media,

journalist-controlled media, private enterprise media and ‘social market’ media. For

Dahlgren (1995), the central tension with broadcast media is in the contemporary
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public sphere, where ‘those media institutions which are of the most significance

for the majority of citizens are … to a great extent beyond the reach of citizen

practices and interventions’ (Dahlgren 1995: 155). In order to overcome this ‘tragic’

(Dahlgren 1995: 5; Garnham 1992: 107) vision of the relationship of media to

citizenship in liberal-capitalist societies, Dahlgren looked to the coexistence of

decentralised and accountable ‘common domain’ media with ‘advocacy media’,

nurtured through public policy, to promote strong citizenship and an active civil

society.

The connection drawn by critical media theorists between public

broadcasting and political citizenship is not as clear-cut as it first appears to be.

Richard Collins (1993) has drawn attention to the tendency in critical theory to

deal with public service broadcasting as a normative ideal, rather than with the

actual conduct of public service broadcasters. The point is not merely a semantic

one since, as Collins observed, in countries where commercial and public service

broadcasters have coexisted, the conduct of public service broadcasters can only

be understood in terms of their interaction with the commercial sector, rather than

as a stand-alone broadcasting system. For Collins, this interaction with the

commercial sector has been a positive influence on public service broadcasting

since, in countries where public service broadcasting developed without pressures

from audience competition from a commercial system, the outcome has largely

been ‘a “top-down” broadcasting service [that] constructed an idealised and

reified public, to which it represented a public sphere of broadcasters’

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imagination’ (Collins 1993: 250). Gay Hawkins (1999) has noted the problems

that have arisen for public broadcasters in their ‘assumption that “quality” meant

“not commercial”’, most notably in the ‘perpetual quandary’ that arises between

ensuring distinctiveness and achieving popularity, and a resulting tendency to

constitute quality in terms that ‘consistently value the middlebrow over the vulgar

and information and aesthetics over fun’ (Hawkins 1999: 176). From the

commercial broadcasting perspective, Stuart Cunningham’s (1993) account of the

historical mini-series that screened on Australian commercial television in the

1980s, and their relationship to discourses of national identity that were reflective

on formative national events, provides an interesting counter-example of ‘nation-

building’ programming on Australian commercial television.

John Hartley (1996, 1999) has developed a very different model of the

relationship between media and citizenship in modernity. In Popular Reality:

Journalism, Modernity, Popular Culture (Hartley 1996), Hartley proposes that,

since popular culture is ‘another name for the practice of media readership in

modernity’ (Hartley 1996: 47), and as it is through journalism that the logic of

democratic equivalence that is at the heart of political citizenship is circulated, it

is not possible to understand the functioning of media in relation to citizenship in

terms of binary oppositions between the quality and the popular, or the public and

the commercial. Hartley extends this argument in Uses of Television (Hartley

1999), proposing that ‘the uses of television are best understood by means of the

concept of transmodern teaching [and] … what television has been used for is the
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formation of cultural citizenship’ (Hartley 1999: 26). Associating cultural

citizenship with the right to claim an identity based upon difference, Hartley

argues that in the great competition of modernity between governmental,

educational, media and critical institutions for popular attention in the public

sphere, it is the broadcast media that have been most effective in leading a

movement from ‘mass society’ and adherence to a national culture, to identity

politics and what Hartley terms ‘do-it-yourself (DIY) citizenship’ (Hartley 1999:

154-165, 186-187).

Hartley’s work significantly challenges the ‘tragic’ account of the

relationship between media and citizenship in liberal-capitalist societies,

developed by critical theorists out of Habermas’s work on the public sphere.1 Its

strengths lie in: its focus upon the incidental means through which the media

contribute to citizen-formation; its focus upon what people do with media rather

than what media do to people; its questioning of a hierarchy of genres in terms of

how the media inform the development of citizens; and its rejection of a

dichotomy between quality and popular media, or public service and commercial

media, from the perspective of how they are used by their audiences. For Hartley,

good popular television can be both popular and critical, fun and informative; it

does not rest upon the ‘sublimation of pleasure to value’ that Hawkins critiques in

the approach taken by ‘quality’ public service broadcasting towards its audience

(Hawkins 1999: 177).

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This thesis, however, distances itself from Hartley’s appraisal of the

relationship of media to citizenship in three key respects. First, while recognising

the material dimensions of textuality to which Hartley draws attention (Hartley

1999: 55-70), there is also a need to reaffirm the positivity of institutions in terms

of their role in constituting a social field, forming individual identities, and

providing a basis for political and social agency and meaningful action. This also

draws attention to the distinctiveness of institutional formations across societies

and over periods of time, and how these constitute the conditions of existence for

the types of television programming that are produced and distributed in national

television systems. Second, there is the danger of concluding that, since media

texts are polysemic and audiences are unknowable to empirical analysis, criticism

is impossible. There is a blurring in such an approach between critiques of

television as an overall system of popular provision of information and

entertainment, which Hartley convincingly argues against, and critique of

particular programs and programming strategies, which continues to have validity

(cf. Flew 1998). Third, since Hartley blurs distinctions between television’s

address to audiences as an over-arching community and its appeal to particular

taste constituencies, his analysis faces difficulties in dealing with some of the

problems that have motivated the development of non-commercial media, such as

the lack of provision of certain program types for economic reasons, as well as

factors that have motivated the regulation of commercial media.2

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Critical media theory has observed the ‘split’ nature of the modern citizen,

between a discourse of media freedom that is associated with the global

information and entertainment market, and a discourse of cultural citizenship that

is typically national in its domain of application, and associated with ‘public

interest’ media regulation. Toby Miller has observed that this is less a matter of

divided subjectivities, and more to do with a ‘policy divide’ (Miller 1991: 204),

whose significance has become more apparent in an era where national forms of

media regulation are becoming overlaid with global trade agreements and other

forms of international law. A major focus of this thesis will be upon the

campaigns of media reformers to use legislative and regulatory mechanisms to

transform the conduct of commercial broadcast television in Australia, with one of

these aims being to make it more responsive to the discourses and principles of

citizenship. In this context, an examination of the impact of media policy reforms

becomes not an ‘add-on’ to other forces which determine the conduct on the part

of Australian commercial television broadcasters, but moves closer to the centre

of an understanding of their modus operandi. In this respect, both the critical

media theory tradition and Hartley’s work present too generalised a framework

for the detailed empirical work on how citizenship discourses have informed the

development of Australian commercial television.

‘Governmentality’ and Citizenship

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Michel Foucault developed the concept of ‘governmentality’ in his later work to

describe the process in modern Western societies where the conduct of the state

shifted from rule by primarily juridical means to an increasingly administrative

and technical basis for rule. Techniques associated with the practice of

government also came to be dispersed through a range of social institutions that

were linked to, yet distinct from, the formal apparatuses of the state. In Foucault’s

work, the state ‘consists in the codification of a whole number of power relations

which render its functioning possible’ (Foucault 1984: 64). An understanding of

the practices of government thus requires that these activities of government are

understood, not in terms of the institutions that undertake them, but rather in

terms of their capacity to guide the conduct of others.

Particularly important in this regard is the development of liberal forms of

government from the mid-eighteenth century onwards, which was associated with

what Foucault describes as ‘the introduction of economy into political practice’

(Foucault 1991: 92), or what Burchell (1991) terms ‘a principle of cost-

effectiveness’ into government regulation. Liberal form of government promoted

the autonomous functioning of civil and economic processes, by establishing

limits to governmental regulation founded around the ‘proper use of liberty’ by

self-governing and self-interested individuals. The result was that ‘civil society’

emerged, not as that which is outside of or necessarily opposed to state power, but

rather ‘as both the object and end of government’, involved with a complex and

shifting set of relationships with state agencies, that provides ‘fertile ground for
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experimental innovation in the development of political technologies of

government’ (Burchell 1991: 141).

Peter Miller and Nikolas Rose (1992) have used Foucault’s approach to

power and government to develop an account of the political rationalities and

governmental technologies that have informed advanced liberal forms of

government. They reject dualities such as those between state and civil society,

public and private, coercion and consent, and government and the market, arguing

instead that ‘the state possesses neither the unity nor the functionality ascribed to

it; it was a “mythical abstraction” which has assumed a particular place within the

field of government’ (Miller and Rose 1992: 175). They also reject notions of

political power that assume the imposition of constraints upon citizens, in favour

of a view of power understood as ‘“making up” citizens capable of bearing a kind

of regulated freedom ... the more so because most individuals are not merely the

subjects of power but play a part in its operations’ (Miller and Rose 1992: 174).

For Miller and Rose, government is primarily a problematising activity, where

‘the ideals of government are intrinsically linked to the problems around which it

circulates, the failings it seeks to rectify, the ills it seeks to cure … the history of

government might well be written as a history of problematisations … it is around

these difficulties and failures that programmes of government have been

elaborated’ (Miller and Rose 1992: 181).

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How governments problematise particular domains, and seek to act upon

them through various programs, involves establishing a relationship between

political rationalities and governmental technologies. Political rationalities have

three characteristics:

1. They have a characteristically moral form, in the manner in which they

address the proper distribution of tasks and actions between different

types of authorities, and the ideals or principles to which these tasks

are related.

2. They are grounded in particular theoretical understandings of chosen

domains, drawn from academic bodies of knowledge, with the

disciplines of the social sciences being particularly important in

defining the social field and rendering it thinkable.

3. They construct problems, and the means of addressing them within

particular discursive fields, or political discourses, in ways that

‘elucidate not only the systems of thought through which authorities

have posed and specified the problems for government, but also the

systems of action through which they have sought to give effect to

government’ (Miller and Rose 1992: 177).

Miller and Rose use the term technologies of government to broadly define

the diverse range of techniques, procedures, calculations, surveys, systems,

designs and vocabularies, deployed across a heterogeneous array of sites and

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through a broad series of domains, that enable ‘the decisions and actions of

individuals, groups, organisations and populations … to be understood and

regulated in relation to authoritative criteria’ (Miller and Rose 1992: 177). What

programs of government, understood as a combination of political rationalities

with technologies of government, enable is influence over the conduct of citizens

through action at a distance. Following Foucault, Miller and Rose observe that

modern liberal forms of government are not characterised by the relentless

expansion of state powers and capacities; rather, state agencies ‘identify a domain

outside “politics”, and seek to manage it without destroying its existence and its

autonomy’ (Miller and Rose 1992: 177). Central to such a mode of government is

the role played by experts and expertise, who enter into a ‘double alliance’ with

political authorities on the one hand, for whom they problematise new issues and

translate political concerns into governmental programs, and individuals and

groups on the other, for whom they provide the techniques and forms of assistance

aimed to enable them to achieve greater personal satisfaction and overcome

material deprivation (Johnson 1993).

Governmentality, Citizenship and the Political Sphere

The theory of governmentality provides the basis for important insights into the

relationship between administrative and policy practices at the level of particular

issues, institutions or ‘problematics’, and larger political rationalities and social

relationships. At the same time, three problems emerge for the theory of
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governmentality as applied in modern liberal democracies. First, there is the

paradox of political power being exercised over free citizens in the name of their

own popular sovereignty. One instance of this is what Foucault described as the

‘welfare state problem’, which is ‘one of the extremely numerous reappearances

of the tricky adjustment between political power wielded over legal subjects and

pastoral power wielded over live individuals’ (Foucault 1988: 67). The paradox

of governmental power being exercised over individual citizens in their own

interest, but without their consent, was also observed by Max Weber in his famous

comment that ‘“democracy” as such is opposed to the “rule” of bureaucracy, in

spite and perhaps because of its unavoidable yet unintended promotion of

bureaucratisation’ (Weber 1922: 990).

Foucault’s own response to this problem was far from consistent. He

described modern forms of state power as ‘demonic’ when they combined

techniques of pastoral power with the question of ‘reason of state’, arguing

instead that ‘liberation can only come from attacking ... political rationality’s very

roots’ (Foucault 1988: 85). The problem with this argument, which draws upon

Nietzsche’s claim that ‘there is nothing more harmful to freedom than liberal

institutions’ (quoted in Hindess 1997: 267), is that it rests upon an antinomy

between power and freedom that Foucault’s genealogy of the modern subject, as a

social agent which has been formed under the sign of various productive regimes

of power, has rendered untenable (cf. Minson 1980; Wickham 1983; Minson

1986). Hindess (1996) notes that such a sweeping condemnation of domination in

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the name of liberty loses sight of the complex links between the acquisition of

capabilities and the growth of autonomy that has characterised the experience of

subjectivity under the various techniques of power in modern Western societies.

Hunt and Wickham (1994) draw attention to a similar contradiction in Foucault’s

critique of law in modern societies, on the grounds of Foucault’s argument that

the principal forms of power in modernity are essentially non-legal, found in the

disciplines and in governmental practice. As a result, according to Hunt and

Wickham, Foucault finds struggles over legal rights and legal regulation,

characteristic of modern democratic politics, to be based upon an ideological

misrecognition of their object, since power and control actually operate in a more

disciplinary, capillary and subterranean level than this surface level of democratic

and legal rights (Hunt and Wickham 1994: 41-52; 59-61). Hunt and Wickham

argue that this account rests upon a caricature of the significance of democratic or

representative institutions, forms of participation in governmental processes and

the implications of extended citizenship rights, providing instead a one-sided

interpretation that ignores ‘the extent to which the new forms of disciplinary

power have already or can potentially become subject to processes of legal rights

and legal regulation’ (Hunt and Wickham 1994: 62).

The second problem that emerges in the relationship between

governmentality and citizenship is the nature of failure as an inevitable aspect of

governance. Malpas and Wickham argue that practices of governance can only

ever involve a ‘partial appropriation of things’, and that they must therefore
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involve instances of failure, since failure ‘marks precisely the limit of governing

practice and not something that lies within its boundaries’ (Malpas and Wickham

1997: 94). Miller and Rose reach a similar conclusion when they observe that

government is not a ‘perfect regulatory machine’, but rather a ‘congenitally

failing operation’, where the ‘will to govern’ is ‘fuelled by the constant

registration of “failure”, the discrepancy between ambition and outcome, and the

constant injunction to do better next time’ (Miller and Rose 1992: 191). O’Malley,

Weir and Shearing (1997) have argued that such approaches to policy failure,

while valid, downplay the significance of political contestation in favour of a

stress upon programmatic failure. They propose instead that governmentality

literature needs to focus more upon political contestation as a limit to programmes

of government, given the ‘abundant evidence that contestations, resistances and

social antagonisms shape rule through systematic provision of alternatives’

(O’Malley, Weir and Shearing 1997: 510).

Third, there is a tension between governance and citizenship, or between

rule through expertise and popular sovereignty. Barry Hindess notes that, as a

consequence of the principle in liberal-democratic societies that there is no natural

or essential basis for the subjection of the majority of the governed population to

rule by a small minority, government ‘has no source of legitimacy outside its own

effectiveness’ (Hindess 1997: 261). The tensions between formal empowerment of

populations in liberal-democratic societies through citizenship, and their

substantive subordination to state authority through practices of governance, lead

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to what has been termed a citizenship gap. The development of institutional

frameworks that enable extended participation in decision-making processes has

frequently been presented as the best means of resolving this citizenship gap. Hall

and Held capture this tradition when they observe that ‘rights can be mere paper

claims unless they are practically enacted and realised, through actual

participation in the community’ (Hall and Held 1989: 175). This understanding of

degrees of democracy based upon the scope for participation can be found in the

of a ‘ladder of participation’ from administrative tokenism to genuine

participatory democracy (Minson 1986), and in the concept of ‘strong democracy’

as a stage beyond representative democracy, where citizenship is realised in its

fullness through what Benjamin Barber describes as ‘a self-sustaining dialectic of

participatory civic activity and continuous community-building in which freedom

and equality are nourished and given political being’ (Barber 1984: 152).

The connections drawn between political participation and active citizenship

typically revolve around three sets of arguments (Richardson 1983). First, there is

the developmental argument, which focuses upon the political skills acquired by

individuals through participation, as part of realising their full potential as

citizens. Second, there is the fairness argument, focusing upon the rights of

individuals to be involved in the making of decisions that affect them. Third, there

is the instrumental argument for participation as producing better outcomes as a

result of a wider consideration of interests and broader process of public

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involvement. Mark Considine draws links between the normative goal of

maximising participation and processes of policy formation in his argument that:

Policy always involves a dual structure. It has an instrumental dimension

in that it produces decisions, programs and other outcomes which actors

value. It also has a set of developmental relationships in the way it allows

for the communication of moral and ethical norms, and the building of

trust and solidarity between actors ... Participation describes three types of

action: it facilitates rational deliberation; it creates and communicates

moral principles; and it expresses personal and group affects and needs.

When all three forms of action are available, then participation provides a

means for the creation of social capital from which all central democratic

objectives spring. (Considine 1994: 130)

It would indeed be a happy combination of outcomes if the extension of

participation not only gave citizenship a revitalised and more active form, but led

to better policy outcomes than those derived from administrative and technical

expertise. Two problems keep emerging, however, in attempts to transpose the

‘abstract’ arguments for participation into practices that can be transposed into

areas of policy formation and governance. First, there is the need to clarify the

goals of participation, and to recognise links between forms of participation and

the likelihood of effective outcomes, recognising that participatory structures do

not themselves lead to positive outcomes from the decision-making process. Kate
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Harrison has noted that a recurrent problem has been that participation was

frequently given ‘motherhood status’, and ‘the advantages of participation were

frequently listed and asserted, often without any attempt to define precisely what

was meant by participation, and without due consideration of the negative features

of increased participation’ (Harrison 1986: 94). Second, the equation of political

participation with active citizenship is frequently based upon the presumption that

the subject of participation is an individual citizen. Rorty (1988) has noted that, in

actual participatory processes, the subject of policy participation is often less

likely to be an individual person, but rather an agent acting as a representative for

a group of people, a legally defined subject such as a corporation, or some other

category not reducible to an individual citizen. Recognition that political

participation is commonly based upon collective forms of organisation raises

issues about the relationship between citizenship and participation. In discussing

the centrality of organised interest groups to processes of policy participation,

Paul Hirst notes that ‘organised interests cut across the common civic sphere …

Organised interests are influential to the extent that they achieve their own ends,

which are different from a notion of the collective sovereignty or common

political will of all citizens’. (Hirst 1990: 164-165)

Consideration of a ‘participation gap’ in relation to broadcast media and

citizenship presents two threshold questions in relation to media policy. The first

is the question of whether the public as citizens have entitlements to be involved

in decisions concerning broadcast media content, as part of the ‘public trust’

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obligations of broadcast licensees. The second issue is how such participation can

be organised. If theorists such as Rorty, Hirst and Hindess are correct to observe

that active citizenship and policy participation is more likely to occur through

organised interest groups than through the actions of individuals, then what are

the conditions under which an organisation or interest group can claim to ‘speak

for’ an audience or sections of it? The emergence of such interest groups in the

broadcast media sphere, and how they have negotiated interfaces between the

broadcast institutions, the policy process and the wider interests of the Australian

community will be explored in the second part of this thesis.

National Citizenship and National Culture

The literature on citizenship in political theory tends to stress its politically

egalitarian dimensions, where full democratic citizenship is an end-state of the

‘democratic imaginary’ unleashed by the French and American Revolutions of the

eighteenth century (Laclau and Mouffe 1985). Yet the formulation

‘nation=state=people’, which has been so central to revolutionary discourses of

citizenship, has also been central to discourses of nationalism, and the notion that

citizenship is derived from a sense of belonging derived from affiliation to a

national ‘common culture’. It is insufficient to conceive of citizenship purely in

terms of an inclusive and egalitarian discourse of rights since, as Barry Hindess

has observed, citizenship has also always been defined not only in terms of

reciprocal obligations to the nation-state, and through various forms of exclusion

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of those deemed to be ‘non-citizens’. The various ways in which citizens are

differentiated from non-citizens, through access to civil, political and social rights

and resources, have developed ‘against the background of a conception of

community in which the unity of a self-governing polity is expected to correspond

to the unity of a national culture’ (Hindess 1993: 39).

Ernest Gellner has defined nationalism as ‘primarily a political principle,

which holds that the political and the national unit should be congruent’ (Gellner

1983: 1). Eric Hobsbawm has also drawn attention to the political dimension of

nationalism, claiming that:

The primary meaning of “nation” ... was political. It equated “the people”

and the state in the manner of the American and French Revolutions... The

“nation” so considered, was the body of citizens whose collective

sovereignty constituted them a state which was their political expression.

For, whatever else a nation was, the element of citizenship and mass

participation or choice was never absent from it. (Hobsbawm 1990: 18-19)

Yet the political element of nationalism, as a principle of citizenship tending

toward universalism, has also coexisted with its cultural element, which stresses

the particularities and commonalities of the ‘people’ of a nation, in relation both

to each other and to those outside of that collectivity. While such claims to

cultural uniqueness on the part of nationalist movements have been treated with
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suspicion since they were first proposed,3 the inculcation of a ‘common culture’ is

central to the promotion of nationalism in the development of modern nation-

states, through national mass educational and cultural institutions.

John Hutchinson (1994) has argued that both Gellner and Hobsbawm

subordinate culture to politics in their accounts of nationalism, in a manner

characteristic of modernist intellectuals who approach nationalism as essentially a

political phenomenon, likely to decline over time as societies become more

secular, rational and cosmopolitan. Stuart Hall makes a similar observation about

the assumption that nationalism, like other ‘particularistic’ attachments, would

wither away over time:

The great discourses of modernity - in this respect Marxism no less than

liberalism, both in their different ways, Enlightenment ‘grand narratives’ -

led us to expect, not the revival but the gradual disappearance of the

nationalist passion. Attachments to nation, like those of tribe, region,

place, religion, were thought to be archaic particularisms which capitalist

modernity would, gradually or violently, dissolve or supercede. (Hall

1993: 353)

The cosmopolitan vision of a common humanity, united by a shared belief

in equality and rationality, has always been implicit in the philosophies

underpinning citizenship (Heater 1990). Visions of a citizenship that transcends

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nationhood have crossed political boundaries, from liberal hopes for world

government or a ‘global village’ united by communications technologies, to

Marxist visions of international working-class solidarity, to the dialectic of

localism and globalism presented as a strategic vision for political action by the

feminist, environmentalist, peace and other social movements. Such

cosmopolitanism emerges in contemporary cultural studies, sociology and related

fields, and is related to a belief that the nation-state is in irrevocable decline as a

result of economic globalisation, global communications flows, transnational

movements of people and cultural forms and practices, and a resulting set of

cultural transformations which have been termed ‘postmodernism’ (cf. Robbins

1998; Cheah 1998). Lata Mani has argued that trends in the global cultural

economy ‘confound, complicate, and increasingly render irrelevant earlier

mappings of the world, whether in terms of binary divisions or discrete units’, and

will in turn ‘offer hospitality, if not centrality, to practitioners of postmodern,

postcolonial, transnational historiography and ethnography, and provide a location

where the new politics of difference - racial, sexual, cultural, transnational - can

combine and be articulated in all their dazzling plurality’ (Mani 1992: 392).

Similarly, in the Australian context, Andrew Milner has argued that economic

globalisation and postmodernity have ‘rapidly reduced to redundancy all cultural

nationalisms’, thereby creating the conditions for a ‘post-national’ cultural studies

that can ‘render this actually existing transnational postmodernity

comprehensible, and thereby hopefully changeable’ (Milner 1991: 110).

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Such a ‘cosmopolitan’ sense of belonging to the world rather than to a

particular nation has always been a minority sentiment, coming more easily to

particular class formations than others, by virtue of factors such as their work

patterns (Heater 1990: 188). Immanuel Wallerstein has noted that ‘world culture,

the humanism of many sages, has long been advocated on the grounds that it

permits one to overcome the provincialism - hence the limitations to moral

growth, and the obscurantism - of cultural particularisms’ (Wallerstein 1990: 103).

Wallerstein is sceptical of such arguments, noting that in spite of the long-

standing ideal of world culture and global citizenship, world history has not been

characterised by cultural homogenisation, but has ‘rather been a trend towards

cultural differentiation, or cultural elaboration, or cultural complexity’, and where

there have been ‘gravitational forces restraining the centrifugal tendencies and

organising them … [and] the single, most powerful such gravitational force has

been the nation-state’ (Wallerstein 1990: 96).

Cultural Technologies of Nationhood: Print, Broadcasting and

National Identity

The concept of cultural technologies has become an increasingly important one in

media, communications and cultural studies.4 Drawing upon the work of

anthropologist and media theorist Eric Michaels, Tom O’Regan argues that

understanding television as a cultural technology is ‘to see it as a site holding

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together diverse though interconnected projects’, including textual, ethnographic

and institutional modes of analysis (O’Regan 1990: 54). Similarly, Jody Berland

has proposed that ‘cultural technologies produce not only content and thus

something called ideology, to be negotiated by already-located viewers, but also

material practices with their own structural effects and tensions’ (Berland 1992:

39, 41). In an analysis of newspapers and national identity in relation to

Australia’s 1988 ‘Bicentenary’ of European settlement, Colin Mercer has

proposed that ‘the newspaper in its historical development is a cultural

technology which … enables a national imaginary to be transacted’ (Mercer

1992: 74).

In perhaps the most famous application of media as cultural technologies to

the emergence of modern nationalism, Benedict Anderson (1991) has linked the

rise of a market in the products of the printed word, or what he terms print-

capitalism, to the rise of the modern nation-state, arguing that ‘the convergence of

capitalism and print technology on the fatal diversity of human language created

the possibility of a new form of imagined community, which in its basic

morphology set the stage for the modern nation’ (Anderson 1991: 46). For

Anderson, this linkage of print media and modern nationalism emerged in three

key respects: the development of ‘vernacular’ languages of trade and

communication that was linked to growth in the international book trade; the way

that print technology gave a new fixity to language, as ‘the printed book kept a

permanent form, capable of virtually infinite reproduction, temporally and

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spatially’ (Anderson 1991: 44); and the emergence of languages of administration

and power with the codification of laws and rules under modern forms of

governance.

Anderson understands the nation as ‘an imagined political community’

(Anderson 1991: 6), and proposes that the symbolic dimension of nationalism as a

series of ‘myths’ grounded in representations and everyday practices becomes

crucial in extending the boundaries of community, promoting a symbolic

unification through common allegiance to a ‘deep, horizontal citizenship’ that

seeks to transcend divisions within the nation-state. Through the modern nation-

state, policies are developed that are self-consciously directed towards cultural

integration, including language policy, formal education, collective rituals such as

national events, public exhibitions of ‘high’ culture in art galleries and museums,

and the mass media. Anderson’s emphasis upon the role of print media as a

cultural technology of national cultural integration is parallelled in Tony Bennett’s

work on museums as cultural technologies of ‘nationing’, where ‘constructions of

the nation’s past and projections of its future destiny … are embodied in museums

and natural heritage sites’ (Bennett 1995: 142).

While an important feature of Anderson’s account of the rise of nations

and nationalism is the explicit attention given to mass communications media as a

bridge linking political nationalism and systems of governance to cultural

nationalism and its links to everyday life, Anderson limits his analysis to print
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media forms. Philip Schlesinger has pointed out that Anderson ‘does not push the

argument further to take account of later, post-Gutenberg media technologies, and

to try and examine their implications for the consciousness of nationhood’

(Schlesinger 1991a: 164). The issue is not simply one of choice of medium to

research, since a characteristic feature of twentieth century nations and

nationalism is the uncoupling of space and time in global communications, as

‘distance has been eclipsed by proliferating networks of electronic

communication’ (Thompson 1995: 149). Communications historians such as Innis

(1951), Meyrowitz (1985) and Carey (1992) have observed that, while print

culture was associated with the rise of nationalism, as it promoted continuity over

time, decentralisation and regional differentiation, broadcast media were space-

binding, promoting centralisation of production, decentralisation of dissemination,

and the need for continuity and instantaneity, and oriented toward international

distribution.5

Globalisation, Nation-States and National Cultures

Globalisation has been defined as a series of interrelated trends that include: the

internationalisation of production, trade and finance; international movements of

people, as immigrants, guest workers, refugees, tourists, students and expert

advisers; international communications flows, delivered through technologies

such as broadband cable, satellite and the Internet; the global circulation of ideas,

ideologies and ‘keywords’; the development of international organisations,

including regional trading blocs, cultural, professional and standards bodies, and
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non-government organisations (NGOs); and the growing significance of

international law to national policies. In relation to communications media, it has

been argued that one implication of media globalisation is that ‘audiovisual

geographies are … becoming detached from the symbolic spaces of national

culture’ (Morley and Robins 1995: 11). Such arguments are associated with wider

claims that globalisation has triggered an uncoupling of culture and polity in

contemporary nation-states. One example of such claims is Arjun Appadurai’s

argument that contemporary global economic and cultural flows have generated

‘fundamental disjunctures between economy, culture and politics’, and that global

‘mediascapes’ produce ‘imagined worlds’ that are increasingly disjunctive to their

lived experience of their audiences in particular places and dominant cultures

(Appadurai 1990: 296, 299). Similarly, John Urry identifies the growing global

access to mass communications forms such as broadcast media with globalising

processes which ‘undermine the coherence, wholeness and unity of individual

societies’ (Urry 1989: 97).

Since a defining feature of nationalism is ‘the striving to make culture and

polity congruent, to endow a culture with its own political roof, and not more than

one roof at that’ (Gellner 1983: 43), such developments would point to the

declining influence of nation-states, as they are no longer to maintain distinctive

national cultures which unify their population. For Appadurai, these global

mediascapes are part of the ‘cultural politics that have subverted the hyphen that

links the nation to the state’, which in turn generate distinctive forms of
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‘deterritorialised’ cultural identity and associated strategies of ‘micropolitics’

(Appadurai 1990: 304-308). Similarly, Urry sees the ‘disorganising’ of modern

nation-states as arising from the simultaneous processes ‘of globalisation from

above, of decentralisation from below, and of disintegration from within’ (Urry

1989: 101).

The globalisation thesis points to some of the critical dimensions of

international cultural and economic flows in the 1980s and 1990s. Nonetheless,

‘strong’ globalisation theories have typically possessed two abiding problems.

First, while their empirical basis is superficially plausible, it is in fact relatively

weak when evaluated in a historical perspective, or when the scale of international

markets is compared to those of national markets. This point is made forcefully by

Hirst and Thompson (1996), who argue that globalisation arguments are

superficial in their use of evidence, lack historical depth and greatly underestimate

the continuing significance of nation-states in regulation and governance of the

international economy. They argue that economic globalisation is not a

historically unique experience of the post-1960s era, and the world economy was

more open in the 1870-1914 period, with volumes of trade, capital flows and

levels of international migration being higher then than now. Linda Weiss (1997)

has developed a similar critique in the East Asian context, arguing that

‘“globalisation” must be seen as a politically rather than a technologically induced

phenomenon’ (Weiss 1997: 23). Second, the thesis draws too heavily upon the

particular experience of the nation-states of Western Europe, and the central

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premise that once-strong and unified nation-states are being dispersed or

disorganised by globalising and decentring tendencies does not work when

applied to the majority of nation-states outside the metropolitan centres of

Western Europe. A related point is that much debate about the so-called ‘global-

local dialectic’, and the associated decline in significance of the national level of

political and cultural engagement, has been animated by the implications of

greater European economic and political integration, and that the implications of

these developments for nation-states outside of Europe have to be approached

carefully. The ‘deterritorialising’ trends identified by Morley and Robins do not

seem as unique in countries such as Australia, New Zealand or Canada since, for

these countries, ‘limited and shared sovereignty is nothing new’ (O’Regan 1993:

101). In such countries, the issue for media policy that seeks to regulate

international flows has often had less to do with communicative boundary

maintenance, to use Philip Schlesinger’s phrase, and more to do with the

establishment of national cultural infrastructures that can be developed and

nurtured in an audiovisual environment that is highly permeable to imported

content.

The construction of dichotomies between media globalisation and national

media cultures is therefore mistaken. While studies affirm the centrality of the

United States to the world audiovisual trade, accounting for 70 per cent of total

audiovisual exports, it is also the case that most of the world’s television product

remains local, both in terms of not being broadcast outside of its home country
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and in its textual style and mode of address. Broadcast media have always been

implicated in global communications and cultural flows, yet, paradoxically,

television has not ‘always been international, both culturally and economically,’

as cinema has been described (Geoffrey Nowell-Smith, quoted in O’Regan 1996:

48), due to the strength of national public broadcasters, national regulatory

systems, and audience preferences for locally produced material in most

countries. The complex relationship between economic and technological forces

that promote imported programming, and political and cultural (including

linguistic) factors which promote local content, results in considerable unevenness

in the degree of penetration of overseas programming in national television

systems. As a result, ‘hybrid’ program forms often emerge which negotiate local,

national and international cultural markets, such as the local production and

international trade in program formats, or what Moran (1998) terms ‘copycat TV’.

Moreover, sustained exposure to overseas television programming is frequently

the trigger for strengthening national production systems, whether through

protectionist cultural policies of le defi Americain (Schlesinger 1991),

development of ‘cosmopolitan’ program formats which ‘play at being American’

(Caughie 1990), or the fashioning of ‘national champions’ which can compete in

definable global audiovisual markets, such as the ‘soaps’ and telenovellas

exported from countries such as Brazil, Mexico and Australia to particular

Portuguese, Spanish and English language audiences (Sinclair et. al. 1996).
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As cultural industries, audiovisual media content continues to bear the

markers of the national cultures it came from, and international trade in broadcast

media occurs ‘on the basis of the irreducibly cultural relationships that are

established between certain types of program and the audiences for whom they

are meaningful’ (Sinclair 1996: 55). It is also apparent that nation-states and

public policy have an ongoing significance in regulating the relationships between

global flows and their local impacts within the national community, that includes

positive initiatives to develop a national cultural infrastructure as well as controls

over cross-border media flows. It is also important to bear in mind that the notion

of strong citizenship, where national institutional structures have sought to tightly

bind national citizens to the state through transmission of a common language,

culture and national identity, may be more historically and geographically specific

than is allowed for by those discourses arising from the ‘strong’ nation-states of

Western Europe, and may not be so applicable to the majority of the world’s

population, who live in countries where weaker notions of national citizenship

and cultural sovereignty have been the norm (Collins 1990; Castles 1997;

Davidson 1997a, 1997b).

Conclusion

Citizenship provides an important link between media as culture and the

development of institutional regulatory forms and policy frameworks. The

paradox of citizenship in liberal democracies, where free subjects are required to

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consent to their institutional governance as populations, means that there is an

ongoing tension between rule through expertise and popular sovereignty. This is

connected to an ongoing debate about the extent to which ‘active citizenship’

should be promoted, where citizens actively participate in the institutional

structures of governance. In relation to an area such as media, such questions are

unavoidably connected to the degree to which commercial media forms and

market relations are held to be sufficient to meet the needs and interests of diverse

populations, or whether activist forms of media policy and regulation are a

necessary corrective to the limitations of the market. This chapter has sought to

question both overly sanguine accounts of commercial media found in liberal

media theory, and the ‘tragic’ accounts of critical media theory, to instead address

media policy as integral to the conditions of existence and modes of operation of

commercial broadcast media, thereby constituting a significant site of negotiation

and political contestation.

The question of national citizenship, and its relationship to national

culture, is also an important animator of media policy. Media have operated as

sites of citizen-formation and the development of national and cultural identities,

and the relationship between broadcasting as a potentially global cultural

technology and national cultures is a complex and contested one. This is seen in

debates about globalisation, which have, nonetheless, been one-sided, in their

tendency to assume strong nation-states and relatively homogeneous national

cultures existing prior to the impact of global media such as broadcasting. If it is

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the case, as Richard Collins has argued, that ‘relatively few actual states … fit the

theoretical model … where a “nation”, bound together by shared ethnicity,

language, religion, stable frontiers, and economic interest, is politically sovereign

in its own state’ (Collins 1990: 18), then it may follow that the apparent ‘newness’

of globalisation, and concerns about the capacity of globalisation to weaken bonds

between culture and polity, may not apply particularly well to the states in which

the majority of the world’s population live. If this is the case, then the model of

‘weak’ national citizenship and an uncertain degree of national cultural

sovereignty, found in nations such as Australia, Canada and Brazil, may indeed

provide a template for the development of national cultural policy and its

articulation to cultural citizenship worldwide.

 1
Habermas’s work on the public sphere was based around the printed word, and can only be extended to broadcast
media with some difficulty. Indeed, as Collins has noted, Habermas was hostile to film, radio and television, arguing in The
Structural Transformation of the Public Sphere (1989: 171) that:

‘In contrast with printed communications the programs sent by the new media [radio, film and television] curtail
the recipients in a peculiar way. They draw the eyes and ears of the public under their spell but ... deprive it of the
opportunity to say something and to disagree.’ (quoted in Collins 1993: 248).
2
An argument can be made for public broadcasting that is not based upon claims about quality, but rather concerns
the tendency for commercial media to undersupply particular areas of broadcast programming with strong ‘public good’
elements, such as public affairs programming, critical and investigative forms of news and current affairs and documentary,
and children’s programming (Herman 1997). This shifts the focus away from defending public broadcasting on the basis of
value criteria, towards the notion of maximising programming diversity within a broadcast media system (cf. Flew 1994).
3
One of the most famous rebuttals of the cultural uniqueness of nations was Ernest Renan’s (1882) account of how
the modern European nation was not founded upon dynastic continuity, racial homogeneity, linguistic unity, a common
religion or geographical limits. Instead, Renan argued that the origins of the modern European nation were historically
contingent, and that the conditions for a nation-state’s continuing existence had to be continuously reproduced and
reinvented, in order to win the consent of its people: ‘a nation’s existence is ... a daily plebiscite’ (Renan 1882, in Bhabha
1990: 11, 12, 19).
4
See Flew (1996) for a more detailed discussion of the concept and its applications. That paper draws attention to
five influences upon the concept: philosophies of technology as developed by Karl Marx and Martin Heidegger;
psychoanalytic film theory; ‘social shaping of technology’ arguments, particularly Raymond Williams’ account of television
as ‘technology and cultural form’; Canadian communications theory as developed by Harold Innis and Marshall McLuhan;
and post-Foucaultian cultural histories developed by Ian Hunter and Tony Bennett.
5
It is important to note that such developments do not necessarily negate nationalism as a political force, but rather
promote the circulation of ideas outside of defined territorial boundaries. Harold Innis drew attention to this in considering
the significance of radio to the territorial ambitions of the Nazis in the 1930s:

In Europe an appeal to the ear made it possible to destroy the results of the Treaty of Versailles as registered in the
political map based on self-determination. The rise of Hitler to power was facilitated by the use of the loud speaker and the
radio. By the spoken language he could appeal to minority groups and to minority nations. Germans in Czechoslovakia
could be reached by radio, as could Germans in Austria. Political boundaries related to the demands of the printing press
disappeared with the new instruments of communication. The spoken language provided a base for the exploitation of
nationalism and a far more effective device for appealing to larger numbers. Illiteracy was no longer a serious barrier. (Innis
1951: 81)