The Parents Television Council (PTC) released a new report today entitled Women in Peril: A Look at TV’s Disturbing New Storyline Trend. The report argues that “by depicting violence against women with increasing frequency, or as a trivial, even humorous matter, the broadcast networks may ultimately be contributing to a desensitized atmosphere in which people view aggression and violence directed at women as normative, even acceptable,” said PTC President Tim Winter.  As evidence the report cites… Nicole Kidman.  OK, it cites more than Nicole Kidman, but the 7-page report and accompanying press release does seem to place a lot of stock in the fact that, while being questioning by a House Foreign Affairs subcommittee hearing about violence against women overseas, “Ms. Kidman conceded that Hollywood has probably contributed to violence against women by portraying them as weak sex objects, according to the Associated Press.”  I’m not sure what Ms. Kidman was doing testifying before Congress on the matter of violence against women overseas — dare I suggest some congressmen were out for another photo-op with a Hollywood celeb? — but the better question is whether Ms. Kidman’s opinion has any bearing on the question of what relationship, if any, there is between televised violence and real-world violence against women. (Incidentally, if she really feels passionately about all this, is she prepared to go back and recut some of her old scenes in “Dead Calm,” “To Die For,” and “Eyes Wide Shut“?)

But let’s not nitpick about the credentials Ms. Kidman brings to the table or whether it makes any sense for PTC to elevate her opinions to proof of theory when it comes to a supposed connection between depictions of violence against women in film or television and real world acts of violence against women. PTC, however, suggests that’s exactly what is going on today. They allude to a few lab studies which are of the “monkey see, monkey do” variety — where the results of artificial lab experiments are used to claim that watching depictions of violence will turn us all into killing machines, rapists, robbers, or just plain ol’ desensitized thugs.

There’s just one problem with such studies, and the PTC report:  Reality.  Whatever lab experiments might suggest, the evidence of a link between televised media violence and the real-world equivalent just does not show up in the data. The FBI produces ongoing Crime in the United States reports that document violent crimes trends. Here’s what the data tells us about overall violent crime, forcible rape, and juvenile violent crime rates over the past two decades: They have all fallen.  Perhaps most impressively, the juvenile crime rate has fallen an astonishing 36% since 1995.

Now, let me be perfectly clear about something.  When analyzing such things it is vitally important to recall one of the first rules of statistical analysis: correlation does not necessarily equal causation. This works in both directions. Even if an increase in real-world violence was closely tracking depictions of violence on television or in video games, it wouldn’t necessarily mean there is a connection. But it would also be wrong to state that, on its own, an inverse correlation (with the trends moving in opposite directions) meant that there was absolutely no connection between these things.

At the margin, I believe that some media can have negative impacts on some people. Certainly, in heavy enough doses, watching non-stop depictions of sex or violence probably would have some sort of negative effect on some people — loss of sleep, if nothing else. Perhaps more.

Then again, I just cannot entirely dismiss the real-world evidence being so starkly at odds with the “monkey see, monkey do” theories bandied about by PTC and some researchers or regulatory proponents. At a minimum, the real-world evidence should at least call into question the “world-is-going-to-hell” sort of generalizations made by proponents of increased media regulation, who all too often make casual inferences about the relationship between media exposure and various social indicators. Such a causal relationship is even more dubious today since all Americans, especially youngsters, are surrounded by a much wider variety of media than ever before. Even though television viewing has gone down slightly in recent years, it has been due to the rise of other media substitutes that command the attention of children, including the Internet, cell phones and video games. Overall, therefore, it appears that children are “consuming” as much, if not more, media than ever before. One would think that if depictions of violence in media really were leading to increased aggression among youth it would start showing up in some of these indicators at some point. But that’s just not occurring. [If you’re interested, I’ve discussed all these issues at much greater detail here, here, here, and here.]

Another argument I often here is: ‘Well, the numbers would be even better if not for media violence!’  But there’s just no way to prove that one way or the other. Would the juvenile crime rate be down 46% instead of the 36% decrease we’ve actually since 1995?  I don’t know. Nobody can know. But I certainly hope that media critics and regulatory proponents aren’t so foolish as to suggest that the crime rate would drop to zero if we just forced everybody to watch “Mary Poppins” all day long.

Finally, let’s assume that the PTC is right and that depictions of violence against women are on the rise on TV. I can actually accept that statement. With all the forensic science shows and crime dramas on TV today, it’s clear that some of the plot lines are going to involve people dying in some fashion and many of those people will be women. And yes, some of the depictions will get pretty gritty. “Fringe” and the various “CSI” shows are clearly showing things we didn’t see on “Quincy” back in the day. (Bring back Jack Klugman! He was awesome.)

But, hey, culture has changed.  Envelopes have been pushed a bit.  A little less is left to the imagination.  But most of us can live with that fact.  Indeed, many of us actually enjoy that fact!  And for those who do not share that worldview or who have heightened sensitivities about depictions of violence in TV shows, movies, or games, I would like to tell them that I really do understand and appreciate where they are coming from.

Yet, there are many other ways you can deal with that without forcing us all to forgo content we might enjoy consuming. And, you guessed it, this is where I remind the world for the umpteenth time that I have written a whole book about parental control tools and methods! [The shameless self-promotion never ends here, folks!]  In fact, part of the reason I have invested so much time in that project — and my ongoing efforts to get companies and other third parties to expand the range of tools, ratings, and other information that we have access to — is because I genuinely want to make sure that those individuals and families who have different needs and values than I have the ability to craft their own “household media standard.”   I want each family to be empowered to make media content decisions for themselves such that they can find the media content they want and discard all the rest. Luckily, that is the world we increasingly live in today. Parents have more tools and methods at their disposal to help them decide what constitutes acceptable media content in their homes and in the lives of their children.

I know that some critics including the PTC feel that the tools aren’t good enough, but I just don’t buy it. Sure, there’s always some room for improvement regarding parental control tools and rating systems, but the existing panoply of tools and methods offer families unprecedented control over their media consumption habits. And that includes tools and methods which enable them to find enriching and educational content, which we have more of than ever before.

I understand PTC doesn’t share my worldview on these matters.  But the difference between us is that they want to take something away from me (the right to watch certain types of content) while I want to give something to them (the ability to block that which they find distasteful).  To be fair, however, their report did not rush to the regulatory solution, even though they did call for more hearings and they warn that:

if the television industry is unwilling or unable to take serious steps to reduce or tone down such graphic images, then we will urge the Congress and the FCC, by virtue of their regulatory authority over the public airwaves, to step in and take action.

The problem is, I don’t think PTC will ever rest until all this content is removed from the airwaves altogether, even if millions of Americans actually enjoy that programming.  Again, the better solution is for PTC to work with others to improve the tools and methods available to families to more effectively make this decision for themselves.  I certainly don’t want others making these determinations for my wife and me and our two kids.  We’ve got the job handled, thank you very much.

Over at Ars Technica, Matt Lasar does a nice job pointing out how the FCC’s quarterly indecency complaint totals have again been inflated by one group: the Parents Television Council. This is something Lasar has written about before and he’s one of the few journalists who continues to ask sharp questions about the ongoing manipulation of these statistics by PTC. As Lasar notes in his latest piece:

for the first quarter of this year, show the viewers relatively calm at 578 complaints in January, then 505 in February, followed by 179,997 in March? 179,997? Um, did we miss something? Did television really get that much more indecent in March? No worries. In these situations, we know what to do. We go over and check out the Parents Television Council‘s website. And sure enough, there’s a plausible instigator—a PTC viewer action alert crusade against a March 8 episode of the animated comedy show the PTC just loves to hate, Fox TV’s Family Guy.

This “complaint box stuffing” is something I wrote quite a bit about in the past, especially in my 2005 paper, “Examining the FCC’s Complaint-Driven Broadcast Indecency Enforcement Process.” As I pointed out there, “The PTC’s increasingly effective use of computer-generated campaigns against specific TV programs is a leading factor in explaining the large jump in indecency complaints in recent years.” Specifically, as I noted in that paper (as well as a Supreme Court filing with my friends at CDT), the FCC quietly and without major notice made two methodological changes to its tallying of broadcast indecency complaints in 2003 & 2004 that PTC  requested:

• On July 1, 2003, the agency began tallying each computer-generated complaint sent to the FCC by any advocacy group as an individual complaint, rather than as one complaint as had been done previously. The advocacy group benefiting from that change had challenged the FCC to make the change by June 30th and boasted later that it was responsible for the FCC’s redirection, citing reassurances of FCC commissioners.
• In the first quarter of 2004 — the time when the Super Bowl incident with Janet Jackson occurred — the FCC began counting complaints multiple times if the individual sent the complaint to more than one office within the FCC. This change, which had the capability of increasing by a factor of 5 or 6 or 7 the number of complaints recorded, was noted in a footnote of that quarter’s FCC Quarterly Report. The footnote acknowledged that “[t]he reported counts may also include duplicate complaints or contacts…”

As I have made clear before, I have absolutely no problem with the PTC, or any other advocacy group exercising their First Amendment rights to petition their government and make their views known. What I do have a problem with — a very big problem, in fact — is when one group so disproportionately influences the process, especially by changing the way complaints are counted. And I’m even willing to ignore the “robo-complaint” nature of their automated complaint-generation machine. After all, countless other groups use similar tactics today to flood government offices and agencies with thousands or even millions of digital form letters. But when you change the rules of the game to favor you and your preferred outcome, well, that’s just shameful.

What’s even more troubling about the way the FCC changed it complaint counting process to make the PTC happy is that the agency failed to provide the public official notice of these changes outside of some limited and quite confusing fine print in the footnotes of quarterly reports. Look as hard as you want at the FCC website and you will not find any press releases or summaries of these changes during that period. And there does not appear to be any mention of these changes in any speeches by FCC Commissioners or bureau chiefs then or since.  More shockingly, as far as I can tell, the FCC only made these methodological changes for indecency complaints, not for any other category of complaints that the agency receives!  Finally, and probably worst of all, these bogus numbers were then used by FCC officials and congressional lawmakers as supporting evidence for the supposed public outcry for more regulation of television and radio.

It’s an outrage, especially when you realize that the programs that the PTC wants censored are among the most popular on television, as I thoroughly documented in my paper.  In other words, they don’t speak for most of us when it comes to what we want to watch or listen to.  I hope the new FCC understands these bogus indecency complaint numbers do not reflect the wishes of most consumers.  Finally, those in the PTC or elsewhere who are offended by “The Family Guy” or other shows on television have plenty of tools and methods at their disposal to make sure those programs are not seen in their homes.  Please don’t try to impose your will on the rest of us when you have the tools at your disposal to do this job for you and your family.  Let’s not make Uncle Sam our National Nanny.

As I mentioned in a post last month, dozens of comments were filed with the Federal Communications Commission (FCC) as part of the agency’s “Child Safe Viewing Act” Notice of Inquiry.  Again, this proceeding was required under the “Child Safe Viewing Act of 2007,” which Congress passed last year and President Bush signed last December. The goal of the bill and the FCC’s proceeding (MB 09-26) is to study “advanced blocking technologies” that “may be appropriate across a wide variety of distribution platforms, including wired, wireless, and Internet platforms.”  I filed 150+ pages worth of comments in this matter, and here’s my analysis of why this bill and the FCC’s proceeding are worth monitoring closely.

Anyway, this week saw many of the same groups that filed before (and some new ones) file reply comments about those earlier submissions.  To make things simple, I have collected most of the notable reply comments down below in case anyone is interested.

• Association of National Advertisers
• American Legislative Exchange Council
• Children’s Media Policy Coalition
• Coalition for Independent Ratings
• Comcast
• Consumer Electronic Association
• Digimarc
• Electronic Frontier Foundation
• Entertainment Software Association
• Funai Electric Co.
• ION Media Networks
• Microsoft
• Motorola
• NAB, NCTA, & MPAA
• Nintendo
• Parents Television Council
• Smart Television Alliance
• TiVo
• T-Mobile
• TV Guardian

I’ve been blathering on about this week’s big Supreme Court decision in FCC v. Fox, [See Parts 1, 2, 3, 4, 5], so I thought I would just wrap this series of essays up with a collection of other articles and views on the decision in case readers are looking for alternative perspectives:

Mainstream Media Stories

• Associated Press
• Reuters
• New York Times (+ more analysis)
• Washington Post
• Wall Street Journal
• Legal Times
• TV Week
• Variety
• Kansas City Star
• USA Today
• Ars Technica

Conservative, Religious, & “Family” Groups

• Parents Television Council
• Common Sense Media
• Concerned Women for America
• Town Hall.com

Free Speech Advocates or Other Views

• The SCOTUS Blog
• Free Expression Policy Project (Marjorie Heins)
• ACLU
• Media Access Project (Andy Schwartzman)
• Center for Creative Voices in Media (Jonathan Rintels)
• First Amendment Center (David Hudson)
• Free State Foundation (Randy May)
• Michael Dorf
• Marc Randazza
• Reason’s Hit and Run
• Volokh Conspiracy (Eugene Volokh)
• TechDirt

The Parents Television Council (PTC), a media activist group that routinely petitions Congress and the FCC for greater content regulation, recently released a new poll which they say proves that the V-Chip and parental control technologies have been a failure.

Their poll finds that only 11% of those surveyed said they used the V-chip or their cable box parental controls to block unwanted content from their television during the past week. And that result is virtually unchanged from a poll they took last September asking the same question. Therefore, the PTC concludes that recent efforts by broadcasters and cable companies to spend hundreds of millions of dollars educating families about these parental control tools have been a failure. And, unsurprisingly, the PTC feels that this again shows the need for government regulators need to step in and do more national nannying for us.

As I’ll make clear in a moment, the V-Chip and current television ratings are certainly not perfect. And I have no doubt that household usage of these tools is quite low for reasons I’ll get into. But let me first address what appears to be a rather glaring methodological deficiency of this PTC poll which makes it difficult to take seriously.

According to the PTC press release announcing the poll results, “The PTC paid for a few questions to be included in omnibus telephone surveys of adults nationwide, conducted by Zogby International.” In other words, the PTC poll randomly surveys all households, which means they are including in their polling results the millions of households that have absolutely no children in them.

This makes their poll results highly suspect. It simply does not make sense to survey all homes about V-Chip or parental control usage because adult-only homes almost certainly would not be using any parental controls to block programming. This would be like polling all Americans, including homes made up of only adults, about whether or not they had baby locks on their kitchen cabinets!

And we’re talking about a significant percentage of homes here. According to the U.S. Census Bureau, almost 68% of American homes do not have any children under 18 years of age in residence. Therefore, the only population that should be surveyed when asking about parental controls is the 32% of homes that currently have children in residence.

Moreover, it is important to keep in mind that even for those homes with children in residence, not all of them will need to use parental control technologies before a certain age (4-5) or after a certain age (15-16) because many parents do not let their kids watch much TV until a certain age and then after a certain age trust their kids or just talk to them about objectionable fare.

Now, that being said, I am sure that even if the PTC had conducted its poll properly, the numbers would still be quite low for homes with children, but that doesn’t mean that the V-Chip or parental controls are a failure. As I argue in my big upcoming report on parental controls, surveys show that many families instead rely on informal household “media consumption rules,” preferring them to technical controls such as the V-Chip or set-top box controls. For example, a 2003 Kaiser Family Foundation survey found that “Almost all parents say they have some type of rules about their children’s use of media.” And a 2006 Kaiser survey of families with infants and preschoolers revealed that 85 percent of those parents who let their children watch TV at that age have rules about what their child can and cannot watch. 63 percent of those parents say they enforce those rules all of the time. About the same percentage of parents said they had similar rules for video game and computer usage.

We’re all familiar with these household media consumption rules even though we often don’t think of them as “rules.” These household media rules can be grouped into three general categories: (1) “Where” rules; (2) “When and how much” rules; and, (3) “Under what conditions” rules.

For example, many families establish “where” rules regarding the placement of TVs or other media devices in the home. In our home, my wife and I have assigned our kids a specific TV for the limited selection of programming we allow them watch and that TV is located in the living room where we keep and eye or ear on what their kids are watching at all times. And all of us probably heard this “under what condition” rule at some point in our childhood: “You have to finish your homework before you get to watch any TV.” And an example of a “when and how much” rule would be: “No TV or video games after 8:00,” or, more stringently: “No TV or games on a school night.”

Many families get even more creative by devising a “media allowance” for their children (especially as they get older) to allow them to consume media within certain boundaries. In our home, my wife and I generally allow our kids one hour of TV viewing per night on weeknights, and two hours on Saturdays and Sundays. Carrot-and-stick incentives can also be used with this approach. For example, better behavior or improved grades at school might be rewarded by adding additional viewing time to their overall weekly media allowance.

And there are countless other examples of such formal and informal household media rules, or the creative use of new technologies to control children’s media consumption. My wife and I have developed a strategy of designating a specific television in our home for most of our children’s media consumption and then using a PVR to amass a large library of programming we believe is educational, enriching and appropriate for them. Dozens of programs can be cataloged and archived in this fashion and then supplemented with VHS tapes, DVDs and computer software. As a result, when we allow our children some TV time, we always know that the episodes of “Dora the Explorer,” “Go Diego Go,” “Blue’s Clues” and “The Wiggles” that we approve of for our kids will be available. Needless to say, such content tailoring was not an option for families in the past.

The PTCs new poll simply doesn’t take things like this into account. For those looking to conduct an honest and accurate assessment of the true state of parental control methods in homes, their polls should: (1) only survey those households with kids in them; (2) then the pollsters should also ask the approximate ages of the children in the home to determine how relevant technical controls are for the family; and, (3) ask whether the parents rely on other, non-technical methods of controlling media consumption. Only then would you be able to draw reasonable conclusions about how American families go about controlling their children’s media consumption and the role technical controls or industry ratings play in the process. But the PTC poll fails on all these counts.