A letter to the Commissioners of the Federal Communications Commission during the public comment period for the FCC's review of the television ratings system.

Office of the Secretary
Federal Communications Commission
1919 M Street, N.W.
Washington, D.C. 20554
 

Dear Commissioners:

I have been an advocate on the issue of a television ratings system since 1990. I appreciate this opportunity to provide comments and suggestions on the industry’s proposal.

While I think a television ratings system is a good idea, I see one major flaw with the industry’s proposal. That is, the manner in which observations of violent and sexual content are grouped together into one combined rating does not allow parents to exercise their own judgement, independent from the content producers, on how much violent content, and separately, how much sexual content is appropriate for their children to watch. Further, I will argue that the combined content rating system has not been selected for the reason promoted by the industry, to simply a parent’s analysis of the suitability of a program’s content, but rather to cloud the issue of what offensive content a program actually contains.

In order to simplify the program ratings process, promote uniform evaluation methods, and give parents better information on programming content, I offer the following suggestions:

1. Separate the program content ratings into at least three categories: Language, Sex, and Violence.
2. Construct for each category of potentially offensive content a detailed, graduated listing of specific actions and/or words of ever increasing severity. Then set thresholds on each of these lists for separating the various ratings levels. (I believe it will be much easier for a group of people to agree on the ordering of a list of acts or words by severity in a given category of offensive content by, than for those people to agree on what level of offensive content from all categories combined is suitable for children of a certain age to watch.)
3. Publish these detailed lists by which content is judged -- perhaps by embedding them as one of the on-screen menu displays in television sets -- so that the public can see exactly how programs are rated. In fact, it would be more meaningful to assign content rankings through a generic numbering system (1, 2, 3, 4, …) of increasing severity, accompanied with information on exactly what range of content they represent, than to assign age levels to the rankings.

For an explanation on why the industry would wish to mask the true nature of the offensive content contained in its programs, I do not offer statistical evidence, but rather some observations that I believe most people would take as common sense.

1. Many people, especially young people, are attracted in part to watch certain television programs because of violent and sexual content they contain.
2. A concerned parent with specific knowledge of the offensive content contained in such programs and an easy way to prevent their children from watching those they deem inappropriate, would choose to block such programs.
3. Consequently, the children would have less interest in watching television and television viewership would decline, as would the revenues of the television program producers and broadcasters.

If you accepts this train of thought, providing an understandable ratings system combined with a convenient blocking system (such as the so called "V-Chip") would clearly not be in the financial interest of the industry. On the other hand, if the industry were able to rate programs with a more ambiguous and flexible ratings system, it would not call parents’ and advertisers’ attention to specific offensive actions or words that they would likely react to. Thus declines in viewership and revenues would be minimized.

The best evidence I can offer of the industry’s distaste for a more detailed and clear ratings system are the reactions I received to a letter I sent on December 5^th, 1990, in which I proposed the idea in a polite, thoughtful manner to various industry and interest groups. Quoting the principle suggestion from this letter:

"Basically, my idea is to include a program content signal with the normal television transmission signal, allowing a viewer’s television set to filter out the programs or portions of programs which that viewer would find offensive. I am a senior-level Electrical Engineering student at Oregon State University and this idea seems quite feasible to me.

Let me suggest how it would work. A viewer who chose to purchase a television with this ‘Parental Supervision Feature’, I’ll call it, could enter the settings of maximum allowable offensive content. For example: Sex=PG, Violence=R, Nudity=PG-13, Language=PG. Any time the broadcast exceeded these limits it would be blackened-out. The parent and the parent alone would have control over these limits through a password or, alternatively, a physical key.

In order for this system to work, programs would have to be encoded with program content signals either at the production level or the broadcast level…"

The reactions I received to this letter from television manufacturers were of curiosity or else of thoughtful reflection. One "family values" interest group responded that it was an interesting idea but doomed to defeat by the networks. The broadcast networks I mailed it to, ABC and NBC, gave standard "thanks for your letter and we’re sorry we don’t have time to respond to it personally" responses. And from the Caucus for Producers, Writers, and Directors; the National Association of Broadcasters; the National Cable Television Association; the Advanced TV Systems Committee; and, incidentally, the Chief, Management Planning and Program Evaluation Office of the FCC, I received no response. Putting these pieces together that I got some considerate responses from those groups that this idea would not threaten commercially and either generic or no responses from those groups that might be so threatened, I took it as an indication that content producers and networks really didn’t like this idea. I enclose a copy of the most interesting response I received in which a Zenith executive argues directly that the networks would oppose this idea for commercial reasons.

In conclusion, I ask you to consider the benefits of enhancing the industry’s ratings system with the improvements I have suggested and to please consider the industry’s arguments with a great deal of skepticism, given their conflict of interest in implementing a system that is truly helpful to parents.

Sincerely,

Scott Langley