Resources - Submissions

Submissions reflect Media Monitoring Africa's attempts to ensure that media policies and codes are in line with South Africa's constitution.

Category: Democracy and Governance [REMOVE]

MMA’s Submission in response to the ICT Green Paper 2014

MMA has responded to the Department of Communication’s call for submissions to the ICT Green Paper Policy, gazetted in January 2014. MMA welcomes this call and the opportunity for submissions.There has however been debate around the issues which are absent from the ICT Green Paper and whether there should be a call for the Green Paper to be completely reviewed and these issues addressed.

MMA oral submission on the Protection of State Information Bill

Media Monitoring Africa responded to a nomination by the National Council of Provinces’ (NCOP) ad hoc committee dealing with the Protection of State Information Bill (POSIB) to make an oral presentation on their submission. MMA welcomes much of the bill, but identified certain provisions of the bill which it views as problematic and suggests changes to seven sections of the bill to make it not only constitutional, but also to fulfill South Africa’s AU obligations.

Submission to the Press Freedom Commission: regulation of print media

Media Monitoring Africa responded to a call for submission by the Press Freedom Commission (PFC) (15 December 2011) on the Regulation of Print Media in South Africa.

MMA supports more independent self regulation. By definition self regulation refers to a peer review system operating within a set of self- imposed rules by the media. It consists of representatives from the media profession passing judgement of complicated matters of journalistic reporting using a Journalistic Code of Ethics which is applied in determining the final ruling , and benchmarking the generally accepted norms and standards.

Presentation to Communication Ministry’s Public Hearings on the Public Service Broadcasting Bill

Media Monitoring Africa raised concerns about elements of the draft Public Service Broadcasting Bill during the Communication Ministry’s public hearings.

MMA argues that the Bill in its current form will give the Minister too much power and won’t solve the problems dogging SABC.

Submission to Department of Communications (DOC) on the ICASA Amendment Bill

Media Monitoring Africa registers its concern over the relatively short time period for submissions. Given the importance and scope of the Bill, not just in terms of the issues it seeks to change but also that if implemented it would impact every person in South Africa, and given that there has not yet been a policy review process we believe the short period has prevented:

- Proper, broad-based meaningful consultation with members of the public
- In-depth debate and discussion on the various changes
- The development of clear alternatives to some of the issues provided.

The move by the Department of Communications to amend the policy governing ICASA is an exciting and invigorating moment for South Africa. It is of fundamental importance to ensure that all South Africans participate in shaping our “independent” regulator’s future. Especially given the history of its formation, and creation as critical to democracy and media independence. In addition, the role of “independent” regulation in this new digital era is critical to ensuring that all citizen’s needs are catered for, and not just a select few, with higher LSM’s for instance.

MMA response to the Public Broadcasting Bill

MMA submission on the Public Broadcasting Bill expresses deep concern about many of the aspects of the Bill, including its economic viability and constitutionality. The response requested more research into the viability of the Bill.

Key areas of concern addressed in the submission are:
- The funding model seems to be inadequate, and it is unclear whether sufficient research has been done on the feasibility and economic impact of the proposed change in funding.
- The Minister’s of Communications’ powers in the proposed Bill, which undermine the independence of the SABC itself, as well as the democratic role of Parliament.
- Legal issues, such as the need to amend several laws, such as the SABC charter changing, the mandate of the Media Diversity and Development Agency (MDDA) and aspects of the Constitution, and the.
- The lack of proper consultation, and far too limited time to do proper research by stakeholders; since the Bill is a complete overhaul of existing legislation, a two month period, over the December holidays, and lack of clear communication by the Department itself, does not constitute proper consultation

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