PTC to Ratings Boss: Fix the Broken TV Ratings System!

Dear Senator Dodd, During your impressive tenure in public office, you demonstrated a commitment to industry oversight built on responsibility, transparency and public accountability. It is in precisely this vein that I reach out to you today in your capacity as Chairman of the TV Parental Guidelines Monitoring Board, commonly referred to as TVOMB. We are nearing the twentieth anniversary of the age-based television content ratings system. During this period of time, numerous studies by the Parents Television Council (PTC) and others have pointed out the systemic failure of the television ratings to accurately and consistently warn parents about harmful, explicit and age-inappropriate program content. In short, the television ratings system, which was ostensibly intended to accurately inform parents about the content of television programming and aid them in limiting their children’s exposure to harmful media content, has failed to live up to its promise. Even worse, the very people creating or distributing potentially harmful media content have been given not only sole discretion over the application of those ratings, but they’ve been handed oversight authority to determine whether ratings are being correctly applied. As a result, the ratings have done little more than serve as cover, allowing those who wish to inject edgier and more explicit content into primetime programming, to do so with impunity. Rather than helping parents to protect their children from harmful and explicit programming, the system has effectively protected the television industry from public or regulatory scrutiny. The PTC and other organizations have tried repeatedly over the years to point out the myriad ways the television content ratings system has failed parents. We have raised these issues with the networks, with the FCC, and with members of TVOMB directly. In the nearly two years that have transpired since I met with and presented in person to TVOMB, there have been little but superficial efforts to address systemic issues I raised. Simply put, I seek your immediate attention to reform the system so as to ensure its accuracy, consistency, transparency and public accountability. It is currently none of these four things, and it is failing those whom it was created to serve: Parents. Here are but a few of the many flaws we believe need to be addressed in a public forum:

1. The content ratings system as currently constituted is deeply flawed because the power to determine content ratings is assigned to the very same networks where the content originates. (Unlike motion pictures and video games, there is no independent evaluation of the age-based rating system for television.) This has created an inherent and unavoidable conflict of interest: It is to a network’s financial advantage to misrate explicit programming as appropriate for children so as to gain a larger viewing audience; and because a majority of corporate advertisers choose not to advertise on television programming that is rated for Mature Audiences Only (TV-MA), every broadcast television series is rated as appropriate for children aged fourteen or younger.
2. An incorrect content rating renders the V-chip worthless. If a parent programs their television’s V-chip to block programs rated as appropriate for “Mature Audiences Only,” their child will still be exposed to graphic and explicit material. Whether accidental or intentional, there are no broadcast television series rated TV-MA; and networks will rate explicit content as appropriate for fourteen year-old children despite the presence of content that would fit the TV-MA definition. Other programs with adult content are even rated as young as TV-PG.
3. The TV Parental Guidelines Monitoring Board has enabled and sheltered this flawed content ratings system, rather than following its Congressional and FCC mandate to ensure the accuracy and integrity of the system:

• The Monitoring Board is not accountable to anyone outside its own membership, nor is it transparent to the parents it supposedly serves. Most Americans don’t even know the Monitoring Board exists. They don’t know that the Monitoring Board is in charge of the ratings system, or how to contact its members.
• Parents have never been told the names of those who sit on the TV Parental Guidelines Monitoring Board; why they are qualified to sit on Board; how they are appointed; when or where Board meets; how they determine what content ratings TV programs ought to have; or how they respond to complaints from parents and other citizens.
• The public is not allowed to attend Monitoring Board meetings. Despite my request for their participation, representatives from the FCC and members of the press were expressly prohibited from attending the meeting where I presented my concerns. There is no transparency beyond the Board members.
• The Monitoring Board is comprised of the very same network executives who routinely rate programming inaccurately. The FCC Report and Order establishing TVOMB stipulates a rotating chairman (currently you) and 23 other members, including six members each from the broadcast television industry, the cable industry, and the program production community. There are only five non-industry seats on the board of 23, despite the board’s express purpose being to serve the needs of parents; and based on the TVOMB website posting as of this writing, not all five of the non-industry seats are filled. One of the non-industry representatives is a lobbyist hired by the entertainment industry. And of those five non-industry seats on the Monitoring Board, all are appointed by the Board chairman, who of course is an industry representative.

Under your regulatory purview in the Senate, you would never stand for a system of “industry oversight” that was so inherently poised for malfeasance. Over the years, the entertainment industry has fought to keep the power to decide what is shown in every living room; but they have consistently chosen to shield the status quo, rather than actively pursue improvements or reform, as the original FCC Report and Order establishing the Monitoring Board required. Senator Dodd, when Americans venture into the supermarket to purchase food products, we frequently look at the back of the box to peruse the contents and nutritional value of what we intend to ingest. We rely on that information to be correct; and if it is incorrect, there are health consequences to the consumer. So, too, should parents be able to rely on a television content ratings system to be accurate, so they understand what their children will be ingesting. In order for parents to have a chance at protecting their children from graphic violence, explicit sexual content and harsh pornography, they need a content ratings system that adequately warns them of the content beaming into their homes. And if the entertainment industry is going to honor its commitment to providing effective tools to families, the TV ratings system must be accurate and consistent, and the ratings process must be transparent and accountable to the public – especially to the parents for whom the system was created. I respectfully but urgently call on you in your capacity as chairman of TVOMB to address in a public forum the aforementioned concerns, as well as the concerns of other informed individuals and organizations; and to implement wholesale and systemic change to the television content ratings system and the Monitoring Board so that it serves the needs of parents and families, rather than the interests of the television industry. Sincerely, Tim Winter President Parents Television Council