Submissions

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

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

Local and Digital Content Development Strategy for South Africa

This submission addresses the following areas:
1. MMA’s Constitutional Assumptions.
2. The relationship with the MMA and the Save our SABC (SOS)-Reclaiming our Public Broadcaster Coalition.
3. Areas of concern relating to the Local and Digital Development Strategy.
4. Summary of recommendations

Draft Digital Terrestrial Television (DTT) Regulations Submission

This submission addresses the following areas:
1. MMA’s Constitutional Assumptions.
2. The relationship with the MMA and the Save our SABC (SOS)-Reclaiming our Public Broadcaster Coalition.
3. MMA’s basic assumptions of digitalisation.
4. Areas of concern relating to the draft regulations.
5. Summary of recommendations.
6. Conclusion.

Public Service Broadcasting: Repositioning for National Development Discussion Paper submission

Media Monitoring Africa (MMA, formerly the Media Monitoring Project) welcomes the opportunity to make a submission to the Department of Communications (DOC) on the Public Service Broadcasting: Repositioning Broadcasting for National Development Discussion Paper- July 2009.

Submission to ICASA on the Digital Terrestrial Television (DTT) Regulations

Media Monitoring Africa (MMA, formerly the Media Monitoring Project) made a submission to the Independent Communications Authority of South Africa (ICASA) on the Digital Terrestrial Television (DTT) Regulations.

The submission addressed the following:

1. MMA’s Constitutional Assumptions.
2. The relationship with the MMA and the Save our SABC (SOS) – Reclaiming our Public Broadcaster Coalition.
3. Areas of concern relating to the draft regulations.
4. Summary of recommendations.
5. Conclusion

Submission to ICASA on the Draft Broadcasting Digital Migration Framework Regulations

The Media Monitoring Project made a submission to the Independent Communications Authority of South Africa on the Draft Broadcasting Digital Migration Framework Regulations. In its submission MMP focuses on key goals, enshrined in the ICASA Act, for media diversity and fairness. 

Save our SABC Submission

MMP, together with other civil society organisations have formed a coalition in order to restoring the credibility, protecting the independence and promoting best practice principles of public broadcasting. View the submissions to the draft broadcast amendment bill.

ICASA submission on the proposed regulations under Section 69 of the Electronic Communications Act

The MMP made a submission to the Section 69 of the Electronic Communications Act to ensure that the Act continues to have human rights presented therein. MMP has made submissions on the original Code of Conduct for Broadcasters, as well as on the SABC’s editorial policies, where it is worth noting that some of MMP’s recommendations were included in the final editorial code currently in operation.

FPB Presentation to Parliament

William Bird, director of MMP presented the MMP submission to the Films and Publications Bill to Parliament on 2 May 2007.

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