THE MULTILINGUALISM ACTION GROUP

MAG has 44 members, among which are representatives of the following organisations:

MAG enjoys the patronage of:

B. Introduction

1. MAG welcomes the publication of the SABC’s “Draft Editorial Policies” and the opportunity to comment on them. Given our objectives as an organisation, we are particularly pleased to note that progress has been made with regard to the formulation of a new language policy for the SABC. The comments offered here relate especially to that aspect of the “Draft Editorial Policies”.

2. We endorse the basic thrust of the “The SABC’s Policy on Language” as included in the “Draft Editorial Policies”. We do so on the understanding 1) that our interpretation of the meaning and implications of the policy is correct, and 2) that the policy is only part of a process that will be completed with the publication of a “language action plan”.

   As far as the latter is concerned, the “Draft Editorial Policies” states (pp.33-34) that the language policy is to be complemented by a “language action plan” which would deal with issues of practical implementation. This is in accordance not only with the requirements of the Board, but also with promises made at the SABC Board’s Language Workshop held in November 2002 in Johannesburg.

   During the aforementioned workshop, which was attended by current members of MAG (and to which some of them made a contribution in the form of a written submission[3]), it was indicated that the Independent Communications Authority of South Africa (ICASA), in accordance with the Public Broadcasting Act (2002), required both a language policy and a language plan to be submitted for their approval during 2003. Importantly, participants at the workshop were given the assurance that an opportunity would be afforded to the public to comment on both these documents. Therefore we would like to stress the importance of publishing the proposed “language action plan” in time, and of making it available for public comment as has now been done with the language policy.

   As far as our interpretation of “The SABC’s Policy on Language” is concerned, we would like to highlight the following aspects:

1. We take the policy to imply that the SABC is committed to a substantial increase in programming in languages other than English in all programme genres and time slots, specifically during peak viewing time (“prime time”).

2. We take the Constitutional principles of “equity” and “equal respect” underlying the policy (p.26) to entail that the SABC does not have an “anchor language” , and that no language will be singled out for preferential treatment on any grounds whatsoever.

3. We assume that in applying the principles that “determine allocations of time to different languages” (p.30), decisions will not be based on widely held perceptions, which often conflict with reality, but rather on properly researched demographic data relating to the size of language groups, geographical spread of languages, levels of understanding between languages, etc.

3. We specifically welcome the following elements in the policy, which are in agreement with proposals conveyed to the SABC in past submissions by individuals and organisations currently associated with MAG: [4]

1. The commitment not only to provide programming in all the official languages, but specifically “to provide a range of distinctive, creative and top quality programmes … in each of the official languages” (pp.26, 31, emphasis added).[5]

2. The undertaking “to integrate Sign Language into broadcasting” and “to include other non-official languages spoken in South Africa, with particular emphasis on the Khoi, Nama and San languages” (p.26).[6]

3. The intention to “use … groupings such as cognate, shared and widely understood languages so as to make cost effective use of limited resources” (p.28).[7]

4. The “application of appropriate technologies [including subtitling, dubbing, simulcast and transmitter separation] to achieve language coverage and access goals” (p.28), and the commitment to undertake “relevant research into the creative use of technologies to facilitate implementation” (p.33).[8]

5. The commitment to “development of mutually beneficial relationships with key social partners, notably the Pan South African Language Board” (p.28) and “collaboration with other organisations” (p.33).[9]

C. Comments on the “Draft Editorial Policies”

1. The Introduction to “The SABC’s Policy on Language” (p.26) mentions “the … duty to treat all the official languages equitably, and with equal respect”, “the need to promote South African Sign Language and the ‘Khoi, Nama and San languages’”, and “commitment to freedom of expression …, including the right to receive and impart information” as obligations deriving from the Constitution.

   To this should be added 1) the constitutional prohibition on unfair discrimination, specifically on grounds of language, and 2) the obligation of the state to take measures to enhance the use and status of previously marginalised languages.

   The phrase “the need to promote” (with reference to certain non-official languages) should be replaced with “the obligation to promote”, in accordance with the provisions of the Constitution in this regard.

2. In the “Statement of Commitment” (p.26) it is stated: “We provide a range of distinctive, creative and top quality programmes in all official languages …” (emphasis added).

   The implications of this formulation are not sufficiently clear: “all official languages” should be replaced with “every official language”. A guaranteed minimum programme content per week in every programme genre, calculated according to the criteria for equitable allocation listed in the draft policy (see p.30), and discussed elsewhere in the present submission, should be stipulated for each language, including the non-official languages.

3. The “Statement of Commitment” further reads (p.26): “We integrate South African Sign Language into broadcasting as a means of making programming accessible to people with hearing disabilities.”

   The reference to “hearing disabilities” places the issue of Sign Language exclusively within the framework of a remedial perspective: Sign Language as a means of compensating for a disability. This perspective does not account for the fact that many Sign Language users (including some whose mother tongue is a Sign Language) do not have hearing disabilities, and that South African Sign Language is in the first place a language spoken by a particular community: Neither the language nor the community is ultimately defined by “hearing disabilities”; rather, the language defines the community, and vice versa. The issue of Sign Language should therefore also be considered within a socio-cultural perspective. This should be reflected in the formulation by adding to the existing text the clause: “…, and to serve the needs of the South African Sign Language community”.

   One implication of the socio-cultural perspective on Sign Language is that the use of subtitles (even for the literate minority among the deaf who can read them) cannot compensate for a limited use of Sign Language in broadcasting, just as (say) Tshivenda subtitles to an isiZulu programme cannot compensate for a limited use of Sesotho on television, even though some Sesotho speakers can read Tshivenda. After all, as a language defining and defined by a community, South African Sign Language — like Sesotho — is more than a mere instrument of facilitating communication. It is also “the carrier of values, attitudes, culture and expression” (p.27) for the South African Sign Language community.

   A further implication is that the South African Sign Language community have a “double claim” to the provision of programming in their language, namely, 1) on grounds of disability, and 2) on grounds of the general linguistic and cultural rights protected by the Constitution. This makes it all the more urgent to specify that “a range of distinctive, creative and top quality programmes” will be provided in South African Sign Language, and not only that South African Sign Language will be “integrated”.

4. The “Statement of Commitment” continues (p.26): “We strive to include other non-official languages spoken in South Africa, with particular emphasis on the Khoi, Nama and San languages.”

   Here, the phrase “strive to” should be deleted so that the sentence reads: “We include … [etc.]” As pointed out above, the public broadcaster has a constitutional obligation to promote the languages in question.

   Furthermore, while the emphasis on “Khoi, Nama and San languages” is in accordance with the Constitution and should be retained, Indian languages like Hindi, Gujarati, Tamil and Urdu should also be specifically included in the policy as broadcasting languages, so as to avoid exclusion of, or unfair discrimination against, the South African Indian community.

   The use (specifically on television) of South African Sign Language, Khoi, Nama and San languages, and Indian languages in “a range of distinctive, creative and top quality programmes” is imperative, not only for the sake of the communities whose home languages they are, but also for the sake of other South Africans, who need to be exposed more regularly to all these languages for the sake of nation building and in order to gain greater access to our whole cultural heritage.

5. Under “Operating Principles” (p.28) it is stated that use will be made of “cognate, shared and widely understood languages”. The principle of language grouping is a sound one, but it should be made clear in the policy what this principle does not entail.

   Firstly, the recognition that certain pairs or groups of languages are “cognate” or “shared” should not be allowed to detract from the SABC’s commitment to provide “a range of distinctive, creative and top quality programmes” in every official language. I.e. the needs of a particular language community are not met adequately by providing programming in a language other than their home language even if many or most of them understand the language in question. After all, the draft policy explicitly — and correctly — rejects an instrumental view of language when it states under “Statement of Commitment” that language is a “carrier of values, attitudes, culture and expression”. Languages, be they “cognate” or “shared” or not, are not interchangeable. (This also applies to the relationship between South African Sign Language and the spoken languages understood by its speakers.) Furthermore, no two languages are “cognate” or “shared” to the extent that all speakers of the one understand the other, and among those who do, levels of understanding vary greatly. Moreover, surveys have consistently shown that viewers and listeners prefer programming in their home language.

   Secondly, the above considerations apply equally to “widely understood languages” like Afrikaans, English and isiZulu. The fact that some languages are “widely understood” should not serve as a pretext for failing to provide a range of programme genres in every official language. To this should be added the consideration that no language is (well) understood by a majority of South Africans. A survey by the Pan South African Language Board PanSALB found that only 40% of South Africans in general, and 22% of African language users, are functionally proficient in English. [10] (A similar picture applies to Afrikaans and isiZulu.) The same study found that large numbers of South Africans are monolingual, i.e. they understand only their home language. It follows that programming in “widely understood languages” would still be inaccessible to a large number of South Africans.

   The fact that some languages rather than others are “widely understood” is a reflection of unequal power relations inherited from the past. While cognisance should be taken of this fact, it should not be done in such a way as to entrench asymmetrical power relations. Rather, all South Africans should increasingly be exposed to the less widely understood languages, so that, in due time, they may become more “widely understood”.

   Therefore, it should be clearly stated in the policy that the “use of groupings … and widely understood languages” may not stand in the way of progressively increasing the amount and range of programming in every official language.

6. “Coverage of events of national importance to promote the development of national identity, unity and nation building” is also mentioned under “Operating Principles” (p.28).

   The National Language Policy (2002) of the Department of Arts and Culture determines that government departments must publish all documents that are of national interest, such as laws and the proceedings of the National Assembly, in the 11 official languages, and that all other documentation should be in at least the 6 main language groups (Nguni, Sotho, Afrikaans, English, Tshivenda and Xitsonga). Similarly, the public broadcaster should commit itself to covering “events of national importance” in as many official languages as possible, at the very least in the 6 main language groups. A policy of using a particular language, e.g. English, to cover all “important events” should be avoided and explicitly proscribed.

7. The “Operating Principles” (p.28) include “Development of mutually beneficial relationships with key social partners, notably the Pan South African Language Board”. This principle is welcomed. Procedures that spell out clearly the role of PanSALB in the SABC’s programming policy should be stipulated in order to increase the powers of PanSALB vis-ΰ-vis public broadcasting so that this body is enabled to play its role more effectively. This role would be particularly important with regard to the “language action plan” that is envisaged as a follow-up to the language policy.

   Other “key social partners” are cultural organisations, language practitioners, media and language interest groups, etc. The policy should commit the SABC to consultation with civil society on the issue of language policy. This should not be a once-off obligation, but a regular part of the monitoring of language policy once a policy and action plan have been decided upon.

   To “key social partners” should be added co-operation with other key players in the field of broadcasting, e.g. e.tv, M-Net, commercial radio stations and broadcasters in neighbouring countries, especially those that use South African or related languages.

8. An aspect not touched on in the section on “Radio” (p.28) is the use of untranslated sound bites, especially in news reports and interviews, in a language (usually English or Afrikaans) other than the language of the service in question.

   This practice is unacceptable and should be stopped because it disregards the fact, already mentioned earlier, that even “widely understood languages” are not understood by a majority of South Africans, and that many South Africans know no other language than their home language. The latter phenomenon occurs especially among the economically disadvantaged, including rural dwellers and the elderly, among whom are many for whom radio is the only accessible source of news and information.

   Making sound bites inaccessible to a large section of the language community for whom a particular radio service is specifically intended (by leaving them untranslated) detracts from the SABC’s commitment to “be sensitive to and reflect the needs and lifestyles of ... children, young people, urban and rural dwellers, and the elderly” (p.28). It disregards “the important part that news and information play in enabling all South Africans to participate effectively, and from an informed basis, in building our democracy, nation and economy” (p.28, emphasis added). It restricts “meaningful access to information” (p.28) to the relatively privileged, and seems to imply that, for some, “only reporting on events” is sufficient, while “analysing issues of significance” (p.29) can be glossed over. As such, this practice discriminates against some listeners on the basis of language.

   Full use should rather be made of radio as “the most widely used and most accessible broadcasting medium in South Africa” (p.28) to give effect to everybody’s “right to receive information”, including all the information contained in news reports and interviews — i.e. to provide “comprehensive radio news and information programmes in all the official languages” (p.29, emphasis added) The use of voice-overs to translate sound bites in other languages does not require expensive technology and can easily rectify this unnecessary problem.

9. Under “Broadcasting Events of National Importance” (p.29) it is stated that “the SABC strives to ensure that all its language services cover them” (i.e. “events of national importance”). Given that “Coverage of these events gives South Africans access to important and relevant information about our developing nation”, it should be stipulated in the policy that such coverage will be provided in all the official languages, so that all listeners can benefit from it. (This should include translation of sound bites, live speeches, etc.)

   We recognise that “treating all the official languages equitably on television” (“Television”, p.29) will have to be achieved “across the television portfolio as a whole and not on each individual channel” (p.29). This also accords with the principle of language grouping (see p.28 of the draft policy).

   However, the logistical limitation pointed to here should not be unnecessarily exacerbated by reserving (almost) an entire channel for one language, or giving one language preferential treatment by using it on several or all channels (as is currently the practice with regard to English). I.e. the principle of “equity” should also extend to the manner in which channels are distributed among the different languages.

10. The last paragraph on p.29 (under “Television”) is not clearly formulated, and could be interpreted such that the principle of “equity” will not apply to the scheduling of programmes in different languages during “prime time” , but only to the programming schedule as a whole. We trust that this is not the meaning intended, and suggest that the paragraph be reformulated so as to make this clear. I.e. it should be specifically stipulated that “prime time” will be distributed equitably among the official languages, and that each language will be allocated a guaranteed minimum programme content per week during prime time.

11. The policy refers (under “Television”, p.30) to “The Constitutional requirement to treat all the official languages and cultures equitably”. Here, the phrase “and cultures” should be deleted, since no culture has, or could have, official status under the Constitution.

12. It is further stated (p.30) that “in meeting its mandate to provide television programmes in all the official languages, the SABC takes into account ... The comparatively little television air time available, especially during prime time, and the complexities that arise in allocating time equitably to all the languages”.

    It is not clear what “takes into account” means in this context. The limitations referred to (“little ... air time available” and “complexities ... in allocating time”) are real, but should not be allowed to serve as a pretext for accepting a less than equitable allocation of air time during prime time. Rather, “takes into account” should mean finding ways of making the most of the “air time available”, and overcoming the “complexities” of allocation. An equitable allocation would mean that all languages share the burden of limited air time inherent in broadcasting to a multilingual audience, i.e. no language should be exempt from this burden.

    Furthermore, and as a consequence of the foregoing, the problems of limited air time and complexity in air time allocation (specifically during prime time) should not be unnecessarily exacerbated by giving preferential treatment to any one language (as is currently the practice with regard to English).

13. The section “Guidelines for Equitable Treatment” (p.30) speaks of “complement[ing] our national television service by providing regional services as required by the Broadcasting Act”. In aiming to provide such regional services the SABC should not lose sight of the fact that some of our official languages (e.g. Afrikaans, English and isiZulu) have a wide geographical spread, and that even the more geographically concentrated languages (e.g. Tshivenda and Xitsonga) occur outside the areas of concentration, albeit to a lesser degree. Account should also be taken of the fact that allocation of air time on the national service confers prestige on a language, and that such prestige should be conferred equitably in accordance with the Constitutional requirement of “equal respect”.

    Specifically, no official language (including South African Sign Language) should be carried exclusively on a regional channel.

    Nor should the regional channels be used to compensate for an inequitable allocation of air time on the national service, or to confer an air of legitimacy on the preferential treatment currently given to English on the national service. Rather, regional channels should be used to increase the “television air time available” for equitable allocation, and to overcome the “complexities” involved in such allocation.

14. The factors given “due regard” in “determining allocations of time to different languages” (“Guidelines for Equitable Treatment”, p.30) should be ranked in order of importance. “The number of home language speakers of a language” (p.30) should enjoy the highest priority. The other factors should be ranked in the order in which they are listed in the draft policy.

    The meaning of “Available resources” (p.30) is unclear. It should mean the resources available to the SABC, with the implication that those resources are to be allocated equitably. If it is meant to refer to the resources (skills, expertise etc.) available to a particular language community, this criterion should be left out of consideration, given the SABC’s obligation to develop the necessary resources for all languages where these are lacking. After all, such a lack of resources is itself a result of marginalisation, so that “equitable treatment” would require addressing it, rather than simply giving it “due regard”.

    In order to ensure that “these criteria are applied effectively” (p.30), proper scientific data relating to language demography should be obtained and used as a basis for air time allocation. Popular perceptions about “number of home language speakers”, “extent to which a language is understood”, etc. should be disregarded. The policy itself should give more detailed guidelines by providing tables indicating how the different languages are ranked at present according to each of the criteria mentioned. (These tables can be amended every 5 years when the policy comes up for review.)

    The criteria should determine the meaning of “equitable treatment”, not only for the allocation of air time in general, but also specifically for the allocation of prime time, air time on the national service, content in each programme genre (including children’s programmes), and channels on which a particular language is used.

    To avoid vagueness, which would result in rendering the criteria inapplicable in practice, a clear formula for applying the criteria should be provided in the envisaged “language action plan” (“Monitoring and Implementation”, p.33). This formula should result in a guaranteed minimum programme content per week during prime time for each official language. The policy should state this explicitly as one of the tasks of the “language action plan”.

15. The draft policy states (“Television Programming”, p.31) that “The SABC strives to ensure that programmes in specific languages are broadcast at times when most of the members of the target audience in that language community are available.” The rationale behind this statement is unclear.

    We take it to mean that programmes in a particular language for children, young people, working people etc. will be aired at times when those viewers are available, and that all languages will be served during prime time when most members of all language communities are available. The latter implication should be spelt out in the policy.

16. Under “Children’s Programmes” (p.32) it is stated that “Children require informative, educational and entertaining programming of excellent quality, in their home languages”, and that the SABC “strives to ensure” this. Here, the term “strives” should be replaced with “undertakes”, i.e. the SABC should commit itself unconditionally to meeting the needs of children in this regard.

    Equitable allocation of air time should extend, not only to air time in general, prime time and time on the national service, but also to the allocation of time for children’s programmes (as to all other programme genres). Each language should be allocated a guaranteed minimum children’s programme content per week, calculated according to the criteria for equitable allocation listed in the policy (see p.30) and discussed elsewhere in the present submission.

    The SABC has a vital role to play in complementing the education that children receive at school. In this regard, programmes that are meant to assist school-going children in mastering the contents of the school curriculum are to be welcomed. However, it is of the utmost importance that such programmes be broadcast in all the official languages as well as South African Sign Language (and, as far as possible, the Khoi, Nama and San languages and Indian languages). Given the importance of this part of the SABC’s broadcasting portfolio to our country’s future, this is one area in which the principle of “equal allocation” can and should be substituted for the principle of “equitable allocation”, which is otherwise applicable.

    In educational circles it is common wisdom that the use of home languages as languages of learning and teaching is a prerequisite of “excellent quality” (p.32) education. This applies not only to “many children, particularly preschool children” who “understand only their home language” (p.32), but to all learners. For this reason, the Language in Education Policy (1997) of the Ministry of Education specifically encourages “mother tongue education” up to the highest level possible, and the SABC should co-operate with the Ministry in this regard, especially since on television mother-tongue education can be implemented immediately, thereby stimulating and supporting its implementation in schools over the longer term.

    Offering educational programmes in all languages can be easily and cost-effectively achieved by making use of dubbing, multiple soundtracks and (to a lesser extent) subtitling. The same applies to other children’s programmes.

17. In connection with the use of “broadcasting technologies such as subtitling” (p.31), it should be specified that subtitles in all the official languages will be used.

    The current practice, where subtitles are used only to translate from other languages into English, is unacceptable, since it confers a special status on English and assumes wrongly that all or most viewers understand (and can read) English. As such, it has unacceptable practical and symbolic implications. Subtitling in languages other than English, particularly in the African languages, would make a significant contribution to increased levels of literacy in those languages. Subtitling also contributes to language learning and thus multilingualism. The regular use of subtitles would help create a “culture of subtitles”, as is common in many other countries, so that any initial resistance to its widespread use would reduce over time.

    Programming subtitled into a particular language should be counted as air time allocated to that language and as “local content” (pp.41ff.). (It could, however, be given a lower count-value in order to ensure that subtitles do not replace entirely the provision of programming with soundtracks in the 11 official languages). This would greatly assist the SABC in meeting its targets in terms of equitable allocation of air time to languages and provision of local content by optimally utilising the “little television air time available” and minimising the “complexities ... in allocating time”. It would also achieve the dual aim of providing regular time slots for each language, while still exposing all viewers to a variety of South African languages for the sake of nation building. The latter would be achieved by translating “unilingual productions” and “multilingual programmes” (p.30) into various languages by means of subtitles. I.e. the same programme can be made to count as air time allocated to more than one language.

18. “Multilingual Programmes” (p.31) should not be regarded as necessarily subtracting from the amount of air time available for programming in each official language. Use of subtitles (in all official languages) to translate multilingual programmes would enable the SABC to meet both objectives at once, as long as subtitles in a particular language is counted as air time allocated to that language.

    The “use of broadcasting technologies such as multiple soundtracks” (“Broadcasting Events of National Importance”, p.32) should not be limited to broadcasting events of national importance. Multiple soundtracks (e.g. utilising the FM radio service to carry a soundtrack in a different language) should also be used for other programme genres, such as drama, film or sports coverage. In the latter cases, programming could be dubbed into more than one language, or the original soundtrack of (say) a foreign film or drama can be carried on the radio, with a dubbed soundtrack being provided on television.

    Both dubbing and simulcast should therefore be reintroduced on a large scale. This could have financial advantages in that repeated use of productions acquired from abroad would be cheaper than in the case of untranslated productions. (In the past, foreign providers allowed the SABC to re-use acquired productions free of charge provided that those productions were dubbed into a local language. French productions have also recently been offered at a reduced charge and with permission to dub.) It would, furthermore, enable the SABC to use foreign programming in languages other than English, thereby broadening the horizons of its viewers.

    As in the case of subtitles, programming dubbed into a particular language should be counted as air time allocated to that language and as “local content” (pp.41ff.). (It could, however, be given a lower “count value” in order to ensure that dubbing does not replace entirely the provision of programming with original soundtracks in the 11 official languages and locally produced programmes). This would greatly assist the SABC in meeting its targets in terms of equitable allocation of air time and provision of local content by optimally utilising the “little television air time available” and minimising the “complexities ... in allocating time”.

    Multiple soundtracks can also be used to make the same programme count as air time allocated to more than one language.

19. We welcome the fact that the SABC “commits itself to undertaking relevant research into the creative use of technologies to facilitate implementation of its mandate” (“Technology”, p.33). We suggest that the SABC give serious consideration to specific proposals that have been put forward in this regard by civil society formations in past submissions, [11] some of which are also put forward in the present submission (see especially section E in the present submission). We believe that the necessary technologies are available to make multilingual broadcasting in the fullest sense of the word eminently feasible.

20. It has already been pointed out that, as far as “Relationships with Other Organisations” (p.33) are concerned, the SABC should also establish “mutually beneficial relationships” (p.33) with civil society formations concerned with language and broadcasting, and with other role players in broadcasting such as eTV, M-Net, independent radio stations and broadcasters in neighbouring countries. At the SABC Board Language Workshop held in November 2002, both the Board and the Management of the SABC undertook to conduct similar workshops in the future with an eye to monitoring progress and sharing ideas on further increasing language diversity in broadcasting. The possibility of hosting such workshops in a different province each year was also raised, as was the idea of involving other media such as the print media. We would like to stress the importance of following up on this undertaking, and to offer our assistance in arranging such an event in the Western Cape.

    Under “Monitoring and Implementation” (p.33), mention is made of the “language action plan” that is to be submitted annually to the SABC Board and (in summary form) to Parliament. At the SABC Board Language Workshop held in November 2002, the representative of ICASA indicated that the SABC had to develop a new language policy and language plan, and that both these documents would have to be made available for public comment. Therefore we would like to stress the importance of making a draft “language action plan” available for public comment once it has been developed, as has now been done with the “Draft Editorial Policies”. Thereafter, the annual “language action plan” should also be discussed with civil society formations and other role players in broadcasting in annual language workshops as part of the monitoring process, and in order to harvest ideas on future progress.

    Apart from “achievements, opportunities and challenges” and “future goals” (p.33), the “language action plan” should contain those elements referred to by the ICASA representative during the 2002 SABC Board Language Workshop, namely, a detailed implementation plan with clear targets and time-frames, which should include a guaranteed minimum programme content per week during prime time for each official language.

D. Aspects not Touched on in the “Draft Editorial Policies”

1. An important issue not touched on in the “Draft Editorial Policies” is the issue of a so-called “anchor language”.

   In terms of its mandate and the Constitution, and given the commitment to “equal respect” and “equitable treatment” expressed in the “Draft Editorial Policies”, the SABC, in broadcasting to the public, does not require, and in fact should not have, an “anchor language”. For the purpose of entertainment, information and education, and as far as the SABC’s functions and obligations are concerned, South Africa has 11 “anchor languages”.

   Therefore the policy should state explicitly that the SABC does not have an “anchor language” .

2. Some important implications follow from the previous point:

1. Continuity presentation (announcements of programmes etc.) should not be in English only (or mainly), but in all official languages. Using English to announce programmes in other languages, or to make general announcements during time slots allocated to other languages, conveys the mistaken assumption that all (or most) South Africans understand English.

2. The same applies to the exclusive use of English in subtitles. It conveys the notion that English-speaking viewers constitute the main target audience of the SABC.

3. At present, the majority (±70%) of broadcasts on all channels are in English (the 5th largest home language in the country). This amounts to grossly unfair preferential treatment for English, limits the amount of “air time available” to other languages, and unnecessarily increases the “complexities” involved in allocating air time on an equitable basis. The policy should state unambiguously that the amount of television air time currently allocated to English, particularly during prime time, will be significantly reduced so as to make more air time available to other languages.

4. Almost an entire channel is currently allocated to English, in addition to its being allocated air time on the other channels. The unacceptable symbolic implications of this practice are exacerbated by the common reference to this channel as the SABC’s “flagship”. English should be treated like the other languages by letting it share a channel with another language, e.g. Afrikaans or the Nguni languages.

5. The practice of using English (and sometimes Afrikaans) content untranslated in non-English (and non-Afrikaans) news broadcasts and other programmes, on both radio and television, is unacceptable and should be stopped.

6. At present, the SABC has a predominantly English “face”, shown by its presenters and programme hosts who function as public role models, especially for the youth, and are in the main either English speaking or highly proficient in English, unlike the majority of South Africans. This feature of television broadcasting gives the SABC an elitist image, and fails to reflect the many faces of South Africa. When the indigenous languages are occasionally used for continuity presentation, the standard of the language used often leaves much to be desired. This shows disrespect towards our indigenous languages and to home language speakers of those languages. Steps should be taken to employ presenters and programme hosts who are fully proficient in South Africa’s indigenous languages.

3. The draft policy does not adequately address the tension often perceived between the obligations of a public broadcaster on the one hand and the need for commercial viability on the other, as it relates to language policy. We believe that language is one area in which these two sets of objectives can be successfully reconciled.

   Surveys have repeatedly shown that South African viewers, like viewers all over the world, prefer programming in their home languages. Some of the most popular television programmes are in the indigenous languages. However, advertisers seem not have taken cognisance of these facts. Afrikaans and English programmes still raise the most advertising revenue. This has occasionally been advanced as an argument for not increasing the amount of programming in other languages. In our view, the SABC should rather strive to develop markets for advertisers in the other languages, given the vast commercial potential of those languages.

   This could be done in several ways:

1. Afrikaans is a special case, since while it raises much advertising revenue, it is nevertheless not allotted its fair share of the available air time (although, in comparison to most of the African languages, it is still relatively privileged in terms of the allotted air time). An increase in the air time allotted to Afrikaans relative to English would not affect the SABC’s advertising revenue negatively, and could in fact significantly raise the amount of advertising revenue earned. This would not benefit Afrikaans only, since some of the revenue thus earned could be used to cross-subsidise programming in other indigenous languages. (Some of the revenue earned with English programming should be used for the same purpose.)

2. Apart from the possibility of cross-subsidisation between languages, the SABC should offer incentives to prospective advertisers for advertising in and to the African languages. One such incentive could be more favourable rates for such advertising, especially during prime time. In this way, a market for advertising in and to those languages could be developed. As advertisers reap the benefits of such advertising, the demand for advertising air time in and to the African languages would rise so that rates could then be gradually increased.

3. The SABC should also consider setting maximum quotas for advertising in each official language. Advertising air time on television, especially during prime time, is a much sought-after commodity, and it is unlikely that such measures would scare off potential advertisers. Rather, we expect that advertisers would adapt to the new demands in order to continue to advertise on television.

4. Finally, a substantial increase in the amount of air time allocated to languages other than English could be seen as a lucrative long term investment on the part of the SABC, since new markets for advertising would be created in this way. A precondition for the success of such an investment is that every language/language group should have a clear air time window on (a) particular channel(s) so that potential advertisers can aim their advertising at specific target audiences.

   Therefore, we believe that more language diversity on television could be achieved, not “in spite of financial constraints”, but as a means of making the SABC more viable commercially in the medium to long term.

E. Practical Suggestions

In what follows, we offer some concrete proposals with a view to the envisaged “language action plan“ in a spirit of constructive co-operation, and in order to help give practical effect to the SABC’s language policy:

1. As regards the grouping of cognate and shared languages, we propose that the four largest languages/language groups — in terms of number of home language speakers, geographical distribution, and being widely understood — be used as the basis for an equitable allocation of air time on the SABC’s television channels:

1. Nguni languages (isiZulu, isiXhosa, SiSwati, SiNdebele)
   
2. Sotho languages (Sepedi, Sesotho, Setswana)
   
3. Afrikaans
   
4. English.

   This means that smaller and more geographically concentrated languages, like Xitsonga and Tshivenda, would require special consideration as not being included in any of the four main groups, as would non-official languages like the Khoi, Nama and San languages and Indian languages, and that South African Sign Language would be spread across all four groups.

2. Cognate and shared languages could be grouped together to share the same television channel, especially during prime time. This could mean, for instance, that:

1. the Nguni languages share a channel;
   
2. the Sotho languages share a channel; and
   
3. Afrikaans and English share a channel.
   
4. Xitsonga and Tshivenda, the Khoi, Nama and San Languages, and South African Sign Language are spread across all three channels in clearly demarcated time slots, in addition to being accommodated on the regional channels.

   (This would reflect the true language demography of South Africa, with the Nguni and Sotho languages spoken by a large majority, and therefore entitled to the lion’s share of the available air time. It would also give wider exposure to the smaller and non-cognate official and non-official languages.)

   Alternatively, some such grouping as the following could be considered:

1. One channel for the Nguni languages and English
   
2. One channel for the Sotho languages and Afrikaans
   
3. One channel for Tshivenda, Xitsonga, the Khoi, Nama and San languages, and Indian languages.

   (This would have the advantage of exposing more Afrikaans and English-speaking South Africans to African languages, and vice versa. It would also make easier the provision of a fixed window on a particular channel for each of the smaller and non-cognate official and non-official languages.)

   It should be pointed out once again that the grouping of cognate and shared languages on the same channel need not exclude the provision of multilingual programmes and monolingual programming in other languages on that channel, as long as subtitling, dubbing and multiple soundtracks are employed to translate such programmes into the designated languages of the channel in question.

   The precise grouping of languages is of secondary importance. However, we offer the above proposals in the knowledge that the question of language grouping has repercussions for viewer loyalty and for the SABC’s advertising revenue.

   Our primary concern is that each language be given a fixed air time window on (a) particular channel(s). Channels and time slots that are likely to raise more advertising revenue in the short term (specifically English and Afrikaans) could be used to support and develop other channels and time slots by means of cross-subsidisation. However, the SABC should also consider creating a market for advertising in and to languages other than English and Afrikaans by offering favourable rates and other incentives for advertising in and to those languages.

3. A fixed broadcasting window during prime time should be created for each language as a means of ensuring a guaranteed minimum programme content per week during prime time for each language. Only thus can viewers’ preferences be properly accommodated, viewer loyalty enhanced, and markets for advertising in and to all the languages developed.

   A block-shared approach should be used for languages/language groups sharing the same channel. This could mean, for example, that one language/language group is accommodated in the late afternoon/early evening slot for 3 days per week, and the alternative language/language group (for the same channel) in the late evening slot on the same 3 days, and vice versa on the other 3 days of the week. The 7th day (which presumably would be Sunday) could have a mixed scheduling approach, with special emphasis on multilingual programming.

   Viewers should know beforehand what language programmes to expect during any specific time slot, and on which channel(s). Naturally, continuity presentation (announcements of programmes etc.) in a particular air time window should be made in the language to which that time slot is allocated.

4. A minimum guaranteed programme content per week during prime time should be allocated to each of the languages/language groups. Given the availability of 3 TV channels (to be expanded with 2 regional channels in the future), it is possible to have as many as 30 hours per week in each of the four largest languages/language groups during prime time.

   This amount of air time can be further maximised by using subtitles, dubbing, multiple soundtracks and Sign Language interpreting in order to serve more than one language in the same time slot. (E.g. a programme in Tshivenda, broadcast with isiZulu subtitles or simulcast in isiZulu in an isiZulu window, would count as air time allocated to both Tshivenda and isiZulu. Similarly, a multilingual programme subtitled or simulcast in Afrikaans and interpreted in South African Sign Language would count as being allocated to both Afrikaans and South African Sign language.)

   It is proposed that in the short term (to be attained within 1 year) the SABC should endeavour to guarantee (say) a minimum of 20 hours per week during prime time in each of the four largest languages/language groups (at present this would mean increasing the amount of programming in the Sotho languages and Afrikaans), and to increase this amount of air time progressively each year. Eventually, a realistic goal of a minimum of 30 hours per week could be striven for in the long term (five years’ time). The languages not thus catered for, which receive little or no coverage at the moment, should also be guaranteed a minimum in the short term of (say) 2 hours per week.

5. As pointed out earlier, all the available technological capabilities to cater for a multilingual society should be exploited to the full in order to achieve the above guaranteed minimum programme content for each of the languages/language groups. These include subtitles, dubbing, simulcast and transmitter separation.

1. Subtitles: Of these, subtitling is the cheapest method, although a culture of subtitles (which is hardly used at present by the SABC, except to cater for the needs of English speakers) would have to be established by the SABC. In countries like the Netherlands and Israel, subtitles in a different language are used extensively to cater for multilingual needs. The use of subtitles, especially in the African languages, could contribute significantly to the development of literacy and language learning among South African viewers.

2. Dubbing: Dubbing is normally preferred over subtitles by the majority of viewers. However, this could change in future as a culture of subtitling is increasingly established and literacy levels progressively raised (inter alia through the increased use of subtitles in all the official languages). While dubbing is more expensive than subtitling, these costs should not be overestimated. The financial advantages, e.g. in terms of lower costs for re-using foreign acquired productions when these are dubbed, should also be taken into account. Importantly, the development of skills and infrastructure in this area should be seen as a golden opportunity for job creation.

3. Simulcast: Simulcast (the use of multiple sound channels for the same video feed) is especially suitable for sports commentaries (but could also be used for other programme genres, like dubbed dramas and films), and could utilise the FM network for alternative simultaneous sound channels.

4. Transmitter separation: Transmitter separation (regional broadcasts) should take into consideration the language demography of South Africa and the fact that a number of official and non-official indigenous languages are highly concentrated geographically. It could be used to increase the amount of air time allocated to those languages. However, broadcasts on regional channels should not be used to compensate for a less than equitable allocation of air time on the national service.

5. Voice-overs: Voice-overs can be used on both radio and television to translate sound bites in languages other than the designated language(s) on a particular channel, e.g. in news broadcasts and interviews.

6. Within the guaranteed minimum for each language/language group, an acceptable spread of programme categories (genres) should be covered for each language/language group. This should also be specified in the “language action plan” in terms of a guaranteed minimum per week, for example:
   

   
   
   
   

   Programme genre Variety Music Religion Children Adult drama Youth drama/magazine Magazine News Actuality Educational

   Minimum hours per week 1 1 1 3 2 0,5 1 2 2 2.

   
   The present trend in television broadcasting world-wide is towards low-cost, custom-made, community-directed programmes.

   It is far more preferable to enjoy a low-cost discussion programme, using 2 television cameras and a small studio, televised in a marginalised language broadcast in the region where the language is predominant, than to have to tune in to a high-cost programme in another language that is not (well) understood.

7. In order to help achieve the above objectives, we suggest that subtitles, dubbing and additional soundtracks (with simulcast) in a particular language be counted as air time allocated to that language, and as local content (possibly with a lower count value than programmes with an original soundtrack in that language), at least for the time being, until such time that sufficient local programmes in the indigenous languages are available. This would have the additional advantage of making the provision of international content in languages other than English possible, thereby broadening the horizons of South African viewers.

F. Concluding Remarks

1. The Multilingualism Action Group (MAG) is of the opinion that the SABC and other role players have the infrastructure and capabilities to provide our society with a broadcasting service that would satisfy the diverse needs and tastes of our language and cultural communities. All that is required is the determination to implement the language policy of the SABC, once it has been finalised, and to apply the knowledge gained from studies and surveys of the listening and viewing habits of the SABC’s target audiences since the introduction of television more than two decades ago.

2. Since 1996, the proposals put forward here have been submitted at several levels to the SABC, the previous Independent Broadcasting Authority (IBA) and the Parliamentary Portfolio Committee on Communication by individuals and organisations currently associated with MAG.[12] As in the case of the language issue at other levels of our society, solutions could easily be found in co-operation between the SABC, other media role players, and other key social partners, like PanSALB and various civil society formations.

3. Finally, we would like to reiterate our suggestion that the SABC hold regular (i.e. annual) workshops on how language diversity could be implemented more effectively with the existing infrastructure and on the available television channels (as undertaken at the SABC Board Language Workshop held in November 2002). In this way, continuity in the planning of language policy implementation can be ensured. The focus should be the monitoring of language policy implementation, and practical solutions for overcoming the obstacles encountered in this area. Such workshops could be constituted as an official committee or working group of the SABC. MAG, with its wide network and database of organisations working in the field of multilingualism, would like to offer its co-operation in the planning of such workshops.

Signed by:

Mr Mhlobo Jadezweni (Chairperson)

On behalf of the Multilingualism Action Group

Contact details: The Secretary, Multilingualism Action Group, 15 Herold Street, Stellenbosch 7600. Tel.: 021-8872713; Fax: 021-8872710; E-mail: MAG@linguasek.co.za.

[1] This document draws extensively on proposals contained in a submission authored by Profs J.B. du Toit and Christo Viljoen of Tabema and Dr Gerrit Brand and Mr Andre van der Walt of the Taalsekretariaat, entitled “Towards a Multilingual Public Broadcaster: Contribution of the Taalsekretariaat and Tabema to the SABC Board Language Workshop on 29 November 2002”, and available online at www.mweb.co.za/litnet/taaldebat/sabcboard.asp.
[2] The full text of MAG’s constitution is available online at www.mweb.co.za/litnet/taaldebat/multi.asp.
[3] See footnote 1.
[4] See ibid.
[5] In ibid. it was suggested that “Within the guaranteed minimum for each language/language group … an acceptable spread of programme categories (genres) should be covered for each language/language group.”
[6] In ibid. it was pointed out that “sub-titles do not really cater for the deaf, since the majority of the deaf in South Africa are illiterate, due to the special difficulties of learning to read a language other than sign language”, and that “other indigenous languages, like the Khoi and San languages, and Indian languages” should also be integrated.
[7] See ibid.: “The SABC should more consistently apply its own language principle of grouping cognate languages on the same channel. This is a universal principle underlying all user- and communication friendly public broadcasting.”
[8] See ibid.: “All the available technological capabilities to cater for a multilingual society should be exploited to the full in order to achieve the … guaranteed minimum programme content for each of the four languages/language groups. These include subtitles, dubbing, simulcast and transmitter separation.”
[9] Ibid. advises co-operation between “all relevant role players (SABC, M-Net, eTV etc.), the different language groups and cultural organisations and other civil society formations, like the trade unions, and … consultation with the Pan South African Language Board (PANSALB) and the Portfolio Committee on Communications as the constitutional and parliamentary bodies responsible for the promotion of multilingualism in public broadcasting.”
[10]10 PanSALB, Language Use and Language Interaction in South Africa: A National Sociolinguistic Survey (conducted by MarkData (Pty) Ltd on behalf of the Pan South African Language Board), Pretoria: PanSALB 2000.
[11] See e.g. footnote 1.
[12 See e.g. footnote 1.

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