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Submission by the Multilingualism Action Group (i-MAG)
and Tabema[1]

to the Ministry of Communications
on the occasion of the

National Summit on “Broadcasting Content and Languages: Implications for Public Service, Community as well as Commercial Broadcasting”

on 25 and 26 November 2003 at the Kopanong Hotel, Benoni

Table of contents

Executive summary

Key issues and focus areas

  1. View expressed at the Provincial Mini-Summits

  2. Media and Democracy: Is the South African Broadcasting system
    reflecting South Africa’s Transformation?

  3. Special Role of Broadcasting in National Life

  4. Broadcasting and National Culture

  5. Broadcasting and Language: Ensuring that there is an equitable
    distribution of all South African official languages within the
    broadcasting system

  6. Funding Strategies to support and build public broadcasting

  7. Strategies to grow and develop the South African broadcasting
    production sector

Appendices A-F

“If you talk to a man in a language he understands, that goes to his head. If you talk to him in his language, that goes to his heart.”
    - Nelson Rolihlahla Mandela (i-MAG patron)

Executive summary

I-MAG and Tabema believe that more language diversity in broadcasting is key to “adequately serving South African needs”.

Increasing language diversity will enhance democracy and reflect South Africa’s transformation by strengthening the rule of law and enabling all South Africans to participate in public discourse. Furthermore, the composition of the SABC Board and the selection of presenters and programme hosts on television should broadly reflect the language demography of South Africa, and all stakeholders should be consulted when decisions on broadcasting are at stake.

The SABC’s role in national life is that of a Public Service Broadcaster. Consequently, the needs, interests and tastes of particular sections of society should not enjoy precedence over those of others, regardless of their relative buying power. Fulfilment of this role requires an equitable language dispensation on radio and television.

The SABC should contribute to the development of a national culture by reflecting the diversity that is so characteristic of our society and exposing South Africans to one another’s languages and cultural expressions.

In order to achieve an equitable distribution of all South African languages within the broadcasting system, a guaranteed minimum programme content per week during peak viewing time and in all programme genres should be allocated to each language/language group as part of the licence conditions of the SABC. An initial benchmark can be set in this regard, to be expanded over a specific period.

Languages should be grouped into cognate and shared languages, and a fixed airtime window should be provided for every language/language group.

All the available technological means, including subtitling, dubbing, simulcast, voice-overs and transmitter separation should be used for this purpose. Subtitles in all languages should be used, and programmes dubbed or subtitled into a particular language should be counted as programming in that language and as local content.

Transmitter separation should be used to serve regional needs, and it is proposed that one of the unused frequencies be utilised to provide additional programming in languages other than English.

Continuity presentation should be in all languages; the quality of language use, especially with regard to African languages, should receive attention; and English sound bites should not be used untranslated during programmes in other languages.

As far as funding strategies are concerned, the SABC is too dependent on advertising revenue. We propose a number of alternative funding models to replace the current system of TV licences, one of which is a levy on electricity consumption. In addition to such funding strategies, we propose ways in which, under the present system of funding, the disproportionate amount of airtime in English can be decreased without a dramatic loss in advertising revenue.

In order to grow and develop the South African broadcasting production sector, the SABC should consider the introduction of access television, whereby communities are given access to broadcast time for which they produce programmes themselves. Such access should be distributed equitably among the different languages, and should also make provision for multilingual programmes during particular time slots.

Key issues and focus areas

1. Views expressed at the Provincial Mini-Summits
Several members of the Multilingualism Action Group (i-MAG) were invited to attend the Provincial Mini-Summit at the Lord Charles Hotel in Somerset-West on 11 September 2003. I-MAG, together with one of its affiliates, Tabema, used that opportunity to present its views on the theme of the Mini-Summit as these views were developed in an earlier submission to the SABC Board on their “Draft Editorial Policies”[2]. The document that was prepared for this purpose was presented by the secretary of i-MAG, Dr Gerrit Brand, who addressed the Mini-Summit as one of the panel members,[3]. Proposals included in the document were also accepted by some of the discussion groups in which i-MAG members participated, and should be reflected in the report of the Mini-Summit.

I-MAG is of the opinion that language diversity in broadcasting is not only important for its own sake, but is also the key to “adequately serving South African needs” in many other areas as well, including culturally, in terms of differing personal tastes, and with regard to regional interests.

We recognise and appreciate the efforts made by the SABC to increase language diversity on radio and television. At the same time, we believe that the current situation is unacceptable, and that much more can be done with the technological infrastructure and resources already available to the SABC to serve the languages of South Africa on an equitable basis. In addition to this, we put forward concrete proposals for making our Public Service Broadcaster less dependent on advertising revenue, and suggest certain policy/legislative measures that could help to make an equitable language dispensation even more feasible.

2. Media and democracy: Is the South African broadcasting system reflecting South Africa’s transformation?
I-MAG recently took the position that “a multilingual country with a monolingual government cannot be called a democracy.”[4] In our view this applies not only to government structures, but also to public institutions in general, and to the SABC as a Public Service Broadcaster in particular. Our reasons for taking this position are inter alia the following:

2.1 We believe that equitable treatment of all South Africa’s languages will contribute significantly to deepening democracy and increasing the pace of transformation. After all, since this is what the Constitution, the SABC’s mandate and its own language policy dictate, it is an important aspect of strengthening the rule of law, an essential part of any democratic order. Moreover, democracy involves participation, and such participation by all sectors of our society depends on the extent to which they have access to public information, and can follow and participate in public dialogue and debate. To the extent that our Public Service Broadcaster does not yet grant “parity of esteem” and “equitable treatment” (Article 6 of the Constitution) to all our languages, it is not yet fulfilling its responsibility with regard to the strengthening of democracy, a vital aspect of our transformation.

2.2 Part of the transformation needed in South Africa is that public institutions should become more representative of the whole population. One way of achieving this is to have the composition of public bodies broadly reflect the demographics of the country. Recently some concerns have been raised about whether the proposed new SABC Board satisfies this criterion when measured against South Africa’s language demography. We would like to plead with the Ministry of Communications to take these concerns seriously, investigate whether they are well founded, and make any adjustments that may be necessary in this regard.

It is, furthermore, our impression that the presenters and programme hosts on SABC TV are mostly, if not exclusively, either English speaking or highly proficient in English. As such, the public face of the SABC is very elitist, and represents only 40% of South Africans (and 22% of black South Africans) who, according to the most comprehensive language survey yet conducted,[5] are “functionally proficient” in English.

2.3 Democracy also entails accountability, which, in turn, depends on wide consultation. At the Provincial Mini-Summit in the Western Cape, concerns were raised about several organisations working in the media and/or language fields who had not been notified of, or invited to the Mini-Summit, with the result that these stakeholders did not have the opportunity to contribute to discussions or to have their views represented at the National Summit. In future, the Portfolio Committee and the SABC Board should take care to involve all relevant stakeholders in discussions of this kind.

3. Special role of broadcasting in national life
The role of the SABC in national life is that of a Public Service Broadcaster. Public Service Broadcasting (PSB) generally implies the following characteristics[6]:

Public ownership, usually involving a large degree of financial autonomy; accountable to the public through parliament (which does not imply state control, ie not a state broadcaster).

Universal availability through open broadcasts, irrespective of geographical location; the coverage area is therefore national (countrywide), or regional when directed at a specific interest and/or cultural group.

— PSB caters for all interests and tastes, with commitment to a balanced schedule across the different programme genres, which would incorporate elements of information, education, and entertainment.

— PSB also caters for minorities; this means that every member of the viewing or listening public will, at some time or another, find something of interest in its programmes.

— There is a concern for the “national identity and community” , implying a focus on domestic programmes too (as opposed to only programmes of a “universal” or “international” approach, or from foreign sources).

— PSB programme content should be independent of vested interests and government; political impartiality means political output should be impartial and balanced.

— PSB should be funded mainly by its users, eg from licences and/or fiscal funds; licence fee funding is a form of (poll) tax levied on the owners of television receivers. In most cases, with the notable exception of the BBC (until recently) and Australian ABC, advertising is a common supplement to the licence fee income.

— The emphasis in PSB is on programming rather than on audience numbers.

Local production is an obligation to transmit a minimum level of domestically produced programmes.

The programming schedule and broadcast content should therefore be determined exclusively by the interests, needs and tastes of all sectors of South African society, and should neither be biased in favour of particular cultures or languages, nor dictated to by the interests of advertisers or the agenda of the state. In practice this means that the SABC cannot have an “anchor language”, that no language should receive preferential treatment, and that the funding strategies and legislative framework within which public broadcasting functions should be designed to enable an equitable allocation of airtime to all our languages. To the extent that this is not realised in practice, the SABC does not function as a Public Service Broadcaster, and therefore does not play its proper role in national life.

At present, and despite significant progress that has been made, the dominance of English on television at the expense of the indigenous languages still clearly serves the interests, needs and tastes of only a section of actual and potential viewers, more specifically of those with buying power and of advertisers. This needs to be rectified as a matter of urgency.

4. Broadcasting and national culture
From the characteristics of a Public Service Broadcaster listed under the previous point it will be clear that the SABC as a Public Service Broadcaster has a special responsibility to reflect and contribute to the development of a national culture. The SABC would be fulfilling its role in national life and contributing to the development of a national culture if it reflected the cultural and linguistic diversity so characteristic of our society. In a diverse country such as ours, nation-building can be premised only on equal respect and recognition granted to all communities by the state and public institutions. Our Public Service Broadcaster has an important role to play in providing opportunities for cultural expression and exposing South Africans to one another’s languages and other cultural expressions. In the words of Dr Neville Alexander at the first Annual General Meeting of i-MAG, “language policy should be an integral part of public policy in the context of the transition from a colonial apartheid society to a non-racial, post-colonial society.”[7]

5. Broadcasting and Language: Ensuring that there is an equitable distribution of all South African official languages within the broadcasting system
We welcome the efforts that have already been made to move closer to an equitable distribution of languages on television, and we commend the SABC for now offering news bulletins in all the official languages - this is indeed a major achievement. We also trust that the SABC is committed to continuing to expand the range of programming available in each of the indigenous languages, and therefore offer the following suggestions in a spirit of constructive co-operation:

5.1 We propose that a guaranteed minimum programme content per week during peak viewing time (“prime time”) and in all programme genres be awarded to each official language as well as South African Sign Language and the Khoi, San and Indian languages. Here, the Ministry of Communications can play a vital role by creating the necessary legislation to make such a requirement a licence condition for the Public Broadcaster to be monitored by ICASA, as is already the case with regard to local content and the amount of advertising time allowed. We realise that an equitable allocation of airtime cannot be implemented overnight. Therefore we propose that an initial benchmark be set for each language, and that this be extended every year until equitability is achieved (see Appendix A).

5.2 In order to achieve the above guaranteed minimum for each language, languages should be grouped into cognate and shared languages as suggested in the SABC Board’s “Draft Editorial Policies”, and a regular airtime window for each language/language group should be created. In Appendix B, specific proposals for how languages could be grouped and accommodated on the existing channels are put forward.

5.3 We further propose that all the available technological means be used to increase the amount of programme content available in languages other than English. These include subtitling, dubbing, simulcast, voice-overs and transmitter separation (see Appendix C).

In the specific area of subtitling, important research has been done for PanSALB by the School of Languages at the Vaal Triangle Campus of Potchefstroom University (see Appendix D). We strongly suggest that the SABC and the Ministry of Communications take cognisance of this research, as it includes very useful practical proposals and cost estimates.

We agree with these researchers that, since English is already dominant on television, it does not make sense to provide subtitles in English only, as is currently the practice. Rather, the emphasis should be on subtitles in the indigenous languages.

We also propose that the licence conditions of the SABC be amended so that programmes that are dubbed or subtitled into a particular language be counted as programming in that language and as local content, albeit with a somewhat lower count value attached in order not to detract from the production of local material with soundtracks in the indigenous languages.

5.4 The Broadcasting Amendment Act makes mention of regional broadcasts as a way of extending language diversity in public broadcasting. We believe that the establishment of new regional broadcasters would not be cost-effective, and that the much cheaper method of transmitter separation should be explored as a way of accommodating regional needs. This method can be used not only to aim different programmes at different regional audiences, but also to provide subtitling in different languages for the same programme content. Details concerning the latter application can be obtained from the School of Languages at the Vaal Triangle Campus of Potchefstroom University (for contact details, see Appendix D).

5.5 Another option that should be explored is the use of one of the frequencies that are currently not utilised for programming in languages other than English. Initially this could be done experimentally on the basis of a few hours per day. Tabema has prepared a proposal on how the 10 indigenous languages could be accommodated on such a broadcasting schedule, and combined with the use of transmitter separation to serve especially the smaller languages (see Appendix E).

5.6 Finally, “equitable distribution of all South African languages” relates not only to the allocation of programme content, but also to various other matters relating to language use on radio and television.

For instance, we welcome the fact that continuity presentation on SABC 1 is increasingly also being done in languages other than English. We strongly recommend that this practice be implemented on SABC 2 and 3 as well, since it is unacceptable that programmes in languages other than English are announced in English. Nor should “general announcements” (e.g. concerning the programming schedule for the evening or for the coming week) be made in English only or mainly in English.

At the same time, concerns have been expressed about the quality of the language used by presenters when they use African languages. This problem is probably linked to the fact that presenters seem to be chosen exclusively from that section of the population who are proficient in English but not necessarily in other official languages. Good language skills in other languages should weigh at least as much as proficiency in English, and proficiency in English should not be a requirement for employment as a television presenter, unless the position is specifically for an English language presenter.

On both radio and television, English sound bites are regularly used untranslated during programmes in other languages (but not vice versa). This practice is based on the false assumption that all or most viewers understand English, and should therefore be discontinued. Voice-overs can be used cheaply and effectively to translate sound bites recorded in a particular language for transmission in another language.

6. Funding Strategies to support and build Public broadcasting
6.1 The SABC is too dependent on advertising revenue, with the result that it cannot fulfil its mandate as a Public Service Broadcaster serving the needs of all sectors of South African society. The interests of those with buying power and of advertisers currently seem to dictate the SABC’s de facto language policy on television, with the result that the majority of viewers are treated as second-class citizens.

Although we believe that more can be done to serve all language communities even under existing conditions, especially if technology is utilised to the full, we also propose that alternative funding models be explored in order to make the Public Service Broadcaster less dependent on advertising revenue, since the current system of TV licences clearly does not achieve this aim.

One model that should certainly be explored is the introduction of a levy on electricity consumption in the place of the current system of TV licences. For more detail on this and other possible models, see Appendix F.

6.2 In addition to alternative funding strategies at the structural level, we believe that a more equitable airtime allocation would, to a certain degree, help fund itself. For instance, an increase in Afrikaans programming together with the other indigenous languages, all of which are currently under-represented on the airwaves, is likely to generate considerable advertising revenue that could be used, together with revenue from English programmes, to cross-subsidise a simultaneous increase in airtime allotted to other languages - i.e. cutting back on the disproportionate amount of airtime currently allocated to programming in English need not result in a dramatic decrease in advertising revenue, even in the short term.

Moreover, the reticence of advertisers to showcase their products during programmes in languages other than English and Afrikaans does not make business sense given the popularity of programmes in those languages. Incentives must be provided for advertising during such programmes so that the commercial value of such advertising can be discovered from experience. This can be achieved by offering more favourable advertising rates during the time slots in question, and by selling packages to advertisers that include time slots during programmes in the African languages.

Advertisers should also be encouraged to produce advertisements in African languages, and financial incentives should be attached to such advertising. Different soundtracks can be relatively cheaply produced for the same advertisement, and subtitling can also be used. The SABC should provide technical assistance to advertisers in this regard. Again, this is a question of discovering the benefits of such advertising through experience, since consumers definitely respond better to advertising in their home language.

The SABC should launch an information campaign to alert potential advertisers to the commercial potential of advertising in all our languages and during time slots allocated to programming in languages other than English and Afrikaans.

7. Strategies to grow and develop the South African broadcasting production sector
If the SABC is to move forward towards a more equitable language dispensation, the local broadcasting production sector will have to be greatly expanded, and new entrepreneurs enabled to enter this industry. Naturally, this can be done through training and funding, both by the SABC and by the Ministry of Communications. However, additional options should also be considered.

One model that we strongly recommend is so-called access television (see Appendix F), which would enable the different language communities to have access to broadcast time for which they are to provide the programmes themselves. Access TV programmes would therefore not be provided by the SABC, but by independent outside production houses, and at their cost, and would have to comply with strict rules (e.g. no party political broadcasts). The broadcast times made available for access television should be distributed equitably among the languages (with provision also made for multilingual programming during specific time slots), in order to ensure that this strategy helps to develop not only the broadcasting production sector as such, but specifically the production sector in each of our languages.



It is proposed that in the short term (to be attained within one year), the SABC should endeavour to guarantee (say) a minimum of 20 hours per week during peak viewing time in each of the four largest languages/language groups, i.e. the Nguni languages, the Sotho languages, Afrikaans and English (at present this would mean increasing the amount of programming in the Sotho languages and Afrikaans), and to increase this amount of airtime progressively each year. Eventually, a realistic goal of a minimum of 30 hours per week could be pursued 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 of (say) two hours per week in the short term.

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 be specified in terms of a guaranteed minimum per week, for example:

Programme genre
Adult drama
Youth drama/magazine
    Min hours per week



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

— The Nguni languages share a channel
— The Sotho languages share a channel
— Afrikaans and English share a channel.
— 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 by means of regional broadcasts.

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 airtime. 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:

— One channel for the Nguni languages and English
— One channel for the Sotho languages and Afrikaans
— 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 does not need to 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 airtime 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.



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 airtime allocated to those languages. However, broadcasts on regional channels should not be used to compensate for a less than equitable allocation of airtime on the national service.

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



The School of Languages at the Vaal Triangle Campus of Potchefstroom University has done extensive research for PanSALB on the use of subtitles as a means of increasing language diversity on television. Among their conclusions are that:

— Subtitling is a cost-effective way of making knowledge, entertainment and information accessible to diverse language communities.

— In the South African context, subtitling could act as a vehicle in introducing people to a variety of languages, and on the other hand, in making programme material accessible to a variety of speakers - in other words, enhancing multilingualism.

— Thirdly, in facilitating the transfer of information, the use of subtitles has a positive bearing on the comprehension of visual material - in other words, contributing towards the elevation of the levels of literacy in South Africa.

These conclusions are based on detailed analyses of practical and financial aspects related to the use of subtitles in the South African context, and accompanied by specific proposals.

Documents relating to this research can be obtained from the VTC School of Languages by writing to ENGJLK@puknet.puk.ac.za or phoning 016-910 3481 or 082 7731320.



TABEMA has been informed that an available channel of the SABC will be used for broadcasting PSB TV services on an experimental basis for six hours per day. This channel is to focus on the ten indigenous official languages of South Africa (ie excluding English, which receives more than adequate coverage on the existing SABC1, SABC2 and SABC3 TV channels, and at present enjoys 91 percent of broadcast time). In view of this, TABEMA proposes the following:


Six hours of broadcast time per day are available. It is proposed that these be slotted into the daily period 16:00 tot 22:00 (with excess time after 22:00 available, which could be used to relay other services). This will allow children’s and youth programmes to be broadcast in the late afternoon, and will span prime time during the evening, besides offering late evening viewing as well.

It is proposed that FOUR language categories be used, and that programme scheduling be done on a per language category basis. The following language categories are proposed, based on language demography and realities in South Africa:

  • NGUNI languages: isiXhosa, isiZulu, siSwati, isiNdebele. This language group represents some 45 percent of the home languages spoken in South Africa, and is the dominant language category in the south-eastern part of South Africa (see language demography map).

  • SOTHO languages: sePedi, seSotho, and seTswana. This language group represents 25 percent of the home languages spoken in South Africa, and is the dominant language in the middle and northern part of South Africa (see language demography map).

  • AFRIKAANS: This language represents 16 percent of the home languages spoken in South Africa, is the dominant language in the western half of the country (see language demography map), and is the third largest single language spoken in South Africa.

  • OTHER MINORITY LANGUAGES: tsiVenda and xiTsonga are the smaller languages not falling into any of the above categories, and represent six percent of the home language speakers in South Africa.

    It is noteworthy that, taken together, 99 percent of all South Africans understand at least one of the languages in the four categories of English, Nguni, Sotho and Afrikaans. Since English is adequately covered on the existing SABC channels, the three categories Nguni, Sotho and Afrikaans (NSA) are taken as the basis of this proposal, with the other minority languages (tsiVenda and xiTsonga) and sign language being treated as special cases.

    An equitable treatment of all languages does not necessarily imply equal time given to each language, since cognate languages are mutually understandable. Equitable treatment would rather imply equal time being given to the three main language categories. At the same time the two minority languages, as well as sign language, demand special treatment.


    It is proposed that the language demography of South Africa be taken into consideration, as exemplified by the following map of the dominant languages in South Africa:

    From this it is clear that the Nguni language category dominates the eastern and south-eastern part of South Africa, the Sotho language category the north-eastern and northern part of the country, and Afrikaans in the western half of the country. It is noticeable that English is the dominant language only in very small areas of Cape Town, Durban, and Johannesburg. This has important implications for any transmitter separation approach, clearly indicating that a division on a north/south basis is not supported by language demographic facts.

    The following weekly broadcast schedule is proposed:

  • This implies that on Mondays and Wednesdays the Nguni language category will occupy the 16:00-18:00 slot, on Tuesdays and Fridays it will occupy the 18:00-20:00 slot, and on Saturdays it will occupy the 20:00-22:00 slot, and mutatis mutandis on a rotational basis for the other two language categories. Thus each of the NSA language categories will have access to two hours of afternoon broadcasts (specifically aimed at children and youth), two hours of peak viewing time in the early evening, and two hours of late evening broadcasts during the period Mondays to Saturdays, with an additional two hours on Sundays (on a time-rotational basis).

  • The schedule is changed every Sunday. For example, on the first Sunday a Monday schedule is followed, on the following Sunday a Tuesday schedule is followed, and on the Sunday thereafter a Wednesday schedule is followed, to be repeated every three weeks.

  • The fourth, "Other minority languages” category (tsiVenda and xiTsonga) is to be provided solely on a transmitter separation basis. These two languages are geographically concentrated in the far north-eastern part of the country, and could therefore be covered by a small number of transmitters which are separated from the main transmitter network for one hour per day during the Nguni category broadcast time. This will give this language category a total of seven hours of broadcasting time per week (half the number of hours of the three main categories) on a regional basis.

  • It is further proposed that transmitter separation of the three main NSA language categories not be implemented during the initial trial broadcast period, but (on the basis of experience gained in the tsiVenda/xiTsonga transmitter separation approach proposed above) that it be considered after the trial period; furthermore, that any future transmitter separation not be done on the proposed north-south division into two sub-networks, but rather on an east-west separation (on the basis of language demographics - see the language distribution map above).

  • It is proposed that one hour of access television be made available during the daily schedule at a fixed time (for example between 18:00 and 19:00) to enable the different language groups to have access to broadcast time for which they are to provide the programmes themselves. Access TV programmes will therefore be provided not by the SABC, but by independent outside production houses, and at their cost, and will have to comply with strict rules (for example, no party political broadcasts).

    It is proposed that the 14 hours of broadcast time available for each of the three main NSA language categories per week be spread over the different broadcast genres in the following manner to ensure a balanced schedule over the week:

    Programme genre
    Adult drama
    Youth drama/magazine
        Min hours per week

    News broadcasts are not included in the above proposed genres, but should it form part of the daily schedule, it could be accommodated by suitable adjustment of the allocation to the other genres.

    It is proposed that the available technological capabilities to cater for the broadcast needs of a multilingual society be exploited to the full in order to promote multilingualism and open programmes to non-speakers of a particular language. These include:

  • Subtitles
  • Dubbing
  • Simulcast
  • Transmitter separation.

    Of these, the use of subtitles is the cheapest method. It is proposed that this be extensively used on the PSB channel, with the proviso that subtitles appear in only one of the ten indigenous official languages (ie excluding English). Also, that continuity announcements not be made in English (as happens on the present SABC TV channels almost exclusively).

    We trust that the above proposals will meet with your favourable consideration and will assist you in establishing a PSB network that is equitable and fair and will not only promote the ten indigenous official languages, but also foster multilingualism and a common South Africanism at the same time, as well as complying with the ideals of the Constitution and the different Acts of Parliament relating to broadcasting.

    Compiled by Prof H Christo Viljoen, for and on behalf of TABEMA, 16 September 2003.
    References: Language Policy Proposal for SABC’s TV Services, Tabema, September 1999.



    The SABC has to rely much more on advertising than on licence revenue. This differs from the situation for public service broadcasters elsewhere in the world.

    In the United States, for example, because of the size of the market, and for historical and other reasons, there is no single national broadcaster. However, a system of networking and franchising allows programmes to be made available countrywide over television and radio stations that have different owners. (No single broadcaster may operate more than 12 radio or television stations in the USA.)

    All broadcasters in the USA (excluding encoded services) are totally reliant on advertising revenue as their only source of income, with donations and grants from private sources enabling the single PSB radio and television service to operate.

    In Britain the BBC derives the vast majority of its income from licence fees. Audience numbers therefore have little or no direct bearing on its financial state and it enjoys an assured income, since it does not chase large audiences. This means that it can also broadcast programmes to cater for minority tastes, for example opera and classical music performances. They ascribe the good quality of their broadcasting service (specifically television) to the fact that the BBC and ITV do not really compete for the same financial sources, but do compete for audiences.

    In Australia the Australian Broadcasting Corporation (ABC) is fully funded by a direct grant from the government. The ABC carries no advertising, which allows it to emphasise its PSB functions (with a healthy mix of entertainment programmes).

    Television receiving licences apply in most countries in order to fund PSB services, the notable exception being the USA, where no television or radio receiving licences apply. On the other hand, almost all PSB services supplement their income with advertising revenue.

    The question is what the ideal ratio of licence income to advertising revenue should be. Too great a dependence on licence revenue increases the danger of governmental control through financing. Too great a dependence on advertising revenue results in the PSB function being relinquished. The European Broadcasting Union (EBU) considers a contribution of between 25 percent and 50 percent by advertising revenue of total income to be the ideal.

    Increasing the level of the television licence fee much above the present level is considered an unattainable target, since that would further increase pirate viewing. An alternative system for funding the SABC to reduce its dependence on advertising revenue is urged by Tabema and should have the following aims:

    To be affordable: too high a licence fee or alternative method of payment would deprive part of the population of television services.

    To reduce the risk of pirate viewing to a minimum, and preferably to eliminate it completely; this implies a secure TV licence collection system, or even conditional access (ie secure encryption of the signal).

    A minimum recovery cost: collection costs that are too high would defeat the primary object, namely the funding of television services.

    To strive for a high probability of success in getting an alternative method of collection approved and implemented; unrealistic or impractical schemes would have little chance of being approved.

    Acceptability: any alternative method of payment would have to be accepted by the authorities, the collecting agent, and television viewers.

    Fairness: any alternative method of collection should be fair to viewers and non-viewers alike; those who need to pay, should pay; those who do not require the service should not be required to pay.

    Payment and services rendered should be clearly linked. Viewers should perceive that they are getting value for money.

    Financing options other than television licence fees

    Tabema has identified the following alternative methods of PSB payment for television services rendered, other than television licences, for South Africa. The figures quoted below would result in an advertising income of approximately 30 percent for the SABC’s PSB services if its total income remains the same as at present. If the advertising income were 50 percent or any other percentage, these figures would have to be amended accordingly:

    1. Fiscal payment of the full amount, as happens in Australia, for example, where the Australian Government fully funds the Australian Broadcasting Corporation. In this way members of the public (ie taxpayers) pay for their broadcasting. It eliminates the problem of annual licence fee increases, piracy, collection and law enforcement. The main disadvantage would be that the SABC could be seen as being owned by the government and not by the public, strengthening the “his master’s voice” perception of government intervention in programme content, which could materialise (as has indeed happened in some countries where the system is in operation), thus compromising the independence of the SABC.

    2. A levy on personal income tax. In this way all tax-paying citizens of the country pay for their broadcasting service. Pirate viewing is then confined to tax evaders, which in South Africa would be fewer than the one in three pirate television viewers. However, allocated taxes are not favoured by many governments. A major disadvantage is that non-taxpayers would not contribute to the radio and television services they receive. A standard fixed contribution (levy) by each payer of personal income tax would not, however, cover a large part of television set owners, ie those who do not qualify for paying income tax. It is calculated that an allocation of approximately 1,25 percent of income tax would cover the needs of PSB services. If this were to be a percental levy added for each personal-tax payer, a disproportionate amount would be paid by different taxpayers.

    3. An increase in Value Added Tax of about 0,2 percentage points. Although this is a fair system, since everybody would contribute, the question of allocated taxes and disproportionate contributions once again arises. Also, there is no direct correlation between purchases on which VAT is charged, and television viewing.

    4. A percentage added to municipal service accounts. Non-payment of municipal taxes and levies in certain communities could present a problem, and large numbers of people receive only communal municipal services. Many municipal taxpayers do not own television sets, and many television viewers are not subject to municipal accounts (eg farmers).

    5. A percentage added to telephone accounts. This has the disadvantage that not every television viewer has a telephone.

    6. A levy on electricity. (This method of collection has been implemented in Portugal and Greece.) A levy of about three percent at the wholesale (Eskom) price would be required in South Africa. Bigger consumers, such as mining and industrial consumers, would then pay relatively more than domestic consumers, and the manufacturing industry would complain that they may not have any TV sets. This system would have the advantage that since Eskom generates 96 percent of the country’s electricity, a single collection system could be implemented (with the additional four percent of electricity generation being done by a small number of municipalities, which can also be brought into the net). It is considered that very few television owners do not make use of mains electricity and would therefore be exempt from this means of payment. However, Eskom is known to be opposed to any levy on electricity. (It should be noted that the system of an annual licence for third party insurance in transport was replaced by a levy on the fuel price, which ensured that all road users contribute to third party insurance, albeit disproportionately.)

    7. Conditional access. If the broadcast signal is encrypted, the owner of a television set would need a decoder to “unscramble” the signal. In case of non-payment the decoder would be remotely deactivated and the viewer could not receive the television picture. With three million viewers and say R600 for each decoder, the total cost of R1,8 billion for each South African television owner to purchase a decoder is considered prohibitive. Furthermore, the collection and administration costs of operating a conditional access system are actually more than the annual television licence fee. This is considered to be the fairest but most expensive of all systems, and is not considered to be viable with present technology.

    Inasmuch as a television receiving licence is regarded as a form of poll tax (payable for owning a television set, not for programme services rendered), any scheme to replace television licences would mean exchanging one form of taxation for another - it would not be a new tax. Tabema strongly urges that the system of television receiving licences be abolished and an alternative system introduced.

    Compiled for TABEMA by prof H Christo Viljoen.

    Reference: Report of the Task Group on Broadcasting in South and Southern Africa. (Chairman: Prof Christo Viljoen.) Government Printer, Pretoria 1991.

    [1] This document was drafted on behalf of i-MAG and Tabema by Dr Gerrit Brand, Prof JB du Toit and Prof Christo Viljoen.
    [2] “Towards greater Language Diversity in Public Broadcasting: Comments of the Multilingualism Action Group on the SABC’s ‘Draft Editorial Policies’”. This document can be viewed at www.litnet.co.za/taaldebat/magsabc.asp.
    [3] “Presentation by Dr. Gerrit Brand, Secretary of the Multilingualism Action Group (i-MAG), to the Mini-Summit of the Portfolio Committee on Communication on ‘Broadcasting Content and Languages and their implications for Public Service, Community as well as Commercial Broadcasting.’ (The Lord Charles Hotel - Somerset-West, 11 September 2003). This document can be viewed at www.litnet.co.za/taaldebat/magsabc.asp.
    [4] See “Media Statement by the Multilingualism Action Group (10 February 2003): National Parliament should not regress on Language”. This document can be viewed at www.litnet.co.za/taaldebat/magsabc.asp.
    [5] See Pan South African Language Board, “Language Use and Language Interaction in South Africa: A National Sociolinguistic Survey”, Pretoria: PanSALB 2000.
    [6] These characteristics are contrasted with commercial broadcasting in “The Broadcasting Amendment Bill of 2002: Submission by Tabema and the Taalsekretariaat”. This document can be viewed at www.litnet.co.za/taaldebat/magsabc.asp.
    [7] See “Berig oor die eerste Algemene Jaarvergadering van die Meertaligheidsaksiegroep op 5 Junie 2003”. This document can be viewed at www.litnet.co.za/taaldebat/magsabc.asp.

    13 January 2004


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