BSA Decisions Ngā Whakatau a te Mana Whanonga Kaipāho

Complaint
The Rock – a number of complaints – offensive language – offensive behaviour – broadcasts inconsistent with maintenance of law and order – denigration of women – discrimination against women – unsuitable for children

Findings
(1)  5 August broadcast – no uphold

(2)  6 August broadcast – no uphold

(3)  7 August broadcast – no uphold
 
(4)  10 August broadcast – reference to wanking unsuitable for children – Principle 7b – uphold

(5)  11 August broadcast – discussion with child character about pornography – unsuitable for children –
      Principle 7b – uphold

(6)  21 August broadcast – gratuitous use of "fuck" – Principle 1 – uphold – Principle 7b – unsuitable
     for children – uphold; discussion about plasticine penis – no uphold; mocking of homosexuals –
     Principle 1 – uphold; Principle 7b – unsuitable for children – uphold; "mummy mummy joke" –
     no uphold

(7)  22 August broadcast – reference to oral sex – Principle 1 – uphold; Principle 7b – majority –
     no uphold

(8)  24 August broadcast – reference to anal sex – derogatory reference to named woman – Principle 1 –
     uphold; Principle 7b – unsuitable for children – uphold

(9)   25 August broadcast – story about anal sex; Principle 1 – uphold; Principle 7b – unsuitable for
      children – uphold

(10) 29 August broadcast – "Suicide" song – "fuck" – context – social message – majority – no uphold;
      ral sex/penis "joke" – Principle 1 – uphold; Principle 7b – unsuitable for children – uphold

Order
Costs to the Crown in the sum of $5,000

This headnote does not form part of the decision.

---

Summary

R K Watkins complained to The RadioWorks Ltd, the broadcaster, about morning broadcasts on The Rock on 5, 6, 7, 10, 11, 21, 22, 24, 25 and 29 August 2000. She considered that aspects of the broadcasts breached standards relating to good taste and decency, the maintenance of law and order and social responsibility.

The RadioWorks responded to each of the complaints to the effect that no broadcasting standards were breached. In relation to good taste and decency, it considered that there had been no breach in the context of The Rock’s 18-39 year old male target audience, and in the contexts in which each of the items complained about were broadcast. As to social responsibility, The RadioWorks maintained that the broadcasts were legitimate humour.

Dissatisfied with The RadioWorks’ responses, R K Watkins referred the complaints to the Broadcasting Standards Authority under s.8(1)(a) of the Broadcasting Act 1989.

For the reasons given below, the Authority upholds some aspects of the complaints relating to breaches of Principles 1 and 7. It orders the broadcaster to pay costs to the Crown in the sum of $5000.

Decision

The members of the Authority have listened to tapes of the items complained about, where copies were provided by the broadcaster, and have read the correspondence which is listed in the Appendices. The Authority determines these complaints without a formal hearing.

The Complaints

R K Watkins complained to The RadioWorks about morning broadcasts on The Rock on 5, 6, 7, 10, 11, 21, 22, 24, 25 and 29 August 2000. The aspects of the broadcasts she complained about were (not including those which she did not subsequently refer to the Authority for review):

5 August (10.35am) – comment made during promotion for nude tennis game: "I’ll show
                                 her my green fuzzy balls"

6 August (8.55am) – comment by announcer: "Tiffany, the dirty slut"

7 August (9.08am) – comment by announcer: women at stag party called "whores"

10 August (7.55am) – comment by announcer: nude tennis – references to wanking

11 August (8.10am) – discussion with child character about pornographic material

21 August (7.20-8.55am) – use of "fuck" by announcer; discussion about plasticine penises;
                                        discussion which mocked homosexuals; "mummy" joke made
                                        by announcer

22 August 2000 (8.07am) – oral sex reference made in relation to a named woman

24 August 2000 (8.40am) – anal sex story told by announcer

25 August 2000 (6.35am) – comment by announcer: anal sex reference

29 August 2000 (6.50 and 7.37am) – use of "fuck" in song "Suicide"; oral sex/penis "joke"
                                                        made by announcer

Ms Watkins considered that the broadcast items referred to above breached standards relating to good taste and decency and social responsibility, and that aspects of the broadcasts also breached standards relating to the maintenance of law and order. She asked that her complaints be assessed under the following standards contained in the Radio Code of Broadcasting Practice:

Principle 1

In programmes and their presentation, broadcasters are required to maintain standards which are consistent with the observance of good taste and decency.

Guidelines

1a  Broadcasters will take into consideration current norms of decency and good taste in language and behaviour bearing in mind the context in which any language or behaviour occurs and the wider context of the broadcast eg time of day, target audience.

Principle 2

In programmes and their presentation, broadcasters are required to maintain standards which are consistent with the maintenance of law and order.

Guidelines

2a  Care should be taken in broadcasting items which explain the technique of crime in a manner which invites imitation.

Principle 7

In programmes and their presentation, broadcasters are required to be socially responsible.

Guidelines

7a  Broadcasters will not portray people in a manner which encourages denigration of or discrimination against any section of the community on account of gender, race, age, disability, occupational status, sexual orientation; or as the consequence of legitimate expression of religious, cultural or political beliefs. This requirement does not extend to prevent the broadcast of material which is:

i)   factual; or

ii)  a genuine expression of serious comment, analysis or opinion; or

iii) by way of legitimate humour or satire.

7b  Broadcasters shall be mindful of the effect any programme may have on children during their normally accepted listening times.

7d  If a programme is likely to disturb, an appropriate warning should be broadcast.

Ms Watkins took issue with The RadioWorks’ description of The Rock as targeting males aged between 18 and 39 years. Rather than reflecting the attitudes of its target audience, she considered that The Rock was:

forming and encouraging a disturbing portrayal of women [which would] expose them to ridicule, contempt, denigration, exploitation, hatred and ultimately violence.

She also commented that some of the items she complained about were also devoid of humour and unsuitable for children.

The RadioWorks’ Responses

The RadioWorks declined to uphold any of Ms Watkins’ complaints. It maintained that in the contexts of each of the items, the broadcasts Ms Watkins complained about were not offensive. The RadioWorks referred specifically to The Rock’s target audience and submitted that the broadcasts were "legitimate humour", usually involving fictitious characters. The RadioWorks also commented in relation to each of the complaints that Ms Watkins was the only person to have complained. On several occasions, The RadioWorks suggested that Ms Watkins stop listening to The Rock, and stop "attempt[ing] to impose her standards on the rest of the community".

In relation to the song "Suicide", it also explained that the song was anti-suicide, and that through its broadcast, The Rock was "attempting to be active in stopping this serious problem [of youth suicide]."

The Referrals to the Authority

In the referrals of her complaints to the Authority, Ms Watkins made the following comments:

• She referred to previous decisions of the Authority which she considered established that The Rock’s target audience and "style" were not good defences to a breach of broadcasting standards.
• She disagreed that the broadcasts could be described as legitimate humour, commenting specifically that there was nothing humorous about rape, or jokes that exploited the innocence of children.
• She considered it irrelevant that she was the only person to complain about the broadcasts. She said she believed that many did not complain, but nevertheless found broadcasts offensive or otherwise in breach of standards.
• In relation to "Suicide", she said that:-
the issue here is not whether a song by an American artist is for, or against, suicide; but rather the cumulative effect of inappropriate language on unsupervised children.

The RadioWorks’ Responses to the Referrals

In The RadioWorks’ responses to the referrals, the following points were made:

• It maintained that competitive broadcasting conditions in New Zealand required radio stations to deliver a product demanded by their respective target audiences. It considered that its listenership reflected its success in this area.
• It reiterated its argument that New Zealanders had a wide range of listening options on radio, that Ms Watkins was not part of the intended audience for The Rock, and that those who were among its target audience had not complained about the broadcasts which Ms Watkins considered breached standards.
• In relation to Ms Watkins’ complaint about "Suicide", The RadioWorks repeated its submission that the track was played in an attempt to help stop youth suicide.

The Final Comments

In Ms Watkins’ final comments she submitted that broadcasters could not restrict their audience just to those they targeted. She added:

Besides, why should an audience have a right to a radio station that reflects, as well as forms, bad attitudes towards women?

Ms Watkins also commented that:

Freedom of choice is all very well if you are an adult. Most would choose to turn the dial. But due to the time of day these comments were broadcast, the cumulative effect on unsupervised children must be given consideration.

The Authority’s Findings

The Authority considers each of the complaints separately, against the standards which were nominated by the complainant.

5 August broadcast

The complainant maintained that a comment made by an announcer during a promotional segment breached Principle 1 and Guideline 7a to Principle 7 of the Radio Code. The comment to which she objected was "I’ll show her my green fuzzy balls".

The Authority was not provided with an audiotaped copy of this broadcast. The RadioWorks explained that it did not retain recordings of station promotions. However, it did not dispute the complainant’s version of the broadcast, and offered to provide the Authority with a transcript if required.

The RadioWorks explained that the comment had been made in the context of an advertisement for an upcoming nude tennis match which it was promoting.

The Authority is required to consider the context in which the broadcast took place when it considers any complaint alleging a breach of the good taste standard. On this occasion, the Authority considers it relevant that this broadcast took place during normal school hours (at 10.35am), when it would expect the audience to comprise mostly adults. To this minor extent, the Authority considers that The Rock’s target audience argument is relevant. However, the Authority comments below on the difficulties which, in its view, limit the effectiveness of arguments based on niche marketing.

Taking into account the broadcast’s context, the Authority does not consider that the broadcast was sufficiently objectionable to breach Principle 1. Nor does it consider that the comment would have encouraged denigration of or discrimination against women, or that the comment breached any other aspect of Principle 7. Accordingly, it declines to uphold Ms Watkins’ complaint about the 5 August broadcast.

6 August broadcast

This complaint related to an on-air reference to a member of the pop group "Bardot". During a discussion about the group, Tiffany was referred to as "the dirty slut". Ms Watkins considered that this broadcast breached Principles 1 and Guideline 7a to Principle 7.

The Authority declines to uphold the complaint about this broadcast. In its opinion, the reference – which was obviously made facetiously – would have been considered to fall within audience expectations among those listening to the station just before 9.00am in the morning. It also considers that it was insufficiently offensive to cause any breach of Principle 7.

7 August broadcast

This complaint relates to a broadcast at 9.08am. A story was told about a stag party at which some men’s wives and girlfriends were present. According to the broadcast, the women present were required to be referred to by their partners as "whores".

Ms Watkins again complained that the broadcast was offensive and discriminatory. The RadioWorks disagreed, and commented that Ms Watkins may have missed the punch line, which was that the "girls had the meal and left leaving the men to pay". It acknowledged that the use of the word "whore" was strong, but considered it was acceptable in context.

The Authority also considers that the use of the word "whore" is strong. However, it acknowledges that the language was used in the context of telling what an audience listening to The Rock at that time of the morning could construe as a humorous story. Again, the Authority considers it relevant that the broadcast did not take place at a time when the broadcaster ought reasonably to expect that children would be listening.

The Authority declines to uphold the complaint about this broadcast.

10 August broadcast

During this broadcast, a caller won tickets to a nude tennis event promoted by The Rock. The announcer told the caller not to forget to bring his "wanking towel". The caller then said he would be "having bloody wet dreams all week". The announcer was then heard to make a panting noise. This broadcast took place at 7.55am.

The Authority does not consider that this broadcast was sufficiently offensive to breach standards of good taste and decency. However, it considers that the comments which were the subject of the complaint were at the outer limit of acceptability for broadcast on radio. And, as the broadcast occurred at a time when children could have been listening, the Authority considers that Guideline 7b to Principle 7 was breached. In its view, the broadcaster did not demonstrate that it was mindful of the effect of the broadcast on children.

11 August broadcast

A discussion about pornography between the host and an apparently fictitious child character, was the subject of this complaint. During the discussion, the "child" asked for birthday presents and pornographic material for his father. He revealed that he was blackmailing the announcer because he had photographs of him with his kindergarten teacher "over a barrel". This broadcast occurred at 8.10am.

Again, the Authority considers that this broadcast, while at the borderline of acceptability, was insufficiently offensive to breach Principle 1. However, it does find that the broadcaster failed to demonstrate that it was mindful of the effect that the discussion may have had on children. As noted above, the broadcaster could have expected that children would form part of the Rock’s audience before school hours had begun. Accordingly, the Authority concludes that the broadcast breached Guideline 7b to Principle 7.

21 August broadcast

The first of four aspects of The Rock’s 21 August broadcast concerned the pronunciation of the place name "Whakamarama". An apparently fictitious caller repeatedly pronounced the word as "Fuck! amarama", and appeared to take great delight at his ability to incorporate the word "fuck" into the radio broadcast.

The Authority considers that the use of the word "fuck" was over-emphasised and gratuitous. It refers to its research which indicates that a large number of New Zealanders find that the word is offensive. It also records that it is not persuaded that the broadcast had sufficient contextual justification. Accordingly, the Authority concludes that this aspect of the 21 August broadcast breached Principle 1. Furthermore, as the broadcast took place at 7.20am, well before school hours, the Authority also concludes that the broadcast breached Guideline 7b to Principle 7.

The second aspect of the 21 August broadcast about which Ms Watkins complained involved a discussion about plasticine penis modelling. The broadcast occurred at 7.40am.

In the Authority’s opinion, this segment of the broadcast was neither sufficiently offensive to breach Principle 1, nor to demonstrate any failure by the broadcaster in its obligation to be socially responsible. The Authority does not uphold this aspect of the complaint about the 21 August broadcast.

The third aspect of the 21 August broadcast about which Ms Watkins complained concerned a conversation with an apparently fictitious man named Bryce, who told a story about his male friend whose home was broken into by another man. The male friend had sex with the intruder. This conversation took place at 7.50am.

The Authority considers that the apparent humour in this item was derived from the mockery of homosexual male mores. It finds that this breached both Principle 1 and Guideline 7b to Principle 7.

The final part of the 21 August broadcast which Ms Watkins considered to breach standards was a "joke" told by one of the announcers. The Authority was not provided with an audiotaped copy of this aspect of the broadcast, but notes that the broadcaster did not dispute the complainant’s version. Ms Watkins maintained that the "joke" was:

CHILD:         Mummy, mummy, when will the pool be filled up?
MOTHER:    Shut up and keep pissing.

According to Ms Watkins, the broadcast took place at 8.55am.

In the Authority’s opinion, the "joke" was neither sufficiently offensive to breach Principle 1, nor to demonstrate any failure by the broadcaster in its obligation to be socially responsible. The Authority does not uphold this aspect of the complaint about the 21 August broadcast.

22 August broadcast

The following morning, an announcer said "Big Adrian – That’s why Belinda’s got stretch marks on her mouth" at 8.07am.

In the Authority’s view, this comment breached Principle 1, as it associated a named woman with a sex act in a denigratory and fairly explicit fashion. The Authority considers that the statement was deliberately intended to convey this particular offensive meaning, and finds that this transgressed standards of good taste and decency. It notes that whether "Belinda" is a real or imaginary woman, the comment remains in breach of the standard.

As to Principle 7, the Authority is divided in its determination. A majority considers that the broadcast did not breach any aspect of Principle 7. In particular, the majority considered that the meaning of the statement would probably not have been understood by most children.

The minority disagrees. In the minority’s view, older children may have understood the intended meaning, and were in any event being incited to understand. The minority considers that, in these circumstances, the broadcaster was required to demonstrate that it was mindful of the effect of the broadcast on children. It considers that there was no evidence of such a demonstration.

24 August broadcast

The woman "Belinda" was again referred to in a segment which Ms Watkins complained about during the following morning broadcast. The Announcer stated "Belinda's on heat – bring your arse lubes". This statement was broadcast at 8.40am.

The Authority considers that this sexual reference was explicit, crude and unacceptable, and that its meaning would have been clear to most listeners, including children. Accordingly, it concludes that the 24 August broadcast breached both Principle 1 and Principle 7.

25 August broadcast

This complaint concerned a story apparently taken from Loaded magazine. In the story told on air, a man had used mustard as a lubricant during anal sex. This broadcast took place at 8.40am.

As with the 24 August broadcast, the Authority considers that this sexual reference was explicit and unacceptable, and that its meaning would have been clear to most listeners, including children. Accordingly, it concludes that the 25 August broadcast breached both Principle 1 and Principle 7.

29 August broadcast

Ms Watkins also complained about the use of the word "fuck" in the song Suicide by Bobby Gaylor. The song was broadcast at 8.52am.

The Authority is divided about this complaint. The majority considers it highly relevant that the song is intended to have a serious anti-suicide message. The majority considers that the presence of a strong social message in the song distinguishes it from the other broadcasts about which Ms Watkins complained. In this context, the majority does not consider that the use of the word "fuck" was gratuitous or offensive. It therefore declines to uphold Ms Watkins’ complaint that Principle 1 was breached. It also declines to uphold Ms Watkins’ complaint that Principle 7 was breached, as it considers that the song’s serious message sufficed to satisfy the test set out in Guideline 7b requiring broadcasters to be "mindful of the effects of the broadcast on children". The majority therefore declines to uphold Ms Watkins’ complaint about the 29 August broadcast.

A minority of the Authority disagrees. In its view, the word "fuck" should not be broadcast at a time children could be listening to the radio. The minority does not consider that the social message of the song was sufficient to save the broadcast from breaching either Principle 1 or Principle 7. Accordingly, the minority upholds the complaint.

29 August broadcast – part ii

Finally, Ms Watkins complained about a "joke" broadcast at 7.37am. She reported that a character named "Bryce" told a story about little Johnny using a public urinal and telling the man standing next to him that his father had two penises and "one is little and wrinkly that he uses for taking a leak, the other is long and hard and he uses it to brush my mummy’s teeth".

The broadcaster did not provide a tape of this broadcast, but responded in its submissions that the joke had been told by a fictitious character and was a legitimate attempt at humour targeted at The Rock’s niche audience of 18-39 year old blue collar workers. It noted that none of its 268,000 regular listeners had chosen to complain. It said that as the complainant was not in the target audience, and did not understand the lifestyle, humour and personality of that audience, she should not attempt to impose her standards on them. It suggested she choose another station to listen to.

As with a number of the previous broadcasts, the Authority considers that this sexual reference was explicit and unacceptable, and that its offensiveness would have been evident to listeners, including children. Accordingly, it concludes that this broadcast breached both Principle 1 and Principle 7.

General

These complaints raise the broad question of the extent to which niche marketing provides any defence to a broadcaster for the broadcast of material which might be offensive. The Authority has, on previous occasions (for example Decision No: 2000-003 , Decision No: 1999-191 and 192) found that while the target audience of a broadcast is a relevant contextual factor which it considers when determining whether there has been a breach of the good taste and decency standard, it does not provide a blanket defence to a broadcaster. Nor is it likely to be convincing during hours when children might reasonably be expected to be listening to the radio.

Furthermore, the Authority will consider all relevant contextual matters in relation to a broadcast when it makes a decision on a good taste complaint. The relative importance of each factor will depend on the circumstances of the complaint, and the decision overall must reflect the community’s expectations of good taste and decency.

The argument about niche marketing is consistently used by The RadioWorks in answering these complaints. But, the Authority notes, while The RadioWorks claims that The Rock is aimed at a "tightly niched target audience of blue collared 19-39 year old males", it also claims to have an audience of 268,000. This, in the Authority’s view, indicates a wider and less tightly targeted audience than the niche market argument indicates. Radio broadcasters are unable to exclude those outside the target audience from their broadcasts, and this would seem apparent both from the number claimed to be regular listeners, and from the broadcaster’s own research about the composition of its audience.

For the reasons given, the Authority upholds the complaints that:

• a broadcast on The Rock on 10 August 2000 breached Principle 7 of the Radio Code of Broadcasting Practice
• a broadcast on The Rock on 11 August 2000 breached Principle 7 of the Radio Code of Broadcasting Practice
• aspects of a broadcast on The Rock on 21 August 2000 breached Principle 1 and Principle 7 of the Radio Code of Broadcasting Practice
• a broadcast on The Rock on 22 August 2000 breached Principle 1 of the Radio Code of Broadcasting Practice
• a broadcast on The Rock on 24 August 2000 breached Principle 1 and Principle 7 of the Radio Code of Broadcasting Practice
• a broadcast on The Rock on 25 August 2000 breached Principle 1 and Principle 7 of the Radio Code of Broadcasting Practice
• a broadcast on The Rock on 29 August 2000 breached Principle 1 and Principle 7 of the Radio Code of Broadcasting Practice.

A majority of the Authority declines to uphold the complaint that a broadcast on The Rock on 22 August 2000 breached Principle 7 of the Radio Code of Broadcasting Practice.

A majority of the Authority declines to uphold the complaint that a broadcast on The Rock on 29 August 2000 breached Principle 1 and Principle 7 of the Radio Code of Broadcasting Practice.

The Authority unanimously declines to uphold any other aspect of the complaints.

Having upheld a complaint, the Authority may make orders under s.13 and s.16 of the Broadcasting Act. Accordingly, it invited the parties to make submissions on penalty.

Ms Watkins asked the Authority, when deciding on an appropriate penalty, to consider the large number of breaches which had occurred over a three week period, and the broadcaster’s "continued tolerance of the distasteful and explicit language" in its broadcasts. She submitted that the broadcast of an apology was not an appropriate penalty.

The RadioWorks submitted that an appropriate penalty for the breaches of Principle 1 was an apology. It maintained that the broadcasts were not a blatant attempt to transgress the standards, but were attempts at humour. In relation to the breaches of Principle 7, the broadcaster submitted that an appropriate and sufficient penalty was the broadcast of a disclaimer warning the public that The Rock was a station for adults. It also observed that only one member of the community had complained about the broadcasts. It suggested that this indicated that The Rock had broad community acceptance.

In reaching its decision on what penalty is warranted, the Authority emphasises that in assessing these complaints, it has applied an objective test which reflects prevailing community standards. It is irrelevant that the complaints were made by only one member of the community.

To the broadcaster’s suggestion that the broadcast of a disclaimer is an appropriate penalty for the breaches of Principle 7, the Authority responds that this is entirely inappropriate. It is not possible for a broadcaster to contract out of its statutory responsibilities in this manner. All broadcasters are bound to maintain standards of good taste and decency and to be mindful of children in the listening audience.

Having considered the submissions, the Authority makes the following order:

Order

Pursuant to s.16(4) of the Broadcasting Act 1989 the Authority orders The RadioWorks Ltd to pay, within one month of the date of this Decision, the sum of $5000 in costs to the Crown. That sum comprises an award of costs of:

$750 in relation to the 10 August broadcast
$750 in relation to the 11 August broadcast
$750 in relation to the 21 August broadcast
$500 in relation to the 22 August broadcast
$750 in relation to the 24 August broadcast
$750 in relation to the 25 August broadcast
$750 in relation to the 29 August broadcast

Signed for and on behalf of the Authority

Peter Cartwright
Chair
18 December 2000

Appendix I – 5, 6 and 7 August Complaints

The following correspondence was received and considered by the Authority when it determined these complaints:

1. R K Watkins’ Complaint to The RadioWorks Ltd – 8 August 2000
2. The RadioWorks’ Response to the Formal Complaint – 21 August 2000
3. R K Watkins’ Referral to the Broadcasting Standards Authority – 25 August 2000
4. The RadioWorks’ Response to the Broadcasting Standards Authority – 5 September 2000
5. R K Watkins’ Final Comment – 10 September 2000

Appendix II – 10, 11 and 21 August Complaints

The following correspondence was received and considered by the Authority when it determined these complaints:

1. R K Watkins’ Complaint to The RadioWorks Ltd – 17 August 2000
2. R K Watkins’ Complaint to The RadioWorks Ltd – 21 August 2000
3. The RadioWorks’ Response to the Formal Complaint – 29 August 2000
4. R K Watkins’ Referral to the Broadcasting Standards Authority – 5 September 2000
5. The RadioWorks’ Response to the Broadcasting Standards Authority – 21 September 2000
6. R K Watkins’ Final Comment – 4 October 2000

Appendix III – 22, 24 and 25 August Complaints

The following correspondence was received and considered by the Authority when it determined these complaints:

1. R K Watkins’ Complaint to The RadioWorks Ltd – 28 August 2000
2. R K Watkins’ Complaint to The RadioWorks Ltd – 28 August 2000
3. The RadioWorks’ Response to the Formal Complaints – 6 September 2000
4. R K Watkins’ Referral to the Broadcasting Standards Authority – 9 September 2000
5. The RadioWorks’ Response to the Broadcasting Standards Authority – 21 September 2000
6. R K Watkins’ Final Comment – 6 October 2000

Appendix IV – 29 August Complaint

The following correspondence was received and considered by the Authority when it determined these complaints:

1. R K Watkins’ Complaint to The RadioWorks Ltd – 1 September 2000
2. The RadioWorks’ Response to the Formal Complaint – 7 September 2000
3. R K Watkins’ Referral to the Broadcasting Standards Authority – 11 September 2000
4. The RadioWorks’ Response to the Broadcasting Standards Authority – 26 September 2000