Roy Greenslade makes a number of valid and helpful points in his proposal to come up with a ‘PCC Plus’.In particular he notes the experience and conscientiousness of the current PCC secretariat (i.e. those who run the organisation on a day-to-day basis). Anyone who has dealt with the secretariat would almost certainly agree with Greenslade. The secretariat is bright, hard-working and do their utmost to help those who contact them.But by choosing the case of the Middleton photographs Greenslade misses a number of critical questions that remain unanswered by his proposition:What does PCC Plus do about news organisations that refuse to participate?Northern and Shell (which includes Express Newspapers) stopped paying its dues towards the upkeep of the PCC and were, as a consequence, ejected from the current system in January 2011. Any new system of self-regulation has to be able to explain how it would deal with organisations like Northern and Shell.What sanctions would PCC Plus have and how would it reach consensus about these within the industry?Greenslade notes that meaningful sanctions are important but does not say what these ought to be, outside showing scepticism for fines. Right now the PCC does not have a sanction. It cannot instruct a news organisation to do anything. If it upholds an adjudication then the news organisations within the system agree to publish that adjudication somewhere within their paper. To agree anything stronger would require a considerable effort within the industry, especially at a time when it can point to the ‘unregulated web’ where no such sanctions exist (outside the law).How would one invest a PCC Plus with the powers and resources to do proper investigations?The ‘investigations’ the PCC did into phone hacking – in 2007 and 2009 – are now widely accepted to have been superficial and wrong (in re-iterating the News of the World line that phone hacking was limited to one rogue reporter). The 2009 report – the one criticising the Guardian rather than News of the World – has finally been withdrawn. But to do proper investigations would require more money, more power, and greater independence. Other regulators have worked out various ways to resolve this. The Financial Services Ombudsman, for example, charges the business against whom a complaint is made a ‘case fee’. Though it will only charge businesses that receive more than three chargeable cases against them. As for news, it is far from clear whether the industry is prepared to give a self-regulator such powers and independence, or how it would go about doing so.How to pay for the PCC Plus?The current PCC costs the industry about £2 million. This is a bargain compared to other regulators. Even the ASA – the body the PCC is most often compared with – costs more than three times as much (Ofcom costs over 50 times as much). Were there to be a PCC Plus, the ‘Plus’ would presumably equate to a higher cost. Given the dire economic straits many news organisations find themselves in it is hard to see them agreeing to pay more towards the PCC, especially if it is given the power to impose sanctions, which may include fines.What needs to be done to make the PCC Plus more independent? The PCC regularly calls itself independent. Its critics (I’m holding my hand up here) suggest that when it is financed by the industry (opaquely – we do not know who pays what for it), its rules are written and adapted by editors within the industry, and many on the Commission itself are senior figures within the industry, then it is hard to argue that it is genuinely independent. So what would independence mean? Would it mean much broader sources of funding? Would it mean many more stakeholders from outside the industry within its constituent bodies? Would it mean an editor-free Commission? Not easy questions for PCC Plus to answer, or to agree within the industry, but ones which have to be addressed.Greenslade is absolutely right to look for ways to preserve self-regulation. Self-regulation is infinitely preferable to any kind of State control. But any new system has to be able to answer the hard questions, or else it will fail on the same grounds as the previous one.*From the Media Standards