Last week saw NPR CEO Vivian Schiller resign after the organization’s chief fundraiser was caught in a hidden-video sting seemingly calling the Tea Party racist, Republicans stupid, and declaring that NPR would be better off without government funding. The sting was the latest imbroglio for the broadcaster in the lead-up to what will be a tough fight in a congress flush with representatives baying for the CPB’s blood and treasure. We thought it would be interesting to see how public broadcasting controversies play in other countries.

Unlike NPR, the Australian Broadcasting Corporation (ABC)—which includes television, radio, and online—is fully and directly funded by the Australian government (bar for a small slice of revenue from retail sales at ABC stores); like NPR, it is frequently the subject of right-wing attacks. Assistant editor Joel Meares spoke to the ABC’s Jonathan Holmes, host of twenty-year-old media watchdog show Media Watch, about the NPR situation, the difference between public broadcasters in the U.K., Australia, and the U.S., and why he couldn’t work for PBS. This is an edited transcript of that conversation.

What did you make of the way that NPR was stung in this situation, and the way the organization responded—by firing CEO Vivian Schiller?

I haven’t been reading everything written about the situation, but I’m a little bit surprised because there’s no suggestion that she was actually involved in that meeting. Clearly, the whole thing is a classic example of entrapment, which in all honesty would not be legal in Australia (although you could justify it in public interest terms, possibly). All states in Australia have a law that used to be called the Listening Devices Act and nowadays is called the Surveillance Devices Act that applies to cameras as well as microphones. It basically says you cannot secretly record a private meeting and use that recording to do a public report without the consent of all people. There is a public interest defense: Someone would have to argue it was in the public interest, but the courts are very strict about that. That kind of entrapment is very rare in journalism in this country.

Australia’s two big tabloid news-magazine shows, Today Tonight and A Current Affair, don’t use hidden cameras?

No, they don’t, and for precisely this reason. There was a very recent case here that shows this—though, mind you, it’s not perfectly comparable. A seventeen-year-old girl was having an affair with a football coach—and football in Melbourne is far more important than politics. This guy had very unwisely gotten involved with this girl who had previously been involved with some of his players. She videoed him and tipped off The Herald Sun, the biggest newspaper in Melbourne, and the reports were all based on these recordings that were made without his knowledge. It would have been illegal to use them. Eventually, people did use them, but only after the story had been rumbling along for several days. So far, nobody has taken either the girl or the television station that finally used these shots to court. They were very concerned at the time that it was illegal to do it.

So there is that constraint. In the NPR case I suppose you could argue that there’s a much clearer public interest. We’re talking about a partly publicly funded institution. That kind of deception and entrapment, which is used all the time in the U.K., would be very dodgy if done in Australia.

That’s a legal difference. But is there a difference in the political nature of the U.S. and Australia that changes the dynamic of the attacks on a public broadcaster?

It might be clearer from this distance than when you’re in the middle of it, but the degree of political divide in the United States is and has been for many years far more dramatic than in most other Anglophone countries. The consequence of that is that organizations like NPR and PBS, which are publicly funded and expected to be in the middle of the fray to a greater degree than the mainstream media, have an even greater difficulty than the classical mainstream media.

Joel Meares is a former CJR assistant editor.