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This paper explores the status of advertising practitioners as cultural intermediaries. It uses that analysis to think through the contested relationship between consumption and production, and culture and economy. Using examples and illustrations from interview data with advertising practitioners in the uk, I explore how the circulation of rhetoric functions as one form of mediation performed by advertising practitioners.
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Cronin- Regimes of mediation advertising practitioners as cultural intermediaries.doc
This paper explores the status of advertising practitioners as cultural intermediaries. It uses that analysis to think through the contested relationship between consumption and production, and culture and economy. Using examples and illustrations from interview data with advertising practitioners in the uk, I explore how the circulation of rhetoric functions as one form of mediation performed by advertising practitioners.
This paper explores the status of advertising practitioners as cultural intermediaries. It uses that analysis to think through the contested relationship between consumption and production, and culture and economy. Using examples and illustrations from interview data with advertising practitioners in the uk, I explore how the circulation of rhetoric functions as one form of mediation performed by advertising practitioners.
Cronin (2004) Regimes of mediation: advertising practitioners as
cultural intermediaries?! Consumption, Markets and Culture! "ol. #! $o. 4! pp. %4&'%(&. Abstract This paper explores the status of advertising practitioners as cultural intermediaries and uses that analysis to think through the contested relationship between consumption and production, and culture and economy. Using examples and illustrations from interview data with advertising practitioners in the UK, I explore how the circulation of rhetoric in the advertising industry functions as one form of mediation performed by advertising practitioners. I argue that practitioners role should not be understood solely in terms of a mediation between producer and consumer! instead, their role should be conceived in terms of a negotiation between multiple "regimes of mediation, including that of the relationship between advertising agencies and their clients. Agencies perform commercial relationships, bringing them into being and constantly redefining them. Attending to these multiple modes of mediation opens up #uestions about the status of advertising, the role of cultural intermediaries, and the relationship between production and consumption, economy and culture. Keywords$ advertising agencies! advertising practitioners! consumption%production! cultural intermediaries! culture%economy! mediation & 'amously identified as a key part of "the culture industry (Adorno &))&*, advertising has been sub+ected to many claims about its power to persuade consumers, disseminate capitalist ideologies and articulate cultural change (e.g. ,oldman &))-! .eiss, Kline and /hally &))0! 1ernick &))&*. & 2espite advertisings place at the centre of debates on culture and commerce, relatively little empirical work has focused on the practices, views and impact of practitioners within the advertising industry (although see 3alefyt and 3oeran -004! 3iller &))5! 3ort &))6! 7ixon &))6, -004! 8later &)9)*. :f these studies, many tend to focus on the role of research in advertising practice, the definition of creative work, and promotional practices of agencies in competition with other agencies (,rabher -00-! ;ackley -000, -00-! ;irota &))<! Kover and ,oldberg &))<! 3iller &))5*. 'ar less attention has been directed at advertising practitioners potential role as cultural intermediaries, and the few existent studies which take this as their focus tend to draw on theoretical rather than empirical sources (e.g. 'eatherstone &))&*. This lack of analysis is particularly striking given the widespread claims about the growth in significance of such cultural intermediaries (e.g. =ourdieu -000! .ash and Urry &))>*. 'or instance, Appadurai argues that even in the simplest economies a "traffic in things has long been established but that this traffic has expanded its scope and social significance in contemporary consumer capitalism$ ?i@t is only with the increased social, technical and conceptual differentiation that what we may call a traffic in criteria concerning things develops. That is, only in the latter situation does the buying and selling of expertise regarding the & I would like to thank the following for reading drafts of earlier versions of this paper and offering comments$ AnneA3arie 'ortier, 7ick ,ebhardt, Adrian 3ackenBie, and Alan 1arde. 3y thanks also to the editors of the +ournal and to anonymous reviewers for their helpful suggestions. - technical, social, or aesthetic appropriateness of commodities become widespread. (&)96, p. <>* 'or Appadurai, the contemporary capitalist moment can be defined (in part* by the circulation and commercial exchange of expertise in the socially appropriate purchase, use and display of commodities. In this understanding, groups that lay claim to skills in this trafficking of value and taste A or expertise in the translation of such values between producers and consumers A will therefore come to play a more prominent part in the economic and social realms. This account is part of a broader trend towards understanding social change by analysing consumption, exemplified by Cierre =ourdieus analysis of taste, consumption and the role of cultural intermediaries such as advertising practitioners. =ourdieu (-000, p. 4&0* argues that "the new logic of the economy distances itself from "the ascetic ethic of production and accumulation and comes to focus instead on consumption and pleasure. 1ith this shift, new social standards are established and new groups gain social and economic prominence. This economy demands a social world which +udges people by their capacity for consumption, their "standard of living, their lifeAstyle, as much as by their capacity for production. It finds ardent spokesmen in the new bourgeoisie of the vendors of symbolic goods and services, the directors and the executives of firms in tourism and +ournalism, publishing and the cinema, fashion and 4 advertising, decoration and property development. Through their slyly imperative advice and the example of their consciously "model lifeAstyle, the new tasteAmakers propose a morality which boils down to the art of consuming, spending and en+oying. (=ourdieu -000, pp. 4&0A4&&* 8imilarly, 'eatherstone (&))&, p. 4<, p. <* argues that these new cultural intermediaries are "specialists in symbolic production and "cultural entrepreneurs and intermediaries who have an interest in creating postmodern pedagogies to educate publics. As cultural intermediaries, the role of advertising practitioners is here defined as the translation or relaying between the purportedly distinct realms of production and consumption$ in educating the masses in the art of consumption and the social distinctions of taste, these cultural workers are thought to mediate between the needs of producers and the desires of consumers. As part of a rising class fraction +ostling for position with more established groups, they aim to legitimise (and indeed intellectualise* their own areas of expertise. - =oth =ourdieu (-000* and 'eatherstone (&))&* frame the increasing importance of cultural intermediaries in terms of the rise of the new petite bourgeoisie and the parallel expansion in demand for expert knowledges to assist consumers in deciphering the increasingly complex cultural terrain. =ourdieus (-000, p. 4&&* account reveals a rather functionalist tendency whereby practitioners D as cultural intermediaries D translate and transmit new ways of consuming through their "slyly - =auman (&)95* make a similar argument, claiming that the traditional role of intellectuals and leaders such as religious figures ("legislators* has been displaced by the new "interpreters such as advertising practitioners. These interpreters offer to the public models of living A ways of conducting oneself A which tend to focus around consumption. > imperative advice in order to align consumers practices with the demands of the new economy. Thus for =ourdieu, practitioners mediate taste and consumption practices in tune with the needs of the system of production$ advertising practitioners are "needs merchants who manipulate consumers needs and wants not through the classic hard sell of oldAstyle marketers, but by importing new subtle techni#ues of domination ("velvet glove methods* from America (=ourdieu -000, p. 46<, p. 4&&*. Eecent studies of advertising have criticised =ourdieus (-000* and 'eatherstones (&))&* analyses on a number of counts. 1hilst 'eatherstone (&))&, p. >0* calls cultural workers such as advertising practitioners "new cultural intermediaries, 7ixon (-004* and 3c'all (-00-a* argue that such practitioners are neither new, nor can their contemporary role be considered significantly different from their role in the nineteenth and early twentieth centuries. 3oreover, 7ixon (-004* argues that "cultural intermediary is a very inclusive category and, as such, lacks the critical purchase necessary to understand the multiform activities of workers such as advertising practitioners. 2espite these #ualifications, advertising practitioners are generally seen as a key mediators. 4 'or instance, 7ixon (-004, p. 4<* argues that "agencies play an active role in helping to constitute and articulate the economic relations between consumers and clients through techni#ues like planning and market research that they mobilise. =ut less sustained attention has focused on the precise nature of this commercial mediation and the detail of its practice. Analyses such as those of 7ixon (&))6, -004* and 3ort (&))6* focus on practitioners (gendered* habitus and the way in which they operationalise their informal knowledges in their commercial practice. This is an important focus which attends to the reproduction of certain classed, 4 1hilst their numbers may be limited, 7ixon and 2u ,ay (-00-* suggest that cultural intermediaries may exert a disproportionately large influence on economic and cultural life. < racialised and gendered workplace practices and illuminates their impact upon the character of the products (advertisements themselves*. =ut this focus constitutes only one element of the complex mix of discursive practices of the industry. It does not offer a precise analysis of the nature of cultural workers intermediation D or mediating role D nor the multiple forms of mediation that coAexist within the promotional imperatives of the agency, the commercial imperatives of their clients, and the personal motivations of practitioners. Fontrary to some accounts, I will argue that the role of advertising practitioners as cultural intermediaries is not restricted to the translation or mediation between producers and consumers! nor is their role limited to channelling tastes in consumption or directing cultural change. The overAemphasis on practitioners mediating role as "taste makers or primary drivers of new cultural trends is exemplified in the disproportionately intense focus on Freatives in the advertising literature (e.g. ;irota &))<! 7ixon -004! 8oar -000*. > This emphasis does not ade#uately address the significance of Account 3anagers, Account Clanners or 3edia =uyers within the industry. < The following section goes some way towards redressing the balance by outlining the multiple mediations involved in the daily practices of agencies. It draws on interview material with practitioners from key .ondon advertising agencies and situates their accounts within the context established by > 7egus (-00-* makes a similar point, arguing against the emphasis on aesthetic forms of mediation in discussions of cultural intermediaries. ;e calls for a more multiAlayered, subtle approach which includes the role of other types of practitioners in the culture industries such as accountants in the music business. < Freatives are art directors or copywriters who produce the ideas for an advertising campaign and the images and the copy (written text*. Account Clanners write briefs for the Freatives outlining the remit and aims of a campaign! they generate the campaigns longAterm strategy, and coAordinate with research companies. Account 3anagers deal with overall pro+ect management and finance, and mediate the agencys everyday contact with the client. 3edia =uyers select and buy media space for the placement of advertisements. 6 other empirical studies of the advertising industry. 6 The following analysis does not assess the status of ad practitioners as cultural intermediaries through a detailed ethnographic account of practices within the industry! such accounts are indeed lacking in the field and their input is urgently needed in order to fully appreciate this complex arena. Instead, the aim of the paper is rather more modest, offering illustrative material from interviews with practitioners as a means of opening up #uestions about the relationship between production and consumption, and exploring certain presumptions in the existent literature about practitioners status as mediators between those realms. F:33GEFIA. 3G2IATI:7 An analysis of the discourses and practices of advertising practitioners and their agencies reveals what I call multiple "regimes of mediation which interlink, overlap, and conflict with one another in complex ways. I will suggest that these practitioners can be considered "cultural intermediaries only when employing an expanded and nuanced definition of mediation that attends to their heterogeneous commercial practices. These multiple elements together constitute a constellation or regime of acts and discourses. In general, the advertising industry is considered an important commercial nexus which functions as a "point of intersection for the ma+or institutional forces such as the media, producers of commodities and services, and consumers (.eiss, Kline and /hally &))0, p. &)&*. In this understanding, advertising 6 This was a smallAscale research pro+ect focusing on ) advertising practitioners in the following advertising agencies! ,rey 1orldwide, :gilvy and 3ather, Cartners =22;, Eainey Kelly Fampbell Eoalfe%HIE and one midAsiBed agency which wished to remain anonymous. Gach interview lasted between & and -.< hours and was conducted in /anuary -00-. 5 practitioners and their agencies are figured as specialists in "mediated communication about selling (ibid., p. &9&*. :f course, all communication is mediated in a broad sense. =ut .eiss, Kline and /hallys (&))0* analysis casts advertising as a special form of mediation due to its intermediary status between producers (of commodities and services* and consumers, and its commercial use of media space as a vehicle for this marketing communication. =ut the many other facets of the mediating role of both advertising and its practitioners attract far less attention. 'or instance, several studies have outlined how advertising and advertising agencies mediate cultural specificity and difference, and the demands and opportunities of globalising markets and media within particular national contexts such as /apan and 8ri .anka (Kemper -00&! 3alefyt and 3oeran -004! 3iller &))5! 3oeran &))6*. 3y analysis, however, will focus on the mundane practices and commercial imperatives of agencies in the UK. The first point I would like to make concerns the significance of analysing advertising practitioners themselves. Typical of textual analyses of advertising, /udith 1illiamsons (?&)59@ -000* classic account of advertisements consistently brackets the significance of advertising practitioners impact upon their products. 1hilst practitioners certainly cannot be said to determine viewers reception of their texts, completely excluding practitioners from the analysis skews understandings of the significance of advertising practice and its textual products. This inattention to the process of production and the influence of practitioners social position and beliefs on this process thus detracts from a full analysis of advertising as an industry. As an industry, it has its own culture and values into which new practitioners are duly initiated (7ixon -004! 3ort &))6*. 'or example, Freatives learn to "act creative, that is, to behave eccentrically, develop 9 "artistic temperaments, and "dramatiBe their personae (;irota &))<, p. 445*. This was certainly evident in my visits to advertising agencies where (male* Freatives played football in the corridors, wore TAshirts bearing pithy and sometimes challenging slogans, and cultivated a very casual, fashionable look. ;owever, the informal feel to agencies belies their fairly rigid gender, race and class structuring and their heterosexist outlook. 5 :ne female 8enior Freative commented that all the advertising agencies she had worked in had been very conservative in their employment practices, reproducing a white, heterosexual, male organisation$ I think were really insular J I think were xenophobic, I think were homophobic. There are twentyAtwo teams in this Freative department and there are > women. Its a boys clubJ In all my years, I think Ive met 4 black Freatives. (8enior Freative &* 8ignificantly, social class is absent from this Freatives catalogue of exclusionary practices, a fact which exemplifies the takenAforAgranted middle class nature of the industry (see =ourdieu -000! 'eatherstone &))&! 7ixon -004*. Fonsidering the social positioning of advertising practitioners is significant for analysing the textual endA products of the industry as it impacts upon the form and content that the 5 Accurate demographic figures about advertising practitioners are difficult to obtain, and my small study cannot be taken as representative. In 7ixons (-004, p. 64* study, many of the agencies personnel had received private education and half of all senior personnel were graduates from elite universities such as :xford and Fambridge. 7ixon (p. 66* cites Institute for Cractitioners in Advertising figures which indicate that <0K of those employed in UK agencies belonging to the ICA were below 40 years of age, and 90K below >0. 7ixon (p. )<* cites an estimate that black and minority ethnic groups constitute &K of the advertising workforce in the UK, whilst women constitute )K of senior agency staff (e.g. managing directors* and --K of board directors. 1omen are overArepresented among secretarial, clerical and +unior administrative staff, with nearly &00K of secretaries being women, whereas the picture is more even amongst account handlers (<>K women* and media buyers (>>K* (7ixon -004, p. )6*. ) advertisements take. 'rom my interviews it became clear that in the process of producing advertising campaigns, practitioners draw on their own experience as viewers of advertisements and as consumers of products (also see 8oar -000*. Indeed, they tend to use selected elements from other practitioners campaigns in producing their own advertisements. 'or example, my respondents often cited other agencies beer advertisements as a source of inspiration (and admiration* when creating their own campaigns. As noted above, the dominant profile of advertising practitioners tends to be young and male, which tallies with the target market for many beer brands. This makes working on beer campaigns, and using others beer campaigns as creative inspiration, doubly attractive$ the youthfulness of the target market legitimises the humorous approach that many clients sanction in their beer ads whilst also making them personally appealing to practitioners as consumers (of ads and products*. As I argue more closely in later sections, this selfAreferential, recursive relationship between practitioners dual status as producers (of ads* and consumers (of ads and products* reproduces social divisions and hierarchies. This is evident in the working practices and ethos of agencies L as the above #uotation makes clear L and in the textual content of advertisements that are generated within this environment. The youthful nature of the practitioners I met in agencies (-<A>0 years old* was significant in another respect. 1hen asked about the age profile of the advertising workforce, one senior practitioner commented$ its perhaps reflective of the way that ?advertisings@ all about contemporary culture and advertising is essentially ephemeral and a lot of it is about L I hate to &0 use the word L BeitgeistJ I think that people who have their finger on the pulse of that tend to be on the younger side. (Account 2irector* This comment points to the relatively narrow ageArange of practitioners but also highlights the way in which culture, and particularly popular culture, is used as a resource by those practitioners. The popular perception is that advertisings mediating role centres on leading cultural trends and directing artistic and commercial change. =ut my interview material casts doubt on the supposedly proactive nature of advertising and instead highlights the ways in which advertising is reactive and relies on siphoning off ideas from culture A practitioners strategically raid new cultural trends they see appearing across a range of sites (fashion, art, popular music, design, television* and put selected elements of them to work in their campaigns. In this alternative perspective, advertising is not the dynamic driver of cultural change! rather it is an industry in which the practitioners are constantly scouring the terrain of popular culture for new ideas, images and techni#ues to meet their clients brief. As one 8enior Freative stated, "I think were five years behind the times. ;ere, advertising does not so much mediate cultural change as feed off, and trade in, cultural changes that practitioners perceive in a number of contemporary arenas. As both producers of ads and consumers of ads and products, practitioners are implicated in a selfAreferential, recursive enactment of creativity, change and consumption. This selfAreferentiality is not restricted to practitioners and their campaigns. Cotential consumers tend to be conservative in their +udgement of what constitutes a good or convincing advertisement, relying on past campaigns as their benchmarks. This has a && significant, material impact on the production of new campaigns. 3any of the practitioners I interviewed complained about the difficulties of carrying out the preA testing of advertisements that is fre#uently re#uired by clients. CreAtesting involves showing the early stages of an advertising campaign, or the storyboard for an advertisement, to focus groups drawn from the general public in order to assess the likely appeal of the finished advertisement. :ne Account 3anager commented that this form of research is unpopular amongst practitioners as focus group members tend to draw on their stock of remembered advertisements when +udging the trial ad$ "Hou go in ?to a focus group@ with a script or a storyboard and consumers will feed back on their current knowledge ... of advertising and they say Moh well, Im not used to seeing thatN (Account 3anager &*. Thus when focus group members assess the ad on the benchmarks established by the familiar stock of existent ads, it becomes difficult for practitioners to introduce new, more "creative, styles of advertisement A clients are often not willing to take creative risks that they perceive may translate into commercial risks. The client firms brand managers are also caught between their status as representative of the producers and their more general status as consumers of products and ads (thus potentially representing the taste of possible consumers of the ad and product*$ "?they@ get very nervous when they first see it ?the ad@ because they dont know how to take it. They dont know if theyve got their client hat on, or their personal hat on (8enior Freative -*. ;ere, the commercial and creative decisions made by the brand manager from the side of production interface with that brand managers personal status and taste as consumer when faced with the #uestion "is this a good adO. This demonstrates the way in which the habitus, generalised beliefs and taste of the brand managers at client firms A as well as those of advertising practitioners A have a material impact upon the type and style of advertisements that &- get approved and produced$ here, the realms of production and consumption can be seen as indistinct and mutually implicated. This all points to the rather conservative, selfAreferential nature of the advertising process and its textual endAproducts. The production process is less a creative blitB than an often tense negotiation between the creative drive of agencies and the commercial imperatives of clients. In addition, it is implicated in consumption tastes and practices of the key actors in complex ways that cannot be separated from production decisions about the advertisement. I explore this relationship more fully in later sections. Cractitioners are also considered cultural intermediaries in relation to their supposed role in disseminating capitalist ideologies. 8ome accounts have launched scathing attacks on the personal motivations and perceived hypocrisies of practitioners. 'or example, 8oar argues that the discourse of creativity functions as a kind of "ideological smokescreen$ It shields the intermediaries, particularly ad creatives, from the potential epiphany that their endeavors may merely be the prosaic, artless instruments of capital accumulation, and it deflects societal scrutiny away from the selfAsame discovery, planting it instead in the everAattractive spectacle of charisma, showmanship and entertainment. (-000, p. >4-* 'rom another (e#ually critical* angle, =ourdieu (-000, p. 466* argues that advertising practitioners L or "intellectual lackeys L develop a language of +ustification for their commercial practices and social role. 'or =ourdieu (ibid.*, many cultural &4 intermediaries are leftAwing individuals who are "inclined to sympathise with discourses aimed at challenging the cultural order and, thus, in order to "accept their ambiguous position and to accept themselves doing so, they are forced to invent the skilfully ambiguous discourses and practices that were, so to speak, inscribed in advance in the very definition of their position. As the context of =ourdieus analysis was the 'rench activism of &)69, it is understandable that he should emphasise the paradoxical relationship between the intermediaries commercial and ideological function and their social%political commitment. In a contemporary =ritish context, however, any sense of social responsibility and associated selfA+ustificatory strategies take on a very different character. Amongst the practitioners I interviewed, none saw his or her role as socially problematic in a general sense. 9 3oreover, there was no evidence of the swaggering bravado that 8oar (-000* identifies. All the practitioners in my study were highly selfAreflexive about the nature of their +ob, and were critical of the selfA+ustificatory discourses that they say are common amongst their peers. =ut these +ustifications were not based any sense of advertising as a socially corrosive force, but on practitioners own experience of the banality of the advertising industry. Gveryone in advertising likes to think that theyre fantastically creative and its an industry up there with writing and filmAmaking and other creative industries, but it isnt L its +ust selling things J =ecause advertising is supposed to be creative and it isnt always that creative and it isnt making films and it isnt being in a rock band, I think you get a lot of people trying hard to +ustify to themselves why theyre involved in it ... when people do leave and go and do 9 8everal practitioners, however, were ambiguous or explicitly negative about tobacco advertising although, interestingly, not about alcohol advertising (see Fronin -00>*. This suggests that practitioners do not perceive advertising in general as socially detrimental, but focus their ob+ection to tobacco advertising on its reference to a dangerous product. &> something thats perceived as more meaningful like academic study or psychology or going travelling or whatever, everyone goes, "oh, thats fantasticP Thats so brave. Im going to do something like that. Im going to get out. 8o youve got this weird selfA+ustification and insecurity thing about people in the advertising industry, because ultimately they are +ust making ads. (Account 3anager &* This account certainly deflates the glamorous, creative image that is so often associated with the advertising industry. It also points to the complex ways in which practitioners think about their +ob and their social role. This is significant as it impacts in important, material ways on the nature of the ads they produce and their motivations for taking certain creative approaches to a brief. 'or example, a key element of the dayAtoAday practices of agencies is the negotiation between client and agency in terms of the initial sketches or storyboards for a campaign. This is a tense moment both for the agencys Freatives and for the clients brand manager. It is mediated with great care by Account 3anagers with due regard for the clients anxieties about creating a successful campaign and Freatives concerns about maintaining what they see as the artistic "integrity and commercial impact of their approach. The Account 3anager takes the clients comments back to the Freatives and presents the criticisms, comments and ideas as diplomatically as possible. As one Account 3anager put it, "In terms of the creative process, theres always a lot of J heated debate in terms of taking the clients comments and trying to maintain the integrity of the work (Account 3anager -*. 'rom the Freatives point of view, this is the moment at which their artistic vision is vulnerable to "interference from the client$ &< 1e get anxious when the ad leaves our layout pads and goes to the client and its out of our hands and the account people have taken it off us. Its that time when were waiting for the debrief when they go, "weve got a few client comments, a few little comments wed like to address. (8enior Freative 4* As another Freative puts it, the perception is that the brand managers are under pressure from their superiors to include too many elements in the advertisements message, thus detracting from its overall impact$ Theyre probably putting something in because their boss told them to put something in. 8o we put it into the advert and instead of telling the punter one thing, were now telling them three things. =ut the one thing is strong and the three things dilute it. (8enior Freative -* The "dilution of the advertisements visual impact is significant for the Freatives as they gain considerable +ob satisfaction from producing what they consider to be innovative, artistic ads. =ut it is also significant as Freatives are additionally motivated by the lure of winning creative awards such as the UKs prestigious "2IA2 (2esign and Art 2irection* awards. These offer personal recognition and status$ "Its like having a medal after youve been to war ... you did something and youve got something to show for it (8enior Freative -*. This is particularly significant for them due to the ephemeral nature of their artistic creations$ "Hou dont really have an end product, not like car designers who can point to a car on the road &6 and say MI designed thatN... all our stuffs tomorrows chip paper (8enior Freative 4*. :f course, winning awards also translates into increased salary, status and enhanced career opportunities. This example of the negotiation of the draft or storyboard of a campaign demonstrates how practitioners such as Account 3anagers mediate between the agency and client, but also mediate between the clients criticisms and the Freatives artistic sensibilities. It also supports my earlier point that practitioners own habitus, tastes and (artistic and careerAoriented* motivations impact upon the style and content of the finished advertisements. Another important mediation that is evident in my interview data is the very medium through which practitioners present their views on advertising. 3any of the accounts draw on and recirculate advertising "folklore and a cannon of axioms and modes of expression, for example$ "Freativity for creativitys sake is worth nothing (Account Clanner*! "8uccessful advertising is very true to the brand or the product (Account 3anager -*! "3y +ob is to tell consumers what they want next (Account 3anager -*. These discourses on advertising are drawn from multiple sources, including pep talks by their bosses, the trade paper Fampaign, and books by the "great men of advertising such as =ullmore (&))&* and :gilvy (&)6>, &)94*. This circulation of modes of understanding the role of both advertising and practitioners within the industry itself constitutes a "regime of mediation$ it mediates practitioners presentation of the industry and their articulation of their identities to themselves. This is not to suggest that practitioners accounts are false or distorted, but rather indicates that the circulation of these axioms and promotional epithets are part of the very &5 currency that constitutes the commercial relationships between agencies and clients, as well as the very habitus of practitioners themselves. This "advertising talk is part of agencies response to commercial imperatives re#uiring them to constantly promote their role and skills to potential clients, and functions to make the advertising world turn. I have explored both these issues in more detail elsewhere by focusing on what I call practitioners "promotional beliefs (Fronin -00>, p. 6&*, and I give more consideration to the issue in the next section. The point I would like to emphasise here is that any analysis of advertising practitioners as cultural intermediaries must broaden its scope to encompass more than their assumed role in mediating between producers and consumers. Analyses should include the multiple regimes of mediation that occur in the everyday commercial practices of agencies. These include the mediating role of media buyers in agencies who broker relationships with specific media sites (e.g. television, radio, cinema, outdoor advertising companies*! the complex and sometimes fraught mediation of conflicting approaches that occurs in any one campaign between individual Freatives, Account 3anagers and Account Clanners! the mediation through advertising axioms of practitioners own selfA understandings! the mediation Account 3anagers effect between clients and agencies! the mediating role Account Clanners take when commissioning, analysing and "translating commercial data from research companies into usable ideas for campaigns! the role that such Clanners play in imagining and constituting specific (ideal* "market segments and incorporating them into advertising strategy and endA products (advertisements*. The following section offers the beginnings of such an analysis by focusing on +ust one of these regimes$ the form of commercial mediation that agencies foster between themselves and their clients. &9 T;G F:33GEFIA. EGA.38 :' A,G7FIG8 A72 :' T;GIE F.IG7T8 Theorists have claimed that the significance of cultural intermediaries such as advertising practitioners is growing in contemporary societies ('eatherstone &))&! .ash and Urry &))>*. =ut if this claim about the augmentation of their role is correct, it is centred not only on a growth of a "traffic in criteria (Appadurai &)96, p. <>*. It also derives from a multiplication of commercial mediators such as advertising practitioners to include management consultants and, more recently, branding consultants. This expansion of institutions offering expert knowledges to producers represents for advertising agencies increased competition and, as my interview data reveals, impels them to engage in more intensive promotional practices (also see 3alefyt -004! 3iller &))5! Kover and ,oldberg &))<*. These efforts are oriented firstly, towards promoting advertising as an efficient commercial tool (in competition with other promotional forms such as branding events, packaging and distribution etc.*! and secondly, towards the selfApromotion of individual agencies +ostling for business in a crowded market place. To compound the uncertainty and highly competitive nature of this context, advertising has to address the problem of demonstrating its commercial efficacy. The indeterminacy of advertisings effects on sales has long been recognised by agencies and their clients, and this places added stress on agencies to promote themselves as skilled creative and commercial practitioners who will generate successful campaigns (see Fronin -00>! .ury and 1arde &))5! 3iller &))5! 8chudson &))4! Tunstall &)6>*. 3oreover, practitioners find themselves in a position of chronic uncertainty with regard to their clients who are perceived as fickle and wont to change agency without warning (Kover and &) ,oldberg &))<*. Agencies respond to these challenges by promoting their skills and by presenting themselves as experts, particularly as "experts in communication (Alvesson &))>, p. <>4* and experts in researching and "delivering the consumer. 8ome academic accounts have argued that advertising practitioners deployment of research techni#ues operates an efficient panopticism on consumer behaviour, conducting "a disciplinary surveillance on consumer culture (;ackley -00-, p. --6*. ;ackley argues that, "the surveillance, categoriBation and interpretation of consumer data by advertising agencies represents a significant dynamic driving advertisings ideological force (-00-, p. -&4*. =ut this emphasis, I think, misses the crucial point about agencies deployment and reinvention of such techni#ues. As 'oucault (&))&, p. -0-* has argued, panopticism "automatiBes and disindividualiBes power$ in effect, anyone can operate the technologies of panopticism. Thus, such research techni#ues do not in themselves guarantee specific agencies an advantage in promoting their commercial skills to potential clients. =ecause anyone A including client firms themselves and rivals such as management and branding consultants A can operate such techni#ues, individual agencies must expend even greater effort in attempting to persuade potential clients of the benefits of employing them. All these factors combine to pressurise agencies into refining or "rebranding their role as intermediaries between producers (who, practitioners claim, lack the necessary creative skills and branding experience to promote their products* and consumers (who, so the pitch claims, are difficult to reach and persuade without the aid of agencies commercial skills*. 'or example, one of my interviewees claimed that in response to such pressures, his agency was redefining its role as an expert in branding rather than an expert in other areas traditionally associated with agencies, e.g. -0 consumer research. :ne important sideAeffect of this manoeuvre to promote advertising agencies as indispensable intermediaries between producer and consumer is to reinforce the perception L amongst clients, agencies and indeed academics L that the realms of production and consumption are strictly distinct. ;ere, agencies active mediation of discourses of commercial legitimacy has a constitutive effect$ theirs is not a passive role, merely relaying and channelling flows of ideas and finance between different commercial realms. Eather, practitioners actively enact or constitute the commercial realm and the perceptions of the relationship between its multiple elements. Another element to practitioners mediating role is their management of clients anxieties and conservatism with regards to innovative campaigns. 'rom practitioners point of view, clients (like the members of focus groups* are very conservative in their +udgement of advertisements and tend to favour familiar advertising formats and styles. In effect, clients are producers (of commodities and services*, but it is also their status as consumers (of ads and products* that orients their commercial decisions about how their advertisements should look. To illustrate, one Account 2irector discussed the problems of managing car campaigns$ I think it has become more difficult, not only because of regulation, but partly because of the problems with being creative, original J car ads all look the sameJ and thats partly because all car manufacturers expect the same sort of thing for their advertising. 8o for example, the cars must look fantastic with lots of camera time spent on the car J the hero of the whole thing has got to be the -& car and it has to be in a great location. Its getting to the point that theyre all being set in the same place, starring the same people, doing the same thing. (Account 2irector* As car campaigns tend to be very expensive, the brand manager or contact person from the client firm is anxious to get the advertising right and thus relies on other companies car advertisements as a touchstone for good or effective advertisements. Additionally, changes in the productAtype alters the information that the advertisement is re#uired to present and this makes the agencies task of brand differentiation more difficult. 'inancial advertising is notoriously difficult to work on because, again, everyone wants to say the same thing. There are certain things that suddenly become very important L over the last few years its been about flexibilityJ so everyone ?clients@ wants to do the same thing like sheep. They all lurch off in the same direction. It becomes really difficult to differentiate brands in that sort of arena. (Account 2irector* =ut more generally, clients conservatism is manifested in a desire for familiar advertising styles and formats, ones they have viewed from their position as consumers. 1hen asked about the most anxietyAprovoking stage of the advertising process for the client, the 8pokesperson for the Institute of Cractitioners in Advertising said$ -- The moment a client is most terrified is when theyre given a script or when theyre shown a press advertisement, because most people dont know whether its good or bad. And if that advertisement is novel, challenging, brave, then unless that client is extremely selfAconfident ... theyre being asked to make a +udgement on something which is going to cost a lot of money to make. (ICA 8pokesperson* ;ere, as in previous sections, the recursive implication of advertising practice is evident in clients internalisation of what constitutes a good (or "safe* advertisement. ) Cractitioners have therefore played a significant role in mediating clients views of "good advertisements prior to an agencys pitch to that client for a new campaign. Crevious advertisements thus constitute a "cannon or a familiar lexicon of advertising style and content which orients clients (and indeed practitioners* understandings of appropriate or effective ads. In the above analysis, there is a clear interArelationship between the consumption of cultural artefacts (images, signs*, cultural practices (e.g. watching television programmes that are liberally interspersed with commercials*, and commercial decisions of clients. This indicates a complex relationship between consumption practices and production decisions. =ut the significance of such relationality between commerce and culture must be analysed with caution. 1arde (-00-, p. &9<* identifies, and problematises, a growing number of social science accounts that posit an increasing "culturaliBation of society, for instance, studies that argue that culture is playing a more important role in the economic. ;e explains this culturalising trend by ) A decision about what constitutes a "safe advertisement clearly draws on notions of risk. This is an area which has been explored most notably by =eck (&))-*, but a discussion of his complex thesis goes beyond the scope of this paper. -4 the parallel growth in analyses of consumption and its relationship to production, and particularly in the way in which many such analyses assume that consumption is becoming "more cultural, that is, becoming more oriented around sign values and symbolic gains than use values and the satisfaction of needs. 8everal points can be drawn from 1ardes insights. An increase in academic interest in "culture risks figuring a parallel growth in significance of "the cultural in the world (of commerce or of consumption* that academics are analysing (see also 3iller -00-b*. This potential solipsism of academic analysis also risks positing an augmentation in the importance of cultural intermediaries to mirror the purported rise in significance of culture. This academic "worldAmaking impelled by intellectual interest A and the institutional demands to publish "new arguments A functions in a parallel way to the "worldAmaking of advertising practitioners driven by commercial imperatives to promote their skills to potential clients. /ust as advertising practitioners perform a division between the realms of producers and consumers by claiming competencies in translating between the needs of the first and the desires of the latter, so also some academic analyses perform a division between culture and economy, or culture and commerce. &0 Eegistering these cautions, I would claim that my analysis points to the inextricable relationality between elements and motivations standardly termed "cultural and those standardly termed "economic or "commercial. As 8later (-00-, p. <)* argues, these categories are "logically and practically interdependent$ "producers cannot know what market they are in without extensive cultural calculation! and they cannot &0 In the UK, the current government pressure on universities to establish more formal links with "users such as local government, museums and schools, and to produce "useful research that can be deployed by industry, points to the ways in which =ritish academics are being positioned as "intellectual intermediaries between academic analysis and "the real world. -> understand the cultural form of their product outside of a context of market competition (see also 3c'all -00-b*. In this framework, it makes little sense to claim that society is becoming "more culturalised or that the role of cultural intermediaries is becoming more significant in any straightforward sense. This would imply that the realms of commerce and culture that they are supposedly mediating are either drifting apart, and therefore re#uire more intensive suturing together! or that they are merging into one, large "culturised formation, thus foregrounding the role of cultural intermediaries in directing tastes in "cultural consumption. Gither scenario presumes that the realms of commerce and culture were once separate (although linked by a traffic in commercial imperatives*. Instead, my analysis suggests a complex, provisional and contested nexus of motivations, practices and imperatives centring on practitioners engagement in "trafficking commodities and services, their marketised exchange, and the role of advertising in framing their value. These motivations and practices are not merely set within a cultural context or within an economic context$ they function to constitute that very context. The following section explores this formation and draws together the multiple elements of this article to consider advertising practitioners status as cultural intermediaries. 3G2IATI:7 :' 8:FIA. F;A7,G 3any accounts have identified the mediation of social change as a key element of advertisings role. Analyses such as that of .eiss, Kline and /hally suggest that advertising practice L e.g. research and audience segmentation L and advertising -< products (the textual artefacts themselves* function to mediate, organise or structure social and cultural shifts$
through research ?advertising@ appropriates the social structure of markets for goods and audiences for media, and recycles them as strategies targeted towards segments of the population. Thus, advertising is a communications activity through which social change is mediated L and wherein such change can be witnessed. (&))0, pp. &)-A&)4* 8uch broad statements gloss the more complex interactions that actually comprise such "mediations. Advertising practitioners certainly work on and manage what Appadurai (&)96, p. <>* has called the "traffic in criteria about goods in ways that frame taste or the "appropriateness of certain goods and brands. Fallon et al (-00-, p. &)6* call this "the #ualification of products A a process which classifies products according to relations of similitude (or substitutability* and dissimilitude (or singularity*. This is a dynamic process which continually #ualifies (defines* products and re#ualifies them according to an array of factors such as input from consumers. Cractitioners role in producing ads for financial products, for example, involves a re#ualification of type and class in order to establish a particular products place in a very uniform marketplace of such products. In this new service industry regime A what Fallon et al call "the economy of #ualities A cultural intermediaries or economic agents such as advertising and marketing practitioners become increasingly significant due to their central role in #ualifying products (Fallon et al -00-, p. &)5*. This is a contentious claim which I have addressed in the previous section. 3y -6 concern here is with practitioners "#ualification or management of criteria about goods. This is not restricted to the organisation of types or classes of products and brands, or of consumers taste! it also involves organising the commodity candidacy of things which relies on "criteria (symbolic, classificatory and moral* that define the exchangeability of things in any particular social and historical context (Appadurai &)96, p. &>*. This includes framing the acceptability of entering certain classes of thing into an arena of marketised exchange. This process is most evident in controversial examples of trafficking in things, such as the contested acceptability of the marketised exchange of human organs. Advertising practitioners process the criteria of things for the commodities and services they are employed to promote. They do not +ust finesse the useAvalue and enhance the exchangeAvalue of products by brandAbuilding! they facilitate the entry of those products or services into particular regimes of exchange. && As I have argued, practitioners role is not a simple mediation between "commerce and "culture, between producers and consumers L it is, rather, an active structuring of classes of products and their relationships to forms of exchange. This commercial practice classifies and reclassifies in a dynamic way, making and remaking the relationships between different types of product, between brands, and between consumers and those products. It has also been claimed that advertising functions to mediate the legitimacy of consumer capitalism. 'or instance, 8chudson (&))4* has argued that advertising operates as a form of "capitalist realism that offers images of life not as it is, but life as it should be according to capitalist ideals. In such understandings, advertising has an ideological function of naturalising and disseminating capitalist principles of social && 8ee ;araway (&))5* for a discussion of the creation of commercial relations between people and things, and between categories of things, with regard to genetics and branding. -5 organisation$ it is politically implicated in transmitting certain capitalist ideals about the legitimacy of social structures based on private ownership and exchange. An Account Clanner in my study made an interesting point about advertisings supposed function of dissimulation in relation to the famous case of ,erald Eatners chain of +ewellery shops in the UK. &- Theres that belief that people are meant to believe Q when notAQ is the case. =ut those cases are few and far between. 1hen people are genuinely lied to, when people are utterly misled L its really hard to point to those cases. The paradox with branding is that people actually #uite like being misled L the famous Eatners case. If you ever thought about it you must have known the stuff was crap. =ut whole point was that people wanted +ewellery without paying money and Eatners magic was that he said "you can have +ewellery without paying the money. JAnd they bought it and it was hugely successful, and if it wasnt for that one incident, hed be hailed as a marketing and business genius. =ut he went out and said "youre stupid to believe in my products and people said, "Im not letting you call me stupid, so I wont buy your products. ;e broke his own magic. =ut he didnt tell them anything that wasnt true ?about the product@ L it was public, everyone knew it. There was no deception in what Eatner did J The point in that is that people wanted to believe in it. (Account Clanner* &- ,erald Eatner owned a large chain of lowAcost +ewellery shops across the UK. In a &))& speech to The Institute of 2irectors, he famously remarked that his +ewellery was "positioned as very downA market, that it had "very little to do with #uality, and that his +ewellery was, in fact, "total crap. ;is comments were widely reported in the press with the result that an estimated R<00m was wiped off the value of the company. The case has since become part of business folklore. -9 This Clanner maintains that advertisings role is very rarely that of straightforward deception and that consumers are complicit in its "mythAmaking processes. ;owever, my understanding of this commercial anecdote differs from that of the Clanners in that I do not believe that it exemplifies consumers desire to be misled or a willingness to play along in any une#uivocal manner with the illusion that advertising and branding offer. In relation to the Eatner example, consumers invested in the imaginative alchemy that made it possible to buy "valuable +ewellery at such low cost despite their underlying, unarticulated understanding that the "bargain was less than magical. Indeed, the bargain between the producer A Eatner A and the consumer was to suspend any discussion or investigation of price and #uality, and instead to focus on the value of the product to consumers. &4 This value is multiple and is not illusory in any simple sense$ it lies in the +ewellerys symbolic status, its function as gift, its use as a "treat etc.. In this sense, the price or cost of the +ewellery did not directly relate to the +ewellerys value for the consumer$ its value was embedded in the variety of social functions and symbolic regimes that the +ewellery articulated. Thus there was no lie or deception in its branding and advertising! +ust a pact which was broken by Eatners negative articulation of price in relation to value and his condescension to his customers. This "mythAmaking is often articulated in relation to brands, and many of the practitioners in my study talked about brands as organising tropes which rendered the consumers environment predictable and secure$ &4 8ee 3iller (&))9, -00-a* for a discussion of the embeddedness of "value in social relationships and social practices. -) 1hat advertisers do is ... work with meanings, and the things that bear those meanings are brands ... Its very hard to imagine a world without brands because they give a great deal of consistency and reassurance and safety to the world ... =rands make the world more likely to go on being the same. (Account Clanner* In this account, brands offer stability and reassurance to consumers in the world of products, helping them make increasingly difficult choices between very similar products. In this way, this Clanners comments tally with the analysis of Fallon et al (-00-* who argue that cultural intermediaries "#ualify or set a frame of definitions around a product. =ut the Clanner also suggests that brands render consistent the world outside the realm of products and help consumers navigate their lives through the flux of contemporary capitalist society and make sense of conflicting, overlapping social processes. Fontrary to some accounts which argue that advertising agencies and producers render the world predictable and reassuring for (anxious, undecided* consumers, .ury and 1arde (&))5* suggest that advertising agencies play on producers anxiety and insecurity when faced by a world of unpredictable consumers by offering their commercial skills as a corrective. I would push this analysis further and argue that the above #uotation also points to the ways in which brands and branded products make the commercial world more predictable and manageable not only for the consumer and producer, but also for the advertising agency. 8o whilst agencies mediate between producers and consumers by "activating or "animating branded products A attaching meanings and potential emotional responses to them A the existence of brands makes 40 the commercial world more stable and navigable for advertising agencies. :n one level, brands facilitate agencies task of differentiating products and services in a commercial realm that is densely populated by competitors products, and whose task is hampered by conservative clients who wish to commission campaigns very similar to existing ads. Thus, on another level, brands function as commercial signAsystems that mediate the commercial legitimacy of agencies. They provide a tangible site around which agencies claims to that commercial legitimacy and creative expertise are centred. =rands, then, should not be understood simply as tools used by agencies to mediate ideas about products to consumers$ a brand functions as an organising nexus, drawing together and articulating the commercial imperatives of agencies, practitioners role in "#ualifying products, and consumers imaginative investment in their potential relationship to the product. I have argued that advertising practitioners role as cultural and commercial intermediaries is more complex than commonly supposed and operates in terms of multiple regimes of mediation. =y focusing on one such regime L the relations between client and agency L I have attempted to demonstrate the multiple commercial imperatives of agencies and of clients, and the ways in which practitioners mediate these numerous and sometimes conflicting interests. This form of intermediary activity can be seen in terms of Eaymond 1illiams (&)99* account of mediation as conciliation L that is, a drive to reconcile adversaries or an interestAdriven attempt to suture fields. Agencies expend considerable time and money in this attempt to suture or articulate certain realms, such as that of the clients interests in selling and the potential consumers interests in buying. =ut this is not to argue that the realms of production%commerce and consumption%culture should be characterised as separate. 4& Het, practitioners efforts to persuade clients that they have the skills to reach out to the "cultural consumption realm of the consumer paradoxically reinforces the common perception that the realms of production and consumption are strictly distinct. In effect, practitioners selfApromotional claims about their intermediary status performs a division between producers and consumers, and commerce and culture. In claiming mediating skills that can render the "cultural realm of consumption knowable and available, practitioners perform what .atour (&))4* would call an act of division between the inextricably linked Bones of consumption and production. In addition, by failing to recognise the mutually implicated status of practitioners and of client brand managers as both producers (of ads and products, respectively* and as consumers (of ads and products* in their everyday lives, the realms of production and consumption are again figured as strictly distinct. This division is reinforced, and constantly made and remade, by the integration of commercial imperatives and beliefs about advertising into the practices of advertising practitioners and their clients. In effect, the division is acted out or performed. =y circulating claims and selfApromotional rhetoric, agencies attempt to institute specific regimes of exchange between themselves, clients and potential consumers that are based on the currency of their purported skills and expert knowledges. They try to ameliorate their unstable position in a highly competitive market by establishing this currency of skills around branding, creativity and claims about their capacity to effectively reach their clients target market. As part of this operation, practitioners engage in a "traffic in criteria about products (Appadurai &)96, p. <>*. =ut they do not merely differentiate similar products with the aim of promoting one over another! they actively order or class types of thing, and define their status as commodity. In a 4- subtle and complex form of mediation, they bring goods and services into a finely calibrated regime of marketised exchange. I have given examples of this ordering of classes or types of things in relation to practitioners management of accounts for financial products. ;ere, very similar products re#uire differentiation in the market, but the "traffic in criteria also operates at more profound levels. =randing and advertising attempts to order and reAorder classes of commodities, for example in advertisings active management of the distinctions between medicines, nutritional (or "health* supplements, and food. ;ence, some yoghurt drinks are now being marketed as having health or medicinal benefits in a reclassification of their conventional status as (nutritious* food to a new status as food supplement or even medicine. :n a more radical level, I have also noted that advertising can work on reclassifying the parameters of acceptable marketised exchange, for example by attempting to enter certain classes of materiality, such as human organs or eggs, into the status of commodity and hence into the realm of legitimate market exchange. Thus, the account I am offering here nuances the supposedly axiomatic statement that advertising practitioners channel or transmit cultural change. In my analysis, practitioners can be seen as trying to establish frameworks for defining or "#ualifying products and consumers in relation to specific forms of marketised exchange. =ut such attempts to establish marketised relations of exchange (of knowledge, of commodities* does not necessarily mean an increasing commodification of the social or a triumph of a particular form of capitalist exchange. Eesponding to Fallon et als (-00-* characterisation of expanding marketisation (and parallel expansion of intermediaries*, 3iller (-00-a* argues that the representation of such marketisation in, for example, marketing rhetoric should not be mistaken for individuals actual 44 practices. Ceople are not compelled to order their transactions within capitalist models! in fact, ethnographies which track embedded social practices demonstrate the complex ways in which individuals and groups orient their consumption practices and exchanges in very different ways. These may run parallel to dominant capitalist frameworks but are not determined by them (3iller -00-a*. 'or Fallon et al (-00-*, marketised exchange constitutes the frame within which we act in capitalist society. =ut for 3iller (-00-a, p. -->*, "what lies within the frame is not the market system as an actual practice, but on the contrary a ritualiBed expression of an ideology of the market. 8o whilst advertising processes, practices and products (advertisements* are often read as part of a superAefficient commercial tool for channelling and stimulating consumption practices within a particular regime of exchange, their actual status and impact is rather more ambiguous and modest. The advertising process is more disarticulated and contingent than is commonly portrayed A advertising practices do not translate automatically into increased sales for a product or service (see 8chudson &))4*. 7or can advertising practitioners be said to lead or direct social or cultural change L their practices are more reactive than proactive. Adapting 3illers (-00-a* insight, it is possible to understand advertising practitioners role as that of trading in ideologies of the market, but not +ust in the sense of promoting ideologies of consumption to consumers. Cractitioners mediate understandings of exchange of branded products to clients and attempt to trade in expert knowledges about consumers. Indeed, I would argue that the imperatives, rhetoric and practices of advertising agencies emphasise the contested and provisional status of marketised exchange rather than its unambiguous triumph. 3arketised relations of exchange must be continually performed, worked and reworked because the ideologies of such exchange presented by advertising do not wield enough power to permanently fix 4> consumers beliefs and practices. As in the example of Eatners +ewellery, the ideologies of exchange and possession do not fully explain why people bought the +ewellery and do not fully explain why they stopped buying it. This is because such understandings, whether deployed by advertising practitioners or by academics, do not ade#uately appreciate the embedded nature of values in social practices that are not fully determined by marketised exchange. Advertising practitioners must negotiate these tensions and in doing so continually invest considerable effort and time in attempting to manage brands and promote products L indeed, it is well known that many new products launched on the market fail (8chudson &))4*. Advertisements and products are constantly appropriated by consumers, and their meanings and social function reworked. Cractitioners attempt to manage these practices and simultaneously aim to promote their "#ualifying skills to potential clients. In this way, agencies perform relationships through multiple regimes of mediation, bringing those relationships into being and constantly redefining them. These relationships incorporate and rework practices, motivations and ideals that are conventionally called either "cultural or "economic, but cannot in practice be isolated from one another. 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DEPARTMENT OF HOMELAND SECURITY U. S. COAST GUARD STATEMENT OF MS. TERRI DICKERSON DIRECTOR, COAST GUARD OFFICE OF CIVIL RIGHTS ON THE COAST GUARD’S CIVIL RIGHTS PROGRAM BEFORE THE COMMITTEE ON TRANSPORTATION AND INFRASTRUCTURE SUBCOMMITTEE ON COAST GUARD AND MARINE TRANSPORTATION U. S. HOUSE OF REPRESENTATIVES APRIL 1, 2009