That is. There's are more fundamental related point. Part of this is about efficiencies. You do want a system which doesn't involve too many cases going through formal adjudication, and you want a system which is accessible to complainants, also those that can't fund huge costs, but you, at the same time, want a system which does establish some pressure for culture change, some pressure for a behaviour change. The consensus is that the Press Complaints Commission was a complaints-handling body but it didn't really establish those pressures for culture change.
So whilst, lower down the pyramid, larger numbers of complaints will indeed be handled by press councils, ombudsmen, different forms of accountability mechanisms -- much larger numbers of complaints -- it's also essential that somehow in this system, mediation and settling of those complaints isn't something which is just simply under the radar, as I think did happen in the Press Complaints Commission, but it is brought somehow into a system where complaints are understood and addressed and monitored in ways which stand some chance of then impacting press behaviour and development of journalism ethics and practices.
So whilst, lower down the pyramid, you do want alternative accountability mechanisms, you at the same time need to design a system which creates incentives to change.