Sylvia
Harvey, Professor of Broadcasting Policy, University of Lincoln,
Principal
Associate Director,
Arts and Humanities Research Board Centre for British Film and
Television Studies
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Citizenship,
Culture and Public Service Broadcasting
1.1. We
welcome the opportunity to respond to the first phase of the Ofcom
review of public service television broadcasting and we support the
concept of an evidence-based approach to the framing of public
policy. We also welcome the detailed factual and statistical
information contained in the document Is Television Special? (ITS)
and in its accompanying annex documents (made available on
CD-ROM), in particular the sections on audience opinions and on
viewing behaviour. 1.2.
However, we are concerned that - in bringing forward its own
propositions - Ofcom may have given too much weight to market
expansion arguments and too little weight to public interest
arguments. In particular we think that Ofcom appears to be
downgrading the central role that public service broadcasting plays
as part of the infrastructure of citizenship in a modern democracy
(1). 1.3. We
believe that the second phase of Ofcom’s review of public
service television should more adequately reflect the brief outlined
by Parliament in the 2003 Communications Act. For the purposes of
this discussion we think that the three key legislative requirements
are that Ofcom has a duty to:
‘further the interests of citizens in relation to
communications matters’ (Clause 3 of the Act) ‘secure…
the availability throughout the United Kingdom of a wide range of
television and radio services which (taken as a whole) are both of
high quality and calculated to appeal to a variety of tastes and
interests’ (Clause 3) review
the work of public service broadcasters ‘with a view to
maintaining and strengthening the quality of public service
television broadcasting in the United Kingdom’ (Clause 264). 1.4. It is
because of these concerns about the fulfilment of the parliamentary
remit that the first part of our submission identifies what appears
to be Ofcom’s uncertainty about the legitimacy and necessity of
public service broadcasting. In the second section we offer brief
replies to the ten questions for consultation. And in the final
section we summarise Ofcom’s key propositions and highlight
those areas which we believe offer a helpful elucidation of the
parliamentary remit while also identifying those issues where we
believe that Ofcom may have started from the wrong premises and
therefore offers us inappropriate arguments and solutions. back to top
1.5.1. Our
reading of both the UK Communications Act of 2003 and the European
Treaty of Amsterdam of 1997 is that public service broadcasting has
been accepted as a necessary and valuable component of the
communications infrastructure of democratic societies. Thus, while we
welcome Ofcom’s exploration of the ‘enduring case’
for PSB (ITS, p.73) we note that there seems to be considerable
uncertainty in the Phase One documentation about this case. Two
statements stand out in this respect. The first may be found in the
document’s Executive Summary:
We believe that in the future, public service broadcasting will no
longer be needed to ensure consumers can buy and watch their own
choice of programming (ITS, p.9) 1.5.2.
While this statement may be accurate as a description of the emerging
digital television market it appears not to recognise the continuing
necessity and value of broadcasting services that are universally
available and free at the point of use. Such universal information
provision appears to us to be one of the vital support systems for
universal adult suffrage and for active citizenship, as important for
democratic participation in the future as it has been in the past. It
seems to us that the values embodied in the
‘information-for-democracy’ approach reflect continuing
(and non-partisan) political and cultural priorities. These
priorities cannot be dismissed as ‘anachronistic’, as
seems to be suggested in Ofcom’s Conceptual Review of Public
Service Broadcasting (CRPSB, p.15) – one of the annex
documents accompanying Is Television Special? Moreover, the
implied assertion that to ‘start with the market’ offers
a method that is superior, in some kind of evolutionary sense, to
approaches that start with alternatives to the market seems to us to
be unhelpful, since both market mechanisms and market alternatives
will continue to be important in the digital age.
1.5.3. A
second statement which appears to downgrade the role of public
service broadcasting may be found in the fourth section of Is
Television Special? In presenting the ‘conceptual framework
for the digital age’ the document suggests that:
The ‘public good’ problem can be largely resolved.
Encryption and conditional access systems allow broadcasters to
charge consumers directly for their television and to adopt more
sophisticated pricing policies that can reflect the differing values
that individual consumers put on individual programmes. For example,
the first showing of premium content can be priced much higher than
subsequent showings, bringing more viewers to the programme for each
of the different release ‘windows’. (2) (ITS, p.74). 1.5.4.
This statement seems to us to ignore the cultural significance of the
‘live’ nature of television and the consequences of its
universal availability. In the case of news, current affairs and most
documentaries it is obvious that programmes cannot await a later
release window. But the same is true for critically and culturally
aware comedy and entertainment programmes such as ‘Have I got
News for You’ and ‘Big Brother’. Such programmes
have a currency in the workplace, the street and the playground as
well as in the home. With this statement Ofcom seems to be resigned
to the view that television services, considered as commodities, will
become increasingly like computer games or feature film, with all of
the divisive consequences that some children and some adults will be
excluded from the encounter with trend-setting developments in both
politics and culture. 1.5.5. By
contrast, there are other points in the Phase One review
documentation where both the limitations of market provision and the
continuing importance of public service broadcasting are recognised.
Thus, for example, the ITS Executive Summary notes:
Even if the TV market provided all the programming that consumers
desired and were willing to buy, it would probably not offer
sufficient programmes that are valued by society as a whole (ITS,
p.9) And the
Conceptual Review acknowledges that television is ‘uniquely an
accessible mass medium, which can, for example, provide large
audiences with an introduction to science, history, nature, music and
the arts’ and argues that:
..there will still be a need for some form of intervention in the
market as PSB will be under-delivered relative to the socially
optimal outcome even in the digital world. (CRPSB, p. 16)
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II.
Ofcom’s Ten Consultation Questions (ITS, pp. 81-82) 2.1. Do
you agree with the overall assessment of the current system? 2.1.1. We
appreciate the detailed research findings that underpin the overall
assessment. However, we find this assessment to be both inconclusive
and at times unsupportive of public service broadcasting. This is, in
part, because empirical data can be interpreted in different ways.
Thus the fact that around 23% of television viewing time in the UK is
now devoted to watching a large number of relatively new and
non-terrestrial channels (Fig. 14) can be taken to denote
public dissatisfaction with the output of the five existing public
service channels (BBC1, BBC2, ITV, Channel 4 and Channel 5), and to
signal that we are living through a ‘digital revolution’
(3). But the evidence can also be interpreted in a rather different
way. 2.1.2. It
seems to us obvious that new technologies are assisting the delivery
of new services and we welcome the increased choice that this brings
for audiences, though it is also clear that significantly less news,
current affairs and serious factual programming is being viewed in
multi-channel homes and this may contribute to a continuing
‘democratic deficit’ (ITS, Fig. 26, p. 45). However, we
think that the stated or implied argument that the UK audience is in
the process of abandoning the older services is not correct. Ofcom’s
own research found that viewers considered television to be ‘a
hugely important and influential medium for the majority of the
population. Audiences want the main terrestrial channels to offer
easy access to responsible, high quality, varied and innovative
programming that offers a shared experience’ (Annex Document:
Audience Opinions, p. 5). And our belief is that the UK
audience continues to value the PSB services. There are several
reasons for this belief: The
continuing wide ‘reach’ of the PSB channels (Fig. 14;
with the exception of Channel 5 all terrestrial channels have a
weekly reach of between 65% and 86% of the total UK audience) The
fact that over half of viewing time in multi-channels homes
continues to be devoted to the PSB channels (Fig. 46 and ITS, p. 44) The
top ten programmes in multi-channel homes are all from PSB channels
(Fig. 30) The
fact that the most-watched of the non-terrestrial channels (Sky One
with a 2.9% share of total audience) has a significantly smaller
audience share than the least watched of the terrestrials, C5 with
around a 6% share of audience. The
fact that the top twenty non-PSB channels take only a 20% share of
total audience between them (Figure 35) The
fact that on seven of these top twenty channels much of the
programming derives from investment made by their associated PSB
channels (ITV2, UK Gold, CBeebies, E4, BBC News 24, Granada Plus,
BBC3). We think
it is important to recognise the significance of the changes in
viewing habits brought about by new technologies and new patterns of
investment. However, it is equally important not to overstate the
cultural significance of these changes. back to top
2.2. Do
you agree with our interpretation of the data provided to us by
broadcasters, and the key findings we have set out? We agree
with Ofcom’s interpretation of trends that ‘despite
increased competition, the television services provided on the main
terrestrial channels would appear to be in reasonably good health’
and note with interest the observation that between 1998 and 2002 the
share of total TV revenues taken by the five PSB channels reduced
from 65% to 57% (ITS, p. 27). This seems to indicate highly
cost-effective provision on the PSB channels, from the users’
point-of-view – 77% of total viewing for 57% of total costs. We
also note the Ofcom figure of a real increase of 19% on programme
spending during that period on the PSB channels (including the cost
of sport and film rights) (ITS, pp. 27-8). However, - with the
exception of the new BBC channels - we note the absence of any
comparable data on investment in original programmes by the
non-terrestrial channels and believe that Ofcom should now research
and publish this information (ITS, p.40). back to top
2.3. Do
you agree with our analysis of audience trends, and the challenges
posed by digital TV and changing viewer behaviour? In our view access to
new digital television services, for those who can afford them,
offers welcome additional choice (Fig. 4), though it may also be
accelerating a process of social fragmentation and a reduction in
public understanding of public spending decisions. It will require
judicious and determined public policy initiatives to ensure that the
contribution made by PSB services to the advancement of public
knowledge and understanding is maintained. We repeat here our general
assertion that it is not possible for democracy to function without
an informed electorate. We do not wish to see a return, in the
twenty-first century, of the discredited and elite ‘bread and
circuses’ approach to the provision of public entertainment. We
think that all citizens are entitled to access to the highest quality
of information and entertainment services and to a plurality of
public narratives that reflect the complexity of life in the United
Kingdom to-day. back to top
2.4. Do
you accept this interpretation of the role of television in society? We appreciate the work
undertaken by Ofcom in seeking to define and to measure public
service broadcasting and endorse the four point ‘Citizen
Rationale’ outlined in ITS (p.9). However, we feel that a more
robust and extensive definition of PSB could be developed and that
the important role of creative and fictional work as well as of
comedy and entertainment should not be forgotten. It would be a
mistake to think that the role of PSB in society should be limited to
the provision of factual information (though it should include this). back to top
2.5. What
are the implications of these responses for broadcasters and for this
review? We
highlight and endorse Ofcom’s finding that the general public
attach ‘social value’ to ‘soaps, sport and drama as
well as news and information’ (ITS, p. 81). back to top
2.6. Do
you agree that competition for quality between the main terrestrial
networks is an important aspect of the current system, but that it
has been put under strain by increasing competition for viewers, even
from the BBC? 2.6.1. We
agree that competition for quality has been an important feature of
the ecology of British broadcasting in the past. However, we think
that increased ratings pressures over the last decade and a half have
tended to make all terrestrial broadcasters more cautious and less
innovative or risk-taking in their programming. It is a paradox of
the multi-channel era that there is now less competition for quality
across the broad range of programming though more intense competition
in particular areas (for example, in the acquisition of sports
rights). There has been a ‘dash for the middle ground’,
described in economic theory as the ‘Hoteling effect’;
this should be seen as a distortion of competition and inimical to
retention of the high standards of PSB.
2.6.2. In
our view there will need to be regulatory intervention in order to
encourage innovation across the PSB system. This should take the form
of a modest amount of new public spending or, preferable, some
reduction in fees and taxes on the terrestrial commercial providers,
in addition to the continuing existence of the licence fee. 2.6.3. In
respect of the historic practice of competition for quality, and the
network of industry awards designed to express peer approval, we note
that the new Chairman of ITV has confirmed that increased
profitability in the commercial sector (rather than the quality of
programmes) is now the primary concern. Sir Peter Burt, is reported
as saying:
..at the end of the day I’ll look at the bottom line. If he
[the Chief Executive] says to me that he’s won Baftas and all
sorts of awards, but there are no profits, he will not have done
well. (4)
2.6.4. We
endorse the view expressed by Charles Allen (Chief Executive of ITV)
that there should be competition between at least two broadcasters
for the production of programmes in all key PSB genres. We also
endorse his view that such programmes should not be funded through a
top slicing of the BBC’s licence fee (5). For further comments
on this issue see Section Three below. back to top
2.7. Do
you agree with this analysis, and think that this definition provides
a good basis for considering the future provision of public service
broadcasting and the means for funding and delivering it? We endorse
Ofcom’s view that ‘there are enduring citizenship
concerns which will continue to call for some public intervention in
the television market’ (ITS, p.82). However, we are concerned
that a method that separates consumer interests from citizens’
interests could have the consequence of removing the genres of
comedy, drama and entertainment from the public service providers. To
ensure that this does not happen, we think that Ofcom should develop
a more robust and extensive definition of PSB. In addition, Phase Two
of the current review should include clear measures for maintaining
and strengthening PSB into the foreseeable future. We comment further
on funding arrangements in Section Three below. back to top
2.8. Can
the challenges of reach and impact be successfully met in a digital
world of fragmenting audiences and revenues? We think
that the challenges of reach and impact can be met, provided that
there is positive regulatory support, adequate and appropriate
finance and well-informed public support. back to top
2.9. Do
you agree with these conclusions about the immediate priorities, and
are there other issues you think we should be considering? 2.9.1. We
agree that the BBC should reaffirm its position as the UK standards
setter for high quality PSB provision, that new approaches are needed
for measuring, monitoring and assessing PSB, that further work should
be done on broadcasting for and from the Nations and Regions and that
– as far as possible - a safe environment should be provided
for children. We have reservations about the notion of ‘more
focus by the commercial networks on the most highly valued aspects of
PSB’ if this means, in practice, that the commitment to
regional broadcasting is diminished.
2.9.2. We
are not convinced that digital switchover, in itself, can be ‘a
means of delivering better choice, competition, quality and range to
consumers’ (ITS, p. 82). We think that this objective can only
be achieved by fostering a culture of support for indigenous UK
production and by ensuring (as far as possible) that there are
adequate resources for this. Increased channel competition, to date,
has resulted in increased television imports and an overall decrease
in the amount of original production (considered as a percentage of
total transmission time). 2.9.3.
We urge Ofcom to give fuller consideration to the proposition
that ‘a healthy UK production sector should emerge from
a healthy TV broadcasting market with the appropriate public policy
intervention. It should not be the goal of such an intervention’
(ITS, p.73). We think this may be an inadequate approach to
the issue of maintaining and strengthening indigenous production. The
approach suggested here does not appear to have ‘learnt the
lessons’ either from the history of the British film industry
or from attempts made in other countries (for example in Canada and
in Australia) to maintain a meaningful share of the national market
in cultural production. back to top
2.10.
Do you agree with our propositions? What considerations should we
take into account in our further analysis of them? We comment
on Ofcom’s propositions in the following section of our
submission. Future Ofcom work should give an indication of the role
to be played by the regulator in ensuring the maintenance of
standards (including the standard of impartiality in news and current
affairs) and of levels of investment in original programming, along
with the measurement of audience satisfaction. In particular, Ofcom
should indicate what action it intends to take in respect of the
areas where problems were identified in current PSB provision (in
education, current affairs, regional programming, arts, religion and
minority programming, children and a ‘safe environment’,
sport, news, innovation and quality, ITS, pp.57-59). back to top
III.
Comments on Ofcom’s Ten Propositions (ITS, pp. 11-12) 3.0. In
this section we offer a brief summary of Ofcom’s propositions
(the wording in italics at the start of each section). In brief, we
are concerned about three issues: that
Ofcom may be proposing an end to the integrity of the licence fee as
an exclusive resource for the BBC. We think that this change might
benefit some media businesses but would not benefit the UK
television audience. We also do not agree that any BBC services
provided for UK audiences should be offered on a ‘locked
entry’ subscription basis.
that the concept
of ‘contestability in funding’ may be a prelude to
adding to Ofcom’s duties a role in the commissioning of
individual television programmes. We do not think that this would be
economically sensible or culturally desirable. that
Ofcom appears to see the provision of public service broadcasting as
a short-term issue. We do not think that digital switchover will, of
itself, ensure sufficient plurality and accessibility in the
provision of accurate and impartial information to viewers
considered as citizens.
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3.1.
Proposition 1: We need to examine the prospects for PSB
funding and alternative resources; audience fragmentation may
jeopardise the continuation of the TV licence fee. 3.1.1. Our
reading of the evidence of changing audience behaviour is that there
is continuing strong support for universal access to broadcasting
services of high quality (see sections 2.1.2 and 2.3 and above). In
our view the BBC licence fee is the fundamental guarantor of
universal access to high quality information and entertainment for
all citizens. We also believe that the provision of such information
is as important and enduring an issue as the provision of healthcare.
3.1.2.
However, the provision of information to citizens needs to be
independent of pressure from governments, advertisers and media
proprietors and there appears to us to be no better mechanism than
the licence fee in order to achieve these ends. We believe that
viewers (and listeners) will benefit most from maintaining the
integrity of the BBC licence fee and ensuring that it is reserved for
the exclusive use of the BBC. We do, however, support the adoption of
more progressive methods for payment. None-the-less the principle
that payment should be made by or on behalf of all television-owning
households in the UK should be retained. back to top
3.2.
Proposition 2: An effective system requires competition in
the provision of PSB programming; we therefore need to examine the
case for sharing existing funding streams among a greater number of
broadcasters.
3.2.1. As
indicated in Section 2.6.3 above we support the principle of
competition in the supply of PSB services. This will require the
development of an appropriate ‘level playing field’ and
it may be helpful to consider examples from other countries. In
Canada, as in other OECD countries, broadcasting legislation is clear
in that each broadcaster is expected to contribute to the creation
and transmission of national programming. This is not so in the UK.
Here, while there is intense competition for advertising revenue, it
is only the terrestrial commercial channels that are obliged to meet
the additional costs of maintaining PSB standards and original
production quotas, while non-terrestrial channels may import
significant amounts of programming, and avoid the higher costs of
original production.
3.2.2. At
the present time only the five terrestrial channels are making a
contribution in terms of consistent investment in original
programming. This imbalance seems to us to indicate that there is
currently no level playing field in the conventional competition
policy sense. It would make sense, therefore to extend PSB
obligations to all suppliers (requiring appropriate contributions to
PSB genres in line with a channel’s longevity, programming
budget, reach and audience).
All
European Union countries surveyed in a 2002 study include broadcast
obligations (as laid down in the EU’s Television Without
Frontiers directive), that 50% or more of transmission time must
be filled by European audio-visual works, principally drama,
documentary and television or feature film (excluding news, sport,
current affairs in studio, talk shows, game shows, advertising and
teletext)(6).
OFCOM
should work with UK-licensed non-terrestrial broadcasters to achieve
measured progress towards this objective, in agreed stages. France,
Spain, Italy and Canada have developed their broadcasting legislation
to ensure that every channel makes a contribution to the
national/European audio-visual industry by demanding an investment
commitment into indigenous drama, film and documentary production as
a proportion of annual advertising revenue or turnover. Importantly
this is applied to all channels. It is argued that it is practicable,
proportionate, and fair and ensures a steadily increasing investment
in original local audio-visual production and particularly the local
film industry. back to top
3.3.
Proposition 3: Where public funding is necessary to secure
PSB different means of distributing funding should be examined;
options include continuing direct allocations to designated
broadcasters and/or allocating funding to broadcasters or producers
through a new intermediary body (a ‘purchaser’ of PSB) 3.3.1. We
do not support the concept of an ‘Arts Council of the airwaves’
(as outlined initially by the Peacock Report of 1986) or the
top-slicing of the BBC licence fee to support the work of commercial
broadcasters or of independent producers. We think that, in so far as
possible, existing PSB commercial broadcasters should continue to
draw on market resources to deliver public information and
entertainment benefits and that the development of a multi-channel
world should not, of itself, be a reason for placing a heavier burden
on the public purse in order to maintain previous standards of
output. 3.3.2. We
also think that the existence and track record of the BBC (as long as
its current level of funding is maintained) gives confidence that
standards can be maintained and that the BBC will continue to act as
a benchmark of quality across the broadcasting system as a whole. In
our view a new body would only be required if the BBC were to be
abolished and this, we think, would be an unacceptable waste of
resources, reputation, brand name and accumulated cultural capital.
3.3.3.
Given the continuing existence of the BBC any new funding body for
PSB is likely to be a costly and wasteful experiment in the use of
public money. In the absence of sufficient evidence to the contrary,
we take the view that the licence fee, supporting a strong central
institution, remains the best method for sustaining cost-effective
and high quality broadcasting for the population of the United
Kingdom as a whole. 3.3.4. We
do not think that general taxation should replace the licence fee.
There is much evidence available on the effects of such action from
different parts of the world. In our view this evidence demonstrates
that the licence fee remains the best mechanism for independent, cost
effective and pluralistic forms of national cultural production. 3.3.5. We
do not think it appropriate for Ofcom to take on the duties of an
‘Arts Council of the airwaves’.
back to top
3.4.
Proposition 4: We should continue to secure a substantial
contribution to PSB by not-for-profit organisations as their
organisational aims may be more aligned with PSB purposes. 3.4.1. We
endorse Ofcom’s view that not-for-profit organisations (of
which the BBC and Channel 4 are prime examples) are especially
well-placed to contribute to the production and transmission of
public service broadcasting. We agree that ‘social purposes may
be more easily achieved when the organisational aims within which
commissioners and schedulers work are closely aligned with PSB
purposes, rather than potentially in conflict with them’ (ITS,
p. 11). back to top
3.5.
Proposition 5: Prior to digital switchover we need to
establish how many of the purposes of PSB could be provided by the
evolving TV market without public intervention. 3.5.1.
There is some evidence that the evolving television market is capable
of providing international news and certain sorts of wild-life,
history, children’s and factual programmes. Some of this
material is excellent in its own right. However, material of this
kind, usually produced by US-based multi-national companies, is
unlikely to be able to achieve the degree of specificity and ‘fit’
with contemporary British culture and politics of the kind that can
be achieved by UK-based commissioners and programme-makers.
In
particular, the power of television to shape the minds and tastes of
children is without doubt. TV schedules provide the second
curriculum outside the classroom and TV plays a vital role in
children's emotional and intellectual development. We, as adults,
have a critical responsibility to meet and fulfill our children's
right to receive TV programmes that are age appropriate, diverse in
content (drawing from their immediate culture and others around the
world, particularly Europe), entertaining as well as educational and
that reflect a broad range of artistic styles and forms .
Furthermore,
if our young people are to truly enjoy not just British but also
European citizenship, then the ‘screen curriculum’ must
give them information and images from British and other European
cultures. Indigenous programmes are an important form of citizenship
education in that they can give our children a sense of belonging to
a particular society: that of multicultural Britain and indeed the
rest of the European continent. The stories that derive from our
culture are the glue that binds us together, our shared social values
emerge from our past and the society we live in is understood through
our stories. These shared values deserve protection and intervention
to ensure that there is transmission of and investment in local
indigenous production for children by all appropriate channels. 3.5.2. In
the case of much work transmitted by non-terrestrial players in a
variety of genres, producers are under pressure to be comprehensible
across many national boundaries and in many television markets. This
work cannot substitute for, though it may complement, ‘home-grown’
material that is able to address a particular context. We recognise
the value of international broadcasting services in reaching
different diasporic communities but, again, believe that this is not
a substitute for material that addresses local priorities and issues
within the boundaries of the nation-state. Since there is as yet no
‘world government’ there can be no ‘world
television’ that offers specific support to elective
democracies, reflecting their priorities and their disagreements. 3.5.3. We believe that
each nation state has the right to develop and sustain broadcasting
services that encourage and extend freedom of expression and that
offer a platform to a plurality of local voices and stories. Public
intervention must ensure that such cultural and political pluralism
is sustained within the medium of television. We think that
television programme content is not ‘substitutable’ in an
international market, in the way that many other commodities are, and
that the high costs of audio-visual production may require public
intervention and support if original work is to be made. 3.5.4.
A drama that reflects the complexities of life in Haiti or in Iraq
may be able to be shown, valued and understood in other national
contexts. But resources must be made available, within a country, for
the drama to be made in the first place. We think that the same
arguments apply in respect of indigenous cultural production within
the United Kingdom. back to top
3.6.
Proposition 6: there is a case for the BBC to undertake a
wide range of activities in support of PSB purposes but these
activities need to be reviewed periodically to check on their
relevance for meeting core purposes; new sources of funding should be
identified (for example subscription) for high cost/low audience
programmes; BBC activities that may not contribute to PSB purposes
should be reviewed. 3.6.1. We
agree that BBC activities should be periodically reviewed to ensure
that they meet core purposes. We think that this could be done by a
new and fully independent Council for Public Service Broadcasting in
conjunction with a reformed BBC Governing body, operating on behalf
of licence-fee payers and with independent status and resources. 3.6.2. We
do not agree that subscription should be introduced as a method of
finance for BBC programmes with low viewing figures. Certain BBC
programmes will reach audiences in their millions, others will reach
audiences of under a million. This is the very function and nature of
public service broadcasting that it caters for wide and narrow
tastes, offering something for everyone. The principle of universal
accessibility should be retained as the one most beneficial to people
of all ages and backgrounds. 3.6.3. In
general we believe that there are fundamental problems with a
subscription method of funding for the BBC and that the licence fee
remains a more productive solution. The
introduction of a voluntary subscription fee would inevitably lead to
a loss of revenue in a transitional phase. Little or no research has
been conducted recently on who would take out a voluntary
subscription to the BBC and thus what income the BBC would enjoy in
order to plan for the future at this crucial point in the development
of the British television industry. Even considering mechanisms that
would subsidise the BBC in an interim period, the instability caused
to the Corporation would have incalculable effects.
Given the
loss of critical mass from which the BBC and its audience currently
benefit, the costs of public television would rise and this would
inevitably act as a deterrent for some sections of the community,
preventing their engagement with programming that not only entertains
but also informs and educates. This would dilute key principles of
public service such as universalism and inclusion, principles that
have underpinned our television and radio services for generations.
The prospect of subscription also offers no solution to the problem
of funding BBC radio. back to top
3.7.
Proposition 7: not all programmes on main commercial
terrestrial channels need to reflect PSB purposes and
characteristics; however, all BBC programmes should reflect these
purposes to some degree in the light of its ‘unique and
privileged funding status’. 3.7.1. We
agree in a general sense with this statement although we feel that it
may underestimate the significance of the cultural character and
identity of a commercial channel considered across the totality of
its output. 3.7.2. We
agree that all BBC programmes should reflect PSB purposes to some
degree but we do not think that this should prevent the BBC from
working across a whole range of programme genres and budgets. 3.7.3. We
note with great interest the BBC’s announcement that it intends
much of its archive material to be available under ‘creative
commons’ licensing arrangements. We think that this will help
to make clear the social and cultural distinctiveness of the
Corporation’s approach to cultural production and reception. back to top
3.8.
Proposition 8: Channel 4’s distinctive role and ethos
should be secured through its ownership status etc. but, as
competition intensifies, alternative sources of income may need to be
found including ‘new commercial initiatives, a share of
contestable funding, a new source of direct funding, or a
share of the licence fee’ . 3.8.1. We
agree that the distinctive role and ethos of Channel 4 and of the
Welsh Fourth Channel (S4C) should be secured through the confirmation
of independent ownership status, and possibly through the creation of
trusts for these two bodies. In the case of S4C there should be
confirmation of the provision of adequate public funding to enable it
to meet its special cultural remit within Wales. We do not think that
either broadcaster should be offered a portion of the licence fee. back to top
3.9.
Proposition 9: There is more scope for independent
producers to enhance the delivery of PSB. Measures could include an
increase in the quota of independent work commissioned by
broadcasters. 3.9.1. We
remain unconvinced on this proposition but would be interested to see
research designed to explore the specific ways in which independent
production might enhance public service broadcasting. Proportionate
investment obligations (as outlined in 3.2.2) will necessarily
increase investment in independent work commissioned by all
broadcasters, including non-terrestrial broadcasters. back to top
3.10.
Proposition 10: Once digital switchover has been achieved
public intervention to secure PSB may not be justified on its present
scale either because market failures are reduced or because it will
be impossible to provide PSB at a reasonable cost. 3.10.1. As
indicated in several sections above we do not think that either
digital switchover or expanding forms of market provision will, of
themselves, meet the cultural and social objectives of public service
broadcasting. We emphasise the importance of PSB as part of the
infrastructure of a democratic state and believe that it is in all
our interests to secure its future. 3.10.2. The maintenance
and enhancement of a public space in broadcasting is a societal aim
that does not change because of digitalisation and we believe that
broadcasting is central to the democratic, social and cultural life
of a nation. In this sense public service broadcasting is precious
beyond any normal sense of accounting. 3.10.3. Intervention
is required in a proportionate manner (as outlined in 3.2.2)
to ensure that all channels make an appropriate contribution to
public service broadcasting in order to enhance the cultural and
linguistic diversity and plurality of audio-visual production,
independent production and broadcast output, as well as strengthening
the indigenous audio-visual industry.
3.10.4. In our view it
is in the public interest to adopt a toolkit of intervention designed
to balance competing interests within the communications market. Such
intervention must ensure freedom and diversity of expression,
resource the information requirements of citizens within a
participatory democracy and provide a platform across all channels
for creative indigenous expression. Such expression reflects the
strong and complex cultural identities that lie at the heart of all
democratic societies.
back to top
1. The
contribution that broadcasting makes to modern democracies is noted
in the ‘Protocol on the System of Public Broadcasting in the
Member States’ in the European Union’s Amsterdam
Treaty of 1997, cited in D. Goldberg et al., EC Media Law and
Policy, Longman, 1998, p.19. 2.
‘Premium content’ refers to valuable or more expensive
programmes or films. 3. Except
where otherwise stated, the numbered figures cited in this text refer
to the ‘Charts to Section 4’ included among the annex
documents on the CD-ROM accompanying Is Television Special? 4. ‘Make
profits not award winners, new ITV boss tells Allen’, Lisa
O’Carroll, The Guardian, 1 March, 2004. 5. ‘Allen
rejects ‘Arts Council of the airwaves’’, Owen
Gibson, The Guardian, 9 June, 2004. The article reports on Mr.
Allen’s appearance before the Parliamentary Committee for
Culture, Media and Sport. 6. Carole
Tongue, ‘A study of public service regulation in 8 OECD
countries’ in P. Collins (ed.) Culture and Anarchy,
Social Market Foundation 2002 We are
grateful for the support of the Arts and Humanities Research Board.
The AHRB Centre for British Film and Television Studies is a
partnership of seven Higher Education Institutions, funded by the
AHRB for a period of five years, from 2000-2005. The Centre combines
historical and policy research, provides doctoral training and
organises seminars and international conferences. The Arts
and Humanities Research Board funds postgraduate and advanced
research within the UK’s higher education institutions and
provides funding for museums, galleries and collections that are
based in, or attached to, HEI’s within England. The AHRB
supports research within a wide subject domain – from
traditional humanities subjects, such as history, modern languages
and English literature, to music and the creative and performing
arts. The AHRB makes awards on the basis of academic excellence and
is not responsible for the views or research outcomes reached by its
award holders. SH/CT 14.6.04
1. Introduction
1.5. Ofcom’s Uncertainty about
the Legitimacy and Necessity of Public Service Broadcasting (PSB)
Footnotes
Acknowledgements
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