APPENDIX 8
Memorandum submitted by the Institute
of Practitioners in Advertising (IPA)
The IPA welcomes the opportunity to submit views
to the Commons Committee on the above subject.
Please find enclosed[64]
10 copies of our response to the Davies Committee Report, which
we have just submitted to the DCMS.
Taken together with the Culture Secretary's
announcements at the Cambridge Convention on 17 September, we
are hopeful that new regulatory arrangements will begin to be
put in place which will not only address the needs of the fast-changing
broadcasting market but will also better balance and coordinate
the relationship between the BBC and the commercial broadcasting
sector.
We see the following elements as necessary components
in the implementation of this process:
1. A single economic regulator for television:
The IPA believes that a single external economic regulator for
television is needed in order to be able to review simultaneously,
and with due regard to complementarity, the BBC and the commercial
sector (this could be the ITC or a newly constituted body). Traditionally
broadcasting reviews have treated the BBC and the commercial sector
separately. Today, it is an approach which fails to take properly
into account the interdependence of an increasingly diverse range
of broadcasters. Economic and remit policy decisions taken in
respect of the BBC inevitably have significant and potentially
damaging impacts on the economics of the commercial sector. For
this reason we recommend that a single regulator should be responsible
for determining the remits of both the commercial broadcasters
and the BBC. This should involve the regulator establishing what
the BBC's public service remit should be and laying down specific
measurable and legally-binding programme obligations separately
for each of the BBC services. With this in mind we therefore welcomed
the Culture Secretary's statement in Cambridge that the main issues
for the next major piece of broadcasting legislation might include
how to rationalise the various regulators to avoid duplication
and confusion and what the role of public service broadcasters
should be in the longer term.
2. Deregulation of the commercial broadcasters:
As the choice of programming available to viewers expands there
is a diminishing need for onerous regulatory requirements to remain
imposed on the commercial broadcasters. In any event, the prime
responsibility for public service broadcasting should in our view
rest with the BBC. We look forward to a progressive deregulation
of the commercial broadcasters'output as a result of the ITC's
forthcoming review. This should enable the commercial sector to
compete more effectively with the BBC, increase their audiences
and thereby generate more advertising revenue to fund programme
budgets to enhance further the range and quality of their schedules.
This relaxation is particularly needed by advertising-supported
free-to-air broadcasters Channels 3, 4 and 5 which face growing
competition from subscription funded and pay-per-view services.
3. BBC Goverance and accountability: The
IPA believes that the BBC, as the unique recipient of a guaranteed
income from the licence fee, should be the organisation which
serves as the quality benchmark for the whole of British broadcasting.
However, we remain concerned that the Davies Committee was given
a limited brief predicated on the assumption that the BBC needs
funding supplementary to that of the licence fee adjusted for
RPI. We do not accept that this assumption is yet proven. It is
to the credit of the Davies Committee that they went beyond their
remit in discussing the BBC's public service role and its governance
because they recognised that these issues were inextricably bound
up with the issue of BBC funding. We regret that the limitation
of their brief and the short period they were allowed did not
permit the Committee to undertake a comprehensive review of the
BBC's current services against a public service remit. We fully
endorse the Davies Committee's proposals for a review of the BBC's
governance and accountability and a clearer definition of the
BBC's public service obligations. We would expect the principles
laid down by the BBC in `Extending Choice' (1992) to be the basis
of such a definition. We recognise too, as the Davies Committee
did, that a definition of the BBC's public service remit will
be difficult, but we believe it to be an essential starting point
to any review of the BBC's finances. We develop these points in
our separate and specific response to the DCMS on the Davies Committee
Report.
4. Timing: The IPA believes that it is essential
for the Davies Committee's proposals regarding the governance
of the BBC to be introduced at the earliest feasible date. We
recognise that the more radical proposals regarding the framework
of the regulatory regime will need to be the subject of primary
legislation. With the aim of moving towards a coordination of
regulation of both BBC and the commercial sector, we envisage
a timetable of administrative and legislative change along these
lines:
2000
Government implementation of Davies Committee
proposals for BBC governance including definition of the public
purpose of each BBC service; new services tested by wide consultation
before their launch; an obligation on the Board of Governors to
insist on clearer criteria for what the BBC is doing; performance
criteria on the BBC's public service broadcasting obligations;
National Audit Office inspection of administrative efficiency.
ITC deregulation of commercial broadcasters.
2000/1:
Government consultation paper on the future
of broadcasting legislation published/BBC Charter review begins.
2002/3:
BBC Charter review completed/new Broadcasting
Bill introduced.
C2003:
New Broadcasting Act, incorporating a single
regulatory body for television, receives Royal Assent.
2007:
New BBC Charter comes into effect.
November 1999
64 Not printed. Back
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