Select Committee on Culture, Media and Sport Appendices to the Minutes of Evidence


APPENDIX 29

Supplementary memorandum submitted by Public Voice

SUMMARY

  Public Voice is a voluntary sector network established to support, defend and protect public service broadcasting in all its forms, now, and in the future. It represents the interests of voluntary and community organisations, the causes they serve and their constituents. Public Voice campaigns to ensure that communications reform is led by public interest objectives, such as plurality of voice, impartiality and objectivity in news, diversity and quality of content, right across the market. The Public Voice steering committee is made up of a number of agencies who have particular expertise in the voluntary and media sectors (Broadcasting Support Services, Campaign for Quality Television, Community Media Association, the Media Trust, Third World and Environment Broadcasting Project [3WE], and the Voice of the Listener and Viewer), and we also have a wide and active membership of voluntary and community groups. Current supporters and members include: NCVO, The Kings Fund, World Wildlife Fund, RSPB, NIACE, CAFOD, Age Concern England, Childline, the Dyslexia Institute, RNIB, RNID, Oxfam, CSV Media and the British Deaf Association.

OUR MAIN CONCERNS

  In this submission we concentrate on four main areas where Public Voice has a unique perspective and particular expertise. These are:

    —  Safeguarding citizens and consumers

    —  Access to high quality diverse services

    —  Defining and protecting public service broadcasting

    —  Development and promotion of digital broadcasting

1.  Safeguarding citizens and consumers

  Any communications reform must recognise the role that broadcasting plays in our democratic society and acknowledge that broadcasters have a responsibility to meet the interests of their audiences as citizens and as consumers. Citizenship in the global information society is an active and participatory process enabled by the provision of information. We believe OFCOM should be given specific responsibility for promoting the interests of both citizens and consumers.

  We are calling for the establishment of an independent citizenship panel to complement the work of the consumer panel proposed by the White Paper. We recommend that this panel, which must be properly staffed and resourced, would have responsibility for:

    —  Monitoring the performance of the public service broadcasters against their Tier 3 requirements and statements of promise; researching the perceptions of the public and civic groups on this performance; reporting to and advising OFCOM; making recommendations for new regulatory approaches; and acting as a consultative body to OFCOM in its reporting on public service broadcasting issues to the Secretary of State;

    —  Assessing new proposals which impact on the delivery of public interest objectives in broadcasting and advising OFCOM on their implications for citizenship;

    —  Commissioning research on how citizens can most benefit from the convergence of other information services around public service broadcast content and making formal recommendations on this;

    —  Further defining the services essential to citizenship and periodically surveying the supply of such services via the world wide web in order to identify areas of essential information which are not covered or inadequately covered, unserved or inadequately served interest groups and to identify questions for public policy arising from these.

2.  Access to high quality diverse services

  Today only a handful of individuals have real power to decide what appears on mainstream television and even senior "commissioning" executives have to get the approval of their controller for almost any commission. Controllers' decisions often appear to be mainly dictated by the search for ratings rather than a desire for range and quality. This is one of the most significant threats to PSB. One answer might be to give the new regulator clear instructions to further the plurality of access to output. This might be done by adding to OFCOM's central regulatory objectives the job of "monitoring, maintaining and increasing" the number of independent commissioning points across the full range in all five terrestrial channels. The Government could also give OFCOM more scope to pursue this objective through the policy of maintaining diversity and plurality outlined in section four of the White Paper.

  It is essential that the draft bill spells out a determination to secure plurality of access as well as plurality of output. Without the first there will not be the second. It may even be necessary for OFCOM to be given the power to insist on new independent commissioning arrangements in line with free and fair competition within channels where they believe there is a problem.

  We also have particular concerns about the impact that the potential merger between Granada and Carlton could have in this area. We do not believe that such a merger should be allowed without careful consideration of all the assurances and the establishment of safeguards to ensure that plurality of voice is maintained and that explicit steps are taken to ensure the continuance of relevant regional and local programming for audiences in each and every area.

3.  Defining and protecting public service broadcasting

  We are campaigning for the forthcoming legislation to contain a clear definition of public service broadcasting and for clear, measurable and published requirements on each broadcaster for all Tier 2 and Tier 3 content provision. In addition we believe there must be clear and enforceable programming investment quotas to ensure that sufficient money is available to make high quality programmes. Such quotas would, we believe, be a valuable long term investment since they would ensure that UK broadcasting retains its leading position in the world market and a ready foreign market for UK productions.

  A mixed schedule and universal access to programmes are at the heart of public service broadcasting. Public Voice believes both are in danger under the current proposals. Monitoring by organisations in membership of Public Voice shows that since the last Broadcasting Act in 1990 there has been:

    —  an emphasis on popular "consumer" issues at the expense of broader and more complex subjects;

    —  a reduction in the total output of factual programmes on developing countries by the four on-going terrestrial channels of almost 50 per cent;

    —  less innovation in drama and an over concentration on domestic and international repeats.

  With UK broadcasters under increasing pressure to achieve high ratings this trend is bound to continue unless there are specific requirements for the provision of a wide range of quality programming.

4.  Development and promotion of digital broadcasting

  Digital programming offers many new exciting and innovative opportunities for programme making as well as significant technological advances which can benefit both radio and television audiences. We welcome such initiatives as long as sufficient safeguards and resources for analogue services are retained during the transitional period so that viewers and listeners are not disadvantaged by "digital drift", (the moving of high quality educative and informative programming from analogue to digital channels).

  One of the real barriers to take-up is the cost of digital radio and television equipment. We have urged the Government to reconsider this issue, and, if it is still unwilling to commit public funds to subsidies, to outline the ways in which it intends to put pressure on the market to reduce costs. We hope these points will be addressed in the draft communications bill.

  In the move to digital services it is important to:

    —  offer special services (easy to use and competitively priced) to meet the needs of those with disabilities;

    —  ensure that those who cannot afford or access digital services are not disadvantaged by an early switchover;

    —  offer clear and objective information to the public on both the costs and benefits of digital services;

    —  special treatment to be given to local and community broadcasters to enable them to have access to either commercial delivery platforms or spectrum.

  The thorough cost benefit analysis of digital services proposed in the draft digital action plan is welcome but it must include a clear acknowledgement of the cultural and social value of public service broadcasting and the recognition of the importance of continuing to make sure services remain readily and widely available.

  We have asked the Government to publicly confirm that the digital terrestrial platform will be retained after switchover is complete and that innovative and imaginative thinking on the future of the platform will be undertaken. We have also asked the Government to confirm that a range of high quality digital services will be available through a variety of routes so that the UK public continues to have choice about how they access free to air digital programmes.

INTRODUCTION

  Public Voice is a voluntary sector network established to support, defend and protect public service broadcasting in all its forms, now, and in the future. It represents the interests of voluntary and community organisations, the causes they serve and their constituents. Public Voice campaigns to ensure that communications reform is led by public interest objectives, such as plurality of voice, impartiality and objectivity in news, diversity and quality of content, right across the market.

  The Public Voice steering committee is made up of a number of agencies who have particular expertise in the voluntary and media sectors (Broadcasting Support Services, Campaign for Quality Television, Community Media Association, the Media Trust, Third World and Environment Broadcasting Project [3WE], and the Voice of the Listener and Viewer), and we also have a wide and active membership of voluntary and community groups. Current supporters and members include: NCVO, The Kings Fund, World Wildlife Fund, RSPB, NIACE, CAFOD, Age Concern England, Childline, the Dyslexia Institute, RNIB, RNID, Oxfam, CSV Media and the British Deaf Association.

  Public Voice has commented in detail on a number of policy proposals and consultation documents over the past year including: the Government's White Paper on Communications Reform, Professor Cave's Radio Management Spectrum Review, the BBC's proposals for new digital services; ITC consultations on restrictive service licences and on cross promotion; the Government's draft digital action plan; and the Towers Perrin scoping report on OFCOM. We will shortly be submitting our response to the consultation document on media ownership. We also submitted written evidence to the Select Committee's earlier inquiry into the Government's proposals for communications reform.

  In this submission we shall concentrate on four main areas which we believe are of particular interest to the citizens and consumers of this country and where we believe Public Voice has a unique perspective and expertise. These are:

    —  Safeguarding citizens and consumers

    —  Access to high quality diverse services

    —  Defining and protecting public service broadcasting

    —  Development and promotion of digital broadcasting

  In its White Paper on Communications Reform published in December 2000 the Government made a number of welcome commitments including the following statements that Public Voice welcomed in its own response to the White Paper. We believe that these commitments are still as relevant today and that these principles should underpin communications reform.

    —  ensuring that the interests of citizens and consumers are paramount;

    —  universal access to public service content through a diversity of media;

    —  the recognition of public service broadcasting, including news and current affairs and original production, educational programmes, children's programmes, religious programmes and coverage of arts, science and international issues;

    —  the explicit retention of key public service channels as mixed schedule networks;

    —  strengthening regional and community media;

    —  ensuring that cultural diversity is recognised and reflected in programming.

    —  universal access to a choice of diverse services of the highest quality

  In the Communications White Paper the main responsibility for regulating public service programming is placed with the broadcasters themselves, in order to allow them flexibility to compete in an open market. Public Voice believes this is an unrealistic and over-simplistic view. A reduction in regulation will put more pressure on public service broadcasters to popularise their programming in order to boost ratings, thus squeezing PSB programmes as well as other support materials and related activities. We believe that appropriate protection of PSB and specific requirements for each public service broadcaster would be in the interests of both broadcasters and audiences whilst still allowing broadcasters sufficient freedom to produce programmes to suit their own target audiences.

  We know that since the last Broadcasting Act in 1990 there has been a significant decrease in the overall factual output on international issues on main terrestrial channels, less innovation in drama, and more repeat programming. A relaxation in regulation would allow this trend to continue and would limit the public service broadcasters' ability to fulfil their remit by informing, educating and involving the public. We know that television in particular is the single most important source of information for the majority of the UK public. The voluntary and community organisations we represent rely on public service broadcasting to help them raise awareness of key issues and to inform, motivate and involve the public. Any further reduction in the regulation of PSB programming would have a detrimental effect on these agencies and on the interests and communities they serve.

1.  Safeguarding citizens and consumers

  In its White Paper last year, the Government stated that communications reform was intended to benefit both citizens and consumers and this commitment was warmly welcomed by Public Voice. We were disappointed, however, that the White Paper did not contain more detail on these issues—in particular in relation to citizenship issues—and that the main proposals in relation to consumer interests appeared to concentrate on matters of taste and decency, or the range and quality of service delivery, and that issues of content were not really addressed.

  The Government must recognise the need to promote the interests of citizens of the UK as citizens of the "global information society" and develop a suitably broad definition and scope of citizenship. It should ensure that UK citizens are enabled to receive the information they need to play a full part in society. In the light of recent world events the need to enable people to develop as well informed citizens is perhaps more crucial than ever before. Citizenship requires the provision of high quality content by the public service broadcasters. Therefore the availability of high quality, informative and educational factual content through public service broadcasting is central to citizens' interests, and has for this reason been recognised by government to be "as important, if not more important than ever before". Citizenship in the global information society is an active and participatory process enabled by the provision of information. It cannot be confined to a passive state of wishing not to be offended and to be reassured that free speech is protected.

  Any communications reform must recognise the role that broadcasting plays in our democratic society and acknowledge that broadcasters have a responsibility to meet the interests of their audiences as citizens and as consumers. This important point, which we believe is central to communications reform, was recently addressed during the report stage of the OFCOM bill in the House of Lords when Lord Corbett introduced an amendment calling for OFCOM to be given a specific responsibility to promote the interests of both citizens and consumers. In responding to this point for the Government, Lord McIntosh said that the Government was in total sympathy with this view and that this could be considered during the debate on the draft communications bill early next year. This is a point we will be pursuing again with the Government and we hope that the Select Committee will give due attention to this matter during your own deliberations.

  In our response to the White Paper we welcomed the proposal for the establishment of a consumer panel to advise OFCOM but called for this panel to be supplemented by an independent citizenship panel that could consider a wider range of issues. We also called, along with colleagues from consumer organisations such as the NCC, for the role of the consumer panel to be widened so that it could consider issues other than service delivery. We also asked for the consumer panel to be properly resourced so that it had sufficient funds and personnel to carry out an appropriate range of research.

  Since producing our response to the White Paper we have talked to a number of Government advisers and officials, to current regulators and to other organisations in the voluntary sector and have developed more detailed proposals about how the interests of citizens and consumers might be addressed. Our latest proposals are outlined below:

  We suggested in our response to the Towers Perrin report that the citizenship panel previously outlined by Public Voice could have four main functions:

  Positive content requirements—monitoring the performance of the public service broadcasters against their Tier 3 requirements and statements of promise, and researching the perceptions of the public and civic groups with regard to this performance; reporting to and advising OFCOM on these; making recommendations for new regulatory approaches; and acting as a consultative body to OFCOM in its reporting on public service broadcasting issues to the Secretary of State.

  New service proposals—assessing new proposals which impact on the delivery of public interest objectives in broadcasting and advising OFCOM on their implications for citizenship.

  Convergence and public service broadcasting—commissioning research and leading discussion of how citizens can most benefit from the convergence of other information services around public service broadcast content; and making formal recommendations on this periodically to OFCOM and the government.

  Market failure in internet services "essential to citizenship"—further defining the services essential to citizenship and periodically surveying the supply of such services via the www, with a view to identifying:

    —  areas of essential information which are not covered or inadequately covered

    —  unserved or inadequately served interest groups

    —  and questions for public policy arising from these

  The principal aim of function IV would be to advise and make recommendations to OFCOM on ways in which public service requirements in broadcasting could be used to correct these market failures, for example:

    —  by adding new Tier 3 requirements in future years;

    —  by bringing untouched areas of content to the attention of public service broadcasters as they prepare annual statements of promise;

    —  by requiring broadcasters to create specific multi-platform approaches that correct market failure on the Web;

    —  by suggesting ways in which public service broadcasters' use of the www could mesh with other public sector and civil society provision to create a "national backbone" of Web-based information essential to citizenship.

2.  Access to high quality diverse services

  The White Paper pledges to retain the public service broadcasters' independent production obligations, to ensure that PSB continues to meet the needs of different communities and cultural interests, and to maintain the plurality of expression. All these are very worthy and laudable statements but they have no real meaning unless backed up by firm regulation and adequate resources.

  The White Paper says nothing about the effective collapse of independent commissioning in British television. 20 years ago many hundreds of different individuals, both employees of the main broadcasters and independents, had real power to influence what appeared and how it was presented on the screen. This led to a rich plurality and a much greater diversity and breadth of achievement than is seen today, despite an expansion of airtime. Today only a handful of individuals have real power to decide what appears on mainstream television and even senior "commissioning" executives have to get the approval of their controller for almost any commission. Controllers' decisions often appear to be mainly dictated by the search for ratings rather than a desire for range and quality. This is one of the most significant threats to PSB. One answer might be to give the new regulator clear instructions to further the plurality of access to output. This might be done by adding to OFCOM's central regulatory objectives the job of "monitoring, maintaining and increasing" the number of independent commissioning points across the full range in all five terrestrial channels. The Government could also give OFCOM more scope to pursue this objective through the policy of maintaining diversity and plurality outlined in section four of the White Paper.

  Public service broadcasters will not promote plurality of expression if the independent sector is limited to fulfilling the commissioning demands of a tiny number of channel controllers. It is essential that the draft bill spells out a determination to secure plurality of access as well as plurality of output. Without the first there will not be the second. It may even be necessary for OFCOM to be given the power to insist on new independent commissioning arrangements in line with free and fair competition within channels where they believe there is a problem.

  We also have particular concerns about the impact that the potential merger between Granada and Carlton could have in this area. We do not believe that such a merger should be allowed without careful consideration of all the assurances and the establishment of safeguards to ensure that plurality of voice is maintained and that explicit steps are taken to ensure the continuance of relevant regional and local programming for audiences in each and every area.

3.  Defining and protecting public service broadcasting

  We have very specific concerns, as outlined in our response to the White Paper, about the proposed regulation of public service broadcasting and with the future of the mainstream free-to-air television channels which carry public service obligations.

  The most important categories of programming here are news and current affairs (Tier 2), and all the programme types which fall into the proposed Tier 3. We believe the proposal to allow broadcasters to regulate their own performance with regard to Tier 3 positive content requirements will greatly weaken this key area of provision. We support the 3WE proposals on Tier 3 regulation which are attached to this submission in Appendix B.

  We will continue to campaign for the forthcoming legislation to contain a clear definition of public service broadcasting (the Public Voice definition is attached here as Appendix A) and also for clear, measurable and published requirements on broadcasters for all Tier 2 and Tier 3 content provision. In addition we believe there must be clear and enforceable programming investment quotas to ensure that sufficient money is available to make high quality programmes. Such quotas would, we believe, be a valuable long term investment since they would ensure that UK broadcasting retains its leading position in the world market and a ready foreign market for UK productions.

  A mixed schedule and universal access to programmes are at the heart of public service broadcasting. Public Voice believes both are in danger under the current proposals. Monitoring by organisations in membership of Public Voice shows some worrying developments since the last Broadcasting Act in 1990:

  A refocusing of current affairs programming to emphasise popular "consumer" issues at the expense of broader and more complex subjects. A reduction in the total output of factual programmes on developing countries by the four on-going terrestrial channels of almost 50 per cent.

  Less innovation in drama and an over concentration on domestic and international repeats.

  In 1994 the main slot for "serious documentaries" on the ITV network (10.30pm on a Tuesday evening) transmitted 34 hours of documentary programming. By 1997 this had dropped to 18 hours.

  Subject matter has narrowed with an increase in the number of films about royalty or celebrities and there has also been a significant increase in the commissioning of popular programmes such as "Neighbours from Hell".

  Budgets for serious documentary programming have steadily been reduced yet ITV companies have taken an increased profit margin (20 per cent off the top of the budget) for each film they produce.

  Despite criticism by its regulator, the ITC, the ITV network has failed to increase its documentary output. The ITC in turn has failed to exercise its punitive powers effectively—demonstrating the need for an empowered and proactive regulator under the new legislation.

  On ITV documentaries now must vie for airtime (and budget) on a purely commercial basis: they must deliver high audiences or face extinction. The result will be a steady increase in ITV's output of the new breed of "confessional" or "popular" documentaries—and a reduction in the sort of "serious documentaries" which the ITC has identified as "the best ITV tradition".

4.  Development and promotion of digital broadcasting

  We recognise that digital programming offers many new exciting and innovative opportunities for programme making as well as significant technological advances which can benefit both radio and television audiences. The Government is right to encourage the development of digital services, and to encourage innovation and investment in such services by broadcasters and we welcome such initiatives as long as sufficient safeguards and resources for analogue services are retained during the transitional period.

  We have serious concerns about "digital drift", (the moving of high quality educative and informative programming from analogue to digital channels), in order to enable the mainstream terrestrial channels to maintain a high share of viewing figures by screening programmes which attract large audiences whilst those programmes which attract smaller audiences are being consigned to the digital channels. Educational programming is already being particularly affected in this way.

  We were encouraged that the Secretary of State for Culture, Media and Sport has for the first time made "online and interactive" services an explicit part of the service offerings expected from the BBC in her decision to approve the BBC's new digital television services. This is the first time that public service broadcasters' use of their advantages (licence fee, public ownership, access to spectrum etc) to diversify into online and multi-platform approaches to communication has been subject to any kind of legislation or regulatory scrutiny, and it heralds a welcome recognition of the significance of convergence.

  The point of a converged regulator, as the government stated in the White Paper, is that it can "see across...converging industries". It should also "see across converging services"—where those are provided by a single industry such as a public service broadcaster.

  One of the real barriers to take-up is the cost of digital radio and television equipment. In 2000 the Government said it was unwilling to consider subsidising the costs of such equipment. We have urged the Government to reconsider this position, and, if it is still unwilling to commit public funds to subsidies, to outline the ways in which it intends to put pressure on the market to reduce costs. We hope these points will be addressed in the draft communications bill.

  Without some significant improvements in this area it seems extremely unlikely that the Government can meet the target of switchover by 2010. We are also seeking assurance from Government that individuals, particularly those on limited budgets, will not be forced into early switchover as no one should be deprived of minimum services. Unless the Government extends its goal for DTT beyond the suggested 72 per cent reach, and takes steps to ensure the costs of accessing DTT are reduced, the goal of having 95 per cent of consumers with access to the main PSB channels free to air by 2010 seems unlikely to be realised.

  We welcome the recognition in the Government's draft digital action plan of the importance of ensuring the development and maintenance of special services to meet the needs of those with disabilities. We hope that due attention will be paid to developing easy to use and competitively priced equipment which will be readily accessible to all.

  We welcomed the proposals in the draft digital action plan for public information campaigns to explain the issues around digital switchover and are extremely pleased that the DCMS has invited Public Voice to join the marketing group that it is establishing to look at such issues.

  The Government's commitment to defining and agreeing a target for digital terrestrial public services after switchover is very welcome and we hope that this is an area where there will be very wide consultation with public interest and consumer groups. We have also asked the Government to publicly confirm that the digital terrestrial platform will be retained and that it will offer free at the point of delivery access to a good range of high quality programming.

  We have also asked for special treatment to be given to local and community broadcasters to enable them to have access to either commercial delivery platforms or spectrum and hope that the Government will recognise the importance of supporting the development of such services.

  The thorough cost benefit analysis of digital services proposed in the draft digital action plan is very welcome but we are seeking assurance that this will include a clear acknowledgement of the cultural and social value of public service broadcasting and the recognition of the importance of continuing to make sure services are readily and widely available. It would be unacceptable to end up with a system in which analysis is undertaken on a purely economic basis and in which the costs of making public service programming is so prohibitive that broadcasters reduce their PSB output to a minimum.

  The Government's commitment in its draft action plan to commissioning research into viewers' needs and expectations is extremely welcome. We have stressed the importance of independent third party research that clearly sets out the costs, as well as the benefits, of digital radio and television. We hope that when this research is commissioned in the first half of 2002 consumer groups and others representing the public interest will have the opportunity to comment on its range and content. We also hope that the Government will take this opportunity to ensure that there is a continuing commitment to provide services which inform, educate and involve citizens so that in the digital era broadcasting continues to play a vital part in our democratic process.



 
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