Memorandum submitted by Pete Browning
Given expected growth in digital TV and likely
developments in the internet and other media, what scope and remit
should the BBC have?
The BBC should continue to have a very broad
remit, if not quite as broad as it has at present. The growth
in digital TV and in broadband poses the greatest technical challenges
that the BBC has faced. In the context of a competitive broadcasting
business sector, these challenges threaten the very foundations
of the BBC as it has existed for eighty years. However, it is
vitally important that the best features of the BBC survive. The
BBC is too important a part of British life for it to be dismantled.
Public Service Broadcasting (PSB) should be
broadly defined. In terms of non-news programming, there is a
danger that PSB is seen as that which cannot profitably be provided
by commercial television companies. This would mean that the BBC
would provide for minority interests, would lose its unique national
status. Public service broadcasting is broadcasting which serves
the public, both as a single national collective and in its many
discrete groups. PSB can include entertainment programmes. Over
the years, the BBC has been able to innovate because it has not
been dependent on the market share needed to attract advertising.
Its range of channels has allowed it to experiment with programmes
on, say, BBC2 before showing successful new programmes on BBC1.
This freedom must be retained.
Ideally, PSB is not just about who is catered
for or what is provided but also how the service is delivered.
It should involve quality of delivery. In the past, the BBC has
come closer to that ideal than its commercial rivals. This has
been one reason why the BBC is highly regarded across the world.
PSB means the provision of high quality and relevant programmes
to a wide range of groups within the UK. To fulfil these PSB goals,
the BBC needs to retain a wide range of broadcast radio and television
channels. It also needs broadband networks to cater for people
who prefer to receive their radio and television programmes in
more innovative ways.
At present, the provision of BBC digital services
runs counter to the BBC's commitment to provide its licence-funded
services to all licence payers. This is intended to be a temporary
phase, prior to the switch-off of analogue transmission around
2010. It is important that the switch over to wholly digital transmission
is accomplished as quickly and as smoothly as possible, in order
to restore the traditional universality of provision. Surveys
suggest that there is a small group who are determined not to
switch, come what may. If they resist all inducements to change,
then that will be their choice. More important is the need to
provide a proper digital transmission service for all parts of
the UK.
The BBC has probably expanded into too many
activities which are only loosely related to the business of public
broadcasting and thus should lose some aspects of its current
work. One example of several such activities must suffice: BBC
Worldwide should not be involved in broadcasting within the UK.
Thus its current joint funding of UKTV should cease. BBC Worldwide
should be as its title suggests, the activities of the BBC outside
the UK.
In the context of scope and remit, how should
the BBC be funded?
This is the most difficult question to answer
as well as the most important. The days of the licence fee are
probably numbered and for two reasons. Firstly, the conversion
to digital broadcasting will provide a means of charging viewers
of BBC channels which is more sophisticated, much more efficient
and fairer than the current licence fee. Secondly, the growth
of multi-channel television and the subsequent fall in the size
of the BBC audience makes it increasingly difficult to ask viewers
to pay a flat-rate licence fee. There is a danger that the BBC,
in order to maintain market share in order to justify the licence
fee provides programmes which are populist rather than popular.
So if the licence fee is to go, what is to replace
it? Not commercial advertising, even on the most popular channels.
A key feature of BBC programmes is that they are free of advertisements—except
for their own programmes, which is another matter. This financial
freedom allows the creative freedom mentioned earlier. And viewers
need a contrast of channels and approaches. For many young people,
unaware of the history of the BBC and its contribution to British
life, it is the feature of BBC which distinguishes it from ITV
and BSkyB. Something significant would be lost if Britain were
to have a BBC funded by advertising.
Thus the only alternatives are either subscription
or taxation. Though the BBC's External Services are funded by
the taxpayer, the BBC's national services should not be. To do
so would make it harder than ever to distinguish the BBC from
the British state, would make the BBC even more dependent upon
the decisions of politicians for the amount of funding it receives.
I do not support the proposal of the recommendation of the Broadcasting
Policy Group's recent report Beyond the Charter, which
argues that radio broadcasting should be "sourced from tax
revenues".[11]Does
this mean all BBC Radio, including Radios 1 and 2, which probably
could be run commercially? I would argue against "privatising"
these channels.
Which leaves subscription. The danger with subscription
funding is that not enough people will subscribe to the BBC's
services in order to provide funding equivalent to that lost by
scrapping the licence fee. The Broadcasting Policy Group assumes
that "20% or more will not subscribe to the BBC".[12]
"Or more" could make a big difference
to estimates and arguments. Let's assume that the withdrawal rate
is 25%. Which means that the BBC's current licence fee of £121
would have to increase by some £30 to £150 per annum.
By £3 per week, 42p per day. Which is the price of a tabloid
newspaper. And as the licence fee is charged per household, the
actual daily charge per person is less than 42p. I would have
thought that across the BBC's breadth of programmes, three-quarters
of the British people listen to or watch programmes for which
they would pay 42p a day or £3 per week.
In other words, subscription could work. However—an
important point this—people should subscribe to the BBC
as an organisation and not to particular services. (To get around
the fairness argument against a flat-rate levy, the BBC would
have to be innovative in its charging policy—which, presumably,
digital broadcasting would allow it to be.) There is a great amount
of public goodwill towards the BBC, a goodwill which must be used
much more effectively. One benefit of a BBC subscription would
be that it would have a new, more direct relationship with its
viewers and listeners. A subscription-funded BBC could provide
it with a new lease of life.
How should the BBC be governed and/or regulated
and what role should be played by the Office of Communications?
Concern has been expressed about the dual role
of the Board of Governors of the BBC. How can the Board be responsible
for both running the BBC and regulating its activities? Its role
during the events surrounding the death of Dr David Kelly, where
it was seen to have failed, is quoted as the example which shows
the need for reform. Even before the Kelly Affair, some had called
for the Governors' regulatory function to be transferred to the
Office of Communications (Ofcom), then in the process of being
established. Their arguments seem to have been strengthened by
the Dr Kelly Affair and the subsequent Hutton Report. The pressure
for the separation of powers appears irresistible.
This pressure should be resisted, at least for
the foreseeable future, and for three reasons.
Firstly, Ofcom already has several powers to
monitor and regulate aspects of the work of the BBC. These include
most programme code standards, eg taste and decency, as well as
quotas for independent productions. Ofcom, a very new organisation,
has enough to do without being given additional and very demanding
duties. Admittedly, it is odd to divide the regulation of "accuracy
and impartiality" between Ofcom and the BBC Board of Governors
but the decision was made recently, just a year or so ago, by
government and parliament. It would make no sense to change it
now, especially as it would seen as a response to a failure of
controls over one particular broadcast at a time of great national
controversy.
Secondly, the BBC is likely to revise its method
of governance following the publication of the Hutton Report and
the appointment of a new Chairman and Director-General. Before
the responsibility for regulation is transferred to Ofcom, the
BBC should be given the opportunity to make its own efforts to
improve its governance and management. These efforts can be reviewed
by external agencies, such as parliament and other media, as is
already the case.
Thirdly, to bring the BBC wholly under the regulatory
control of Ofcom would be to threaten further the uniqueness of
the BBC. The BBC and its form of governance have served the country
well. One danger of imposing several major reforms on the BBC
all at once is that the BBC might lose its special and essential
qualities. The governance of the BBC should be changed only after
full and careful evaluation of all the alternatives. A new regime,
involving Ofcom, is being developed. Let it be evaluated after
it has been given a proper chance to work, say in five years'
time.
In a changing communications environment, does
a 10-year Royal Charter and Agreement with the Secretary of State
together provide the most appropriate regime for the BBC?
The life of Royal Charters establishing the
BBC has varied from a just few years to 15. However at the present
time 10 years is probably the optimum. Anything less and the attention
of the BBC management would be deflected by yet another charter
review from its prime role of providing high quality programmes.
Anything longer would be too long, especially given the current
speed of technological change.
The duration of the next Royal Charter is also
affected by the ending of analogue broadcasting. If it does end
in 2010, maybe 2012, it would be undesirable to end the BBC Charter
at around the same time. However, by 2016, the end of a 10 year
Royal Charter, the analogue era would have concluded some years
previously. The experience of the end of analogue and the first
few years of wholly digital broadcasting could then usefully inform
the next Charter review.
As to the Royal Charter itself, it could be
argued that using a largely symbolic device to establish the BBC
is redundant. It was significant when first used in the 1920s
because it showed that the BBC was not the creature of the government
of the day. By the 21st century that tradition is well established
and could be just as well preserved by use of parliamentary statute.
However, the Royal Charter symbolises the BBC's special status
and its deep roots in the history of the British people in the
20th century. It should be retained.
14 April 2004
11 See Broadcasting Policy Group, Beyond the Charter,
2004, p49. Back
12
See Broadcasting Policy Group, Beyond the Charter, 2004,
p49. Back
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