Memorandum submitted by UK Film Council
The UK Film Council welcomes the Select Committee's
timely inquiry into the future of public service media content
and the terms of reference the Committee has chosen.
The UK Film Council responds to the Committee's
seven points as follows:
The prospects for maintaining plurality in public
service broadcasting in the digital age
For the last 50 years, plurality of provision,
and competition between providers, has been one of the key underpinnings
of British public service broadcasting, and has proven to be an
approach that has served UK citizens and consumers well, certainly
when compared with models of public service broadcasting in many
other European states, or in the US. While the benefits of this
plurality may be particularly obvious in the provision of genres
such as news, it has been as important in driving quality and
range of output in other genres such as drama, current affairs,
comedy and film—by both originating new British film production
and through film acquisitions and by stimulating interest in film
culture in the UK well beyond mainstream. In all these genres
of programming, original production has been, and remains, the
strongest distinguishing feature of the public service broadcasters
in contrast with their non-public service competitors.
Ed Richards, the Chief Executive of Ofcom, recently
estimated that while the five public service broadcasters invest
around £2 billion per annum in original production, the equivalent
figure for all their several hundred non-public service competitors
is only £100 million. Original programming is essential to
ensuring a media environment which properly reflects contemporary
life in Britain, rather than simply filling air-time with acquired
programming from the US and elsewhere. It also sustains one of
the most consistently creative and successful areas of the UK
economy and, without question, the skills and experience of British
television have a direct and beneficial relationship with the
success of British film and the health of film culture. Furthermore,
it is becoming clear that these two industries will have an even
closer relationship in an all digital world than they do today.
For all these reasons, the UK Film Council believes
it is important that Britain should continue to hold plurality
of public service provision as one of the central tenets of broadcasting
policy for the foreseeable future. With two major public service
providers, BBC and Channel Four, in public ownership there is
no reason why the critical mass of plurality should not be maintained
even if the incentives for ITV and Five to retain public service
obligations evaporate with digital switchover. However, the time
is now right for public policy to explore ways of bringing new
public service providers into the market, as Ofcom is now doing
with its proposals for a Public Service Provider or Publisher.
The practicality of continuing to impose public
service obligations on commercial broadcasters
It is clear that public policy has diminishing
leverage over the two commercial public service broadcasters which
are in private ownership, although it could be argued that Ofcom
has conceded defeat before it was necessary to do so. However,
many commercial broadcasters, both in television and radio, choose
to provide elements of programming which have all the characteristics
and quality of conventional public service broadcasting, because
audiences want it and therefore it is in their commercial interest
to provide it. Even so the quantum is small which is why the UK
Film Council believes more consideration should be give to ways
of encouraging and incentivising broadcasters to provide what
could be described as public service content and, in this connection,
we welcome the proposed Public Service Provider as a good example
of how plurality and public service might be maintained and enhanced.
The viability of existing funding models for ITV,
Channel Four and FIVE
Television advertising may be slowly losing
its historical potency, and it is obvious that the fragmentation
of the TV advertising market is changing and will continue to
change many of its most familiar characteristics. Nevertheless,
television remains the most powerful advertising medium and, as
ITV's recent experience has shown, even significant audience decline
does little to diminish its attractiveness as the medium for advertising
many products and services. With the growth of sponsorship and
pay services, it is premature to assume that internet advertising
or the decline of real-time viewing or the fragmentation of the
advertising market will make commercial terrestrial television
untenable in the short or medium-term.
The case for public funding of broadcasters in
addition to the BBC
With the exception of Ofcom's proposed PSP,
little thought has been given to ways of funding particular kinds
of content other than through the BBC licence fee or, as importantly,
by considering other providers than the existing broadcasters.
No systematic thought has been given to the role of other DCMS
sponsored agencies, including, for example UK Film Council and
Arts Council England, although both agencies make a contribution
to the commissioning and production of media content which is
of public value, and the Exchequer makes occasional forays into
this area—the recently announced £6 million Youth Media
Fund, managed by the Department for Education and Skills, being
a case in point. The UK Film Council would welcome a debate which
looked at public support for the creation and distribution of
public service media content in this wider context and which explored
the possibilities for improved joint working and activity.
There is an assumption that any public funding
for other broadcasters or content providers would come from top-slicing
the BBC licence fee. This would make the licence fee a general
media tax with little direct accountability, it would severely
damage the clear and widely understood relationship between the
licence fee and the BBC's overall output of services and, given
the growing expectation that the licence fee is unlikely to last
beyond the next Charter period, it would not provide a secure
and sustainable source of public revenue.
The debate about public funding for broadcasters
other than the BBC has been largely focused on the future of Channel
Four. The current Ofcom review of Channel Four will shed further
light on this question but it seems inevitable that changes in
viewer behaviour combined with the fast uptake of digital television
will in time render Channel Four's current business model unsustainable.
This is a matter of national concern given that Channel Four is
a key public service provider.
The future of key areas of public service media
content such as news provision and children's programming
Given the high level of public trust in television
news as opposed to print news, maintaining a plurality of serious
news providers must remain a core principle of media regulation
in the medium term, however it is achieved.
With regard to children's programming, there
is now a real possibility that substantial original programming
on public service networks may soon be confined to the BBC alone;
the changes in rules about food advertising will put an additional
pressure on both ITV and Five, and Channel Four has never had
children's programming as part of its remit. In view of the growing
recognition of the importance of media literacy and the interest
of young people in creating as well as consuming content, the
role of the public service broadcasters in meeting the needs of
children and young people, whether on-air or online, and their
relationship with other agencies—including the UK Film Council—needs
to be considered in an integrated way. This is an area in which
dedicated public funding might play a useful role in sustaining
and extending public service values as well as public service
content.
The UK Film Council notes that the 2003 Communications
Act identifies many other areas of programming as being in the
mix of public service content, including arts and film. The UK
Film Council has frequently argued that Ofcom has failed to address
its monitoring and enforcement responsibilities with regard to
film on public service broadcast channels—both in terms
of the range of classic and contemporary films from Britain and
around the world which audiences can access on the public service
channels, and the commitment of the broadcasters to commission,
develop and produce films for theatrical and broadcast distribution.
In 2006, the UK Film Council agreed a Memorandum
of Understanding with the BBC to give clarity and commitment to
the BBC's contribution to film. A similar arrangement is being
sought with Channel Four. This is an area in which the traditional
role of the public service broadcasters is under some threat and
there is a need for a wider public debate which includes agencies
such as Arts Council England, and its sister bodies in the home
nations, and the UK Film Council and its regional and national
agencies, to ensure that the arts—however broadly defined—and
film, (both of which are such vibrant parts of Britain's public
life), do not suffer reduced public access in the transition to
an all-digital broadcast environment.
The value of the PSP concept as advanced by Ofcom
The UK Film Council welcomes the concept of
the PSP—loosely defined though it is. We welcome the need
for the debate now and we recognise that the new media world is
already creating new model forms of content and possibilities
for creative citizen engagement which could be of significant
public value, but we also believe that this potential is unlikely
to be realised by the activities of the market alone. We believe
this important debate therefore needs to engage a much wider range
of public agencies than simply broadcasters.
All the major questions remain to be addressed:
On what basis will the PSP be funded? On what basis will it make
funds available to others? On what basis will PSP output be distributed,
and by whom? If it is an organisation which commissions content
and negotiates distribution deals, on what basis should it be
constituted? What safeguards would be required to ensure that
it really served to reinforce the range and quality of existing
public service broadcast content and not undermined it (the maintenance
and strengthening of public service broadcasting being the formal
justification for Ofcom's initiative in this area)? In the same
vein, how could the PSP enhance the existing public service digital
media activities of agencies such as the UK Film Council and the
Arts Councils? Finally and perhaps most importantly, what is the
precise nature of the market failure that the PSP seeks to address?
What is the extent of that failure, what is the cost of the remedy,
and who will pay?
All these are questions which will now be aired
in the coming months as Ofcom drives the public debate. The UK
Film Council welcomes that process and looks forward to playing
an active role, first, on behalf of the UK film industry and film
culture, secondly, as an agency which seeks to develop and nurture
creative skills in moving image media and, finally, as one of
the lead agencies in driving the media literacy agenda in the
UK.
The case for provision of public service material
on new media
There is a wealth of evidence that the availability
of high quality public service content on new digital platforms
is valued by many people in Britain. The success and the evident
public value of the BBC's online services is one case in point.
Furthermore, both the BBC and, to a lesser extent, Channel Four
are developing distinctive services of public value which encourage
public participation and engagement in a way which has the potential
to transform over time the current concept of public service broadcasting,
and certainly goes beyond what the market alone is providing or
will provide. However, it is also clear that this re-invention
must go beyond the established broadcasters to open up new possibilities
for individual citizens and for other public agencies, including
the UK Film Council and its partners and stakeholders.
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