Select Committee on Culture, Media and Sport Minutes of Evidence


Examination of Witnesses (Questions 360-379)

24 APRIL 2007

MS IONA JONES, MR BOBBY HAIN AND MR DAVE RUSHTON

  Q360  Rosemary McKenna: You will know that there has been some concern earlier on this year when the political broadcasting, as the rumour mill had it, was all going and, I have to say, I am delighted that the coverage of the Scottish elections and the local elections just now has been very, very good and much more than you have ever done in the past, so that is a real plus and I think people are looking forward to the further development of SMG's Scottish Television side. ITV have already given us their view and they represent most of the Channel 3 providers, but where does your submission differ from theirs? Where do your views on public service broadcasting differ from ITV's?

  Mr Hain: Well, our starting point is that, having not been consolidated into the 11 licences of ITV plc, we need to always stand up and say, "Actually the ITV network, as it was, is not mapped directly on to what we now call ITV1 in large parts of the country", because in Scotland STV is still the ITV network and we deliver the network properties to people insofar as the drama properties, like the new drama on Sunday night, alongside material that we will make, whether it is Taggart or Rebus, we have the X Factor, we have all those properties, but actually it is our sovereign schedule and it is our responsibility to take that network material and to enhance it and to make it relevant for the people of Scotland by introducing our own regional programmes, and you mentioned the current affairs offering, the regional news offering which has actually been a very big success since we invested quite heavily behind it last year. Only last week we got to a position where STV's news was actually head and shoulders above the BBC's news at six o'clock and at six-thirty in terms of ratings and that is a steady growth that we have seen since we revamped our news product and also introduced a more localised service. Now, those enhancements in public service broadcasting, I think, give us quite a different perspective from ITV. I can understand the business rationale behind trying to reduce the regional commitments of ITV, even though that is where its roots have come from, but actually in Scotland I think we absolutely need to have a reflection of the national difference, if you like, a reflection of the differences, the sense of nation that we have, and that we need to have a regulatory framework within the ITV network which allows us to do that.

  Q361  Rosemary McKenna: In your submission, you are a bit bleak about maintaining an appropriate level of public service broadcasting, but Scottish Screen, for example, do not see that problem.

  Mr Hain: I have not seen the Scottish Screen proposal. I think if you look at the economics of the ITV network as a whole, which includes ITV1 and STV, UTV Channel and so on, then when you consider the effect that CRR has had, for example, in depressing revenues, not just for us, but I think for television as a whole because the money which has come out of the ITV system is difficult to reintroduce into other broadcasters and there simply is not the audience real estate to be able to handle that kind of money, so I think that that is a challenge for us, the fragmenting audiences are a challenge for us and maintaining a level of investment in public service broadcasting. We spend, for example, just on news, between what we contribute to ITN for national and international news and what we spend on regional news, the best part of £10 million a year. That is a considerable investment to make when your revenues are reducing through CRR and declining audiences are at the rate that they are, so I am not sure of the economics of the Scottish Screen proposal, but I do know our own business and it certainly underlines what we said in writing to you in January.

  Q362  Paul Farrelly: This is to Dave and, as I read from the biography, you have long been struggling to bring ultra-local television to our screens in England. You were one of the few people who managed to get a seat that was not filled by the mass ranks of the BBC earlier, so you heard my comments about Staffordshire TV just completely passing me by and maybe that was good editorial judgment on their part, but it did not really make much of an impact, so what evidence have you got, given that sort of perception of what the BBC was doing, that this local TV service or content is actually wanted by people and actually provides such wider benefits that it justifies giving voluntary organisations of the sort you might want to encourage free spectrum?

  Mr Rushton: I think it goes back to 1974-75, the period when the IBA was looking at what viewers wanted from regional television and the Crawford Report came out in 1974 actually suggesting that a new ITV might be divided into smaller, localised areas. The effect was that this was to some extent put to one side largely because the expectations of cable would be that this would cover a city-based service across up to 180-200 cities and communities across the country. If you recall, the 1984 Cable and Broadcasting Act made local provision for services provided other than by the owner of the cable operation as well as by citizens and by community and voluntary organisations. But, because cable was unsuccessful largely until the late 1980s/early 1990s, many of the, shall we say, community obligations that were placed on the companies in their applications, all of them made these obligations, were rescinded by the Cable Authority and they were let off the requirement to deliver these. We had other opportunities in 1988 with MVDS with Channel Six as an additional service to Channel Five. The Channel Six frequency spectrum got rolled into Channel Five. The ITC described Channel Five as being essentially a national service, even though we contested that legally, and only two months before the applications had to be in did they realise that they should not have said that it had to be essentially national, it could have been local. Therefore, we have had a series of stumbling and halting moves in the direction of regulation and in the same period, when you look at the analysis of regional provision as far as viewers are concerned, there is always an echo of them describing their local area as being something smaller than regional television's area. We got choosy with Channel Five and you had an opportunity to deliver services to what we call the "second city" of each region and we developed proposals around that, Edinburgh to Glasgow, Sheffield to Leeds, Liverpool to Manchester, Nottingham to Birmingham, so you would actually give that second large community an opportunity to have its say, and there was work done around that period where, it is suggested, there was a very strong interest in services that would provide a sense of location and a sense of dynamic to that. More recently, we have had Pride of Place research by the ITC in 2003 which also explored the introduction of the RSLs, the only piece of work that has been done by the ITC or Ofcom on that which actually was specific. Looking at the North West, the suggestion was that, if the regional ITV companies were to withdraw progressively from regional programming, the viewers felt that local television should come in, step in, and replace that. Similarly, on a general basis, the recent Ofcom research of 2006 also found that the top priority as far as viewers are concerned from new services from the digital dividend are essentially local news delivered on TV and local services providing information and a greater sense of enhancement of the community. When you look back at that 2006 mirror, you can almost see a reflection of the 1970s/1980s requirement that there is too little programming that enhances a sense of where you live, and the ramifications of that of course fall into culture, to the representation in political terms as well as into a sense of engagement and participation, so the fundamental thing that local television will offer is an opportunity to see faces like your own, to hear voices like your own and be encouraged to participate. Because these are not strangers, these are people down the street, these are people around the corner and, therefore, to enable people to become more engaged with broadcasting and the delivery of news, information and cultural activity.

  Q363  Paul Farrelly: So we have long politically shunted Nottingham off into the East Midlands, so let us take Stoke, Birmingham, shall we, which is my local city. What is the biggest impediment to having Stoke TV, in your view?

  Mr Rushton: Well, the biggest impediment at the moment is that the option offered by Ofcom for the use of interleaved spectrum falls fairly haphazardly across the country and it will not necessarily provide the piece of spectrum that would coincide with either Stoke, Birmingham or with other large parts of the country. Twenty-nine areas have been identified and that is far too few. The problem with television, which is very often not realised, is that it is really dependent upon the way in which viewers receive the signal. You have got to get the new television signals so that they go into people's aerials on their houses. You do not expect to go out and buy a new TV receiver to pick up a local service, it is one additional service amongst 40 or 50, so we have to go with the grain of the distribution system which means you have got to insert local television into the digital multiplexes in such a way as to arrive at as many homes as possible. Also, one of the fundamental problems for some parts of the community is the reliance on relays and not on the main transmitter sites, so any service which does not send a signal down to the relays is going to find that those in the more remote geographic parts of the community, virtually all of those north of Cardiff, in the valleys, for example, receive their signal from relays and it is the same kind of situation across the rest of the country. You really need to have a service that is delivered for everybody, so I would underwrite Mark Thompson's view of public service broadcasting, that fundamentally what underwrites this is universal availability, and the same applies for a local television service, that it has to be universally available in the local area which it is addressing to be able to say, "We offer a public service, we have a public purpose and we are reflecting the overall balance of views within our community and everyone has an opportunity to take part in this to receive it and to participate in that area". This cannot be delivered on anything other than a platform or a multiple of platforms that will arrive in every home without any additional expense.

  Q364  Paul Farrelly: So now let us assume that Ofcom sees the light, you are the guru that they follow and offers these opportunities. Presumably you would want to see, for reasons of quality and diversity, a competition between different groups to get this bit of free spectrum and provide a local service. If we can keep the BBC out of it for one moment, are there any restrictions you would like to see Ofcom putting on who can compete for these things? My concern is that my local newspaper, which is owned by the Daily Mail and General Trust which does not have the political complexion that is mine, has long since gobbled up all the free sheets and the local newspapers and might see this as an opportunity, as well as a threat, and might put in a bid which, on quality grounds alone, might, drawing on its resources, knock everybody else out of the water.

  Mr Rushton: Yes, I think there are two criteria which should be applied. One is that the licence itself should direct, shall we say, the advertising and also the reception issues in terms of delivery of public service programming to the community that the licensee wishes to address and not to a much bigger community, so that is the fundamental one. Secondly, I think that in terms of preserving plurality, there might well be a criterion, a necessity to say that you cannot own all three local media, that you cannot own the radio station, you cannot own the local TV and you cannot own the local press. Whether one says that you can only own one of those three is up for debate, but certainly perhaps you should not own more than two, so there has to be some degree of plurality. Whether the BBC becomes involved obviously will add another equation to that, so you might be able to relax slightly on the criterion as to whether the newspaper could own the radio, the commercial telly and the newspaper if the BBC were involved, so that partly depends, I think, and it needs to be reasonably flexible as to how you resolve that. The other issue is that the point at which the cost should come in as a fee, I suspect, is at the point of issuing the licence and not to gain the spectrum because, if the spectrum were packaged in such a way, the fear would be that one or more, maybe a few, large existing media players would opt to look for large areas across the country and acquire spectrum for those and be less interested in the spectrum that would reach the rural communities which, I suggest, would be delivered probably best by municipal services or community services. Therefore, our view has been to say that we have to take a balanced view between commercial and municipal, and councils now have the possibility of licences and what else would they use them for if not local radio or community television in some form, and also the community itself. There are two good, strong community television services, one running in Belfast and one running on the Isle of Wight, funded on a non-commercial basis, so those models also should have a right of access to the spectrum.

  Q365  Paul Farrelly: So, given your particular engagement in this topic, this is a no-brainer question really, not least because ITV has been reducing its local news coverage, do you think there is a valid market in which people will be interested for Stoke TV, a sort of Stoke Today sitting alongside Midlands Today?

  Mr Rushton: Yes. The thing about the ITV regions was that they were an accident of commercial scale, as anticipated in the early 1950s, and geography. We are still stuck with the geography, so we have to make the best of that because that is the way television is distributed, but I think we can focus now much more on to the smaller community than the West Midlands. People do not think they live necessarily, or they certainly do not live in Granadaland; they live in Liverpool or Manchester, Lancashire, Preston or wherever. Your association, in spite of television, has remained very strongly with the community, by and large, in which you have a relationship with the hospital, with the school, with the communities that are involved with going to the theatre, going to the cinema, and reflecting that pool of cultural and political interest and involvement is fundamentally important, I think, to reengage people with the political process at the local level, which is why I think there is a political dimension to this, which is why I think this House should take an interest in local television as a contribution to public service broadcasting and its renewal. It should not be seen as a monopoly, nationally or regionally; this should be something that public service broadcasting is allowed to develop at a local level where the localness is identified with relatively well-known civic and accepted areas of activity that people can become better involved with.

  Q366  Paul Farrelly: Iona, can I turn to you. I am one of the 200,000 who deliberately turns his aerial across the Cheshire Plain to Wales and north Staffordshire to pick up the rugby, so thank you very much. You would consider yourselves as being a local broadcaster in Wales and you might have a different perspective about the impact of your business and the sorts of ultra-local TV that we have been talking about in England where ITV and the BBC have lodged national creations, but what sort of impact do you think it would have on your business? Would it be a threat or an opportunity?

  Ms Jones: From our perspective, we are kind of working the other way, we are going Wales, UK, global, and obviously what Dave is doing is kind of coming the other way. We are actually quite excited about the prospects of getting more platforms, new services which could make use of the content which originates from S4C's commissioning process, and that is why we have taken a very different view to rights management from other broadcasters in that not only have we given back the rights since the 2003 Communications Act where it was a requirement, but we have also offered the rights in all programmes commissioned by S4C since 1982 to the producers with a view actually to giving them the opportunity to exploit the kinds of opportunities which Dave and others in the area of local TV might want to promote. Therefore, the role of S4C as a broadcaster is very much about developing audiences within and outside Wales and globally, but at the same time ensuring that all of the opportunities which may come through different services can be exploited primarily by our producers who will now have the rights in order to make those opportunities realistic for them.

  Q367  Paul Farrelly: Bobby, your group has not given up the ghost and sold out to national ITV and you have made it quite clear that you see that your job is to bring that different flavour to different parts of Scotland, so again the same question to you: would this gifting of spectrum to ultra-local TV operations be a disadvantage to you? Would it be more of a threat than an opportunity?

  Mr Hain: I think you need to contextualise how this is being done because it would seem to me slightly eccentric to abandon the existing forms of public service broadcasting, particularly within Scotland where there is a very strong connection from STV to viewers and we have regionalised that and actually localised it to a degree in the past year or so and it has been very successful with our news offering which, as you say, has travelled in the opposite direction from other ITV regions where there has been consolidation. It would seem to me to be slightly eccentric to abandon that and move straight towards a system of trying to deliver public service broadcasting and news and community information at a local level because I suspect that you could see a case where you reduce reliance on one established method and it is a long time before you have any traction and scale and penetration universality and some the real common themes of public service broadcasting, it may never happen. I think that it is a very interesting concept and I think that the local nature that Dave has been talking about in terms of its touchstones of the hospital and the area where you live and go to work and so on, that has very identifiable resonance with people. However, I am not sure what the business model is behind it, but I have not been convinced that there is a business model that would make it work, so I think in that sense it is a significant risk and our focus is much more on trying to maintain, and enhance, what is already in existence.

  Q368  Chairman: Can we just examine the general question of funding which obviously applies in different ways to each of you. Starting with Iona, you actually benefit from a pretty significant direct subsidy from the Government. Now, others, who when that possibility has been raised have expressed huge concern that this will lead to all sorts of political interference, lack of editorial independence, et cetera. Has that been your experience at all or have you any concerns about that?

  Ms Jones: No, I think you quite rightly say that it is a direct subsidy, but, because it is actually set in primary legislation, it is not subject to a kind of annual discussion which others may or may not face or even a slightly longer time period, so we have the visibility and the stability of funding, but I think the fact that it is in primary legislation actually means that there is a distance between the annual scrutiny which we may be subjected to, so we are quite happy with that position. We have of course got commercial freedoms and the airtime sales and sponsorship obviously costs too, it is a very important part of our mixed funding model which, I think, gives us a kind of commercial edge and a slightly different view of the way in which we schedule and commission. I should also add that, since we last appeared before this Committee, there is a new strategic partnership with the BBC which is another very important part of S4C's funding model going forward in that, for the first time, we have an allocation from the licence fee of £72 million over the next three years which, in the first instance, supports S4C's Welsh language commitment, but is also a way of the BBC delivering on its obligations to the indigenous languages of the UK, so those are the kind of three areas of funding that we now enjoy.

  Q369  Chairman: But you also receive programming from the BBC, do you not?

  Ms Jones: Yes, the Act states that they have to provide us with a minimum of 10 hours. What the strategic partnership has done is to translate those hours into financial terms and the agreement of how that money is spent is done in partnership with S4C with a view to delivering on S4C's programme strategy as opposed to any particular BBC programming objectives on their other channels.

  Q370  Chairman: Clearly the general thrust of our inquiry is to look at ways in which we can support public service content outside the BBC. Do you see this as potentially a model which could be applied elsewhere?

  Ms Jones: It may well be, but obviously it is a partnership which means it is working for S4C and it is working for the BBC, and that may prove to be slightly more complicated for others, but I think the secret of the success of this partnership is that it does indeed support, as Professor Roger Laughton and others have said, Welsh language broadcasting going forward into digital, but it does not in any way diminish the BBC's accountability to its licence fee payers and it does not contradict any of the public purpose values that the Charter has adopted, so there is a synergy which we have identified between the partnership which is, I think, a blueprint, as far as we are concerned and there are probably some very interesting principles which may be worth exploring elsewhere, but it is not top-slicing and I think that is the key.

  Q371  Mr Evans: You say it is not top-slicing, so do you mean that the BBC do not actually write you a cheque even though you have had a negotiation, let us say?

  Ms Jones: They do not hand over licence fee money to S4C, but all the other components of the partnership mean that the way in which that is spent is very much in line with S4C's programme strategy.

  Q372  Mr Evans: Of the 10 hours, after Pobol y Cwm and the news services, how much have you got left then to be creative with that?

  Ms Jones: There is some factual programming which actually meets our landmark programming test and they are still a contributor in sport. The other element which may best illustrate the changing nature of this relationship is that the BBC will become an increasingly important player in the field of children's programming and we very much hope that, if the Secretary of State allows us to set up a children's channel, the BBC will be a very important part of that provision, so that is the way in which we have been able to discuss with the BBC things which are of importance to S4C and to amend the contribution and the investment accordingly, so it works very well for us.

  Q373  Chairman: Turning to Bobby Hain, SMG have indicated that you think there is a "strong case" for some kind of public funding for Scottish content. Would you see that as being taken from the licence fee?

  Mr Hain: I would not rule it out. I think that the example of S4C is interesting where there is a BBC apportionment of resources which goes to S4C. Now, actually that, to my mind, is an indirect top-slicing of the licence fee. I think that it may be that we would prefer a more direct version of that, going forward. I do not think it is the only way that we could look at additional funding and I think that the public service publisher is also aware that we should be looking to play actually a key role because I think in our position, being so far out of London and being very established as a broadcaster, this is an area where we could work with other related parties within Scotland. We could use our building, for example, as a centre for incubating ideas and getting other ideas for content to a position where they could be more readily pitched to whoever was making a decision. I think one of the key factors behind any additional funding that we would be making a claim for would be actually that this drives value for viewers and that this enhances our offering and it takes us into the online world, I think, where the commercial barrier to entry, because of the dominance of the BBC, is actually quite high. I know that public service content, as opposed to public service broadcasting, features very high on the agenda and that the digitised and online world is a place where people are spending more time and there is a real sense that they want to find the kind of content that they have seen on their televisions delivered through broadband and other areas. I think that that, is a key pivotal area into which to introduce funding for getting material to a new audience.

  Q374  Chairman: David, you are principally asking for gifted spectrum rather than direct subsidy. Is that correct?

  Mr Rushton: Yes. I think we are also not looking at the digital dividend. At the moment, the preference would be for some of the benefit of the changeover from 16-64 QAM, which is taking place on the public service muxes, that some of that benefit is released spectrum to provide two or three extra channels on those public service broadcasting networks allocated to local television, the reason being that those are the only muxes that at the moment are going to reach the 1,152 transmitter sites across the country. We are very concerned that, in terms of taking a historical overview, there could well be pressure on the ITV companies at some point in the future to come back to the 81 transmitter sites and not to support the continuation of those 1,152. I think our concern is to maintain universality in the delivery of services and it is particularly important in different local communities, where relay is very, very predominant, to ensure signals arrive in the homes of those people who are further out of the main cities, so those are the people who are also not at the end of a switch, so they do not get broadband or they do not get broadband at high capacity. Therefore, our concern at the moment is to deliver television on DTT and to then use that as a barker channel for flagging web access for those who have access to the Internet for local city councils, for health service information and so on and, in the same way that the BBC and Channel 4 particularly have provided a portal, if you like, and a reason to go up to your bedroom and have a look at your computer, this is what local television can do; it has to be in that framework, available for everybody. Our argument with the PSP is that, in between the PSB reviews when local television was identified as a possible candidate for receiving funding, it shifted across to being defined as a broadband media service. We have put our foot down on that, as far as we have a foot to put down at the moment, and said quite straightforwardly, "No, something like £70 million of the identified £300 million across the UK as a whole was really in the expected reduction of regional programme content over that period, and that money should go straight back in to support the introduction of local television to replace effectively face-to-face public service debate and participation in a television form which people recognise and through which they still wish to receive their local content".

  Q375  Chairman: But you would not accept that local TV might actually be more appropriately delivered via broadband than via—

  Mr Rushton: Not at this stage, no. Because the roll-out of the digital switchover is actually taking place across the rural areas where broadband is not so readily available to those communities and because those communities tend to be older, Lord McIntosh has identified local digital terrestrial television as being the fundamental form that he thought television should move forward in at the local level, and it is something that we have agreed with for the last two or three years. At some point in the future when broadband has caught up so that IPTV is available across the country, we think it would be a fantastic opportunity for what we call `neighbourhood television' on a smaller scale, community or local, where you actually are having debates on the hustings in your local area on a very, very small footprint, but IPTV at this stage is, I think, estimated to be available for three million households across the country out of whatever, 21 million, so it is not something at this stage we could deliver local television on because it is unevenly available.

  Q376  Rosemary McKenna: Can I ask that question of Bobby Hain. You have said in your submission that there are difficulties involved in trying to provide content specific to Scotland via traditional broadcast media. Would broadband not be a really good answer in an area like Scotland?

  Mr Hain: I think the point that Dave has made actually similarly applies to our network because, when you consider that the universality and the scale and reach of public service broadcasting has some of the prime characteristics it needs to have, at this moment where you have STV, for example, reaching about four million out of five million people in Scotland every single week, then yes, you can make content available and it is a convenient place to park it and to get extra distribution channels. It may be a long time before you get anything approaching the kind of impact, scale and reach that you already have, and our point on broadband is that there is no universality compulsion. In the build-out of transmitters that we are currently undertaking to provide DTT across Scotland, we will get to a UK figure which is the same as the analogue services now, 98.5%. That is absolutely fixed as something that we need to do and there will be universality, there will be freely available material via STV and I think that really is our primary focus. That is not to say it is not important to have additional content which can be made available via broadband and via mobile and via other means—

  Q377  Rosemary McKenna: But it is an add-on?

  Mr Hain: —but it is absolutely an add-on. Our experience with broadband is that we launched an online service last year which is very well used and we also started a Scotland on TV service which is really for expats which takes our Scottish programming around the world. Now, there is a lot of interest in that, but we are really running it as a trial. I think you are a long way off being able to support anything like the production values of STV as it exists now in terms of high-quality news and current affairs with a commercial model that you could derive from the Internet because I think people's expectation is content on the Internet is free and, until you can get a subscription or some kind of pay per view or some kind of advertiser-funded model which really gives you some scale to commission programmes, you are going to see a very different kind of content on the Internet. The other thing to bear in mind is that it is in our interests in having a brand as STV to make sure that our Internet content fits the brand values of our regulated service, that it has editorial independence, that it is impartial, but it is high quality, and that actually for other operators where there is no regulatory compulsion to do so, it is much more difficult to achieve that objective just by leaving it to the market.

  Q378  Chairman: Can I quickly touch on the PSP which has featured already, but just to clarify. Iona, S4C's attitude to the proposal of the public service publisher, although you have made a return to Ofcom, it was not absolutely clear to us whether or not you did support its creation, so can you just clarify a little?

  Ms Jones: I think that was the impression we were trying to convey! Obviously there is a need to address the deficiencies of the PSP going forward as far as commercially funded operators are concerned. The reason why we probably lacked some clarity was that we are not sure that this actually addresses the question in hand, and as to the focus on developing something in new media, I think this is an opportunity to use, in our case, the public investment in TV content primarily to be developing new services. We readily acknowledge that, even though ITV have been quite innovative in online terms, innovation at the kind of levels proposed by Ofcom are not being delivered at present, so there is quite a lot of discussion to be had around that, but it may be there needs to be more focus on the way in which they are training the sector, that skills should become more transferable as far as different platforms are concerned, so we are interested.

  Q379  Chairman: Whereas SMG are positively enthusiastic about it.

  Mr Hain: We are, and I think that the caveat is only that we do not see it as an either/or situation. I do not think you can take the existing public service broadcasting certainly within Scotland that STV delivers and say, "Right, instead of that, we are going to have this public service publisher", which, judging by the kinds of examples I have seen, pushes at the fringes of innovation and really takes to the limit what you can do in new media. I think that is very commendable and it is very interesting, but I do not think that is in any way a replacement for high-quality news and current affairs. I think they are different flavours and I think there is a place for both of them. My interest and, I think, STV's interest is: where is the crossover and could you actually use the public service publisher if it is trying to extract some value and reinvest it from the digital dividend into our existing audiences for the benefit of our existing audiences, and then there comes a point when public service publisher money may be used to subsidise existing forms of public service content? I am not sure that is all you would want them to do. You would want them to be made available in new forms and on new platforms, but I think there is a bit of a crossover here, and I go back to my earlier answer where one of the dangers in only having as the preserve of public service publisher content an online destination is that you do not have any regulatory levers to pull to make sure that that is absolutely high quality and that it has scale and impact and reach and it is available to a vast majority of the audience. Therefore, I think there are some caveats and I think, on balance, we are very enthusiastic about it because we do see that it has a role to play in extending public service content, but I think it could also be argued that it also has a role to play in maintaining, and enhancing, existing forms of PSB.


 
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