Culture, Media and Sport CommitteeFurther supplementary written evidence submitted by the Commercial Broadcasters Association (COBA)

Thank you for publishing COBA’s supplementary evidence to the Culture Select Committee’s inquiry into support for the creative industries, in which we attempted to clarify the conflicting figures for the amount invested by PSBs and non PSBs in UK-made television content. Having looked at the BBC’s supplementary evidence on this point I would be very grateful if you would allow us to make a further few points as we do not recognise the figures for investment by COBA members that the BBC is using. A body of evidence—from Oliver & Ohlbaum’s research for us, to Pact’s annual census, through to annual company statements by individual broadcasters—now indicates that the landscape for investment in UK content is changing. PSBs still account for the majority of spending, but other sources such as non PSBs and the independent production sector are increasingly contributing and it is, in our view, extremely important that the Committee takes this into account in its thinking.

According to its supplementary evidence, the BBC has based its assertion that non PSBs account for 10% of UK television content investment on figures cited by Mediatique in its report for the DCMS last year (“Carriage of TV Channels in the UK: policy options and implications”). We are unclear how Mediatique arrived at its figures for UK content investment by COBA members. Mediatique’s report says that its figures are “informed by an informal audit of stakeholders and its own analysis”, but COBA is not aware of Mediatique having consulted any of its members about their investment in UK content for this report. Mediatique adds that Ofcom’s market report confirmed its estimates, but Ofcom does not publish figures for COBA members’ investment in UK content, only their overall content spend including imports—it only reports on an annual basis on UK content for PSBs as part of monitoring the fulfilment of their statutory requirements.

Even if Mediatique’s figures were accurate, we would still question why investment in UK sports production (as opposed to rights) should be left out of its estimates. This clearly prejudices the non PSB sector as sports production is a significantly bigger proportion of our spending. The BBC acknowledges that the Mediatique figures do not include this genre.

In addition, the Mediatique analysis does not take into account any investment by the independent production sector, which as the Committee is aware is another emerging player in this area.

As we have outlined to the Committee, COBA commissioned Oliver & Ohlbaum last year to conduct an authoritative analysis of non PSB investment in UK content, and to look more widely at other sources (their report is attached). In short, investment in first-run UK content (excluding repeats, payments for sports rights and regional production) in 2011 broke down as follows:

PSB: £1.85 billion.

Non PSB multichannel: £568 million.

PSB portfolio channels: £308 million.

Independent producers: £218 million.

We believe this provides a comprehensive and up to date picture which takes into account emerging sources of funding as well as the more traditional. According to this analysis, PSB investment (including their portfolio channels) amounts to 73% of total spend, and core PSB channel spend (ie excluding portfolio channels) 63%, as we explained to the Committee in oral evidence and in our previous evidence.

I would be very happy to discuss this further, or for this to be treated as further supplementary evidence.

May 2013

Prepared 25th September 2013