Memorandum submitted by the Campaign for
Quality Television Ltd
The Campaign for Quality Television was set
up in 1988 to express the concern of programme makers about the
then proposed de-regularisation of television. Over the next two
years it played an important role in ameliorating some of the
worst excesses of the 1990 Broadcasting Act. Its efforts are widely
credited with having led to both the quality threshold and exceptional
circumstances clauses in the Act. These allowed the Independent
Television Commission to draft licences setting higher standards
than would otherwise have been imposed. After the passage of the
Act, it was decided to rest the Campaign, to avoid the risk of
exhaustion. In 1995, with so many important developments taking
place in British broadcasting, it was decided to relaunch the
Campaign. In 1998 it published two reports Serious Documentaries
on ITV, and The Purposes of Broadcasting, and in 1999
published A Shrinking Iceberg Slowly Travelling South research
which looked at the changing pressures of broadcasting and the
impact on programmes.
The Campaign's aims are to:
promote public service television,
choice and quality for all viewers in the United Kingdom. Recent
developments in television have been driven by a narrowly financial
agenda and the role it plays in informing and educating people
from all sectors of society is being largely ignored
ensure that efforts are made in an
era of rapid technical advance, to match the new breadth of choice
with a true breadth of quality
ensure that public service television
is adequately funded
persuade legislators towards policies
which are creative and imaginative and which treat the viewers
as partners in the enterprise of television rather than sources
promote public debate about television.
The new draft Communications Bill stresses the
promotion of public service broadcasting in a bid to maintain
the distinction and diversity of British broadcasting in the twenty-first
Century but it is not carried through in concrete proposals.
The Bill contains powerful contradictions which
will frustrate public service broadcasting, unless amended. The
Bill has all the appearances of reflecting the demands of the
most powerful, conflicting lobbying groupssaying yes to
each of the loudest voices, a position which is unlikely to give
the public a better quality broadcasting service in the future.
Key policies outlined in the Bill, particularly
PSB, are dependent on the effectiveness of the proposed new single
regulator for enforcement. Yet the largest broadcaster is largely
exempt from the scrutiny of the regulator. This reflects giving
way to pressure from the BBC, makes a nonsense of a single regulator.
Most recent concerns about the BBC relate to the exploitation
of its monopoly position and its tendency to use licence funds
for commercial ends, drifting away from PSB. The new regulator
will be in a weak position to counter this and will have little
standing with other broadcasters when they see the BBC continuing
weak outdated in house regulation.
The Bill endorses the formation of one ITV based
in London, and intends to encourage global ambition, and the amalgamation
of the London advertising market. This reflects giving way to
pressure from ITV. There is no recognition of the effect on the
nations and regions, a crucial aspect of PSB. This is the creation
of another monopoly and the exchanging of a regional structure
based in and serving the regions, for a metropolitan one, which
has a purely commercial purpose and is bound to further diminish
this PSB aspect of ITV. It may be argued that one ITV is essential
for other reasons but that should lead to the proposal of alternative
policies for the broadcasting of regional programmes and the production
of network programmes from the regions. These are conspicuously
absent. Today there are 10 national channelsall in and
The Bill's reassessment of PSB has done nothing
to improve the existing position and nothing to address the controversial
issue of fair competition surrounding PSB. The Bill simply assumes
that the five existing main terrestrial broadcasters will continue
to have varying degrees of public service commitment underlining
the status quo. There is no recognition of a changing broadcasting
ecology; no recognition that broadcasters with little or no PSB
commitments have and do trade unfairly against those which have
a more distinct remit. Channel Five, for example, which has the
lightest PSB requirements has been able to run pornography, sport
and old films against the PSB slots on C4 and ITV to great commercial
advantage. Similarly Sky, which has no PSB has been able to do
the same thing against the BBC and ITV. This causes the main terrestrials
to seek to evade or dilute their PSB position (which is quite
easy)hence the upsurge of explicit sex on C4. This raises
a dilemma. Should there be less PSB on the commercial channels
in order that they compete more fairly against C5 and Sky. But
this would not only reduce PSB but crucially drive the BBC downmarket.
Alternatively should some measure of PSB should be introduced
for Sky and C5, now that they are very profitable, to even the
playing field. The Bill's proposal to sit in the middle with its
hands over its eyes is no solution but does reflect successful
lobbying from C5 and Sky.
The Bill proposes to relax ownership rules substantially
though not completely. While this may be thought good for investment
(and again reflects lobbying from Sky) it contains remarkable
anomalies and nothing for PSB. Looked at in context it will be
the fourth successive relaxation in ownership rules in little
over a decade and it isn't easy to discern great benefits for
the viewer. New monopolies have been created, ITV has been dismembered
and retreated to London, Sky is being given greater access to
ownership of the British Media without its parent company paying
any taxes. But the ownership question is a disturbing one-way
street. American companies such as News International will be
able to buy C5 but British companies cannot buy American broadcasters.
European broadcasters will be able to buy ITV but it is exceptionally
difficult to buy the principal French or German broadcasters.
This and much else in the draft Bill reflects the strength and
thinking of the Department of Trade; the weakness and lack of
experience of the Department for Culture Media and Sport.
Other significant things which might do much
for competition and for range and diversity of content are missing
from the Bill. There is no recognition that in the consolidation
of the new monopolies in television there has been a collapse
in the diversity of access points for commissioning in broadcasting.
There has been much anxiety about a reduction in range and diversity
of output but no recognition that if the points of input are narrowed
this will be the result. Fifteen years ago there were dozens of
commissioning points, many of them outside London. It led to a
rich plurality and a much greater diversity and breadth of achievement
than is seen today. Now there are in reality only a handful of
commissioners, all in London. Even senior "commissioning"
executives must get the personal approval of their controller
for almost any commission, an approval which is usually dictated
by the scheduler searching for ratings. This is one of the most
significant threats to PSB and the answer may be to give the new
regulator clear instructions to further plurality of access. OFCOM's
central objectives might include the job of "monitoring,
maintaining and increasing" the number of independent commissioning
points across the full range of output of the five main terrestrial
It is worth noting that the BBC created an effective
Independent Commissioning Group. This proved very successful and
independents won a substantial proportion of BBC output and provided
many of the Corporation's winning programmes when allowed to compete
with in house staff on equal terms. Despite that, the new Director
General chose, in order to favour in-house staff, to dismantle
this effective new commissioning point in what can only be described
as a move to protectionism.
Secondly parts of broadcasting, notably ITV,
(and potentially Channel Four and Channel 5) were periodically
refreshed by a review of the franchises. This helped maintain
public service standards, removed poor performers and brought
in new blood. Another failing of the 1990 Broadcasting Act, reinforced
by this proposed Bill, has been the granting of franchises virtually
in perpetuity. They were granted in 1992 for 20 years (rather
than five to seven) with a review point at 10 years. In practice
they are very difficult to lose, almost impossible to win with
the obvious consequences.
Commercial public service broadcasters need,
if they are to meet proper public service demands, reasonably
stable and secure income (it being, of course, the fear of losing
such income which makes franchise renewal such a potent weapon).
There is not only no recognition of this in the Bill, but there
an emphasis on increasing (often unfair) competition in an already
cut-throat industry. In other words the Bill pushes in the opposite
directioncommercial broadcasters will be obliged to put
even more emphasis on maximising ratings and profits at the expense
of PSBif they are to protect themselves against hostile
The proposal of a Content Board within OFCOM
is a positive aspect of the Bill but it currently lacks a clear
definition and role. We would support the proposals of PUBLIC
VOICE (of which the Campaign is a part) and draw particular attention
to clauses 7.8, 7.10 and 7.13 of their paper relating to the Board.
The relative weakness of PSB in the draft Bill
owes much to its recent history. The real assault on it began
in the 1980s led by Margaret Thatcher and Rupert Murdoch. Although
Mrs. Thatcher failed in her bid to secure advertising on the BBC,
her subsequent legislation, the 1990 Broadcasting Act severely
weakened the public service role of ITV, which in turn made it
harder to sustain on the BBC. Murdoch made his position clear
in his 1989 Edinburgh Lecture in which he envisaged a role for
the BBC similar to PBS in the United States (about seven per cent
of the market) and he unashamedly used his newspapers to further
a partisan campaign designed to enhance his commercial interests
This drive against PSB continued long after
Mrs. Thatcher left office, eg the franchise for C5 was awarded
in the mid-1990s on the same basis as the ITV franchises although
the system was widely discredited, a fact acknowledged by Mrs.
Thatcher herself. It was only with a change of Government in 1997
with Chris Smith as Secretary of State at the DCMS that a more
balanced view was taken. He began to steady PSB after it had been
undermined for more than a decade.
Smith encouraged a clearer PSB mandate for Channel
Four and leant against the BBC's drift down the commercial road
but that is as far as it went. As the prospect of new legislation
grew closer the attacks renewed, usually self-serving. Richard
Eyre, chief executive of ITV pronounced PSB "dead";
the Conservatives promised to privatise Channel Four (which would
effectively end its PSB role) and perhaps most astonishing, Michael
Jackson, chief executive of C4 attacked PSB as "drained of
all purpose and meaning" and "a redundant piece of voodoo".
The fact that Jackson had spent all C4's money, left it in debt
and off-course, and was leaving for a new career in America, may
have affected his judgement. But the more serious inference was
that he simply did not, despite years at the BBC, understand PSB.
Remarkably no senior figure from broadcasting or government effectively
In the period leading up to the present draft
Bill there have been constant calls to produce a new updated definition
of PSB. The drafters have done their best, but they appear to
have gone round in a circle.
The new version (Annex B) contains many, though
not all, of the original principles of PSB and the general aspirations
expressed are very similar. There is a reason for the difficulty.
There was no need to redefine PSB, merely a need to defend it.
It is after all, contrary to what Michael Jackson asserts, a timeless
concept, which a society has or doesn't have in greater or lesser
degree. It is based on eight principles, which distinguish it
from a purely commercial system or from a state system of broadcasting.
It is notable that the draft Bill's version,
while wide ranging, fails to reflect three important principles
critical to PSB
1. That a PSB system recognises citizens,
not merely consumers, and that they have responsibilities as well
2. That the system seeks to cater for substantial
minorities as well as majorities in the television audience.
3. That the system should be independent,
particularly of political and commercial interests.
The Campaign for Quality Television would argue
that PSB has been substantially weakened in Britain in the past
15 years and that this draft Bill, as it stands, will continue
that trend. It contains specific proposals designed to enhance
commercial interests and generally a lack of proposals designed
to enhance the principles of PSB, only sentiments. But it need
not be so. It is perfectly possible to tangibly improve PSB, as
Chris Smith demonstrated with the re-writing of Channel Four's
But it will require specific proposals to reconcile
the above contradictions and include the above exclusions if the
Bill is to achieve what it claims to aspire to.
Two thirds of the population of Britain live
in the English regionsmore than forty million tax and licence
But these people have been shamefully neglected
by broadcasters for the last ten years. And despite brave words
from the Government, the new broadcasting Bill will do nothing
to remedy that situation. On the contrary it is very likely to
increase media concentration in, and on London.
Before the 1990 Broadcasting Act the principal
commitment to fairly reporting and reflecting the rest of Britain
came from ITV which had companies with headquarters in their respective
regions. The BBC made a contribution but it was always a poor
second with 80 per cent of its spend in London and a very limited
range of regional production. Channel Four made no regional programmes
and a limited number of network programmes from the regions. Generally
broadcasting institutions were heavily concentrated in London.
Since the 1990 Act the position has greatly
changed and to the detriment of the regions. Much of this is because
of the effect of the Act on ITV. It took a great deal of programme
money out of the system, encouraged the companies to eat each
other and witnessed a general retreat to London.
Typical is Granada Television, once a beacon
in the North of England. Granada brought the north of England
alive on its screens, brought a non-metropolitan perspective to
the news; a more non-conformist approach to current affairs and
drama; and it tapped the vast writing, comic and entertainment
talent of the north. All this created new cultural industries
and helped reflect what the north could produce to a wider world.
The position today
Today Granada controls seven ITV franchises,
but all now from London. Its commitment to and presence in Newcastle,
Leeds, Carlisle, Liverpool, Manchester, Southampton and Norwich
is a shadow of what existed in the mid-1980s. On the ground the
production of regional programmes are commonly made with budgets
that are a quarter of those more than a decade ago.
There has been some compensation in an improvement
in the BBC and C4's commitment to the regions. But it is quite
limited. In 1993 the BBC recognised that it could not continue
to take a licence fee, 80 per cent of which came from outside
London and spend 80 per cent of it in London. The BBC resolved
to increase its regional spend to 33 per cent. Nearly a decade
later the percentage spend has risen but not to the one third
claimed by the BBC. Unfortunately their figures have consistently
included tranches of programmes still made in or from London and
even programmes made in the Irish Republic.
Channel Four too, with a rewritten licence,
committed itself to 30 per cent of its production from outside
the M25 by 2002. It is unclear whether the target is being met
given that again the figures included a proportion of programmes
made in London, but not as pronounced as the BBC. Again Channel
Four takes a very high proportion of its revenue from the regions
and has most of its viewers there but the culture of its programmes
remains rooted in a SW1 mentality.
In 1996 there was an opportunity to break the
mould and set up a new channelChannel Fiveoutside
of London but again the broadcasting establishment took the easy
route. Channel Five has had little affinity (and no licence commitment)
to the regions. It aspires to a mere 10 per cent of production
from outside London. During the late 80s and 90s various new broadcasters
arrived, Sky, Discovery, A&Eall are based in London.
All this is significant not only because of
the obvious economic and employment benefits of a broadcasting
presence. The production of regional programmes and of network
programmes from the regions permits other critical things that
conventional industries do not provide. Television provides the
majority of news and information; television educates; it promotes
democracy and provides some of the cement that binds society together.
It is not just an economic activity.
As television has drifted more to the metropolis
in what is already the most centralised state in Western Europe,
the people in the English regions have felt penalised. It isn't
merely that job opportunities are lost and skilled personnel drift
away but whole regions are under-reported both to themselves and
to the wider world; they feel under-represented politically; unreflected
culturally compared with what was true before the 1990 Act.
The proposed new legislation
Now, with the imminence of new broadcasting
legislation the position is changing againand again further
to the disadvantage of the regions. The new draft Communications
Bill is committed to one ITV company, the end of the federal system
and the amalgamation of the London advertising market. A government
spokesperson has said that this will not affect ITV's commitments
to the regions. Unfortunately that is simply not true.
The ITV federal structure was created on a regional
basis to fulfil commitments in and from the regions. The new ITV
will be based in London with a global ambition. While it is possible
that a super ITV company may compete in New York, Sydney and Hong
Kong it is just silly of the Government to believe that the same
company will devote the same money and good people to fulfil the
regional role for which it is no longer designed and for which
it has no commercial imperative. Not much energy will be spent
in Newcastle, Nottingham or Liverpool.
Nor is there any encouragement in the new "regional
charter" agreed this month between ITV and the ITC. It permits
a reduction in the range of regional programmes and a substantial
reduction in hours in exchange for an increase in spend on the
remaining programmes that is less than current spendin
effect a large cut in volume and a small cut in value. The charter
also states that ITV will have a target of network production
from the regions, which is substantially below what it currently
It seems equally unrealistic to imagine that
the BBC or C4 could fill the vacuum. Channel Four has already
indicated that it cannot do better than 30 per cent for the next
few years. The BBC after a decade of effort, has never truly met
its target in network programmes from the regions and still produces
less than half of ITV's output in regional programmes.
Once ITV becomes a single metropolitan company
with a global outlook it seems inevitable that the network of
regional stations will be rationalised. Politicians may argue
that licence commitments do not permit this. But this is another
The whole purpose of the merger is to take out
costs (£65 million has been mentioned for starters)and
there are no licence commitments to keep the large regional centres
that previously made network programmes; only facilities for a
minimum of regional programmes.
In other words Granada's Manchester Quay Street
site, worth hundreds of millions to developers, could be exchanged
for an out of town business shed and still fulfil licence commitments.
The fringes of the site have in fact already been sold. In any
event licence commitments are periodically renegotiated.
So how can the new legislation fulfil the support
it claims to give to public service broadcasting and to the regions.
The politicians' rhetoric is strong but the specifics are vague.
A range of options exist though none seem to be being considered.
The distribution of viewers
First it is important to remember the distribution
of viewers. They pay the licence fee; they pay for advertising
and they are the customers watching the programmes; they are also
the citizens being informed, educated and entertained.
Less than 10 million live in London which receives
an overwhelming proportion of broadcasting spend and attention.
10 million live in Scotland, Wales and Northern Ireland, which
while leagues behind London, do have some commitments and do have
two minor broadcasters. The 41 neglected millions in the English
regions do not have a single broadcaster.
A radical shift in policy is required if the
whole nation is to be effectively served. The following non-exclusive
list could be considered:
1. One or two of the many London broadcasters'
channels could be moved to other parts of Britain. The four main
terrestrial broadcasters now have some ten channels between them
all in inner London. A real impact would be made by basing say
BBC-2 in the North. The BBC is supposed to be the pre-eminent
public service broadcaster; it has the most channels and yet it
remains a heavily metropolitan organisation. The opposition would
be ferocious but anything less is really tinkering.
2. The two principal public service broadcasters,
the BBC and C4 could be required by licence or charter commitments
to increase their commitment to the regions but this would need
to be a structural change otherwise, as already indicated it will
not happen in practice.
3. Public service requirements including
the regions could be extended to other channels such as C5. That
would have the added benefit of ensuring fairer competition and
end the situation where C5 and Sky can unfairly take advantage
of the other three terrestrial channels because they carry little
or no public service requirements.
4. A number of small, restricted service
licences have developed supplying local services in some regions.
But they operate under extremely limited conditions. There are
proposals for putting these services on a much stronger footing
so that an effective local television network may develop.
5. Digital broadcasting presents another
possibility. A new channel using either a digital frequency or
a section of analogue (after switchover) could be based in a northern
city and used for the production of regional programmes and network
programmes from the regions. If ITV's regional programmes were
transferred to this new channel, ITV would make two great financial
gains. It would no longer have the cost of regional production
and it would free up lucrative airtime on ITV for profitable network
production. In exchange for these gains ITV could help fund, on
a tapering basis, a new consortium dedicated to launching the
new channel in the regions.
So much turns on the prevailing climate:
It is only a few years ago that, for example,
ATV that held the Midlands franchise sought to keep the bulk of
its production at Teddington, London. Although it had offices
in Birmingham in the West Midlands, it greatly neglected the East
Midlands. Eventually the IBA forced the company to restructure,
to close Teddington and to open in Nottingham on the grounds that
if the company wished to make money from the region and to serve
its viewers (as it said it did) then they must be there to do
Similarly later Channel Four could have been
set up in the regions as could Channel Five. Either would have
had a much more distinctive character contributing to broadcasting
rather than duplicating the London scene. They were not because
most broadcasting people were in London to start with and it was
convenient for them. Executive preference mattered far more than
either their customers or their markets.
None of these thoughts, or anything that will
deliver for the vast majority of the population who live in the
English regions, is reflected in the draft Broadcasting Bill,
only policies that are likely to lead to a further consolidation
on London, a further repetition of channels and programmes, and
a further drift of the audience away from television.