Appendix 1 is attached, addressing the
questions raised by the Select Committee
1. What should be the main duties of public
Public service broadcasting is about a relationship
with the viewer/listener that stimulates participation, interest
and community. It is at its most effective when the wide range
of the intended audience can fully engage with the output.
The definition "inform, educate and entertain"
remains a valuable indicator of content, but there is little that
reflects the wider aims of public service broadcasting on a statutory
level. The risk is that in codification, public service broadcasting
will be reduced to a recipe of so-called less popular genres defined
in statute. In this context, the "soul" of psb is in
danger of being lost along with its duty to engage or surprise
the listener or viewer, reflect the world in which we live and
2. Are the core public purposes of BBC services,
as defined in the Green Paper, appropriate?
There is rightly a great emphasis on culture,
but little clarity about what this includes. If sport is culture,
then what about religion? The cultural mandate should be to portray
the prevailing cultures and other cultures inclusively. The prevailing
cultures should reflect not just present-day understandings of
multiculturalism, but also the nation's Judaeo-Christian heritage.
The balance must be right between showcasing creative talent,
nurturing, training etc and the public purposes of inclusion,
creating community, cohesion and education.
The role of religion and the faith communities
in fostering social cohesion, their contribution to local and
national community life and the role of religion in fostering
diversity in society must not be overlooked. An understanding
of the role that religion plays in society should form an essential
component of public service broadcasting output Indeed, it seems
sensible that s260 (6) of the Communications Act, which of course
did not exist when the 1996 Agreement was written, should be reflected
quite closely in the Agreement's wording. For example, we believe
under 3.2 (b) in the 1996 Agreement, in the section "Programme
Content," the words "and religious" should be inserted
in the section after the word "cultural" in the phrase
"cultural activity in the UK," and, in (e) we would
ask that "religion" be retained. We do not think that
"education" will meet the issues raised in our paper.
3. How do you see the BBC's role as a world,
national and regional broadcaster?
The BBC's role can never be seen in isolation
from other broadcasters or the wider broadcasting landscape. Within
the UK, it should strive to be a focus of excellence and a provider
of trusted content. It must both reflect and help to shape culture,
but never in a manner that is not earthed in the cultural realities
of its audience. It should not impose its own culture or its own
cultural preconceptions on others.
Internationally, the BBC is a trusted source
of impartial information and this should continue and develop.
However, it is important that the BBC does not inadvertently export
an image of the UK at variance with the reality as lived in local
communities across the country.
We see the BBC continuing to have a substantial
in-house programme-making facility. Whilst we welcome the development
of an independent production-making facility in religious programming
which will encourage a lively and creative market place, we believe
that without a properly resourced and staffed in-house religious
affairs department to act as a centre of expertise to infuse and
inform all programmes, the greater understanding of the faith
communities outlined in our submission will not be possible.
4. Should one of the conditions of the new
licence fee settlement be that the BBC play a leading role in
the process of switching Britain over from analogue to digital
The principle of promoting 100% digital coverage
is vital to the prevention of digital exclusion. This could be
accomplished by a variety of means, including the involvement
of the BBC in leading the process.
Clarity is needed about to what extent the licence
fee is expected to cover the costs associated with this additional
purpose, or whether Government funding will be available for (say)
providing set top boxes to low income groups.
5. Is a Royal Charter the best way to establish
the BBC? Is 10 years the most appropriate period for the next
Royal Charter to run? Is there a case for establishing the BBC
on a statutory footing?
The key requirements of independence from Government
and stability without stagnation are met by a Charter. A statutory
basis might make the BBC more vulnerable to political whim. In
relation to the changing landscape of broadcasting, the BBC needs
stability, direction and clear purpose. Ten years is the minimum
term for a Charter that offers these.
The proposed BBC Trust might be better placed
than the Governors to have the power to seek an extension or review
of a Charter at an earlier or later time, say up to two years
early or four years late. This might provide additional stability
and the possibility of emerging directions or new projects bedding
down before future Charter Renewals or reviews.
6. Is the proposal in the Green Paper to replace
the BBC Governors with a BBC Trust and Executive Board the best
way to address the issues of governance and regulation of the
There must be better separation between governance
and management. The Trust proposal achieves this. The BBC plays
a unique role in national life. We therefore think there is nothing
anomalous in having unique governance arrangements, which although
they should contain the key features of all good governanceaccountability
and transparency for instancedo not have exactly to mirror
the governance of other organisations, public or private.
7. Is the role of the proposed BBC Trust sufficiently
clear? How should the Trust be constituted? How can it be made
accountable to licence fee payers?
Accountability: The Trust should guarantee the
delivery of what is promised in the service licences. The service
licences should therefore comprehensively outline what is expected
from each BBC service. A balance should be struck between holding
meetings in public and the discussions that it is only possible
to have in private.
8. How should the rights of licence fee payers
be defined and protected? How should the BBC handle complaints?
The rights of licence fee payers could be set
out in the service licences. Complaints need to be handled consistently,
transparently and rigorously.
9. Are the measures proposed in the Green
Paper sufficient to protect the independence of the BBC from outside
pressure and to ensure that BBC broadcasts are accurate and impartial?
Yes. Faith communities believe that the Charter
is the best guarantee against political pressure. The licence
fee is the best guarantee against commercial pressure. There is
a risk that making the Trust responsible for impartiality and
accuracy is replicating the present position of the Governors.
The Trust's role ought to be to consider, impartially, questions
referred to it about accuracy and impartiality as a regulator,
not a management group.
10. Are the current arrangements for the scrutiny
of the BBC's spending by the National Audit Office adequate?
Yes, if the Trust has powers to commission investigations
into value for money.
11. Are the Green Paper's proposals to regulate
the BBC's impact on competition adequate? Should Ofcom be responsible
for approving the BBC's internal rules governing their commercial
Ofcom should be a statutory consultee as should
the DTI, but the impact on competition rules should be a matter
for the BBC Trust.
12. Should there be a further review of alternatives
to the licence fee and if so when?
The present review has concluded, against the
expectations of many, that the licence fee is viable for the time
being and that the alternatives postulated have significant downsides.
Circumstances either need to change radically or new and viable
alternatives found before a consideration of all the options,
including retention of the licence fee, are reconsidered. A further
review in 10 years' time might be appropriate, if there are new
options to consider or other factors post switch-off.
13. How can the plurality of Public Service
Broadcasting be safeguarded in the digital age?
The significant challenge arises from the preponderance
of digital output that is not produced as public service broadcasting
and is not aimed at fulfilling a specified remit, although it
remains to be seen what the viewing habits of late adopters of
digital technology become.
Although Ofcom has asserted that some output
from purely commercial digital channels fulfils public service
purposes, this is entirely ad hoc and could just as easily double
as disappear. It cannot be counted towards the measurement of
psb without significantly weakening, not strengthening, psb.
Plurality between the BBC channels alone does
not create plurality of provision. This is an area of public policy
that is likely to require further development. Attention should
be given to what incentives can be developed to create enduring
public service expectation and delivery from a wide range of channels.
The maintenance of the plurality of public service
broadcasting, which is such a rich contributor to our heritage
and plays such a vital part in our national life, is a crucial
matter of public policy. If lost, it cannot be rekindled. Market,
consumer and economic forces will not sustain it; indeed, as has
been seen in recent times, they argue strenuously against it.
Public policy must safeguard public service broadcasting and find
diverse and plural means of preserving it whilst delivering it
in innovative and contemporary ways.
14. What is the best way to ensure the BBC
gives independent and external television and radio producers
a fair chance to get their ideas commissioned? Should there be
mandatory quotas for external commissioning?
Independent production is an important tool
for maintaining a plurality of approaches to psb programmes and
avoiding an overbearing sameness in "house style." A
system of open competition between in-house and independent production
has the drawback of creating uncertainties about what level of
independent production can be sustained in the marketplace. Too
much variation year to year risks far greater uncertainty than
many independents except for the largest could sustain. A mixed
system of mandatory quotas and open competition might offset this.