Select Committee on BBC Charter Review Minutes of Evidence

Letter from the Football Association

  The Football Association is looking forward to meeting with the Select Committee on 17 January 2006.

  In consultation with David Davies and other colleagues, we are happy to offer the following written observations and we trust that these will be of assistance to the Select Committee, forming the context of our appearance before the Committee in January.


  The Football Association ("The FA") is the governing body of association football in England. The FA was founded in 1863 and is responsible for all regulatory aspects of the game of football in England, the promotion of the game, the governance of the administration of the game and for exploiting The FA's key assets in order to generate funds for distribution throughout and investment in the development, of the game of football. The FA's activities are many and varied. They including promoting the development of the game amongst all ages, backgrounds and abilities in terms of participation and quality, and promoting the availability of the sport to the greatest number of people. It includes regulating the game on and off the field through the relevant Laws and Rules, sanctioning either directly or indirectly all matches, leagues and competitions in England and overseeing the administration of the disciplinary system and the administration of refereeing throughout the game.

  The FA organises a number of senior men's, youth and women's national competitions and a number of representative England teams at all ages and for all abilities. The FA's main commercial assets include The FA Challenge Cup and the England Men's Senior Team, events, the rights to which are of great interest to radio and television broadcasters both in the UK and overseas. It is from the exploitation of broadcast and sponsorship rights to these primary properties that The FA is able to generate the revenue which in turn is used to develop the game of football at all levels, improve standards and increasing participation, and is distributed to clubs, leagues, counties and associations throughout the game.


1.  "The audience figures for live football on the BBC and on other channels"

  We attach at the end of this letter audience figures for live matches that the BBC has broadcast from The FA Cup and England Internationals for the three previous complete seasons.

2.  "The importance of BBC television and radio to football"

  The BBC has broadcast football, whether on radio or television for over 70 years. As the nation's publicly funded broadcaster, and as a free-to-air channel, the BBC has always been an important outlet for the broadcasting of top sports events. For many years the BBC has broadcast The FA Cup Final, and as independent television developed and as the amount of football available to be broadcast on television increased, main matches in The FA Cup together with The FA Cup Final and England matches have been shown on free-to-air television between BBC and ITV attracting huge audiences. On radio, The FA has had an almost unbroken relationship with the BBC allowing both live commentary of main FA Cup and England International matches, as well as scoreflashes, news, reports and features.

  In the broadcasting environment of 2006 the BBC is still a major player in the broadcasting of football. In relation to the rights held by The FA, we have a four year agreement with BBC television expiring in June 2008, allowing the BBC to broadcast live matches from The FA Cup, live Home England Internationals and matches from the Women's FA Cup and other FA tournaments. Other broadcast rights are owned by BSkyB to broadcast in partnership with the BBC. For example, in each round of The FA Cup, four live matches may be broadcast, three by the BBC and one by BSkyB. Each broadcaster is able to broadcast highlights of each round.

  BBC Radio Five Live has an agreement, also expiring in June 2008, to broadcast live commentaries of up to seven 7 matches in each round of the FA Cup, together with Home England Internationals, and is able to offer Scoreflashes and updates from all other FA Matches.

  The BBC is currently an important broadcast partner of the Football Association, and we enjoy a successful and fruitful relationship with them. As can be seen from the viewing figures set out under question one, the BBC enjoys extremely healthy viewing figures from its broadcasts of FA Cup and England matches. It is through this arrangement that The FA has been able to ensure that its main football properties are available to the widest possible audience. In that respect the BBC is an important part of the broadcasting landscape in general and a key partner of The FA in particular.

3.  "The effect on the game of the decreasing amount of live football on free-to-air television"

  The FA disputes the suggestion that there is a "decreasing amount" of live football on free-to-air television. In relation to The FA's own rights, in its current broadcasting arrangements, there are currently more matches available live on free-to-air television than was the case under our previous broadcast agreements.

  The FA also notes that the UEFA European Championship and FIFA World Cup are available live on free-to-air television, and are, in addition, listed events. UEFA Champions League matches are still live on free-to-air television, with a wider choice being offered to subscribers to pay television and there are an increasing number of matches within the UEFA Cup which are available on free-to-air television on an ad hoc basis.

  The FA would ask the Committee to note that there has not been live coverage of top league matches on free-to-air television since 1992, and that there has been comprehensive highlights coverage of the FA Premier League and Football League matches in that period.

  We would argue that the balance of coverage between free-to-air television and subscription television across all of the football properties available for exploitation within the UK is fair. In particular, the rights exploited by The FA tend to be "major events". All those matches are available on free-to-air television.

4.  "Whether the BBC should have a duty to bid for certain sports events"

  The FA does not express a view whether the BBC should have a duty to bid for sports events. However, as a publicly funded broadcaster which draws its funding from a compulsory licence fee, we would observe that the BBC must always seek to ensure that it is offering a spread of programmes that appeals as widely as possible to as many of its licence fee payers as is possible. On that basis, since football is the nation's most popular sport, and football broadcasts are amongst the most viewed broadcasts in any particular year, the BBC will retain widespread support and credibility amongst licence fee payers if it is able to offer a good mix of attractive football broadcasts as part of its public service obligations.

  The FA notes that the BBC has always taken the approach that it should bid for key sports events, and has always expressed an interest in bidding for rights to The FA's properties. As part of the current broadcasting arrangements between The FA and the BBC, not only can the BBC broadcast live the most attractive matches, but it also exercises a public service remit in giving coverage to matches within the "grass roots" level of the game, such as the Women's FA Cup and other FA competitions. This assists the development of the game at the "grass roots" and provides wider exposure of certain of those events. In that respect, the BBC is exercising its public service remit and providing a service to the public that helps it to retain support and credibility amongst licence fee payers.

5.  "The BBC's approach to bidding for sports rights"

  We would be pleased to answer the Committee's direct questions on this point when we appear before the Committee.

  However, we would hope whenever the BBC is bidding for sports rights, that it participates openly and fairly in any bidding process, that it offers what it considers to be a fair market value for the rights in question, reflecting the value of the rights to the BBC, and that it does not attempt to rely on legislation or other regulation to attempt to secure rights below the market price. The FA is pleased to assure the Committee that, in our experience, the BBC has always operated in this way in its negotiations with The FA for our broadcast rights.

6.  "Whether there should be an independent review of the way the BBC bids for sports rights"

  The FA offers no comment on this question.

7.  "Whether the BBC can provide enough air time to fully realise the value of your rights"

  We are satisfied with the amount of coverage that the BBC provides across television and radio for the rights of The FA which it exploits.

8.  "Whether a specialist BBC sports channel is desirable"

  The FA expresses no position on this question.

9.  "Whether the listed events system provides sufficient balance between protecting free coverage of sporting events and securing income for sports"

  The listed events legislative regime has existed since the mid-1950s. At that time, it was devised to protect the BBC against competition from the newly created independent television. Since then the regime has been adapted to offer protection for free-to-air broadcasters against the arrival of subscription and pay-per-view broadcasters, so as to ensure that the so called "crown jewels", being the most popular and iconic sports events, should remain available to free-to-air viewers on a live basis.

  Since the listed events regime has been a part of the broadcast market environment for many years, we have seen no basis for intervening and changing it. The FA Cup Final has been a listed event ever since its inception and it would not be The FA's position to argue for either removing The FA Cup Final or for adding any additional matches within our inventory onto the list. We do not believe in making any further alteration to the balance of the broadcast market by either removing events from the list or by adding to it.

  If there were no listed events regime in place now, we would not argue for there to be one. However, since there has been a listed events regime for many years, we believe that the market is mature enough to deal with the balance caused by some events being reserved for free-to-air broadcasters. We are aware that many have challenged the whole concept of listed events on the basis that it distorts the markets and reduces the income available to rights owners whose events are on the list. We do not believe that this need necessarily be the case. As long as the free-to-air broadcasters continue to offer a fair market price, reflecting the value of those events to those broadcasters, then there is no reason why the listed events regime should distort the market.

  The Select Committee will be aware of the CCPR Voluntary Code on broadcasting rights, which all the major spectator sports have signed up to. This Code guarantees that at least 5 per cent of all TV revenue derived by the signatory sports is reinvested into the sport. This illustrates how most major sports take a responsible view of raising broadcast revenue. Of course, The FA invests considerably more than this in the sport at all levels.

10.  "Whether the European Commission's reform of the sale of Premier League broadcasting rights present a genuine opportunity for terrestrial broadcasters to acquire live rights"

  The FA offers no comment on this particular question.

  We hope that this information is of assistance to the Committee and look forward to appearing on 17 January 2006.

5 January 2006

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