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
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
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
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
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
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
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
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 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
10. "Whether the European Commission's
reform of the sale of Premier League broadcasting rights present
a genuine opportunity for terrestrial broadcasters to acquire
The FA offers no comment on this particular
We hope that this information is of assistance
to the Committee and look forward to appearing on 17 January 2006.
5 January 2006