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RSA publishes response to Ofcom
The RSA (Royal Society for the encouragement of Arts, Manufactures and Commerce) has submitted its response to the public consultation on Phase Two of Ofcom's Review of Public Service Television Broadcasting and says that public service broadcasting plays a crucial role in building, tolerant, informed communities and should continue to be supported in the digital television age.
The submission is shown in full below.Submission by the RSA (Royal Society for the encouragement of Arts, Manufactures & Commerce) to the public consultation on the Ofcom review of public service television broadcasting Phase 2
Introduction
Since its inception in 1754 the RSA has encouraged the development of a principled and prosperous society, in which human potential can be fully realised.
Today, supported by 22,000 Fellows, we do this through five manifesto challenges:
• encouraging enterprise
• moving towards a zero waste society
• fostering resilient communities
• developing a capable population
• advancing global citizenship.
Public Service Broadcasting (PSB) can make an enormous contribution to the RSA’s manifesto, particularly to fostering resilient communities, developing a capable population and also to advancing global citizenship.
In our response to Part One of Ofcom’s review we called for a definition of PSB that explicitly addressed the need to reflect the lives of different people and communities internationally as well as in the UK.
We are therefore delighted that Ofcom’s revised definition of PSB now includes the need, “to make us aware of different cultures and alternative viewpoints, through programmes that reflect the lives of other people and other communities, both within the UK and elsewhere.”
PSB and funding
We believe that PSB is a public good and as such should receive public funding. We welcome Ofcom’s commitment to this, but we are concerned by the proposition that “if audiences for PSB content were to decline significantly in the digital age, the case for continued funding at near to current levels would weaken.”
We strongly believe that it is the quality of PSB that determines how far it is beneficial to society and not simply the number of people who watch it. A focus on content and its value would provide a more solid argument for continued public funding.
• We would therefore urge Ofcom to seek to develop a more sophisticated qualitative evaluation of PSB’s impact than simple audience numbers.
• One way of doing this might be to charge a group of relevant but neutral organisations with assessing the qualitative impact of PSB. The RSA would be very willing to form part of such a group. At the same time, we believe that to ensure the best use of public resources and to maximise the independent sustainability of PSB, it is also important to explore other funding streams so that public subvention is kept to a minimum.
Plurality and the future
One of the key functions of PSB is its role in exposing audiences to a variety of cultural, geographic, political and other perspectives. It may achieve this in any number of formats: through news and factual programming, but also through drama, entertainment, foreign films etc.
This allows PSB to make a very real contribution to the development of tolerant, informed communities that are comfortable with diversity in all its forms. In order to ensure the fullest expression of this diversity we support Ofcom’s emphasis on plurality as a central value of PSB. This plurality should encompass providers, programme formats, platforms and technologies.
• It is essential, however, that plurality in these areas remains a means for delivering the diversity of perspective described above and does not become an end in itself. The evaluative focus needs to be on content and not simply on a numbers-driven check list. Thus in the field of new technologies, for example, we believe that it is essential that PSB makes full and innovative use of broadband, third generation mobile phones and other emerging media.
• This should be driven by a concern to deliver PSB objectives in the fullest way possible and not simply by the attraction of technical novelty.
• We would also welcome more consideration by Ofcom on whether and how new technologies might be used to ensure continued public access to PSB programming post-transmission.
Current Providers
The proposal that current PSB providers retain their obligations seems sensible given their experience of providing such content.
• We would have liked to see a more rigorous examination, however, of how far these providers are in fact presently fulfilling these obligations. As we argued in our submissions to Part One of the Ofcom review and to the Barwise enquiry on BBC digital channels, while the number of programming hours definable as PSB has been maintained, the quality and thus the public service impact, of such programmes is much more open to question.
• Again, it seems to us that there is an urgent need for the development of a qualitative evaluation of PSB that moves beyond programming hours, audience figures and other quantative measures. We would urge Ofcom to emphasise such evaluation and to make it central to their ongoing assessment of PSB providers. We are also concerned by the proposal to examine alternative funding arrangements for current commercial providers “in the event of” market failure.
• We would urge Ofcom to make plans for such a contingency now so that there is no uncertainty about the future or direction of PSB if market based initiatives are not able to deliver.
A new Public Service Publisher (PSP)
The RSA has mixed feelings in relation to this proposal. We can see many attractions in a new organisation “charged with making imaginative use of new technologies and distribution systems” to provide a new model of PSB for the digital age, particularly if it operates with the security of guaranteed funding.
• Quality of content must be the central objective of any new PSP.
• We would like to see greater clarity on the relationship that such an organisation would have with existing PSB providers, particularly the BBC.
• It is vital that as proposals for a new PSP are developed they build a genuinely dynamic, competitive environment and not a creatively stale, moribund duopoly.
Conclusion
Subject to the caveats above the RSA supports Ofcom’s analysis of the future of PSB and its proposals for managing it. We believe that high quality PSB provision is vital to the development of healthy, tolerant and informed societies. We welcome Ofcom’s ongoing commitment to this goal and urge them to continue to ensure that quality and not simply quantity is the yardstick by which its success is measured.
RSA
(The Royal Society for the encouragement of Arts, Manufactures & Commerce)
8 John Adam Street, London WC2N 6EZ
www.theRSA.org
Founded in 1754: registered in England as a charity, number 212424
Paul Crake, Programme Director
Jonathan Carr-West, Programme Development Manager
24 November 2004
Copyright © 2004 RSA
Please note that this response does not necessarily represent the views of the RSA’s Fellowship as a whole, nor necessarily those of individual Trustees of the RSA.LINKSThe RSA website
PDF of the RSA submission
Last modified: Friday, November 26, 2004
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Previous stories
Ofcom
We must save regional TV...
ITV regions face more job cuts
NUJ launches protest at job losses in the ITV regions
Charter Review Monthly Report No 6 - October 2004
First tranche of October Ofcom documents published
Ofcom publishes report on BBC's digital services
Consultation on OFCOM broadcast code
Ofcom review: A flawed, contradictory document
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Ofcom Consultation - Principles for setting Licence Fees and Administrative Charges
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Other submissions to Ofcom and Charter Review
OfcomWatch
OFCOM NEWS RELEASE - Ofcom simplifies advertising regulation with 'one-stop-shop' for consumer complaints
OFCOM UPDATE - Ofcom publishes process for the future licensing of FM commercial radio
Ofcom consultative documents
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