» SubscribeMain section
-
Top story
Campaign responds to Ofcom PSB review
Campaign for Press and Broadcasting Freedom
The response of the Campaign for Press and Broadcasting Freedom to Phase 2 Meeting the digital challenge: Ofcom's Review of Public Service Broadcasting Television.
The CPBF submission to Ofcom - reproduced here in full - argues that the regulator's current thinking on public service broadcasting "represents a retreat from any attempt to require commercial broadcasters, including BSkyB, to honour public service commitments. At the same time, the BBC has additional programming demands placed on it, restrictions on its ability to develop new services, and a licence fee, which effectively will require it to cut jobs and sell off assets. That is why we think the proposals, which claim to want to defend public service television, are flawed and contradictory."General Points 1 Ofcom's report on the second phase of its statutory review of public service broadcasting starts by assuring us that its proposals are designed to maintain and strengthen public service television in the digital age. The Campaign is concerned that they may have exactly the opposite effect, although there are some elements in Ofcom's analysis on the tools can be used to promote PSB in the future, which the Campaign welcomes. In addition, we welcome Ofcom's acknowledgement of the importance of public service broadcasting in the UK, and of the contribution, that public policy has made to the success of system. 2. This submission, however, raises some critical points about the overall implications of the policy in the Phase 2 Document. In this respect, we broadly support the analysis developed in the NUJ's submission on the Phase 2 Document.(1) It also proposes some positive steps that Ofcom could take to sustain and develop, ITV, S4C, C4, C5 and the BBC into the digital future. Ofcom and the idea of public service broadcasting 3. We regret the narrowing of the concept of 'public service', which has allowed a distinction between 'commercial' and 'public service' to evolve. To speak of 'PSB programming' as if it were completely different from the rest of the output contradicts the spirit of our valued public service system, where 'entertainment' is not separated from other types of output, and is also expected to be 'high quality, innovative, engaging and challenging'.(2) 4. In the Phase 2 document, Ofcom pays tribute to the 'mutually reinforcing mix' of public service broadcasting, which has developed in the UK over the last 50 years or so. If, as they claim, this is not sustainable in the digital era (2.1) new ways must be found to sustain it.(3) 5. Yet Ofcom develops a distorted account of the economics of broadcasting in order to justify a reduction in the overall spend on public service broadcasting. By excluding the vast majority ITV's income from its calculations, (£2.6 billion in 2003) Ofcom comes up with a spurious figure of £3 billion as the sum spent on psb in the UK. It then argues that this figure should be frozen in real terms in the future. 6 The Campaign considers that all of ITV's revenues and facilities constitute the network, which sustains commercially funded PSB in the UK. If you add in ITV's contribution, then the overall contribution of ITV brings the total spend on psb in the UK up to approximately £5.2 billion out of a market total of around £9 billion, or around 54% of the market. 7. Ofcom achieves this feat by defining some programmes produced by ITV as PSB and others as not. In our view, this narrows radically what PSB programming has been, is and should be in the future. 8. By retaining a definition of public service programming that includes entertainment as well as 'elevating' progammes, it is possible to argue that the future of public service broadcasting can include ITV. It is simply a matter of policy choice on the part of Ofcom whether this is or is not done. Equally, by suggesting that the BBC should not be involved in ratings driven programming is to deny the very basis on which the BBC has built public support over the years. PSB encompasses the trite, the glorious, and the elevating. It cannot be chopped up into neat little blocks for the purpose of financial measurement. Freezing PSB 9. At the heart of the Ofcom document is an assumption. This is that in the future the public service sector in UK TV will have to be reduced because the market is better at providing broadcasting. As a result of this assumption, Ofcom develops a policy framework, established at the very beginning of the document, where it states it wants to freeze in real terms the amount of money spent on public service broadcasting in the near future.(4) 10. Ofcom therefore wants to preside over the reduction of the amount of money spent on public service broadcasting in the UK. It provides no evidence that this strategy is justified in terms of the current expressed preferences of the public, or in terms of what better product can be provided by the market in the place of the public service provision it is stripping out of the system. 11. The fact that this approach is a matter of choice by Ofcom, rather than a strategy forced upon it by circumstances, is born out by a number of things. Firstly, the success of the BBC in expanding into online and digital broadcasting shows that, properly funded PSB can play a major role in the new economy of broadcasting. Secondly, the joint venture of Freeview, which has been a major success, shows that timely policy intervention can deliver digital choice in a public service framework to the public. Thirdly, Ofcom details a whole raft of policy tools that could be used to sustain ITV, C4, C5 and S4C as public service broadcasters, but chooses not to use them for this purpose. It chooses, however, to use these tools to create a new body, the Public Service Publisher, which, relative to ITV, C4, C5 and S4C will be a financially and institutionally tiny. 12. Thus, the valuable financial and policy analysis and data in the report is misused to support a policy programme that is essentially political. Were this not the case, then Ofcom would be using the resources it has at its disposal to build on and develop the various public service platforms we have in the UK (ITV, BBC, S4C, C4, C5) so that they are strong presence in the digital future. In addition, it could add to this mix by developing local TV on a non-commercial basis. We hope we are wrong, and that Ofcom has simply adopted an over cautions pessimism about the strengths and potential in the current system, but we have yet to see any evidence to support such and interpretation. ITV 13. The contents of the report were good news for ITV's shareholders. The share price of the merged ITV group rose, and analysts advised 'buy' because of the proposal that ITV non-news regional programming should be reduced from three to one and a half hours, and may be reduced further in later years. This could add £20 million to ITV's annual operating profits. 14. In addition after digital switchover ITV's public service remit will be limited to producing 'high-value UK programming, news, current affairs and, if financially sustainable, a core regional news service.' It will no longer be required to carry arts, religious or children's programmes - and its regional news service is almost certain to go. ITV has the outcome it lobbied for. It has been let off the hook, and the BBC has been given the responsibility to fill the gap left by ITV abandoning its regional remit. 15. This is one policy proposal which is a classic example of stating an intention is to do one thing, when the impact of the proposals, if implemented, will be the opposite. 16. The Campaign is not convinced by the arguments put forward in the document to justify this staged retreat of ITV from its public service commitments. ITV plc is a company that is making profits and will be able to make profits on the new digital platforms. It must not be allowed to dissipate the physical resources (studios, equipment) and skills (production staff, journalists, technicians) that are needed to sustain commercial public service TV in the UK. 17. ITV plc will, if Ofcom allows it to, retreat from providing proper public service programming for the nations and the regions in the UK. However, it will retreat with archives, facilities and a brand name, which are all, in part at least, public assets, built up with public money. If ITV seeks to retreat from PSB in the UK in the digital era, Ofcom should take steps to recover the brand name from the company for public use on the digital platforms of the future, and Ofcom should also seek the powers to take a majority stake, for the public, in the exploitation of ITV's archives. Ofcom accepts the principle that archives can be exploited to generate revenues for PSB. We do not accept that the BBC's archives should be exploited commercially, but we do think the principle of exploiting archives to support PSB should be applied to ITV if it chooses to stop providing public service TV on digital platforms. 18. On a positive note, we strongly applaud the way Ofcom has enumerated the range of policy and fiscal tools and powers it could exploit to intervene in the market place and fund PSB in the future. These include instituting a levy on all commercial broadcasters to help fund public service programming. Ofcom should consult widely in the nations and regions, especially with the Welsh Assembly, so as to be able to develop a package that would make it financially viable for ITV to continue as a public service broadcaster into the digital age. The tools it could use to do this include: tax incentives, grants, EPG prominence, must carry rules, and multiplex capacity. The collapse of national and regional TV 19. Ofcom's proposals for ITV will lead to the collapse of production of ITV programming in the regions of England and in the nations of Wales and Scotland. In Wales, where commercial TV has played a central part in defining and promoting Welsh institutions and culture, providing a counter balance to the BBC and supporting Welsh language programming on S4C the problem is particularly acute. 20. The fact that Ofcom was unable to publish proposals for how to tackle the collapse of public service commercial TV in Wales in its Phase 2 document testifies to how its model of allowing public service to decline in the medium term, will simply deprive people there of programming that responds to their aspirations. 21. We contend that this issue has to be brought to the public in the regions and nations of the UK before there is any final decision on the future of ITV. In addition, ITV should be forced to retreat from its current raft of announcements which are pre-empting public debate about the continuation of commercial public service broadcasting in the nations and regions.(5) BBC 22. The BBC will be severely constrained. The licence fee will not be increased in real terms. Any increases in revenue will come from 'better collection' and the fact that more households will, after ten years, generate an extra £230 million a year. In contrast, revenue from subscription and sponsorship already outstrip the £3 billion raised by the BBC from the licence fee. BSkyB has just announced a £75 million advertising campaign to drive up subscription from 7.4 subscribers to 8 million by next year and 10 million by 2010. 23. There is a clear warning to the BBC in the Ofcom report to stay off the popular programming that commercial broadcasters can supply, and become more responsible for providing those areas of public service broadcasting that are at risk. This strategy will undermine a vital foundation of the BBC's support - its ability to provide programmes across the widest range - to its viewers. 24. The report also proposes: a) that ITV should drop the bulk of its national and regional programming (in Wales, the Midlands etc) and that the BBC should be made to pick up the bill and do these programmes, whilst it will have no extra money to do so. b) that in future the BBC consider privatising some of its activities, charging subscription fees to viewers (thus making them pay twice for programmes) and transferring assets to Channel 4 c) that the government grant the BBC a charter shorter than the standard 10 years, to prevent the BBC from, as it puts it, from 'any tendency to chase ratings' - in other words penalise the BBC if it proves too successful in competing with the commercial sector by putting it through a mid-term Charter review! d) forcing the BBC to have all of its plans for expansion subjected to independent scrutiny - something Ofcom does not propose for its rivals.(6) 25. In our view, the proposals on the BBC, far from protecting its future, will serve to weaken and marginalize its presence as a major and positive force in UK broadcasting. 26. A more positive approach would be to encourage the BBC to expand across the new platforms identified in the report in a staged manner, in co-operation, where appropriate with other public service broadcasters. Of course, the BBC should be subject to proper scrutiny, but a scrutiny designed to manage proper development, not restrain it. 27. There is no case for allowing the BBC to be further regulated by Ofcom. If Ofcom as an organisation were reformed to ensure that it was truly representative of the peoples of the UK, and if Ofcom's main purpose was to promote public service values vigorously across the system, and if both systems of governance were made more democratically accountable, then there would be a case for unifying the regulation of broadcasting. Channel 4 28. Channel 4 was set up as a non-commercial channel to provide a diverse range of programming that is not provided elsewhere. This remit should be protected in the digital age far more strongly than in the present document. There is also a suggestion that, if Channel 4 cannot fulfil its public service obligations in the future, assets that earn income could be transferred from the BBC. 29. OFCOM recognises that the dilemmas for Channel 4 as a not-for-profit organisation arise because its funding is not protected as it was in its early days.(7) It is essential that the distinctive nature of the channel be maintained, if necessary by a new funding formula, but emphatically not by the transfer of funds from the BBC. The Channel must maintain its complete independence and unique character. OFCOM's proposals, as they stand, effectively accelerate the decline in of ITV, Channel 4 and 5 as contributors to the public service ecology of UK television. We have suggested some of the ways this could be done, building on suggestions made by Ofcom, in paragraph 19 above. The future of C4 and C5 cannot be viewed independently from the future of ITV and the BBC. A policy package of the sort we are suggesting needs to be developed to sustain the innovatory role of C4 and the wider public service role of ITV and C5. S4C and the problem of the nations 30. The future of S4C hangs in the balance as result of this document. Instead of an unequivocal statement supporting this vitally important cultural resource, and one which asserts the need to increase the government grant to the body so it can adequately face the challenges posed by digital switch over, there is virtual silence. Ofcom, so agile in its thinking about everything else, freezes when faced with the problem of S4C. Why is this? 31. Ofcom is essentially a centralist body. In spite of many, many representations from the Welsh National Assembly, from trades unions, AMs and MPs the government failed to appoint a Welsh representative at Board level. It also failed to do this for the other nations of the UK. The consequence of this is that where the needs of Wales and the other nations are concerned, Ofcom has no adequate policy. The Board lacks individuals who are politically committed and culturally rooted in these communities. This is a major failing. 32. At the very least Ofcom needs to consult with the political and civil and cultural organisations in the nations before it does anything further to damage the cultural heritage of commercial broadcasting in these nations. At the very least it should commit to regular increases in funding for S4C, and to making sure that ITV does not retreat from programme making in Wales. A new Public Service Publisher (PSP) 33. The document then proposes a new Public Service Publisher, which will provide competition to the BBC by providing what it describes a 'PSB programming' on a new digital channel via new media. 34. We support innovatory and interesting ideas using new media platforms and technology. In the digital-only age, where entertaining and informative material may be received on a variety of platforms, it is essential to imagine how public service principles may be sustained. This proposal potentially opens up possibilities for innovative formats, interactive structures, community media and smaller scale participatory programming. It could have a real purchase on democratic participation. We welcome the suggestion that it will be non-commercial and the commitment to a regional base and to innovative programming. 35. Yet we are puzzled about why the policy tools which Ofcom will be using to launch this (not least of all direct government support, handled at arms length, and subject to a competitive process of tendering) cannot be used to as part of a package to help develop commercial public service broadcasting in general? 36. Ofcom has pointed out that in 2003, total TV broadcasting revenues, including the licence fee, were £9.534 and for the first time subscription, revenue exceeded advertising spending. Subscription was £3.202 billion and advertising £3.148 billion.(8) Ofcom suggests that in 2012 £300 million(9), less than 3% of the 2003 revenues in UK TV, could be spent on the PSP. This is a tiny amount, compared to the ITV revenues in 2003 (£2.6 billion), let alone the size of the total market. In essence, the proposal cannot, using these kinds of figures, be regarded as serious. It would need to be a much bigger amount of money, and even then the question would have to be asked, why a PSP, why not a properly managed increase in support for ITV, C4, C5 and S4C - all of which satisfy Ofcom's stated preference for putting their programming out to competitive tender? How, if at all, could this notional £300 million replace commercial broadcast production in Wales, Scotland and Northern Ireland? 37. Why can't the BBC be encouraged to move into these new territories as well? The BBC has demonstrated its ability to innovate and move successfully into new media. However, the report seems to suggest that this kind of development by the Corporation may be blocked in the future. There is also a lack of clarity about whether the BBC will be allowed to go on the various platforms, which Ofcom wants to devote almost exclusively to the PSP. 38. The existence of a non-commercial publisher might, in the future, be an addition to the mix, not a substitution. As it stands it is a substitution of a much larger provision that Ofcom wants to see removed. Ofcom should not allow the commercial channels to abandon a commitment to be part of a broad public service system and imply, erroneously, that the PSP would be meaningful force for sustaining public service provision in the digital future. Conclusion: on public service broadcasting 39. However, the overall thrust of the Ofcom report represents a retreat from any attempt to require commercial broadcasters, including BSkyB, to honour public service commitments. At the same time, the BBC has additional programming demands placed on it, restrictions on its ability to develop new services, and a licence fee, which effectively will require it to cut jobs and sell off assets. That is why we think the proposals, which claim to want to defend public service television, are flawed and contradictory. 40. We have suggested some ways to tackle the genuine problems posed by change. We do not take the pessimistic position that Ofcom does. We think that Ofcom has outlined the need for the use of a range of policy tools to develop public service broadcasting into the digital future. We think Ofcom has described those tools. We think it is Ofcom's task now to speak for the peoples of the United Kingdom, not for sectional commercial interests, and seek to employ a range of policy tools to sustain and develop Public Service broadcasting in innovative ways into an era of digital communications. Footnotes 1 NUJ, The response of the National Union of Journalists to: Phase 2 - Meeting the digital age Ofcom review of public service television broadcasting. (London, Ofcom, 2004)' (NUJ, London, November 2004). 2 Ofcom, Phase 2. - Meeting the Digital Challenge: Ofcom review of public service broadcasting (London, Ofcom, 2004) paras. 2.12, 2.13. 3 ibid, para. 2.1 4 ibid, para. 2.5 5 See NUJ Response for details of the major programme of redundancies and cuts that started in 2003 and have accelerated in 2004. 6 Ofcom, Phase 2. - Meeting the Digital Challenge: Ofcom review of public service broadcasting (London, Ofcom, 2004) paras, 2.5, 5.57, 6.13,6.18, 6.23, 6.24 6.5,6.62, 6.64 7 ibid, para.2.4 8 Ofcom, The Communications Market 2004 - Overview (London, Ofcom, 2004): 22 9 Ofcom, Phase 2. - Meeting the Digital Challenge: Ofcom review of public service broadcasting (London, Ofcom, 2004) para.2.68 Campaign for Press and Broadcasting Freedom, London E17 9NL. November 2004.
Last modified: Tuesday, December 7, 2004
Previous ofcom stories
RSA publishes response to 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
ofcom watch
Ofcom Consultation - Principles for setting Licence Fees and Administrative Charges
ofcomwatch - bloggers with no agenda!
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
OFCOM Watch
OFCOM Watch
On and Ofcom...
OFCOM AND PRESS REGULATION
OFCOM role to include the BBC?
-
Notices
Events & Announcements
World Press Freedom Day
More reporters are currently imprisoned in Turkey than in any other country in the world. Only a matter of weeks ago lawyers failed to persuade a Turkish court to release a 76-year-old journalist from a Turkish internet news station.
World Press Freedom Day on Friday May 3, 2013 is being marked in Britain by a rally to highlight the dangers facing journalists in Turkey and in this podcast, Nicholas Jones speaks to Barry White, Organiser at the Campaign for Press and Broadcasting Freedom, and Sam Bamford, the TUC's policy officer for Eastern Europe and Africa about the importance of a campaign to highlight international press freedom.
The World Press Freedom Day rally is being staged by the National Union of Journalists at the NUJ head office, Gray’s Inn Road, London WC1 on Thursday May 2, 6pm-8pm.
DATELINE: 27/4/13
UK launch of EU media campaign
DATELINE: 13/3/13
The UK launch of a 'European Citizens' Initiative' calling for EU rules against concentration of media power will take place on Thursday March 21 from 11:00am – 12:30pm in Committee Room 4A at the House of Lords, London. Guest speakers will include actor and activist Hugh Grant (pictured), media consultant Claire Enders, Professor Steven Barnett, Barry McCall (President of the NUJ) and Marc Gruber (Director of the European Federation of Journalists).
A European Citizens' Initiative is an official petition, like a Downing Street petition. If it succeeds in gathering a million signatures across the EU, the Commission is obliged to respond.
This petition calls for the EU to act to protect media pluralism and press freedom.
CPBF Annual General Meeting
DATELINE: 1/3/13
Make a note in your diary
Saturday 13 July 2013 from 10.00am
NUJ HQ, 308/312 Gray's Inn Road, London WC1.
Leveson, media ownership, CPBF future work.
DOWNLOAD FREEPRESS NOW
DATELINE: 26/3/10
Download Freepress in PDF, ePub or mobi format. Issue 194 now available.
MEDIA FOR ALL CONFERENCE
DATELINE: 26/3/10
Papers from the Media for All Conference
MEDIA MANIFESTO
DATELINE: 26/3/10
The media’s job is to inform and entertain us but we rely on them too to tell us what our rulers and representatives are up to. In the run-up to the Iraq war the government used spin and disinformation in the media to create panic and mislead people. The truth is coming out now, but we need stronger, more independent media to be able to scrutinise governments and make informed choices.
-
Previous stories
Ofcom
RSA publishes response to 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
ofcom watch
Ofcom Consultation - Principles for setting Licence Fees and Administrative Charges
ofcomwatch - bloggers with no agenda!
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
OFCOM Watch
OFCOM Watch
On and Ofcom...
OFCOM AND PRESS REGULATION
OFCOM role to include the BBC?
