Ofcom Review of Public Service Television Broadcasting, submission from Professor Sylvia Harvey.
Submission title: Public Service Television: Everyday Life and the Political Process, 30 March, 2004


Sylvia Harvey

30 March 2004

1. The Objectives and Delivery of Public Service
Television and the uses of television are changing, but there remain a number of constant public policy issues.

1.1. There is a continuing requirement for the provision of high quality information, education and entertainment, delivered in a cost effective manner to households throughout the United Kingdom. This is the 'universal service' principle.

1.2. Television programmes continue to make a significant contribution to life long learning and, in particular, to the maintenance and strengthening of democratic political processes. They continue to have the potential to foster a lively and critical civil society and to encourage the many activities of a participatory democracy.

1.3. Television has, and can continue to have, a role in promoting cultural pluralism and social inclusion. This role has been, in part, obscured by the language of choice and by the assumption that market-based choice will of itself deliver sufficient cultural diversity.

1.4. The impartiality rule in British broadcasting was designed, and can continue to ensure that it is the diverse opinions of the listeners and viewers that count and not the opinions of those who own the broadcasting services.

1.5. In the past, public service broadcasting has been delivered through creative competition between a well-funded BBC and a regulated commercial sector funded by advertising. There is no evidence to suggest that there is a better method for producing and delivering cost-effective public service programming, of a high standard, to all households within the United Kingdom. This submission therefore supports the continuation of licence fee funding for the exclusive use of the BBC, together with appropriate regulatory oversight - by Ofcom - of services provided by ITV, Channel 4, the Welsh Fourth Channel (S4C) and Five. The BBC itself should remain independent of the regulatory oversight of Ofcom except for those areas already specified in the Communications Act, 2003.

2. Describing Public Service Broadcasting
Public service television sets standards of excellence in output across the full range of broadcast programming, with work that informs, entertains and educates. Its programmes offer some insight into the economic and social conditions that enable or obstruct the aspirations and choices of individuals whether acting in their capacity as citizens or as consumers. PSB also recognises and seeks to meet the special cultural needs of children. These PSB principles and actions have been important in the past and will continue to be important in the future.

Public Service Broadcasting can be described in the following ways. The list is not intended to be exhaustive or exclusive.

2.1. Public service programmes may: facilitate the recognition of human rights; this is as likely to be realised in drama as in documentary or current affairs enable democratic processes through news and current affairs programmes, investigative journalism, authored documentaries and drama-documentaries dealing with subjects of current public interest represent controversies and reflect conflicts especially where these impact upon cultural values or the political process reflect the complexity of human interactions in public and private life. examine the details and preoccupations of everyday life as well as the 'big issues' explore contemporary and historical realities tell stories in comic and tragic mode recognise the dignity and explore the dark side of our many identities entertain and satirise within a framework that recognises individual and collective human rights reflect the pleasures and values of different sports promote the recognition, expression and exchange of cultural values present and explain scientific findings and artistic projects recognise that audio-visual communication has an aesthetic dimension as well as a more directly communicative function.

2.2. Public service programmes will: be of a high general standard draw on the best available ideas, images and stories include where appropriate the experimental and the innovative include where appropriate the representation of cultural and ideological conflicts respect and facilitate the creativity of cultural producers be adequately resourced recognise that audiences may be tired of being asked 'what they want' and may appreciate the new and the unexpected.

2.3. Public service programmes will not:

3. Regulating for Public Service: Some Priorities for Ofcom

All television programmes are forms of cultural expression, and those with creative and innovative characteristics are also works of artistic expression. Thus it is important for Ofcom to recognise that television is an industry with important cultural significance and effects. And since both factual and fictional genres can embody high standards of innovation and creativity it will be appropriate for members of the Ofcom Content Board to meet directly with programme-makers, on a regular basis. Such informal meetings should take place alongside formal consultations and the commissioning and use of detailed audience research. This section of the submission proposes, in addition, the following priorities and actions for Ofcom:

3.1. Discontinue the use of the hybrid term 'citizen-consumer'. This term is not included in the Communications Act and its use cannot be supported by reference to the parliamentary debate preceding the Act. The term will not facilitate and may obstruct Ofcom (and the Content Board) in carrying out its duties under the Act.

3.2. Consult with programme-makers working in a wide variety of genres with a view to identifying:

3.3. Augment the provisions for regional programming and for network production 'outside the M25' through a renewed commitment to the presence of Ofcom in the nations and regions. The closure of its regional offices by the Independent Television Commission (Ofcom's predecessor) had adverse consequences both for the regions concerned and for the reputation of the regulatory body. These closures were seen by many outside London as evidence of a change of policy within the ITC, and as a sign of the downgrading of its commitment to regional issues.

If Ofcom is to play a part in the development of the creative industries in the regions and nations (as the original government White Paper suggested it might) then it will need a presence in the regions. This presence will include expert staff qualified to make an appropriate contribution to regional development by liasing with regional development agencies, regional cultural forums and other relevant bodies. These staff will be the 'eyes and ears' of Ofcom, respected by key players within the region and able to negotiate the complexities of political devolution and to advise on any implications for the commissioning, production and regulation of public service broadcasting.

3.4. Intervene on the issue of ITV regional programming prior to the end of the normal scrutiny period where there is reason to believe that the closure of facilities and sacking of staff will lead to an unacceptable diminution in the quality of regional programmes. It will also be necessary to intervene where such proposed closures threaten the maintenance of a critical mass of expert staff within a region or sub-region.

3.5. Review the role of independent production within public service broadcasting in order to ensure the best possible outcomes for viewers and listeners. Ofcom and the government are right to seek to support this largely small business sector within the British broadcasting industry. However, there is increasingly a problem with the expectations associated with this word. The term 'independent' can refer either to a mode of production (a sub-contracted supplier to a broadcaster) or to a cultural characteristic (an independence of thought and an innovative approach to production).

The competitive pressures on broadcasters have in some cases led them to issue very detailed programme specifications or to become inappropriately involved in the making and shaping of the sub-contracted programme. In some cases, this leaves very little room for independent producers to exercise their creative freedom. In this context Ofcom should seek to ensure that audiences benefit from the work of independent companies whose work is characterised by independence of thought and by creative, critical and innovative approaches to cultural production. To this end it may be appropriate for Ofcom to issue additional guidelines, after consultation with broadcasters and independent producers, on operational procedures designed to protect the independence of independent producers.

3.6. Develop robust and sensitive systems for assessing the performance of companies in fulfilling their programme promises and in maintaining a high standard of service. It will be vital to accumulate evidence of output in various programme genres and to undertake the difficult task of calibrating changes over both shorter and longer periods of time. In considering the overall output of PSB it will be important to recognise the fact that the presence of 'a little bit of something somewhere in the system' may not constitute sufficient real choice for audiences.

3.7. Meet the challenge of monitoring programme standards despite the difficulty of applying the methods of 'measurement' to complex cultural artefacts. It will be difficult but necessary to exercise judgement on matters of aesthetic quality, on the presence or absence of innovation and creativity and on the range and diversity of programme contents and genres. There is a large body of published work available on the issue of evaluating and comparing forms of cultural production and on assessing the extent to which they offer a rich and lively reflection of the varieties of contemporary life and belief.

3.8. In addition, the following actions will be required by Ofcom in order to fulfil its remit to support public service broadcasting in the United Kingdom:

3.9. Recognise the operational value of the concept of a cultural 'ecosystem' where changes designed to increase profitability in one part of the broadcasting system may have adverse consequences for the range and quality of outputs in another part of the system.

4. Public Service Radio
The current Ofcom consultation focuses on television. However, it is important to note that radio and, in particular, the well-resourced services provided by the BBC make a key contribution to the overall 'mix' of public service broadcasting in the United Kingdom. It is important therefore that the current Ofcom review of public service television notes the importance of this other medium for the delivery of the public service portfolio.


Sylvia Harvey
Professor of Broadcasting Policy
Principal Associate Director
AHRB Centre for British Film and Television Studies
Faculty of Media and Humanities
University of Lincoln
Brayford Pool
Lincoln LN6 7TS

Tel: 01522 886431
Email: sharvey@lincoln.ac.uk


Last modified 2 August, 2004 ; web@bftv.ac.uk