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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
PUBLIC SERVICE TELEVISION: EVERYDAY LIFE AND THE POLITICAL PROCESS
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.
Contact: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
