Ofcom Review of Public Service Television Broadcasting, Phase 1 'Is Television Special?'
Submission from Carole Tongue and Professor Sylvia Harvey
Submission title: Citizenship, Culture and Public Service Broadcasting, 14 June, 2004


Carole Tongue
Visiting Professor, University of the Arts London
former Member of the European Parliament (1984-99)

Sylvia Harvey
Professor of Broadcasting Policy, University of Lincoln
Principal Associate Director, AHRB Centre of British Film and Television Studies

31 March 2004

1. Introduction
1.1. We welcome the opportunity to respond to the first phase of the Ofcom review of public service television broadcasting and we support the concept of an evidence-based approach to the framing of public policy. We also welcome the detailed factual and statistical information contained in the document Is Television Special? (ITS) and in its accompanying annex documents (made available on CD-ROM), in particular the sections on audience opinions and on viewing behaviour.

1.2. However, we are concerned that - in bringing forward its own propositions - Ofcom may have given too much weight to market expansion arguments and too little weight to public interest arguments. In particular we think that Ofcom appears to be downgrading the central role that public service broadcasting plays as part of the infrastructure of citizenship in a modern democracy [1].

1.3. We believe that the second phase of Ofcom's review of public service television should more adequately reflect the brief outlined by Parliament in the 2003 Communications Act. For the purposes of this discussion we think that the three key legislative requirements are that Ofcom has a duty to:

1.4. It is because of these concerns about the fulfilment of the parliamentary remit that the first part of our submission identifies what appears to be Ofcom's uncertainty about the legitimacy and necessity of public service broadcasting. In the second section we offer brief replies to the ten questions for consultation. And in the final section we summarise Ofcom's key propositions and highlight those areas which we believe offer a helpful elucidation of the parliamentary remit while also identifying those issues where we believe that Ofcom may have started from the wrong premises and therefore offers us inappropriate arguments and solutions.

1.5. Ofcom's Uncertainty about the Legitimacy and Necessity of Public Service Broadcasting (PSB)
1.5.1. Our reading of both the UK Communications Act of 2003 and the European Treaty of Amsterdam of 1997 is that public service broadcasting has been accepted as a necessary and valuable component of the communications infrastructure of democratic societies. Thus, while we welcome Ofcom's exploration of the 'enduring case' for PSB (ITS, p.73) we note that there seems to be considerable uncertainty in the Phase One documentation about this case. Two statements stand out in this respect. The first may be found in the document's Executive Summary:

We believe that in the future, public service broadcasting will no longer be needed to ensure consumers can buy and watch their own choice of programming (ITS, p.9)

1.5.2. While this statement may be accurate as a description of the emerging digital television market it appears not to recognise the continuing necessity and value of broadcasting services that are universally available and free at the point of use. Such universal information provision appears to us to be one of the vital support systems for universal adult suffrage and for active citizenship, as important for democratic participation in the future as it has been in the past. It seems to us that the values embodied in the 'information-for-democracy' approach reflect continuing (and non-partisan) political and cultural priorities. These priorities cannot be dismissed as 'anachronistic', as seems to be suggested in Ofcom's Conceptual Review of Public Service Broadcasting (CRPSB, p.15) - one of the annex documents accompanying Is Television Special? Moreover, the implied assertion that to 'start with the market' offers a method that is superior, in some kind of evolutionary sense, to approaches that start with alternatives to the market seems to us to be unhelpful, since both market mechanisms and market alternatives will continue to be important in the digital age.

1.5.3. A second statement which appears to downgrade the role of public service broadcasting may be found in the fourth section of Is Television Special? In presenting the 'conceptual framework for the digital age' the document suggests that: The 'public good' problem can be largely resolved. Encryption and conditional access systems allow broadcasters to charge consumers directly for their television and to adopt more sophisticated pricing policies that can reflect the differing values that individual consumers put on individual programmes. For example, the first showing of premium content can be priced much higher than subsequent showings, bringing more viewers to the programme for each of the different release 'windows'.[2] (ITS, p.74).

1.5.4. This statement seems to us to ignore the cultural significance of the 'live' nature of television and the consequences of its universal availability. In the case of news, current affairs and most documentaries it is obvious that programmes cannot await a later release window. But the same is true for critically and culturally aware comedy and entertainment programmes such as 'Have I got News for You' and 'Big Brother'. Such programmes have a currency in the workplace, the street and the playground as well as in the home. With this statement Ofcom seems to be resigned to the view that television services, considered as commodities, will become increasingly like computer games or feature film, with all of the divisive consequences that some children and some adults will be excluded from the encounter with trend-setting developments in both politics and culture.

1.5.5. By contrast, there are other points in the Phase One review documentation where both the limitations of market provision and the continuing importance of public service broadcasting are recognised. Thus, for example, the ITS Executive Summary notes:

Even if the TV market provided all the programming that consumers desired and were willing to buy, it would probably not offer sufficient programmes that are valued by society as a whole (ITS, p.9)

And the Conceptual Review acknowledges that television is 'uniquely an accessible mass medium, which can, for example, provide large audiences with an introduction to science, history, nature, music and the arts' and argues that:

..there will still be a need for some form of intervention in the market as PSB will be under-delivered relative to the socially optimal outcome even in the digital world. (CRPSB, p. 16)

2. Ofcom's Ten Consultation Questions (ITS, pp. 81-82)

2.1. Do you agree with the overall assessment of the current system?
2.1.1. We appreciate the detailed research findings that underpin the overall assessment. However, we find this assessment to be both inconclusive and at times unsupportive of public service broadcasting. This is, in part, because empirical data can be interpreted in different ways. Thus the fact that around 23% of television viewing time in the UK is now devoted to watching a large number of relatively new and non-terrestrial channels (Fig. 14) can be taken to denote public dissatisfaction with the output of the five existing public service channels (BBC1, BBC2, ITV, Channel 4 and Channel 5), and to signal that we are living through a 'digital revolution'.[3] But the evidence can also be interpreted in a rather different way.

2.1.2. It seems to us obvious that new technologies are assisting the delivery of new services and we welcome the increased choice that this brings for audiences, though it is also clear that significantly less news, current affairs and serious factual programming is being viewed in multi-channel homes and this may contribute to a continuing 'democratic deficit' (ITS, Fig. 26, p. 45). However, we think that the stated or implied argument that the UK audience is in the process of abandoning the older services is not correct. Ofcom's own research found that viewers considered television to be 'a hugely important and influential medium for the majority of the population. Audiences want the main terrestrial channels to offer easy access to responsible, high quality, varied and innovative programming that offers a shared experience' (Annex Document: Audience Opinions, p. 5). And our belief is that the UK audience continues to value the PSB services. There are several reasons for this belief:

We think it is important to recognise the significance of the changes in viewing habits brought about by new technologies and new patterns of investment. However, it is equally important not to overstate the cultural significance of these changes.

2.2. Do you agree with our interpretation of the data provided to us by broadcasters, and the key findings we have set out?
We agree with Ofcom's interpretation of trends that 'despite increased competition, the television services provided on the main terrestrial channels would appear to be in reasonably good health' and note with interest the observation that between 1998 and 2002 the share of total TV revenues taken by the five PSB channels reduced from 65% to 57% (ITS, p. 27). This seems to indicate highly cost-effective provision on the PSB channels, from the users' point-of-view - 77% of total viewing for 57% of total costs. We also note the Ofcom figure of a real increase of 19% on programme spending during that period on the PSB channels (including the cost of sport and film rights) (ITS, pp. 27-8). However, - with the exception of the new BBC channels - we note the absence of any comparable data on investment in original programmes by the non-terrestrial channels and believe that Ofcom should now research and publish this information (ITS, p.40).

2.3. Do you agree with our analysis of audience trends, and the challenges posed by digital TV and changing viewer behaviour?
In our view access to new digital television services, for those who can afford them, offers welcome additional choice (Fig. 4), though it may also be accelerating a process of social fragmentation and a reduction in public understanding of public spending decisions. It will require judicious and determined public policy initiatives to ensure that the contribution made by PSB services to the advancement of public knowledge and understanding is maintained. We repeat here our general assertion that it is not possible for democracy to function without an informed electorate. We do not wish to see a return, in the twenty-first century, of the discredited and elite 'bread and circuses' approach to the provision of public entertainment. We think that all citizens are entitled to access to the highest quality of information and entertainment services and to a plurality of public narratives that reflect the complexity of life in the United Kingdom to-day.

2.4. Do you accept this interpretation of the role of television in society?
We appreciate the work undertaken by Ofcom in seeking to define and to measure public service broadcasting and endorse the four point 'Citizen Rationale' outlined in ITS (p.9). However, we feel that a more robust and extensive definition of PSB could be developed and that the important role of creative and fictional work as well as of comedy and entertainment should not be forgotten. It would be a mistake to think that the role of PSB in society should be limited to the provision of factual information (though it should include this).

2.5. What are the implications of these responses for broadcasters and for this review?
We highlight and endorse Ofcom's finding that the general public attach 'social value' to 'soaps, sport and drama as well as news and information' (ITS, p. 81).

2.6. Do you agree that competition for quality between the main terrestrial networks is an important aspect of the current system, but that it has been put under strain by increasing competition for viewers, even from the BBC?
2.6.1. We agree that competition for quality has been an important feature of the ecology of British broadcasting in the past. However, we think that increased ratings pressures over the last decade and a half have tended to make all terrestrial broadcasters more cautious and less innovative or risk-taking in their programming. It is a paradox of the multi-channel era that there is now less competition for quality across the broad range of programming though more intense competition in particular areas (for example, in the acquisition of sports rights). There has been a 'dash for the middle ground', described in economic theory as the 'Hoteling effect'; this should be seen as a distortion of competition and inimical to retention of the high standards of PSB.

2.6.2. In our view there will need to be regulatory intervention in order to encourage innovation across the PSB system. This should take the form of a modest amount of new public spending or, preferable, some reduction in fees and taxes on the terrestrial commercial providers, in addition to the continuing existence of the licence fee.

2.6.3. In respect of the historic practice of competition for quality, and the network of industry awards designed to express peer approval, we note that the new Chairman of ITV has confirmed that increased profitability in the commercial sector (rather than the quality of programmes) is now the primary concern. Sir Peter Burt, is reported as saying:

..at the end of the day I'll look at the bottom line. If he [the Chief Executive] says to me that he's won Baftas and all sorts of awards, but there are no profits, he will not have done well.[4]

2.6.4. We endorse the view expressed by Charles Allen (Chief Executive of ITV) that there should be competition between at least two broadcasters for the production of programmes in all key PSB genres. We also endorse his view that such programmes should not be funded through a top slicing of the BBC's licence fee.[5] For further comments on this issue see Section Three below.

2.7. Do you agree with this analysis, and think that this definition provides a good basis for considering the future provision of public service broadcasting and the means for funding and delivering it?
We endorse Ofcom's view that 'there are enduring citizenship concerns which will continue to call for some public intervention in the television market' (ITS, p.82). However, we are concerned that a method that separates consumer interests from citizens' interests could have the consequence of removing the genres of comedy, drama and entertainment from the public service providers. To ensure that this does not happen, we think that Ofcom should develop a more robust and extensive definition of PSB. In addition, Phase Two of the current review should include clear measures for maintaining and strengthening PSB into the foreseeable future. We comment further on funding arrangements in Section Three below.

2.8. Can the challenges of reach and impact be successfully met in a digital world of fragmenting audiences and revenues?
We think that the challenges of reach and impact can be met, provided that there is positive regulatory support, adequate and appropriate finance and well-informed public support.

2.9. Do you agree with these conclusions about the immediate priorities, and are there other issues you think we should be considering?
2.9.1. We agree that the BBC should reaffirm its position as the UK standards setter for high quality PSB provision, that new approaches are needed for measuring, monitoring and assessing PSB, that further work should be done on broadcasting for and from the Nations and Regions and that - as far as possible - a safe environment should be provided for children. We have reservations about the notion of 'more focus by the commercial networks on the most highly valued aspects of PSB' if this means, in practice, that the commitment to regional broadcasting is diminished.

2.9.2. We are not convinced that digital switchover, in itself, can be 'a means of delivering better choice, competition, quality and range to consumers' (ITS, p. 82). We think that this objective can only be achieved by fostering a culture of support for indigenous UK production and by ensuring (as far as possible) that there are adequate resources for this. Increased channel competition, to date, has resulted in increased television imports and an overall decrease in the amount of original production (considered as a percentage of total transmission time).

2.9.3. We urge Ofcom to give fuller consideration to the proposition that 'a healthy UK production sector should emerge from a healthy TV broadcasting market with the appropriate public policy intervention. It should not be the goal of such an intervention' (ITS, p.73). We think this may be an inadequate approach to the issue of maintaining and strengthening indigenous production. The approach suggested here does not appear to have 'learnt the lessons' either from the history of the British film industry or from attempts made in other countries (for example in Canada and in Australia) to maintain a meaningful share of the national market in cultural production.

2.10. Do you agree with our propositions?
What considerations should we take into account in our further analysis of them? We comment on Ofcom's propositions in the following section of our submission. Future Ofcom work should give an indication of the role to be played by the regulator in ensuring the maintenance of standards (including the standard of impartiality in news and current affairs) and of levels of investment in original programming, along with the measurement of audience satisfaction. In particular, Ofcom should indicate what action it intends to take in respect of the areas where problems were identified in current PSB provision (in education, current affairs, regional programming, arts, religion and minority programming, children and a 'safe environment', sport, news, innovation and quality, ITS, pp.57-59).

3. Comments on Ofcom's Ten Propositions (ITS, pp. 11-12)
3.0. In this section we offer a brief summary of Ofcom's propositions (the wording in italics at the start of each section). In brief, we are concerned about three issues:

3.1. Proposition 1: We need to examine the prospects for PSB funding and alternative resources; audience fragmentation may jeopardise the continuation of the TV licence fee.
3.1.1. Our reading of the evidence of changing audience behaviour is that there is continuing strong support for universal access to broadcasting services of high quality (see sections 2.1.2 and 2.3 and above). In our view the BBC licence fee is the fundamental guarantor of universal access to high quality information and entertainment for all citizens. We also believe that the provision of such information is as important and enduring an issue as the provision of healthcare.

3.1.2. However, the provision of information to citizens needs to be independent of pressure from governments, advertisers and media proprietors and there appears to us to be no better mechanism than the licence fee in order to achieve these ends. We believe that viewers (and listeners) will benefit most from maintaining the integrity of the BBC licence fee and ensuring that it is reserved for the exclusive use of the BBC. We do, however, support the adoption of more progressive methods for payment. None-the-less the principle that payment should be made by or on behalf of all television-owning households in the UK should be retained.

3.2. Proposition 2: An effective system requires competition in the provision of PSB programming; we therefore need to examine the case for sharing existing funding streams among a greater number of broadcasters.
3.2.1. As indicated in Section 2.6.3 above we support the principle of competition in the supply of PSB services. This will require the development of an appropriate 'level playing field' and it may be helpful to consider examples from other countries. In Canada, as in other OECD countries, broadcasting legislation is clear in that each broadcaster is expected to contribute to the creation and transmission of national programming. This is not so in the UK. Here, while there is intense competition for advertising revenue, it is only the terrestrial commercial channels that are obliged to meet the additional costs of maintaining PSB standards and original production quotas, while non-terrestrial channels may import significant amounts of programming, and avoid the higher costs of original production.

3.2.2. At the present time only the five terrestrial channels are making a contribution in terms of consistent investment in original programming. This imbalance seems to us to indicate that there is currently no level playing field in the conventional competition policy sense. It would make sense, therefore to extend PSB obligations to all suppliers (requiring appropriate contributions to PSB genres in line with a channel's longevity, programming budget, reach and audience).

All European Union countries surveyed in a 2002 study include broadcast obligations (as laid down in the EU's Television Without Frontiers directive), that 50% or more of transmission time must be filled by European audio-visual works, principally drama, documentary and television or feature film (excluding news, sport, current affairs in studio, talk shows, game shows, advertising and teletext).[6]

OFCOM should work with UK-licensed non-terrestrial broadcasters to achieve measured progress towards this objective, in agreed stages.

France, Spain, Italy and Canada have developed their broadcasting legislation to ensure that every channel makes a contribution to the national/European audio-visual industry by demanding an investment commitment into indigenous drama, film and documentary production as a proportion of annual advertising revenue or turnover. Importantly this is applied to all channels. It is argued that it is practicable, proportionate, and fair and ensures a steadily increasing investment in original local audio-visual production and particularly the local film industry.

3.3. Proposition 3: Where public funding is necessary to secure PSB different means of distributing funding should be examined; options include continuing direct allocations to designated broadcasters and/or allocating funding to broadcasters or producers through a new intermediary body (a 'purchaser' of PSB)
3.3.1. We do not support the concept of an 'Arts Council of the airwaves' (as outlined initially by the Peacock Report of 1986) or the top-slicing of the BBC licence fee to support the work of commercial broadcasters or of independent producers. We think that, in so far as possible, existing PSB commercial broadcasters should continue to draw on market resources to deliver public information and entertainment benefits and that the development of a multi-channel world should not, of itself, be a reason for placing a heavier burden on the public purse in order to maintain previous standards of output.

3.3.2. We also think that the existence and track record of the BBC (as long as its current level of funding is maintained) gives confidence that standards can be maintained and that the BBC will continue to act as a benchmark of quality across the broadcasting system as a whole. In our view a new body would only be required if the BBC were to be abolished and this, we think, would be an unacceptable waste of resources, reputation, brand name and accumulated cultural capital.

3.3.3. Given the continuing existence of the BBC any new funding body for PSB is likely to be a costly and wasteful experiment in the use of public money. In the absence of sufficient evidence to the contrary, we take the view that the licence fee, supporting a strong central institution, remains the best method for sustaining cost-effective and high quality broadcasting for the population of the United Kingdom as a whole.

3.3.4. We do not think that general taxation should replace the licence fee. There is much evidence available on the effects of such action from different parts of the world. In our view this evidence demonstrates that the licence fee remains the best mechanism for independent, cost effective and pluralistic forms of national cultural production.

3.3.5. We do not think it appropriate for Ofcom to take on the duties of an 'Arts Council of the airwaves'.

3.4. Proposition 4: We should continue to secure a substantial contribution to PSB by not-for-profit organisations as their organisational aims may be more aligned with PSB purposes.
3.4.1. We endorse Ofcom's view that not-for-profit organisations (of which the BBC and Channel 4 are prime examples) are especially well-placed to contribute to the production and transmission of public service broadcasting. We agree that 'social purposes may be more easily achieved when the organisational aims within which commissioners and schedulers work are closely aligned with PSB purposes, rather than potentially in conflict with them' (ITS, p. 11).

3.5. Proposition 5: Prior to digital switchover we need to establish how many of the purposes of PSB could be provided by the evolving TV market without public intervention.
3.5.1. There is some evidence that the evolving television market is capable of providing international news and certain sorts of wild-life, history, children's and factual programmes. Some of this material is excellent in its own right. However, material of this kind, usually produced by US-based multi-national companies, is unlikely to be able to achieve the degree of specificity and 'fit' with contemporary British culture and politics of the kind that can be achieved by UK-based commissioners and programme-makers.

In particular, the power of television to shape the minds and tastes of children is without doubt. TV schedules provide the second curriculum outside the classroom and TV plays a vital role in children's emotional and intellectual development. We, as adults, have a critical responsibility to meet and fulfill our children's right to receive TV programmes that are age appropriate, diverse in content (drawing from their immediate culture and others around the world, particularly Europe), entertaining as well as educational and that reflect a broad range of artistic styles and forms.

Furthermore, if our young people are to truly enjoy not just British but also European citizenship, then the 'screen curriculum' must give them information and images from British and other European cultures. Indigenous programmes are an important form of citizenship education in that they can give our children a sense of belonging to a particular society: that of multicultural Britain and indeed the rest of the European continent. The stories that derive from our culture are the glue that binds us together, our shared social values emerge from our past and the society we live in is understood through our stories. These shared values deserve protection and intervention to ensure that there is transmission of and investment in local indigenous production for children by all appropriate channels.

3.5.2. In the case of much work transmitted by non-terrestrial players in a variety of genres, producers are under pressure to be comprehensible across many national boundaries and in many television markets. This work cannot substitute for, though it may complement, 'home-grown' material that is able to address a particular context. We recognise the value of international broadcasting services in reaching different diasporic communities but, again, believe that this is not a substitute for material that addresses local priorities and issues within the boundaries of the nation-state. Since there is as yet no 'world government' there can be no 'world television' that offers specific support to elective democracies, reflecting their priorities and their disagreements.

3.5.3. We believe that each nation state has the right to develop and sustain broadcasting services that encourage and extend freedom of expression and that offer a platform to a plurality of local voices and stories. Public intervention must ensure that such cultural and political pluralism is sustained within the medium of television. We think that television programme content is not 'substitutable' in an international market, in the way that many other commodities are, and that the high costs of audio-visual production may require public intervention and support if original work is to be made.

3.5.4. A drama that reflects the complexities of life in Haiti or in Iraq may be able to be shown, valued and understood in other national contexts. But resources must be made available, within a country, for the drama to be made in the first place. We think that the same arguments apply in respect of indigenous cultural production within the United Kingdom.

3.6. Proposition 6: there is a case for the BBC to undertake a wide range of activities in support of PSB purposes but these activities need to be reviewed periodically to check on their relevance for meeting core purposes; new sources of funding should be identified (for example subscription) for high cost/low audience programmes; BBC activities that may not contribute to PSB purposes should be reviewed.
3.6.1. We agree that BBC activities should be periodically reviewed to ensure that they meet core purposes. We think that this could be done by a new and fully independent Council for Public Service Broadcasting in conjunction with a reformed BBC Governing body, operating on behalf of licence-fee payers and with independent status and resources.

3.6.2. We do not agree that subscription should be introduced as a method of finance for BBC programmes with low viewing figures. Certain BBC programmes will reach audiences in their millions, others will reach audiences of under a million. This is the very function and nature of public service broadcasting that it caters for wide and narrow tastes, offering something for everyone. The principle of universal accessibility should be retained as the one most beneficial to people of all ages and backgrounds.

3.6.3. In general we believe that there are fundamental problems with a subscription method of funding for the BBC and that the licence fee remains a more productive solution.

The introduction of a voluntary subscription fee would inevitably lead to a loss of revenue in a transitional phase. Little or no research has been conducted recently on who would take out a voluntary subscription to the BBC and thus what income the BBC would enjoy in order to plan for the future at this crucial point in the development of the British television industry. Even considering mechanisms that would subsidise the BBC in an interim period, the instability caused to the Corporation would have incalculable effects.

Given the loss of critical mass from which the BBC and its audience currently benefit, the costs of public television would rise and this would inevitably act as a deterrent for some sections of the community, preventing their engagement with programming that not only entertains but also informs and educates. This would dilute key principles of public service such as universalism and inclusion, principles that have underpinned our television and radio services for generations. The prospect of subscription also offers no solution to the problem of funding BBC radio.

3.7. Proposition 7: not all programmes on main commercial terrestrial channels need to reflect PSB purposes and characteristics; however, all BBC programmes should reflect these purposes to some degree in the light of its 'unique and privileged funding status'.
3.7.1. We agree in a general sense with this statement although we feel that it may underestimate the significance of the cultural character and identity of a commercial channel considered across the totality of its output.

3.7.2. We agree that all BBC programmes should reflect PSB purposes to some degree but we do not think that this should prevent the BBC from working across a whole range of programme genres and budgets.

3.7.3. We note with great interest the BBC's announcement that it intends much of its archive material to be available under 'creative commons' licensing arrangements. We think that this will help to make clear the social and cultural distinctiveness of the Corporation's approach to cultural production and reception.

3.8. Proposition 8: Channel 4's distinctive role and ethos should be secured through its ownership status etc. but, as competition intensifies, alternative sources of income may need to be found including 'new commercial initiatives, a share of contestable funding, a new source of direct funding, or a share of the licence fee'.
3.8.1. We agree that the distinctive role and ethos of Channel 4 and of the Welsh Fourth Channel (S4C) should be secured through the confirmation of independent ownership status, and possibly through the creation of trusts for these two bodies. In the case of S4C there should be confirmation of the provision of adequate public funding to enable it to meet its special cultural remit within Wales. We do not think that either broadcaster should be offered a portion of the licence fee.

3.9. Proposition 9: There is more scope for independent producers to enhance the delivery of PSB. Measures could include an increase in the quota of independent work commissioned by broadcasters.
3.9.1. We remain unconvinced on this proposition but would be interested to see research designed to explore the specific ways in which independent production might enhance public service broadcasting. Proportionate investment obligations (as outlined in 3.2.2) will necessarily increase investment in independent work commissioned by all broadcasters, including non-terrestrial broadcasters.

3.10. Proposition 10: Once digital switchover has been achieved public intervention to secure PSB may not be justified on its present scale either because market failures are reduced or because it will be impossible to provide PSB at a reasonable cost.
3.10.1. As indicated in several sections above we do not think that either digital switchover or expanding forms of market provision will, of themselves, meet the cultural and social objectives of public service broadcasting. We emphasise the importance of PSB as part of the infrastructure of a democratic state and believe that it is in all our interests to secure its future.

3.10.2. The maintenance and enhancement of a public space in broadcasting is a societal aim that does not change because of digitalisation and we believe that broadcasting is central to the democratic, social and cultural life of a nation. In this sense public service broadcasting is precious beyond any normal sense of accounting.

3.10.3. Intervention is required in a proportionate manner (as outlined in 3.2.2) to ensure that all channels make an appropriate contribution to public service broadcasting in order to enhance the cultural and linguistic diversity and plurality of audio-visual production, independent production and broadcast output, as well as strengthening the indigenous audio-visual industry.

3.10.4. In our view it is in the public interest to adopt a toolkit of intervention designed to balance competing interests within the communications market. Such intervention must ensure freedom and diversity of expression, resource the information requirements of citizens within a participatory democracy and provide a platform across all channels for creative indigenous expression. Such expression reflects the strong and complex cultural identities that lie at the heart of all democratic societies.


[1.] The contribution that broadcasting makes to modern democracies is noted in the 'Protocol on the System of Public Broadcasting in the Member States' in the European Union's Amsterdam Treaty of 1997, cited in D. Goldberg et al., EC Media Law and Policy, Longman, 1998, p.19.

[2.] 'Premium content' refers to valuable or more expensive programmes or films.

[3.] Except where otherwise stated, the numbered figures cited in this text refer to the 'Charts to Section 4' included among the annex documents on the CD-ROM accompanying Is Television Special?

[4.] 'Make profits not award winners, new ITV boss tells Allen', Lisa O'Carroll, The Guardian, 1 March, 2004.

[5.] 'Allen rejects 'Arts Council of the airwaves'', Owen Gibson, The Guardian, 9 June, 2004. The article reports on Mr. Allen's appearance before the Parliamentary Committee for Culture, Media and Sport.

[6.] Carole Tongue, 'A study of public service regulation in 8 OECD countries' in P. Collins (ed.) Culture and Anarchy, Social Market Foundation 2002

We are grateful for the support of the Arts and Humanities Research Board. The AHRB Centre for British Film and Television Studies is a partnership of seven Higher Education Institutions, funded by the AHRB for a period of five years, from 2000-2005. The Centre combines historical and policy research, provides doctoral training and organises seminars and international conferences.

The Arts and Humanities Research Board funds postgraduate and advanced research within the UK's higher education institutions and provides funding for museums, galleries and collections that are based in, or attached to, HEI's within England. The AHRB supports research within a wide subject domain - from traditional humanities subjects, such as history, modern languages and English literature, to music and the creative and performing arts. The AHRB makes awards on the basis of academic excellence and is not responsible for the views or research outcomes reached by its award holders.



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