1.1. The White Paper (WP) covers a lot of ground in its 100+ pages. It offers both a broad statement of the Government’s proposed vision for ‘communications’ regulation and a list of more specific policy proposals on which it invites comment.

1.2. Furthermore, the WP’s publication has been accompanied by an Initial Regulatory Impact Assessment (IRIA) which sheds further light on the WP’s agenda and also invites comment. Our response here has been drafted in the light of both these documents.

2.1. The WP contains a number of commitments and proposals that can be warmly welcomed: on the pivotal role of the BBC, on not privatising Channel 4, on community media, on the importance of impartiality, quality and diversity; and on the regional dimension to its proposals.

2.2. However, on the debit side we find the WP’s overall vision and objectives to be deeply flawed and unbalanced. It prioritises industrial policy and deregulation over citizen welfare and social cohesion, and its chosen model of industrial policy would, we believe, do considerable damage to the ecology of public service broadcasting (PSB).

3.1. Our response is structured as follows. We start by outlining our disagreement with the WP’s core vision and objectives. We then go on to examine the WP’s model of industrial policy, and the divergent regulatory cultures of broadcasting and telecoms. The next sections look at how OFCOM’s agenda does not accord the PSB framework the respect it deserves, and how its ‘3 tiers’ model will entail significant deregulation of Channels 3, 4 and 5. We then look at the place of the BBC, and argue for certain key reform agendas. This is followed by more detailed remarks on Channels 4 and 5. The last two sections look at the community media agenda, and at the interactions between this WP and the recent one on international development.

4.1. The WP notes at the outset that:

"…we need to be clear about two issues: the goals we seek as a society and the regulatory framework that helps us to achieve our goals.." (WP 1.1.25).

4.2. We agree, and for exactly this reason we cannot endorse the WP’s core vision, nor the regulatory model that informs it. The WP is quite clear about where the proposed emphasis should fall. Its declared first objective is to:

"..make the UK home to the most dynamic and competitive communications and media market in the world.." (WP 1.2.1).

4.3. With industrial policy goals in prime position the WP goes on to

acknowledge what it sees as the important but clearly secondary objective of ensuring access, diversity and quality in these sectors (WP 1.2.4).

4.4. In our view this represents a classic inversion of means over ends. The communications arena is the backbone of the body politic, and citizens rights and social cohesion must be the touchstones which guide public policy. Industrial policy agendas must be firmly harnessed to this broader social agenda, not (as the WP has it) the other way round.

4.5. The WP’s downgrading of citizen welfare is doubly surprising given that it stands in direct contradiction to recent Government statements about the need to use communications policy to strengthen social cohesion rather than damage it.

4.6. In particular, the DTI-backed Policy Action Team report ‘Closing The Digital Divide’ [1] (which was welcomed and endorsed by Government [2]) has as its first Key Recommendation:

"..1 The Government must ensure that all of its actions to promote the use of ICTs and e-commerce are coherent and reduce rather than increase social exclusion.." [3]

4.7. Not only does the WP overturn this mandate, subordinating social cohesion to business development, but - as we discuss below - its particular model of industrial policy (in essence, a mix of telecoms-style competition policy and deregulation) would do considerable damage to what is still the most pivotal and socially inclusive of all the communications sectors - namely the public service broadcasting arena.

5.1. As a strategic framework document the WP’s central thrust is to seek to apply the model of industrial policy that was outlined in the DTI’s Competitiveness White Paper of December 1998, "Our Competitive Future - Building the Knowledge Driven Economy" [4].

5.2. This placed a new order of emphasis on competitive markets, competition policy and regulatory reform, but balanced this with a recognition that markets often fail to meet the legitimate interests of citizens and consumers. As the Prime Minister put it in his Foreword to the DTI WP:

"…Old-fashioned state intervention did not and cannot work. But neither does naïve reliance on markets.." [5]

5.3. As a consequence, in this new model the risks of market failure require counter-balancing with regulatory oversight to shape outcomes and protect the public interest.

5.4. Moving regulation centre stage in this way has been accompanied by heightened concerns about the scope and structure of the regulatory agenda. In the financial services sector the Government moved to replace 9 discrete agencies with a new ‘super regulator’ - the Financial Services Authority (FSA). [6].

5.5. The present WP marshals the same genre of arguments applied there (sectoral ‘blurring’, the need for a broader strategic framework, etc) in support of its case for an OFCOM: here the arguments hinge on expectations about ‘convergence’, although this (like its close cousin ‘synergy’) has proved an elusive and recalcitrant Holy Grail - as many businesses and organisations have found to their cost. [7]

5.6. By comparison with the creation of the FSA, designing a new single agency to regulate both broadcasting and telecoms poses much greater risks and challenges, most notably on the broadcasting side. The existing regulatory agencies and cultures are very different, the industries they oversee sharply divergent in history, dynamics and structure, and - most critically - the regulatory ‘toolboxes’ used in each case starkly dissimilar.

5.7. In our view the arguments on paper for and against a new single regulator for these divergent industries remain far from compelling, with risks and advantages in both directions. Not surprisingly, expert commentary has remained divided on its merits [8]

5.8. That said, commentators have tended to agree that in practice

the decisive issue is not the concept of a single agency per se, but rather what might be called the ‘terms of trade’ under which such a reorganisation would take place.

5.9. In our view, the plans for a new regulator must be judged against a simple public interest test. Will they at least maintain, preferably enhance, or in practice diminish the existing regulatory safeguards already in place in their respective industries ?

5.10. The answer to this question turns most decisively on the place that a new agency accords to the existing regulatory standards which govern the PSB arena. This means recognising that the PSB arena cannot be properly understood through a ‘competitive markets’ mindset. As we discuss below, the PSB ecology neither is (nor should it become) ‘just another market’. Policy makers must recognise that this milieu is a complex, socially framed space built up over many decades, and that it represents one of the UK’s most valued and inventive social institutions.

5.11. This means that - in plain terms - an acceptable charter for an OFCOM must address and respect the distinctive social foundations of the PSB realm. Conversely - as we shall see - the mix of policy instruments and regulatory standards which have been deployed in the telecoms arena do NOT provide adequate safeguards for the shaping and oversight of the PSB milieu.

6.1. As a measure of the issues at stake we can look briefly at the policy ‘space’ that can sensibly be allotted to ‘competition’ and ‘competitiveness’ in these 2 arenas.

6.2. In the telecoms arena, competition agendas have been central, and the results have been broadly positive. This approach has worked because for the consumer telephony is positioned and regarded as a simple and largely undifferentiated utility, with a small range of commodity products and services that compete primarily on price not on quality. For the consumer quality considerations come down to a simple binary: dial tone / no dial tone. The growth of Internet telephony services (notorious for their trade-off of cost against call quality) illustrates the price driven profile of this market.

6.3. As a result, the relatively simple product profile of the voice telephony market has made it an acceptable candidate for market liberalisation methods, dominated by price caps, Retail Price -X formulae, and other financial and accounting metrics. That said, even here the limitations of ‘competition’ agendas is now becoming more visible as Governments on both sides of the Atlantic try to grapple with a growing ‘digital divide’ - a set of problems which ‘competition’ policy tends either to ignore or exacerbate.

6.4. In contrast, the PSB realm is one in which the consumer demands a complex and highly differentiated service offer (the TV schedule) made up of bespoke products in which quality considerations are paramount, and price competition is either wholly absent or very marginal.

6.5. Moreover in the PSB arena a one-sided emphasis on ‘competitive’ metrics such as TV ratings is acknowledged to provide a poor test of schedule quality. Indeed it is widely recognised that ‘competition’ (ratings ‘wars’ etc) tends to have notably perverse effects - not increasing viewer choice and schedule variety but working to diminish it.

6.6. Instead of competition, the PSB ecology has evolved a culture of complementarity [9]. For these reasons, Governments have deliberately shaped the PSB arena as a heavily sheltered ‘quasi-market’: a social space in which ‘competitiveness’ and its analogues do not and cannot provide a meaningful compass for public policy.

6.7. This arena has been a classic example (like health care and education) where - in the PM’s phrase - ‘naïve reliance on markets’ has been rejected in favour of a more complex but socially optimal pattern of provision. As a result, the PSB framework concentrates its energies on maximising quality, variety and range across the core ‘free to air’ schedules.

7.1. A close reading of the WP indicates that its vision for OFCOM does not recognise or respect these fundamental distinctions and - as a consequence - its plans do not envisage a partnership of equals between these 2 regulatory cultures. Instead, the WP offers what amounts to a hostile takeover - one in which PSB horizons would be ‘harmonised’ downwards to bring them ‘in synch’ with the more liberalised, deregulatory ‘competitiveness’ based regime deployed in telecoms.

7.2. In practice, despite the fact that the WP acknowledges that OFCOM "..should not demand the same regulation for each medium.." (WP 1.3.5), the underlying logic of its proposed framework is one in which (in the words of the accompanying IRIA):

"..most of the proposals are deregulatory and will reduce burdens on business.." [10].

7.3. Whatever its relative merits in the telecoms sector this approach is completely inappropriate as a guiding framework for the PSB arena. As the

Independent Television Commission (ITC) put it in their response to the EC’s 1999 Communications Review:

"..The viewer led approach which characterises television content regulation is not an irritant to be hived off in order to give firms and technology their head, and avoid the complications of having to reconcile both cultural and economic considerations.." [11].

7.4. Re-basing PSB regulation in this way involves de facto abandonment of the principles and protocols on which the ITC and its predecessors were founded, and poses exceptional and unnecessary risks to viewer welfare.

7.5. Moreover, this deregulatory environment will make it more difficult to sustain the public service remit of the BBC, and the quality and diversity of its services.

8.1. The full extent of the WP’s deregulatory agenda for broadcasting emerges most clearly in its sketch of a ‘3 tier’ framework.

8.2. The WP notes that the current PSB framework is anchored by the BBC’s role and remit, but that it goes much wider. The framework has derived much of its overall strength from the fact that it also encompasses the other ‘free to air’ commercial networks.

8.3. Built up over half a century, this broader PSB ecology has been anchored in the capacities of an independent regulator - one with a mandate to set out and monitor a variety of specific and quantified scheduling and operational obligations on ITV, Channel 4 and Channel 5. Moreover it sets out these obligations in advance - following what we can call a use of the precautionary principle in the broadcasting sphere.[12]

8.4. Remarkably, when we look at the WP’s proposals we find that - despite its affirmation of the pivotal importance of PSB regulation (WP 5.3.8 and 5.3.9) - the central components of its proposed ‘3 tier’ model would involve throwing away this system, and replacing it with a so-called ‘light touch’ regime in which the commercial broadcasters are ‘challenged’ to ‘regulate themselves’ (WP 5.8.2).

8.5. In effect, this schema would turn the PSB framework for these 3 channels on its head. Instead of the positive precautionary framework which commits the broadcasters in advance to a set of detailed programming requirements, we have a weakly indicative regime of general statements of intent - to be drawn up by the broadcasters themselves.

8.6. Given the extraordinary success and prestige of the existing framework, the public could reasonably expect the WP to present a detailed and compelling case for this change. However, apart from passing references to ‘new market conditions’ (WP 5.2.6) and the ‘rapid pace of technological change’ (WP 5.4.2) the WP makes only one brief attempt to justify its proposals:

"..It accepts that the detailed, prescriptive requirements - often dubbed ‘box ticking’ - which are contained in present licences may inhibit creative innovation, and thus harm both the public interest and the commercial success of companies.." (WP 5.4.3).

8.7. In our view to entertain an outlook which labels PSB regulation as ‘box ticking’ is to replace reasoned analysis with caricature. As they stand, the references to market conditions and technological change are too vague and unsubstantiated to provide a fulcrum for policy-making, and the suggestion that PSB requirements ‘may’ inhibit creativity is equally no more than an assertion without supporting evidence [13]. Taken as a whole, these brief passing comments in the WP fall well short of establishing the case for the changes proposed.

8.8. To reiterate, the WP’s proposed deregulatory regime for Channels 3-5 is wholly unwarranted. Instead of this ‘self-regulatory’ model OFCOM - like the ITC - must be given both the necessary powers and the legal duty to enforce broadcasting licences which contain a full range of specific and quantified scheduling and operational requirements on ITV, Channel 4 and Channel 5 . Moreover in each case these licences must be at least as robust and categorical as those now in place.

9.1. We warmly welcome the WP’s re-affirmation of the role and remit of the BBC, and its political and editorial independence (WP 5.6.7). We also welcome the recognition the WP gives to the BBC’s continuing importance in a changing media environment (WP 5.2.6).

9.2. However, given the BBC’s special place in public life and broadcasting culture we can see no case for bringing it within the ambit of OFCOM - especially an OFCOM which is so fundamentally flawed in its proposed approach to the wider PSB environment.

9.3. Nonetheless, in our view there are unresolved issues about the BBC’s status - problems that the WP does not recognise or address. In our judgement, public policy must now plan to tackle 2 issues: the long-standing inadequacies in the BBC’s governance, and the inadequacies in the BBC’s legal status.

9.4. The BBC needs a more diverse and representative Board of Governors, one which is properly independent of BBC senior management, and one which better reflects the public who fund it, and the range of stakeholders who underpin its public role.

9.5. Equally, the BBC should have a corporate status which is a permanent freehold, not a very short lease. It is not beneficial to the BBC’s operations and outlook that it is forced to return every few years to the government of the day to argue for its continued existence [14].

9.6. We therefore propose that the DCMS should establish an independent enquiry on these 2 matters, and then bring forward proposals to enhance the BBC’s governance, and to establish the Corporation on a permanent footing.

10.1. We welcome the Government’s clear commitment to opposing the proposals to privatise C4 (WP 5.6.8). However, we find the rest of the WP’s remarks on C4 to be muffled and opaque. C4’s licence and remit was reviewed and strengthened in the recent past, and we can see no public interest case for revisiting its terms yet again.

10.2. Given the deregulatory tenor of the WP’s ‘3 tier’ model the unavoidable implication of the WP’s remarks about reviewing the remit "to make it more positive" is that the intention is to do exactly the opposite, i.e. to weaken the PSB requirements by diluting them, as well as bringing C4 within the compass of the ‘self-regulation’ framework we have opposed earlier.

10.3. Again, we must emphasise that the WP provides no credible case for change. Diluting C4’s remit, and abandoning the precautionary benchmarks of specific and quantified scheduling requirements is not in the public interest.

11.1. The WP’s comments on C5 provides perhaps the best example of the lack of clarity in its approach to PSB oversight.

11.2. By general consent C5 has had a very mixed trajectory since its launch in 1997. It has struggled with limited transmitter coverage, inadequate budgets and a tendency to opt for cheap and sensationalist programming (thus landing itself with a rather down-market public image). Even so, the channel is now in profit, and the main stakeholders are planning to increase its programme budget by around 50%. The aim is to increase original production, especially in drama. [15]

11.3. As the Channel moves into a more quality oriented phase, the public interest perspective would be to encourage this repositioning by continuing and - where possible - strengthening its PSB obligations.

11.4. Instead of this approach, the WP again wields the blunt instrument of ‘competition’. It proposes to review C5’s PSB obligations, shedding most or all of them to make it "..a far stronger competitor to the other public service broadcasting channels…" (WP 5.6.11), and noting that:

"…If the channel changed some of its public service obligations, its tender payments would of course need to reflect this.." (WP 5.6.11).

11.5. Here we have an illustration of how inappropriate use of competition and deregulation strategies can deliver wholly perverse policy outcomes, ones which are contrary to the public interest which Government is claiming to uphold.

11.6. The public’s overwhelming interest is in C5’s provision of an improved, higher quality schedule. By definition, this would be one which builds on its current PSB mandates on schedule diversity, range and complementarity with the other existing PSB channels.

11.7. Instead, the WP contemplates opting to encourage them to dump these obligations in exchange for a larger tender payment. In effect, this approach would prioritise extra income to Government at the expense of programme investment and viewer welfare. How this sponsoring of a reduction in programme diversity is meant to be squared with the WP’s professed commitments to quality, diversity and choice remains a mystery which the WP wisely does not attempt to address.

12.1. We welcome the WP’s recognition of the value of the community media sector (WP 4.5.1 - 4.5.5). We agree that this growing sector makes a pivotal contribution to media diversity, social inclusion and citizenship at a local level, and we support the view that it would be in the public interest to enhance its capacities via additional public funding.

12.2. In practice, the variety of work now happening in this arena covers a broader spectrum than just radio. We therefore support the Community Media Association’s proposal that (subject to suitable safeguards) the right approach would be to establish a Community Media Fund with a remit to assist provision across a wider media landscape. We note also that this broader approach would work more effectively with other Government initiatives in allied areas - notably on Net Access, IT skills and lifelong learning (WP 3.7 - 3.10).

13.1. We welcome the WP’s recognition that the quality of communications regulation and the character of proposed reforms involves basic matters of citizenship and human rights (WP 6.3.3 - 6.3.6). In this light we welcome the WP’s proposal that OFCOM should have a duty to promote media literacy (WP 6.7).

13.2. Nonetheless, the WP as a whole puts forward a vision for OFCOM which is deeply at odds with this welfare and citizenship agenda. The WP recognises the centrality of broadcasting to social cohesion yet its core agenda for this arena is one which would do great damage to the values of quality, diversity, and pluralism it claims to embrace.

13.3. Emblematic of this failure of vision and purpose is the way this WP makes no connection between its own policy dilemmas and those grappled with in the Department For International Development (DFID) WP on ‘Eliminating World Poverty: Making Globalisation Work For The Poor’, published the previous day. [16]

13.4. Progress on the DFID agenda - which the PM describes as the ‘greatest moral challenge facing our generation’ - depends critically on the degree to which PSB regulation protects the public’s right to high quality programming about the wider world, and to ideas and evidence about the many ways in which local and global citizenship are now interwoven.

13.5. Audits of the shifting ecology of TV schedules in the UK since the late 1980s (broadly the point from which TV was subjected to ‘competition’ based policies) indicates that the total output of factual programmes on developing countries by the 4 main networks (BBC, ITV, C4) has dropped by almost 50% between 1989-1999 [17].

13.6. More recently, a DFID study of British TV coverage of developing countries examined the impact of these changes, noting in particular:

"..a marked imbalance in the way developing countries are portrayed, especially on news where coverage was generally limited to disasters, bizarre events or visits by prominent westerners.." [18].

13.7. If the PM’s challenge is to be taken up effectively, the implications for policy are clear. The communications sector - and the PSB realm in particular - needs less ‘competition’ based policy, not more, less ‘naïve reliance on markets’ not further deregulation.

Taken as a whole, we believe that the WP represents a missed opportunity. Its core values, defining emphases and narrow, economistic vision of the communications industries embodies an outlook we do not share, nor do the public at large. An OFCOM built on these foundations is an OFCOM built on sand.

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NOTES

1. DTI, Closing The Digital Divide: Information & Communication Technologies in Deprived Areas - A Report by the Policy Action Team 15, March 2000, London: DTI. Available online at: www.pat15.org.uk

2. In her Foreword to the PAT15 Report, Patricia Hewitt states: "..As both

e-Minister and Champion Minister for PAT15 I fully recognise the importance of harnessing ICTs to help create a better, more inclusive society. We need to move away from seeing technology as an end in itself…" She goes on to say "..I welcome and fully endorse this report.."

3. PAT15 Report, Executive Summary, page 6; Main Report page 56. Subsequent surveys by Government since Spring 2000 indicate that the ‘digital divide’ continues to grow, reinforcing the imperative on public policy to strengthen social cohesion, not exacerbate it. See: Nicholas Timmins, "Digital divide widens as internet access grows" Financial Times, 27 September 2000; Kevin Brown, "Byers warns of ‘digital divide’ in the regions", Financial Times, November 21 2000.

4. DTI, Our Competitive Future: Building the Knowledge Driven Economy, Cm 4176, December 1998, London: The Stationery Office. Available online at: www.dti.gov.uk

5. Ibid, Introduction, page 6.

6. The FSA project is discussed in: Clive Briault, The Rationale For A Single National Financial Services Regulator, London: FSA Occasional Paper, May 1999. Available online at: www.fsa.gov.uk

7. On the pitfalls of ‘synergy’ see: Mark L Sirower, The Synergy Trap - How Companies Lose The Acquisition Game, 1997, New York: Free Press.

[A summary of his argument is online at: www.talks.com/library/ma082097.html] Professor Sirower’s book is part of a much larger literature documenting the very high failure rate of business mergers (variously estimated at between 50 and 80%). A recent study by consultants at AT Kearney reports that over half (they estimate 58%) of all mergers fail to reach the goals they aimed for. See: M Habeck, F Kroeger & M Traem, ‘After The Merger: Seven Rules For Successful Post-Merger Integration’ London: Financial Times/Prentice Hall, October 2000. Of note here is the 5th Rule offered by the authors: "..Imposing the culture of the acquiring company on the acquired is not always an option. It is often more suitable to combine the cultures or even let them remain separate.." [Further details online at: www.atkearney.com].

8. See the divergent views in the BBC collection: E-Britannia: the Communications Revolution, 2000, Luton: University of Luton Press.

9. On the distinctive character of TV audiences, economics and regulation, see Patrick Barwise & Andrew Ehrenburg, Television & Its Audience, 1988, London: Sage Publishing. On the schedule as TV’s decisive artifact, see "Scheduling: Where Power Lies in Television", Ch. 9 of John Ellis, Seeing Things - Television in the Age of Uncertainty, 2000, London: IB Tauris.

10. DTI, Communications White Paper - Initial Regulatory Impact Assessment, 2000, London: DTI, Paragraph 4.4.

11. ITC, Response to the EC’s 1999 Communications Review, 15 February 2000, London, paragraph 19. Online at: www.itc.org.uk

12. Taken as a whole, the WP adopts a notably ambivalent attitude to precautionary regulation. In Section 2.4 of the WP it sketches out some of the elementary reasons why market power and market failure require its deployment. It then goes on to note:

"…OFCOM will have to use its knowledge of the communications industry to decide in any particular situation which enforcement regime to adopt, whether to use its sectoral powers to set out rules in advance, or whether to wait and rely upon the Competition Act.." (WP 2.4.2)

In practice this apparent preference for devolved pragmatism is not to be extended to the PSB regime for Channels 3 -5. Here the WP has already decided to mandate OFCOM to abandon the principle in favour of a weaker alternative.

13. The way in which the PSB ecology enhances rather than inhibits creativity by providing it with a supporting institutional framework is a key theme in the Culture Secretary’s Smith Institute speech. See: Chris Smith, Public Service Broadcasting For Digital Citizenship, unpublished speech, 11 July 2000. Online at:www.culture.gov.uk

14. The need to undertake a ‘defence through reform’ of the BBC’s governance and legal standing is set out in James Curran’s paper

‘Crisis of public communication: A reappraisal’ in T Liebes & J Curran [eds], Media, Ritual and Identity, 1998, London: Routledge.

The paper provides the most nuanced account available of the enduring strengths of the BBC. Equally, Curran notes how new PSB regulated commercial channels (such as C4 and C5) have demonstrated the sophistication and value of the PSB culture, and represent its success on a broader front, not its decline.

15. On C5’s new gameplan, see: David Teather, ‘C5 content budget to rise by 50%’, The Guardian, November 6 2000.

16. DFID, Eliminating World Poverty - Making Globalisation Work for The World’s Poor, December 2000, London: The Stationery Office. Online at: www.dfid.gov.uk

17. Jennie Stone, Losing Perspective: Global Affairs on British Television 1989-1999, January 2000, London: Third World & Environment Broadcasting Project.

18. DFID, Viewing the World - A Study of British television coverage of developing countries, July 2000, London: DFID. Online at: www.dfid.gov.uk

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NOTE ON THE PREPARATION OF THIS DOCUMENT

This response was written by Simon Blanchard, Visiting Senior Research Fellow at Sheffield Hallam University, AHRB Centre for British Film and Television Studies, with advice and feedback from Professor Sylvia Harvey. The views expressed in this document do not necessarily reflect those of the University, the Centre or the Arts and Humanities Research Board (AHRB). However, grateful acknowledgement is given to the AHRB as the primary funder of the Centre and its work. Simon Blanchard can be reached by email at:

essbee@europe.com

The Centre is funded by the AHRB as part of a new initiative designed to support high quality and in-depth research at ten centres of excellence in the United Kingdom. Funding is provided for a period of five years from 2000-2005. This AHRB Centre - the only one in the field of Film and Television Studies - is made up of a consortium of seven institutions: Birkbeck College, University of London, University of Brighton, Central St. Martin's School of Art, University of Exeter, the Royal College of Art, Sheffield Hallam University and the University of Ulster together with support from the British Film Institute. The Centre has two main areas of interest: film and television history and film and television policy, with an emphasis on the value of archival research and the importance of public policy issues.

Nationally, the Centre can be contacted through its Director, Professor Laura Mulvey at the AHRB Centre for British Film and Television Studies, Birkbeck College, University of London, 43 Gordon Square, London WC1H OPD.

Email: ann.jones@bbk.ac.uk

In Sheffield the Centre can be contacted through Professor Sylvia Harvey, Principal Associate Director, AHRB Centre for British Film and Television Studies, Sheffield Hallam University, School of Cultural Studies, Psalter Lane, Sheffield S11 8UZ.

Email: s.m.harvey@shu.ac.uk