Broadcasting Committee

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Ofcom Review of public service television broadcasting - Phase 2

Broadcasting Committee

Added on 23/11/2004

Ofcom Review of Public Service Television Broadcasting

Phase 2 – Meeting the digital challenge

A Response from the Church of Ireland Broadcasting

1. Narrative

The Church of Ireland is an Anglican church operative
in the two jurisdictions of the island of Ireland. Through the Broadcasting
Committee of its General Synod it seeks to make appropriate interventions
in the debates of the broadcasting policy communities in both Irish
and British contexts.

The Broadcasting Committee of the
Church of Ireland welcomes this consultation and the opportunity
for comment that it affords. Already a submission has been made
in Phase 1 of the Public Service Television Broadcasting Review.
There a certain frustration was felt with regard to having to answer
consultation questions that appeared to direct the tendency of
the answers given. In what follows (as in our more recent response
in the Programme Code consultation) we have tried as far as is
possible to respond to the actual questions asked. At the outset
we are obliged to record that our Christian faith informs at each
stage our attitude towards public policy formation.

The Church of Ireland, in common
with its sister Churches, is concerned to foster the well-being
of the society of which it is a part. The Church of Ireland is
a keen supporter of the principles of PSB as they have developed
historically in the British and Irish contexts and believes that
these principles have contributed to generating and maintaining
the health of our social fabric.

The Broadcasting Committee of the
Church of Ireland maintains that broadcasting ‘products’ cannot
be reduced to simple tradeable commodities
but have a social and public value that must be judged quite
separately from whatever commercial value they might otherwise
display. For this reason, the Broadcasting Committee of the Church
of Ireland does not believe that the audiovisual market should
ever become a ‘normalised’ market, it believes in ‘re-regulation’ not ‘de-regulation’,
it believes in strategic public interventions designed to ensure
continuing social well-being.

A necessary part of this social
well-being the Broadcasting Committee considers to reside in
the cultivation of the potential for democratic access and enablement.
It believes that PSB should function as a mirror reflecting the
actual diversity of our social fabric back into the limited world
of the individual, enabling the individual to think beyond the
monochromatic confines of her world, enabling that same individual
to be parsed as a ‘citizen’ and not to be treated reductively
as a ‘consumer’. The Broadcasting Committee commends
to the attention of Ofcom a paper it
recently commissioned from Dr Jim McDonnell in the context of
a Consultation on Religion and Diversity and now available at (simultaneously)

The Broadcasting Committee of the
Church of Ireland also considers ‘religious broadcasting’ to
be of great importance in the representation of diversity and
to be inextricably part of any actual or anticipated PSB provision.
There is ample statistical evidence to show that religion and
spirituality are matters of public concern and public interest
and need to be part of any PSB configuration. It is the view
of the Broadcasting Committee that the religions can play their
part in the generation of an informed democratic citizenship.
This we believe to be perhaps especially so in the case of Northern

The Broadcasting Committee of the
Church of Ireland is encouraged by much of what it reads in Phase
2 of the PSB TV Review and wishes to congratulate Ofcom on
an impressive and timely piece of work. The particularities of
our comment will be discovered in the answers to specific questions
but a few points can be made at the outset-

  1. PSB is a vital part of any desirable audiovisual
    market- it is that which helps provide the social capital in
    our increasingly pluriform and diverse polity.

  2. PSB should ensure the creative and engaging representation of
    the diversity that actually exists in our society and thus encourage
    the necessary processes of mutual appreciation and understanding
    by providing the grammar of their enablement.

  3. PSB is connected vitally with the ability of the individual to
    transcend her limitations and relate in a healthy, pacific and
    informed way to other individuals from whom she may be separated
    by great chasms of culture or conviction.

  4. Religious programming is justly and classically at the heart
    of PSB provision.
  5. PSB will only be provided by structured public interventions.

  6. As important as the production of PSB is the scheduling of PSB.

2. Specific Responses to Ofcom’s

Question 1: Do you agree with our analysis that the existing
PSB system will not survive the move to the digital age, and may
decline before then

[The end of the analogue PSB model. We have
concluded that if we do nothing to change the existing PSB model,
there is a real risk that PSB across the system will decline both
in amount and effectiveness.]

The Broadcasting Committee of the
Church of Ireland agrees that the digital age will pose significant
new problems to the form in which PSB is generated and delivered.
We feel that the market will never be in a position to guarantee
the provision of PSB without structured public interventions.
The current ‘terrestrial twilight’ period gives us
some pause for thought, however. We feel that there is an unsightly
rush into the process of releasing commercial terrestrials from
their current PSB obligations which cannot themselves be judged
as unduly onerous.

The Communications Act 2003 provides
for certain obligations that we believe Ofcom must
enforce. Any diminishing of these in anticipation of the digital
future must we believe be the subject of extensive consultation
and negotiation between the regulator, the broadcaster and interested
citizen and consumer groups.

2: Do you accept that public funding for PSB continues to be
justified as we approach switchover, and should remain broadly
at a similar level to that provided today?

[The continuing case for public funding of
PSB. Our analysis suggests that:

·       there
is a clear rationale for PSB from a citizenship perspective;

·       the
UK market would not provide the current range of and extent of
high quality television content without public subsidy, even in
the digital age; and

·       the
public still want to pay collectively for programming that contributes
to PSB purposes.]

The Broadcasting Committee of the Church of Ireland agrees entirely
with the idea that PSB justifiably disposes public funds. We do
not believe that the UK market could deliver programmes of the
range and diversity of those currently produced without public
subsidy. This is not to say that all current examples of PSB product
depend on public funding but it is certainly the case that a majority
of them does.

Question 3: Is plurality vital to the future of

[Principles for a future PSB system. We consider that a plurality
of PSB providers needs to exist, to provide alternative perspectives
and competition for ideas

The Broadcasting Committee of the
Church of Ireland believes in maintaining and enhancing a culture
of plurality in PSB provision. We believe that competition will
lead in these circumstances to enhanced creativity and the final
benefit of all social participants. This has been the actual
experience of the so-called ‘classical duopoly’ in
British broadcasting and should find replication and enhancement
in the digital age.

Question 4: Will PSB need to take a new
form, across new technologies, in future?  If so, which
technologies should PSB embrace in the digital world?

[In addition, we suggest that a future PSB
system will need to evolve to take full advantage of new technologies
to meet changing public demand and attain real reach and impact.]

The Broadcasting Committee of the Church of Ireland
believes that every platform for the promotion of PSB content needs
to be explored and exploited. To reprise our initial comment, we
believe that the provision and consumption of PSB content is of vital
importance to our society and to the generation and continuation
of its well-being. PSB content should therefore be available across
all platforms and networks. Regulators and policy makers must strive
to avoid the creation of a ghetto culture in which PSB provision
becomes a live option only for those already disposed to receive

At a recent Westminster Media Forum conference
(3.11.04) it was suggested that broadcast PSB was shifting from
a ‘passive’ model
in which content was supplied from on high to a largely un-interested
public to an ‘active’ model in which an enthusiastic
public deliberately sought out PSB content. The Broadcasting Committee
of the Church of Ireland is inclined to doubt this as a proposition,
we incline more to Cass Sunstein’s definition
of the related concept of ‘public interest’ which holds
that often “There is a large difference between the public
interest and what interests the public”. Responsible public
policy we believe will still aim at a provision of PSB content
which is potentially universal, across all channels, platforms
and networks. Social cohesion will be aided in this way, where
the simple avoidance of PSB content is not an easy option. We have
little expertise in the world of the net but we believe that PSB
content should be available in this form also, that it might reach
those parts of the UK population that more traditional methods
of distribution might not.

Question 5: Do you agree that the BBC should
remain the cornerstone of PSB, but that there ought to be mid-Charter
review and a clarification of the roles of governance and regulation?

[The BBC. We consider that the
BBC should remain the cornerstone of PSB, striving to make sure
all its programmes reflect the purposes and characteristics of
PSB. It should be granted a ten-year Charter, but with a mid-point
2011 review of its funding and its progress in meeting PSB purposes
and characteristics. We believe that the proliferation of reviews
to which the BBC is now subjected is in part a consequence of
a lack of a clear separation between the roles of governance
and regulation, and that a clarification of roles this should
be a central objective for Charter Review.]

The Broadcasting Committee of the Church of Ireland
agrees that the BBC should remain the cornerstone of PSB provision
in the UK. We also agree that a mid-term review would be an appropriate
aspiration given the imminent digital transition.

We are concerned however by what we feel
is a certain reductiveness in the definition
of PSB fielded by Ofcom. It cannot be the
case that PSB programming should be defined as programming that
no-one else would dream of making- we believe this to be the implication
of a far too literalistic understanding of market failure. Lord
Reith established for the BBC his famous Trinity- the organization
was to ‘inform, educate and entertain’. The notion of an ‘entertaining’ BBC
must not be jettisoned or prohibited at the whim of Ofcom.

We believe that part of the BBC’s success
as a public broadcaster resides in its ability to make entertaining
and informative programmes that large sections
of the UK public actually want to watch. The BBC’s development
of a broad ecology of programming is we hold vital to its ‘reach’ and
therefore to its ability to promote the well-being of our society.
Ofcom’s criticisms
might well have the effect of diminishing the reach of the organization
and thus the penetration of its more challenging types of programmes.

The criticism, for example, of the screening
of Hollywood movies on the BBC is short-sighted and takes no account
at all of much recent academic work on the depth dimensions of
popular cultural products. We commend to the attention of Ofcom
- as we did in our Phase 1 response - Martin Brooke’s
report ‘Watching Alone: Social Capital and Public Service Broadcasting’,
(BBC/Work Foundation, 2004). Here is an interesting and solid defence
of the role of the BBC in entertaining programming and a persuasive
account of how ‘entertainment’ can have
a serious intent.

The Broadcasting Committee of the Church of Ireland
refrains from any comment in this consultation on questions of the
governance of the BBC, questions which we believe are to be more
appropriately pondered in the context of the BBC Charter Review.

Question 6: Do you agree with our proposals
on the future funding of the BBC?

[We have concluded that the BBC should
be properly funded by a licence fee model and we
identify factors which should be taken into account in deciding
the level of the licence fee for the
next Charter. We also suggest that in future, the Government
should consider allowing the BBC to supplement its income through
limited subscription services. New technological means of collecting
an electronic licence fee ought to be considered,
to cut collection and evasion costs.]

The Broadcasting Committee of the
Church of Ireland reiterates its view that questions on BBC specifics
are actually better dealt with in the context of the BBC Charter
Review than in the context of this review. We support the continuance
of the licence fee and believe that this must be raised to a
level consonant with the production of high quality and desirable
programming. We believe that the payment of the licence fee establishes
a bond between the citizen and the organization which can become
a platform for organizational accountability. We oppose the development
of any kind of subscription service in the BBC because we reckon
that universality of access is basic to the definition of public
broadcasting. We further see no need for the introduction of subscription
services because we believe in the establishment of realistic levels
of funding through the augmentation –and improved collection-
of the licence fee.

Question 7: Do you think we have judged
PSB role correctly, both in the short term and the longer term?

[ITV1. ITV1 has an important future
in the PSB system, even in the digital age – it provides
a wealth of free-to-air, original UK programming, particularly
in the drama, entertainment and factual genres.  In the
short term, we propose maintaining the current quotas or indicative
targets on original production, news, regional news and other
regional programming in peak-time while adopting a more flexible
approach to the regulation of other content. After switchover,
we propose to maintain a core level of PSB obligations on ITV1:
UK-origination quotas, news, current affairs and – if sustainable – a
core regional news service.]

The Broadcasting Committee of the
Church of Ireland does not assume that PSB content (especially
religious content) is always and necessarily unattractive content.
We find that often ITV religious programming has been underfunded
in production and poorly scheduled in screening. We find therefore
the conclusion that many jump to, that religious programming
is ipso
unattractive and unpopular programming a plainly erroneous
one. The example of Ulster Television (UTV) in Northern Ireland
is a sufficient corrective- here we find a company committed
to making innovative and attractive ‘religious’ programming,
programming that is watched by impressive numbers of the Northern
Ireland populace. Why is it so difficult to replicate this procedure
in a GB context?

We suggest then that the advent of the digital
age should not be used as a simple argument for the excusing of
ITV from existing PSB commitments. The obligations of the Communications
Act 2003 Ofcom needs simply to enforce
and any subsequent negotiations on the relieving of any of these
burdens (not we note very onerous ones) need to involve participation
by all interested groups.

The Broadcasting Committee of the Church
of Ireland further believes regional news provision to be at the
very heart of ITV’s PSB function and would not like to see
the diminishing of this in the digital future.

Question 8: Do you agree with our proposals
for the role of Channel 4, and are we right to ask Channel 4 to
look to self-help and joint ventures to fund PSB for the foreseeable

[Channel 4. We think Channel 4 should
remain a vital force in the provision of PSB in the transition
to the digital age, particularly as a provider of innovative
content to its target audience. We expect it to use its considerable
financial resources to ensure a sharper focus on its public purposes,
and to meet funding challenges through self-help, operational
efficiency and increased cross-subsidy from commercial ventures.
It should be free to form alliances, joint ventures and partnerships.  However,
the channel should remain primarily not-for-profit and should
not be privatised.]

The Broadcasting Committee of the Church of Ireland
is a strong supporter of Channel 4. We would not like to see its
privatization, we see it as an important element in the current and
future PSB mix. We would call for material action in support of Channel

Question 9: Should other means of support
for Channel 4’s remit be considered in the longer term?
If so, what form should they take?

[We recognise that
in the longer term, particularly after digital switchover, Channel
4 may face an increasing tension between maintaining advertising
revenues and its PSB remit and may not be able to provide the
same range of PSB programming as today. In the event that improvements
cannot be made which deliver sufficient financial strength for
C4 to fulfil its PSB remit in a digital
age, there may be a case for considering further action, such
as the transfer of assets from the BBC

The Broadcasting Committee of the Church
of Ireland would prefer to see the monies that Ofcom envisages
might be spent on the funding of speculative PSP used to support
the established creative energies of Channel 4. We further suppose
that a review of Channel 4 support cannot wait for 5 years. We
note that Channel 4 has now decided at an executive level that
it might benefit from state support and we would encourage Ofcom
to give due, serious and urgent attention to this matter. For the
reasons we have before articulated we think that the BBC licence
fee establishes a bond between the licence fee
payer and the BBC itself- the question of using licence fee
revenue to support Channel 4 we therefore believe is not the most
desirable option.

Question 10: Are we right to take a more flexible
approach to the regulation of PSB on Five?

We think Five can continue to play a modest but important
role in contributing to PSB purposes, and stands to gain from
PSB status at switchover, when it will attain UK-wide coverage
for the first time. In future, we suggest Five’s contribution
to PSB will mainly take the form of a commitment to original
UK production and news, and we will expect the channel to increase
investment in production in the run-up to switchover. However,
we will also adopt a more flexible approach to the regulation
of specific genres and to the scheduling
of news on the channel.]

The Broadcasting Committee of the Church
of Ireland does not suppose that Five’s burdens are at all
onerous. Five has developed an interesting track record in PSB
production and seems keen on exploiting some niches at the elite
end of the market. We really see no need for flexibility in regulation

Question 11: Do you support this long-term vision
of programming for the nations and regions?

[Programming for the nations and regions.
Our long-term vision for the nations and regions includes: a
role for ITV1, particularly in national and regional production,
a sharing of non-news regional obligations between the BBC and
ITV1; a new range of innovative local TV services; and a sustainable
future for Welsh language and Gaelic services.]

The Broadcasting Committee of the Church of Ireland applauds the commitment
to cultural and political distinctness enshrined in 7.1 and notes
that this commitment needs to be expressed in tangible and material
terms in the digital future. With regard specifically to Northern
Ireland we believe that the PSB functions (importantly of both BBC
and ITV) need strongly to image the substantial diversity of the

We would commend
to the attention of Ofcom a paper that we recently commissioned
from the sociologist Dr Andrew Finlay and now available at and
(simultaneously) at Here
Dr Finlay notes that the ‘two communities’ view
of Northern Ireland makes a proper understanding of the actual
statistical diversity of the region a precarious and difficult
undertaking. In the context of Northern Ireland there are more
linguistic minorities than the Irish and Ulster Scots ones!

We are encouraged
to learn of the commitment of Ofcom in 7.33 to receiving the voices
of the regions in subsequent discussions.

Question 12: Do you support our specific proposals
for the future of regional programming on ITV1?

[In the short term, we propose a reduction
in ITV1’s English regional non-news programming from three
hours to 1.5 hours, but with a focus on peak hours programming.
In the nations, different cultural and political considerations
apply – non-news programming will still be unsustainable
after switchover, and will need to change before then, but we want
to engage in a wider debate before proposing any changes.  Separately,
we propose to raise out-of-London production quotas on ITV1 to
lock-in current levels of production and to encourage a wider
dispersion of production outside London and across the nations
and regions of the UK.]

The Broadcasting Committee of the Church of Ireland
holds regional programming to be of extreme importance in the discharging
of PSB functions and does not suppose that ITV1 should be excused
from this functioning. The voices of those concerned in each region
need to be heard and listened too. We have already expressed our
view that regional news in particular is not a luxury to be disposed

Question 13: What do you think a sustainable
model for PSB in the nations would be?

The Broadcasting Committee of the Church
of Ireland trusts the judgment of the citizens, consumers and organizations
based in each region and asks Ofcom to pursue the matter with all

Question 13 [sic]: Do you think this is
the right approach? What issues should we take into account in
judging whether further action is needed in 12 months’ time?

[Production. We believe there is
more scope for independent producers to enhance the delivery
of PSB. We welcome the BBC’s recent commitment to fulfil
its 25 per cent quota, and the new terms of trade between broadcasters
and independent producers.  We believe a period of time
should elapse before further consideration is given to the relationship
between the two. We are giving the major players 12 months to
ensure that the market works more effectively, before taking
further action.]

The Broadcasting Committee of the Church of Ireland
supports an increase in the levels of independent production. Yet
it also would like to see some level playing field among the independents
themselves- plurality is not enhanced by a few large independents
siphoning off all available funding. We also support the retention
of strong in-house production units which have their own role and
function in the developing plurality.

Question 14: Do you agree with our assessment
and preference for a system which introduces competition for the
provision of PSB?

[Competition for the supply of PSB. We
assessed three models for maintaining plurality and competition
in the supply of PSB in the digital age: a fully
contestable fund; direct public funding of Channel 4; and
competition between new providers of PSB. We favoured the
third approach.]

The Broadcasting Committee of the Church
of Ireland finds that the notion of an ‘Arts Council of the Air’ while
attractive, would probably be prone to bureaucratic inertia. We
are greatly attracted to the idea of some kind of funding support
for Channel 4 though we would like also to retain advertising on
the Channel.

Question 15: Is the idea of a PSP one worth
pursuing? If so, what form should the new service take? How should
a PSP be awarded?

[A PSP. We have set out an outline
proposal for a Public Service Publisher (PSP). The PSP would
be the first provider of PSB content designed specifically for
a digital world. It would commission a small amount of high-quality
visual content and distribute it across a range of electronic
media.  Its
greatest challenge would be to attain reach and impact, and for
that reason we would not rule out existing broadcasters from
bidding to run the service as a ring-fenced operation. The initial
service would run for up to ten years, subject to a mid-point

The Broadcasting Committee of the Church
of Ireland is intrigued by the idea of a PSP. We wonder however
where the figure of £300 million actually came from and where (perhaps more
to the point) it WILL actually come from? We also note that £300
million would give the PSP approximately 10% of the budget of the
BBC so wonder a little at what might be expected from it. We don’t
think that a PSP producing content severely limited in terms of
output hours is really a replacement for (or as good as) a PSB

On balance the Broadcasting Committee of
the Church of Ireland would prefer Ofcom to explore using funds
of the order of those mentioned in support of programming on Channel
4- a channel that has a solid track record in delivering high quality
watchable (and watched) programmes of considerable creativity
and reach. Perhaps such monies might also be used in the PSB configuration
of ITV1 and Five?

We hope however that the genuinely novel
and interesting issue of a PSP will be exhaustively discussed by
all concerned before any choice is made. We look forward to the
December hypothetical tender documents which should give a better
idea of PSP flavour specifics.

Question 16: What do you think the best source
of funding would be?

[New funding would have to be found to
establish a PSP, either from an enhanced licence fee,
or from tax income, or from a new tax on UK broadcasters’ turnover.
We have set out the advantages and disadvantages of each.]

The Broadcasting Committee of the
Church of Ireland prefers to retain the direct link between the
licence fee and the BBC. A turnover tax would therefore appear
to recommend itself as a hypothetical source of funding for a PSP,
vigorously opposed (we would presume) by the successful commercials.

The Broadcasting Committee of
the Church of Ireland once again thanks Ofcom for
the opportunity to participate in this consultation. We are
happy to assist in the future in any way that might mutually
be felt to be appropriate.

Membership of the Committee-

Mr Tony Fleck (Chairman)

The Revd Dr Alan McCormack (Secretary)

The Revd John McDowell (Treasurer)

Ms Janet Maxwell (Director of Communications)

The Revd Brian Parker (Media officer)

Ms Ruth Buchanan

The Most Revd Dr Richard Clarke

The Revd Michael Parker

The Revd Eileen Cremin

The Revd Tom Gordon

The Revd Dr William Crawley (Consultant)

23rd November 2004