Ofcom on PSB Review

Download Full Submission

EXECUTIVE SUMMARY

1. While addressing some of the broader policy issues raised in this consultation, IBT’s primary focus is on the provision of broadcast content which tells us about the world outside the UK because this is where IBT’s expertise lies.

2. IBT welcomes this Review, however we believe that Ofcom has failed in its statutory obligation to report on changes in the PSB landscape with regards to content about international matters because it no longer collects data on such content.

3. Ofcom used to measure the volume of international content the PSBs broadcast. It no longer does this. Without such data Ofcom cannot fulfil its statutory duty to specify and comment on whatever changes appear to have occurred in the delivery of the public purposes of public service television. Content about international matters is a Tier 3 requirement in the Communications Act 2003 and we therefore urge Ofcom to recommence measuring the volume of such content.

4. In this submission IBT highlights that international content which reaches a mass audience provides significant social benefits. Engagement with the wider world leads to a more tolerant society which is able to do business with the wider world. PSB has an important role to play in providing such content.

5. IBT is very concerned by the decline in the volume of content about international matters on the PSBs, evidenced by our most recent quantitative research. Between 2005 and 2010 there was a 41% drop in the volume of new content about international matters on the main PSB channels. This decline is deeply worrying when set against the increased impacts of globalisation on our lives and economy.

6. We note the research published by Mediatique which suggests that the current ‘Tier 3’ requirements in the Communications Act (2003) which include ‘matters of international significance’ have not been met ever since the statutory requirement to provide them was dropped in 2003.

7. IBT questions Ofcom’s measurement of the delivery of Purpose 1, informing our understanding of the world. Ofcom currently assesses delivery of this purpose only through news and current affairs which mostly focus on negative events and thus present a distorted view of the world. We would like Ofcom to measure the delivery of this important purpose across all genres, including children’s, drama, factual, specialist factual and entertainment.

8. Additionally, we ask Ofcom to improve its assessment of the delivery of Purpose 4, representing diversity and alternative viewpoints. This purpose is to ‘make us aware of different cultures and alternative viewpoints, through programmes that reflect the lives of other people and other communities, both within the UK and elsewhere’. Currently Ofcom only asks audiences whether they are happy there is delivery of ‘cultures and opinions within the UK’. It is our view Ofcom should include elsewhere in the question, thus more accurately reflecting the purpose as a whole.

9. While we acknowledge the drop in live viewing of the main PSB channels, IBT believes that live and recorded viewing remains robust and will play an important role in delivering public service content to audiences for the coming decade.

10. IBT is concerned by the continuing decline in investment in first run UK content by the PSBs which could undermine the current PSB system. While audience satisfaction levels appear to remain high, we fear that in time this reduction in investment will inevitably lead to a reduction in the distinctiveness and quality of UK specific content.

11. We note there is a deficit in provision for 10-14 year olds and believe that this is a key area which Ofcom needs to address in the process of this Review.

12. IBT believes that the BBC needs sufficient funding in the next licence fee settlement to be able to maintain its current levels of provision and that C4C needs to remain a publicly owned commercial broadcaster which can reinvest any revenue back into content rather than focus on the interests of shareholders.

13. Prominence and easy discoverability are crucial to the future success of PSB content and IBT agrees that Ofcom should explore ways to ensure discoverability of such content, putting in place regulation which will remain fit for purpose as technology changes.

14. IBT believes that UK citizens continue to rely on public service broadcasting even though some viewers choose to pay for subscription services. Whilst we acknowledge that access to the internet and subscription TV offer extra opportunities to provide content for those willing to pay for it, only the PSBs provide a full range of UK-produced, universally available programmes at a much lower cost per viewer-hour than subscription services. It is our view that we need to support the current PSB system through more effective regulation if we are to continue to enjoy the quality and levels of delivery of PSB we currently enjoy.