Executive Summary

We agree in general with a strategy that is designed to reallocate resources based on a clarification of priorities and a close investigation of current BBC provision. We also think it is timely to ask if the BBC is currently stretching its resources too thinly across too wide a range of services. We welcome a renewed emphasis on the priority of investing in original content and the declared intention to increase such investment

We are opposed to the closure of Radio 6Music and of the Asian Network as we believe that these two proposed closures would violate the principles of quality, distinctiveness, innovation and diversity in public service provision.

We also think that the proposed closure of the Asian Network is unacceptable from a citizenship perspective. It is only right that the larger range of services opened up by the development of digital radio should allow the BBC to address, more specifically, the diverse cultures and communities of the United Kingdom. We recognise that there may be a difficult cost equation involved in terms of per capita user costs, but the same might be said about Radio 3. The services offered by the Asian Network may need to be improved, reorganised and even re-branded to attract a more substantial audience but we have no doubt about the importance of this service in citizenship terms.

We agree that there could be some reorganisation and rationalisation of the BBC’s web services and that this could enable savings which could then be reinvested in content production on radio and television channels.

We think the BBC should be a little braver in putting challenging factual and dramatic material on its flagship BBC 1 channel, and that significantly more resources should be invested in children’s programming and in contemporary drama on BBC 2.

We endorse the five areas of programming identified as priorities in Section 1 and see both factual and fictional programming as offering valuable resources to UK citizens.

We think that more careful consideration should be given to the costs implications of broadband delivery and reception, to the issue of spectrum pricing, the appropriateness of re-transmission fees and the issue of independence from Government.

(i) Putting Quality First

1. We support this principle of putting quality first, applied across the full range of BBC radio and television programme genres and web services. And we agree with the five areas identified as of special significance, namely:

• The best journalism in the world
• Inspiring knowledge, music and culture
• Ambitious UK drama and comedy
• Outstanding children’s content
• Events that bring communities and the nation together

2. We think that there should be more investment in children’s programming than is proposed by the Strategy Review (i.e. more than an extra £10m per annum, PQF: 30). We applaud the CBBC and CBeebies service. But many of the programmes and channels now available to children, outside of BBC provision, reflect cultures not shared by British children. These programmes reflect, predominantly, American culture. While excellent and richly resourced material has been produced for children in the United States, we think it vital that children in the UK should be able to enjoy stories and information that relate to the already wide range of cultures, languages and faith communities (or none) in the UK. In other words there should be increased investment in the depiction of contemporary British cultures as these are experienced by children living in the UK. We think that there is a particular gap in the provision of programmes for older children and that this should be remedied by the BBC – and not only by Channel 4.

3. We support increased investment in ‘signature television drama’ on BBC 2 in the belief that this will contribute to our understanding of tensions, conflicts and changes within contemporary British society and culture (PQF: 28.)

4. We also think that the Corporation should be a little braver in putting challenging factual and dramatic material on its flagship channel, BBC 1. We acknowledge that the Corporation must constantly manage the competing demands of ‘being popular enough’ whilst ‘not being too popular’ in justifying its receipt of Licence Fee money. The audience share maintained for BBC 1 is impressive but we also think there is scope for some more innovative and demanding material on this channel.

5. We agree that the Government should continue to review and up-date the official ‘Listed Events’ to ensure that sporting and other events of national significance are made available on a universal access basis, through the BBC, and not restricted to subscription-only services. We acknowledge that there are difficult issues of commercial competition at stake here, of copyright and of the pricing of sports rights in particular. We also note with some regret that increased competition in the field of sports broadcasting has frequently resulted in much higher prices for the acquisition of sports rights. Competition has not delivered lower prices in this area and one of the unwelcome consequences of this process has been that some British viewers have been excluded, on cost grounds, from access to popular, live sporting events. We also agree that the BBC should where possible avoid being involved in ‘bidding up’ sports rights and that it is correct, therefore, for the Corporation to limit its investment in this field (PQF: 31).

6. We think that the BBC should regularly review its understanding of the meaning of events of national significance, taking into account the rich diversity of British cultures and the at times distinctive interests of viewers in Scotland, Wales and Northern  Ireland, as well as in the different English regions.

7. There is, we believe, scope for drawing more journalistic and dramatic material from the activities of third sector organisations many of whom are members of the Citizens’ Coalition for Public Service Broadcasting. These voluntary or third sector bodies provide a vital basis for and defence of civil society in the UK.

8. We are a little concerned that the BBC’s imaginative and forward-looking Project Canvas may be duplicating similar systems developed in Germany, France and the United States and designed to converge televisual and internet services onto a single screen. We think it important that the BBC be closely involved in international standard setting in technology and not too inclined to ‘go it alone’, except where this is deemed necessary in the public interest and is cost-effective. We also understand that broadband delivered audio-visual services are likely to be more expensive both to transmit and to receive and that too strong a shift in the direction of Internet Protocol Television (IPTV) could be costly and could exclude poorer UK households (PQF: 32). We return to the issue of universal access in Section 6 of our response.

9. We nonetheless strongly support the wisdom of the BBC’s investment in developing the iPlayer and note the considerable success and popularity of this new delivery mechanism and service. Although ‘over the airwaves’ transmission remains vital for cost-effective access to live news and other services.

10. We note that the BBC and Licence Fee payers have had to absorb significant new costs in rolling out a UK-wide digital transmission network for both radio and television, and that this process is not yet complete. The PQF document tells us that, as a consequence of these liabilities, the BBC is currently spending some 79 per cent of its public service income on content - with the rest spent on transmission costs and overheads. We recognise the legitimacy and necessity of controlled administrative or ‘overhead’ costs. We are nonetheless disappointed that the Corporation envisages only a modest reduction in transmission and overhead costs leading to an increase in spending on content, raised to ‘at least 80 %’ but only by 2017 (PQF: 33). If the value of the Licence Fee were to be reduced by Government either in the new Charter settlement of 2016-17, or prior to that date, this would have damaging consequences for investment in content and the quality of service that can be expected by viewers and listeners.

11. We strongly support the retention of impartiality in news and current affairs programmes for all UK-licence broadcasters. This requirement must continue to be applied to all public service broadcasters, including the BBC, as well as to commercial broadcasters not defined as PSBs in the 2003 Communications Act.

(ii) Doing Fewer Things Better

12. We support the BBC’s endeavour to identify areas where it might close or reduce services in order to enhance the quality of other services. Though we are concerned that Government and/or the BBC’s competitors might take the opportunity afforded by this review to argue for a reduction in the value of the Licence Fee and therefore a reduction in both the quantity and quality of BBC services. We note that PQF identifies nearly £600m or almost one fifth of re-prioritised BBC spending (PQF: 24).

13. We are opposed to the BBC Executive recommendations to close the two digital radio services: 6Music and the Asian Network. We consider these services, taken together, to embody the principles of quality, diversity and innovation. They seem to us to embody the best that might be expected of public service broadcasting.

14. We do not have expert knowledge of the two other services proposed for closure, namely BBC Switch and Blast! However, we are concerned, as indicated above, that children and young people receive adequate investment in services of interest to them.

15. We agree with the proposal to effect some reduction of investment in BBC web-based services. Though we are not able to judge what will be the consequences of the proposed 25 per cent reduction in spend by the year 2013. We would be opposed to any significant reduction in the quality of the BBC’s web-delivered journalism and also think there is legitimate scope for spending on education and on experimental forms of web-based drama and narrative.

16. We agree that investment in local radio should be increased in order to improve these services. We consider them to be vital from a citizenship perspective (PQF: 35).

(iii) Guaranteeing Access

17. We support the principle of providing BBC services free at the point of use. However, we think that insufficient attention has been paid to the transmission and reception costs involved in broadband relay of television programmes. At present a monthly broadband subscription  - with limits on what is regarded as ‘fair use’ consumption – can equal or even exceed the monthly cost of the BBC Licence Fee, adding significant costs for households. It is also worth noting that a significant proportion of UK households – 37 per cent in 2009 - do not have access to broadband (1). In this context it is appropriate to note the obvious point that - apart from the initial cost to households of purchasing a rooftop aerial and a television and radio set - television signals transmitted via the airwaves provide free content to millions of viewers and listeners and without the involvement of a broadband provider.

18. The work being undertaken by the BBC to clear copyright for increased public access to the BBC’s archive of TV and radio programmes is to be welcomed. Though we also note that it is reasonable for the original rights holders to receive appropriate compensation from the BBC. 

(iv) Making the Licence Fee Work Harder

19. In the wake of the ‘Sachsgate’ scandal involving Jonathan Ross and Russell Brand leaving provocative messages on a BBC Radio 2 programme (October 2008), there has been much disquiet expressed about high fees paid to well known presenters. And concern has also been expressed in some quarters about what were seen to be disproportionately high fees paid to senior BBC managers. It was pointed out by some commentators and politicians that, for example, the Director General of the BBC was paid more than the Prime Minister. We support some of these criticisms and agree that the high salary and bonus culture should be reined in and the overall number of senior managers should be reduced. However, whilst it is desirable that BBC staff are remunerated within a broadly public sector framework for senior pay, it is also important that the BBC is able to attract top talent in the entertainment field and in respect of its senior management team.  On balance we welcome the statement that the Corporation is now committed to ‘reducing senior management numbers, freezing pay and suspending bonuses’ (PQF: 50). But we think that as an institution of world class the BBC must remain free to recruit senior staff of world class.

20. We welcome the statement that ‘Overheads as a proportion of the total licence fee have reduced from c24% in 1999 to around 12% to-day’ (PQF: 50). However, we are concerned that a constant salami-slicing of departmental budgets in order to achieve efficiency targets could become counter-productive leading to high levels of stress and reduced emphasis on the primary goal of the organisation, namely the production of excellent radio and television programmes (PQF: 50).

21. We have already noted our support for a review of spending patterns and an increased emphasis on investment in original content. We are therefore pleased to see a commitment to ‘reinvesting savings in new UK programmes’ (PQF: 50).

(v) Setting New Boundaries

22. We think it is right for Licence Fee payers to expect that their collective investment should result in the cost-effective production of excellent programmes appealing to a wide variety of listeners and viewers.

23. We also take the view that the BBC is right to push at the boundaries of the possible and to experiment with new services. We therefore think that the value of particular innovations should be judged more in terms of their level of appreciation by audiences than by their impact on the Corporation’s competitors.

24. We find the language of ‘setting new boundaries’ to be inappropriate in this respect and encourage the BBC to find new ways of meeting the needs of Licence Fee payers while not engaging in unfair competition. We are concerned that adopting a ‘precautionary approach to market impact’ could limit new and bold thinking in respect of existing and new services (PQF: 55).

25. We also note that in times of economic crisis – as demonstrated recently – the instability of some kinds of commercial funding has meant that the relative stability provided by the Licence Fee has been vital for maintaining standards and levels of provision for users of broadcasting services in Britain.

26. We support the proposal to reduce investment in imported programmes but note that any reduction in the overall level of the Licence Fee would undermine this strategy as has been demonstrated, in different ways, in countries such as Canada, Australia and New Zealand (PQF: 56-7). It is generally cheaper to import programmes than to make new ones and correspondingly vital that the BBC places a high priority on investing Licence Fee payers money in original content production.

27. We agree that the BBC should not take any action that damages the already highly vulnerable local newspaper business but think that there is still scope for new forms of cross-sectoral partnership at local level.

(vi) Issues that are missing from the 2010 BBC Strategy Review

28. In a recent speech the Director General of the BBC appeared to endorse the introduction of spectrum pricing (2). If the Government were to require the BBC to start paying for its use of the airwaves or ‘spectrum space’ then two unfortunate consequences would follow. Firstly, programme budgets would be reduced in order to meet the new spectrum fee costs. And, secondly, the principle of free use of the airwaves by public service broadcasters, operating in the public interest, would be destroyed. In the United States early communications legislation saw the airwaves as being owned by the public and therefore to be used for the benefit of the public. One consequence of spectrum pricing would be to make it much more difficult to speak of public service broadcasting as enriching the use of public space in a democracy. Moreover, free access to public service communications could no longer be seen as analogous, for example, to the principle of free access to public parks.

29. We also wish to support the widely accepted principle that the BBC should remain independent of the Government of the day. In this regard, it is important that the BBC is not funded directly by a government Ministry and that Government does not seek to intervene in the way that Licence Fee money is spent. This should be so, even though Government takes responsibility for setting the overall level of the Fee. In this regard the technical re-classification of the Licence Fee as a tax in 2006 should not lead politicians to see this Fee as just another tax and therefore subject to Parliamentary accountability in the way that is expected for other forms of public spending. If it is a ‘tax’ it is a most unusual one, collected not by Revenue and Customs but by the BBC itself. We support the long-established procedures whereby the BBC has been accountable to Licence Fee payers through its own governing body and not, routinely, through the National Audit Office or the parliamentary Public Accounts Committee. It would not be appropriate for Members of Parliament to scrutinise BBC spending priorities in detail, although the presentation of the Corporation’s Annual Report to parliament provides a formal means of basic accountability to the elected representatives who work on behalf of the citizens of the United Kingdom. However, the BBC’s Annual Report should contains more detailed financial information, more clearly laid out than at present. Such improvements would assist Licence Fee payers in scrutinising expenditure.

30. Finally, we think that further consideration should be given to the issue and appropriateness of re-transmission fees being charged by the Corporation, where its services are carried on commercial cable or satellite platforms. In the past the ‘must carry’ rule has been taken to mean that no re-transmission fees would be levied in such cases. Existing practice should now be reviewed in the light of examples from other countries. And one particular reason for reviewing current practice is that Britain’s four designated public service broadcasters (including the BBC) produce the vast majority of original, first run programmes. Ofcom’s figures indicate that as little as 10 per cent of investment in original production comes from the hundreds of commercial channels not designated as PSBs (3). The charging of re-transmission fees could provide welcome additional income for investment in original production.

Notes and References

(1)Government statistics on broadband access may be found at: http://www.statistics.gov.uk/cci/nugget.asp?id=8

(2) Mark Thompson’s speech to the Royal Television Society’s Cambridge Convention in October 2009 noted that spectrum tax might be ‘credible’. Details can be found towards the end of the speech in the section on Digital Britain at: http://www.bbc.co.uk/pressoffice/speeches/stories/thompson_cambridge.shtml

(3) Britain’s four public service broadcasters are the BBC, Channel 4, ITV and Five. Details of which channels invest most in original production may be found in Ofcom’s report of 2009: Ofcom’s Second Public Service Broadcasting Review. Putting Viewers First. London, Ofcom, p. 34.

Citations from the BBC’s Putting Quality First (2010) and the relevant page numbers are recorded thus: PQF: 12.

Putting Quality First may be found at: http://www.bbc.co.uk/bbctrust/our_work/strategy_review/index.shtml

Appendix 1: Members of the Citizens’ Coalition for Public Service Broadcasting (CCPSB) at 21 May, 2010.

1. Organisations

• Association of Chief Executives of Voluntary Organisations (ACEVO)
• BECTU
• Big Bang Lab
• Campaign for Press and Broadcasting Freedom (CPBF)
• Community Service Volunteers (CSV)
• Equity
• Federation of Entertainment Unions
• Hansard Society
• International Broadcasting Trust (IBT))
• MediaWise
• Musicians’ Union
• The National Consumer Federation (NCF)
• The National Council for Voluntary Organisations (NCVO)
• National Council of Women Great Britain (NCWGB)
• National Federation of the Blind (NFB)
• National Institute of Adult Continuing Education (NIACE)
• National Union of Journalists (NUJ)
• National Union of Teachers (NUJ)
• Save Kids TV (SKTV)
• The Society of Authors
• The Stage
• Television for the Environment and Television Trust for the Environment (tve)
• Townswomen’s Guild
• UK Coalition for Cultural Diversity (UKCCD)
• unite
• Voice of the Listener & Viewer (VLV)
• W4B -the TV and Radio Charity
• Writers’ Guild of Great Britain

2. Individuals

• Prof Steven Barnett, Professor of Communications, University of Westminster
• Michael Barton, former Controller of BBC local radio and trustee of the Voice of the Listener Trust
• Prof Georgina Born, Cambridge University
• Dr. Andrea Esser, Senior lecturer in Media and Communications, University of Roehampton
• Paul Evans, Writer and Consultant
• Prof Natalie Fenton, Co-Director Goldsmiths Leverhulme Media Research Centre: Spaces, Connections, Control & Co-Director Centre for the Study of Global Media and Democracy
• Stephen Fry, actor, writer, comedian, author, television presenter and film director
• Prof Ivor Gaber, School of Journalism, City University
• Bruce Hanlin, Senior Lecturer in Media & Journalism, University of Huddersfield
• Dr Jonathan Hardy, School of Social Sciences, Media and Cultural Studies, University of East London
• Prof  Sylvia Harvey, FRSA, Visiting Professor in Broadcasting Policy, University of Leeds, Visiting Senior Fellow, LSE, and Chair of CCPSB
• Dr David Hendy, Reader in Media & Communication, University of Westminster
• Patricia Holland, Bournemouth University
• Prof David Hutchison, Visiting Professor in Media Policy, Glasgow Caledonian University
• Nicholas Hytner, Director of the National Theatre
• Dr Petros Iosifidis, Reader in Media and Communications, City University, London
• Dan Jackson, Lecturer in Media and Communications, Bournemouth University
• Dr Paul Kerr, Senior Lecturer, Broadcast Media, London Metropolitan University
• Michael Klontzas, Senior Lecturer, University of Huddersfield
• Daniel Lee, Writer, Lecturer and Communications Consultant
• Prof Sonia Livingstone, Head of Department of Media and Communications, LSE
• Dr Hugh Mackay, Open University, Wales
• Prof Máire Messenger Davies, Director, Centre for Media Research, University of Ulster
• Dr Maria Michalis; School of Media, Arts & Design, University of Westminster
• Professor Julian Petley, Brunel University,
• Dr Katharine Sarikakis, Institute of Communcations Studies, University of Leeds
• Dr Maria Sourbati, Course Leader, Media Studies, University of Brighton
• Prof Jeanette Steemers, University of Westminister
• Dr Einar Thorsen, Lecturer in Journalism and Communication, Bournemouth University.