1. The Institute of Welsh Affairs (IWA) is pleased to have this opportunity to respond the BBC Trust’s consultation on the Strategy Review prepared by the BBC Executive. The IWA has been concerned with issues surrounding public service broadcasting for some years. We have given oral evidence to the BBC Trust’s Impartiality Report on network news and current affairs undertaken by Professor Anthony King. We made submissions to the different phases of Ofcom’s second review of public service broadcasting and during that process were commissioned by the Welsh Government to carry out an audit of media in Wales. Our chairman was also a member of the Welsh Government’s broadcasting advisory group, which published its report in November 2008. We conducted public consultations on the issues in different parts of Wales, in collaboration with Ofcom, and also held a seminar on the future of PSB in Wales, publishing an edited transcript of the proceedings. Last year we also published a book on what we see as a crisis for English language television broadcasting in Wales. This was a selection of essays that dealt both with the general situation and the factors surrounding different programme genres. We have also supported the previous UK Government’s proposals for independently financed news consortia to deliver news for Wales on ITV.
2. We start from a firm belief that the BBC is the all-important cornerstone of public service broadcasting in Britain, and should remain so for the foreseeable future. We believe that it enshrines public values that reflect the best to which our society aspires and, at its best, enables those values to resonate through our society and its institutions.
3. We also believe that the BBC has, over the decades, made major contributions to Welsh culture and society, and that it can and should continue to enhance that contribution in the coming years, conscious of the retreat of the other main public service broadcaster, ITV, from its previous extensive provision in Wales. Our connection with the BBC is a source of creative strength, which we should maintain.
4. We applaud the BBC for the initiatives it has taken to decentralise production, to Cardiff, Manchester and Glasgow, and particularly its decision to create the drama village in Cardiff to capitalise on the network drama successes of BBC Wales over the last decade. We are only sorry that Channel 4, now to be the only other significant public service broadcaster, has not so far been willing set itself similar targets, and that ITV has sought to reduce its traditional high spend outside London.
5. For these reasons we are broadly supportive of the overall thrust of the Strategy Review: that the BBC should act as one of the main guarantors of public space, that it should concentrate on being a creator of quality, that it should be a catalyst and connector through making its partnership role with other civic institutions central to its mission.
6. This submission addresses the biggest single omission in the Strategy Review, namely the total lack of consideration of or even reference to the programme services made in and specifically for the smaller nations of the UK. We do so because we have found it difficult to believe that such an omission could have been possible at the end of the first decade of devolved government within this country, in the light of the close attention given to broadcasting by all the devolved administrations, and especially so soon after the severe criticisms of the BBC’s metro-centricity in network news coverage made by Professor King. The omission calls into question some fundamental aspects of the working of the corporation.
The Welsh context
7. First, however, we wish to emphasise the context in which the BBC’s services in Wales operate, namely that the media provision in Wales is, overall, substantially weaker than in Scotland or Northern Ireland. The only exception is the provision for the Welsh language. The details have been rehearsed endlessly in the media debate in Wales in recent years but, if anything, the situation continues to deteriorate.
8. Indigenous print media in Wales are already limited, particularly at the all-Wales level. No London newspaper publishes a Welsh edition. As the IWA’s media audit concluded: “perhaps the most startling fact of all to emerge from our researches is that each day only 100,000 readers in Scotland read a newspaper with no Scottish content, where as in Wales 1,760,000 (nearly 90 per cent) are reading papers with virtually no Welsh content. It seems to us impossible to argue that those figures do not have serious consequences for informed democracy in Wales.”
9. Wales is the country where the BBC is most dominant in radio and television. Wales has the weakest commercial radio provision, with no speech radio competition for the BBC. It is the only one of the three nations where none of its commercial radio stations is indigenously owned, and the only one whose ITV franchise-holder was absorbed into ITV plc.
10. English language television has born the brunt of recent structural changes. ITV programming for Wales has declined from a peak of 624 hours per annum to the current 286 hours, of which 208 hours are news. Without some government intervention (currently unlikely) the remaining 90 minutes per week of general programmes for Wales, will disappear soon.
11. BBC Wales television output in the English language, has also declined from its peak of 883 hours of originations in 2003-04 to 721 in 2008-09, a reduction of 18%, with a concomitant reduction in the range of programming. A further reduction has taken place in 2009-10. From its peak of more than £26 million in 2003-04 spend on the service has already declined to £23m and, at the current rate, could well be below £20 million by 2012-13 when the current savings programme comes to an end.
12. Wales will have the lowest population coverage of any of the four UK countries for terrestrial digital transmission systems in both radio and television. In terms of coverage DAB transmission is sure to be significantly inferior to the current FM/AM mix.
13. Broadband take-up has been slower in Wales than in any other part of the UK, and it is likely that high speed broadband will have even greater difficulty is establishing effective coverage and penetration.
14. The Strategy Review enunciates many sound principles to underpin and prioritise its programme investment, and we full endorse them. But these principles need to be applied not only to the BBC’s network services but also to its services for Wales and the other smaller nations. However, these principles cannot be applied effectively without the resources to deliver the volume and range needed to create a rounded service. We would refer you to the conclusion of the Welsh Government’s Broadcasting Advisory Group:
“As a nation, the people of Wales have a right to easily available media in the English language that reflect all the purposes of public service broadcasting as defined both by Ofcom for all PSB providers and by the Government for the BBC.
“Such provision should be in addition to the specific and different needs of Welsh-speakers, for whom S4C remains the only television platform available in their own language.
“The totality of media provision in Wales must contribute to and fully reflect:
i) a properly informed democracy, able to access high quality reportage, analysis and investigation from a variety of professional sources.
ii) a culturally rounded society, for which the media provide adequate room for full and varied expression.
iii) A visibly creative economy in which the media pioneer innovation and are a driver of the creative industries.”
“The current system does not achieve all these goals now, and needs substantial enhancement. Without significant intervention it will weaken further and the opportunity to fulfil Wales’s creative potential, with all the economic and democratic benefits that that would entail, could be missed.”
15. With the effective demise, outside news, of the ITV service for Wales the BBC has a particular responsibility to fulfil this task, especially in television for the majority non-Welsh-speaking audience. It needs to be accorded a far higher priority than it has been given hitherto by the BBC, in order to fulfil the first two principles enunciated in the Strategy Review, namely ‘putting quality first’ and ‘doing fewer things better’.
Prioritising quality services for Wales
16. An examination of the service licences issued by the BBC Trust shows that the total spend on the BBC’s four main UK television services, plus channels for children, news and Parliament, is now £1.814 billion. The spend on the BBC Wales English language television service is slightly more than £23 million, less than 1.3 per cent of the UK spend.
17. Another 1.4 per cent is spent on BBC Wales programmes for S4C, but it should not be forgotten that when S4C was established the BBC received a small addition to the licence fee that has been built into its baseline ever since. In broadcasting the cost of supporting the oldest living language of these islands - arguably, more precious than any other British cultural artefact - has been seen as a UK obligation, as also evidenced by the method of funding S4C. It is not a cost that should be borne by short-changing the non-Welsh-speaking audience in Wales.
18. Within the BBC’s current resources it has ample capacity to re-balance its spend within the UK to deliver the kind of rounded national services for Wales and Scotland that have been argued for by the Welsh and Scottish Governments, on the back of research by various committees and commissions in both countries. That this is possible is implicit in the Strategy Review’s own claim that ‘investing more in content would also help relieve pressure on the creative industries.’ If that is true for the UK, it is doubly true in Wales.
19. Addressing the issue in Wales, where the English language television spend (£23m.) is less than half that in Scotland (£49m) should be the first priority. We also note that the spend per hour in Scotland is almost double that for the English language service in Wales. We do not question the spend in Scotland, but neither do we believe that delivering services of comparable range and quality for the two countries can be achieved by applying an informal ‘Barnett formula’ within the BBC.
20. This re-balancing should be achieved over a three-year period by halting the present budgetary cuts within BBC Wales, and beginning with a switch of not less than £5m into Wales to allow for an additional two hours per week of originations. The budget should then be progressively grown to around £40 million which would allow the development of a service of a volume, range and quality that could properly reflect the complexity and vitality of Welsh society and culture.
21. One caveat needs to be entered about the volume of such a service. The success of a television service made in and for Wales cannot be measured simply in hours of output. The emphasis must be on quality, a relevance to the Welsh situation, and a capacity to engage different audiences within Wales - some large, some much smaller. However, taking the BBC Wales and ITV Wales services together, at present around 85 per cent of the output is accounted for by news, current affairs and sport. That leaves only 15 per cent of the output (around 150 hours, i.e. just three hours a week spread across the three most important channels), a painfully inadequate space to accommodate a proper ration of drama, music, arts, factual and light entertainment programmes. It is in these areas that we would expect to see a better provision. These are programme genres that are of proven importance to the audience, and they need the space and resources with which to grow and flourish.
22. We believe it is important that any new plans that emerge to fill the void in the Strategy Review at it stands, should apply the same quality principles deemed fit for network services to the services for the nations. We shall attempt to address each of these in turn.
The best journalism in the world
23. We endorse all the aspirations for quality journalism within the BBC set out in the Strategy Review, but we would urge that the BBC take greater care to ensure that that also applies to non-network journalism. This is particularly the case in Wales, where the relatively young democracy that has emerged since 1999, needs purposeful and incisive journalism, that can win a large audience but is not afraid to be serious.
24. We share some of the reservations on current news and current affairs output in Wales set out in the report of the Welsh Government’s Broadcasting Advisory Group. It is worth setting them out in full:
“Many to whom we spoke, while generally supportive of BBC Wales and ITV Wales news and current affairs output, also voiced criticisms that are seen as common to many regional news programmes - relying too heavily on a diet of crime and casualties and sometimes too ready to put entertainment value ahead of editorial purpose. This can result in programmes that do not always seem to aspire to the same journalistic values as the UK news programmes that precede them. This was characterised succinctly by one member of the public in one of our discussion groups by reference to ‘the big news and the little news.’
“Such a pithy perception throws out a challenge to the Welsh journalistic culture, and perhaps to non-metropolitan journalism as a whole. Some practitioners have wondered whether declining morale at ITV has blunted the competitive edge of both ITV and BBC offerings.
“In current affairs, staff and budget reductions at ITV Wales have reduced the investigative capacity of its current affairs programmes, while both ITV and BBC are seen to be reluctant to attempt extensive engagement with policy issues. Others have questioned why a Welsh equivalent of the BBC’s Question Time exists in the Welsh language on S4C (Pawb a’i Farn) but not in English on BBC or ITV.
“These criticisms apart, people have been unanimous in seeing the presence of news and current affairs about Wales on both ITV1 and BBC1, with their different and complementary demographics, as the most important single means of keeping the Welsh public informed of events and issues in Wales.
“The weekly reach of the BBC’s Wales Today is 575,000, while that for ITV’s Wales Tonight is 250,000, and it is important to note that there is only a small overlap between the audiences to both programmes, with only 10% of the audience viewing both. The potential loss of an ITV early news programme for Wales would, therefore, mean a very marked reduction in the audience to news of Wales, particularly amongst the C2DE groups.
“As the IWA noted, “Although some viewers would no doubt transfer to the BBC Wales programme, there would certainly be a considerable drop in the total audience since ITV would, in those circumstances, be certain to schedule aggressively against the BBC’s early evening news hour.” 
“Similarly, the withdrawal of ITV from Welsh services would mean an even more significant reduction in the audience to current affairs programmes for Wales, since the ITV Wales programme (Wales This Week) is the only one currently scheduled in peak, at 1930, delivering a larger audience than the BBC’s equivalent programme (Week In Week Out) scheduled on BBC1 at 2230. Wales This Week wins an audience share greater than the share figure achieved by the ITV network’s Trevor Macdonald programme in the same time slot.
“The prospect of such large and avoidable reductions in the audiences to news and current affairs is all the more forbidding given the absence at the all-Wales level of any speech radio competition for the BBC and the very limited nature of Welsh print media.
“It is important that this public purpose remains to the fore, so that citizenship and civil society is supported. Despite the considerable progress of recent years, broadcast and print journalism in Wales still has some way to go before it matches, qualitatively, in every regard the challenges posed by the existence of new legislatures and governments. We would stress that these new institutions, while serving the three nations, are also an integral part of the British constitution. For that reason, their needs in terms of public engagement, and their ultimate success are issues not only for Wales but also for the UK as a whole.
“News and current affairs on ITV in Wales must not only be preserved, in order to maximise the audience, but also be better resourced, while BBC Wales should seek to use its considerable journalistic resources, particularly in television news, to even better public effect.
“The BBC Trust’s decision not to approve the BBC’s proposals for localised online video will be welcomed by many as offering an encouragement to other providers to invest in online services. The implications of such a decision are surely that BBC Wales should maintain and enhance the quality of its national focus as its true priority. The outcome envisaged, namely that the money allocated to BBC Wales for online services should now revert to central funds, with a real reduction in journalistic resources in Wales, is perverse.
“Steps must also be taken to ensure a deeper and more open discussion about the nature and development of journalism in Wales across all media. It should be a discourse that engages practitioners, civil society and the wider public.”
25. We would add that if the Government can yet be persuaded to support the proposal for an independently financed news consortium to deliver a news service for ITV In Wales, then the proper response for BBC Wales should be ensure that its own nightly television news programme marks out an even more distinctive position, showing no less serious a journalistic intent than the BBC’s six o’clock news throughout the duration of the programme.
Inspiring knowledge, music and culture
26. Throughout the debate on public service broadcasting the IWA has argued for the importance of non-news programming within Wales. Our view is that pluralism is about guaranteeing a range of expression, but that that should involve much more than guaranteeing a range of expression for journalists. Range of expression expands exponentially if you extend it to dramatists, documentary makers, comedians, satirists and artists of all kinds. Different forms allow different truths to emerge. That is as true and as relevant for the broadcast services within Wales – radio and television – as it is for network services.
27. Currently, budgetary constraints mean that Welsh society and politics lack the regular challenge of comedy and satire, while light entertainment can tap only a fraction of Wales’s deeply rooted performance culture.
28. The nature and diversity of Welsh culture and arts also demands both fuller and more varied treatment, suitable for both mass audiences and smaller niche audiences. This area provides much scope for creative partnerships between BBC Wales and Welsh arts organisations that would play to the BBC’s aspiration to become ‘a better partner both with other broadcasters, media players, and with other public institutions.’ Such partnerships could be disproportionately beneficial at a time when the subsidised arts will be under severe stress due to pressures on public expenditure. This approach should embrace, television radio and online. It would also chime with the review’s talk of ‘a recommitment to thought-provoking, intelligent and ambitious factual programming on BBC2.
Ambitious UK drama and comedy
29. A clear distinction needs to be made between BBC Wales’s role in network drama and the need for drama output made specifically for the Welsh audience, even if there is a connection between the two. Despite the striking success of Dr. Who, Torchwood, we cannot hope to see Welsh talents bring genuine cultural diversity to UK networks, if there is not the space for them to develop their own voice at home in the language of their choice. Drama lies at the heart of most high quality television services, yet is all but absent from English language services in Wales. Last year there were only four hours of English language drama made for Wales by BBC Wales, compared with 56 hours in Scotland. The same applies to comedy.
30. There is also scope for BBC Wales to develop its presence in film by closer partnership with independent producers, the Film Agency for Wales and the Creative IP fund. This would dovetail with the new emphasis on the creative industries in the economic development policies of the Welsh Government.
31. This should not absolve the BBC from seeking to reflect greater cultural diversity in its network drama output, even if we are realistic about how difficult it will be to achieve that. In this network context it is disappointing that the Strategy Review does not paint a fuller picture of its overall objectives in drama, not least to bring a greater reflection of the literatures of the UK to the screen, beyond Jane Austen and Charles Dickens.
Outstanding children’s content
32. Very little programming has been made for children in Wales, other than programming with an expressed educational intent. But there is a real need to allow Welsh children to see their own recognisable communities, and to hear their own accents in television programming. This is an area where there is considerable scope for cost-effective collaboration between BBC Wales and S4C, allowing S4C to reciprocate the benefits that it receives from the licence fee.
Events that bring communities and the nation together
33. Network programmes will continue to bring all the nations of the UK together for many events, such as political events, commemorations and sporting events that are external to the BBC, as well as the peaks of entertainment that are created by programme-makers. The BBC in Wales should continue its tradition of giving space to our great cultural festivals and sporting occasions, but additional resources would also allow it to explore new territory. The talent and creativity exists also to create television events for Wales that would draw large audiences.
Radio Wales and Radio Cymru
34. As the only two national radio services for Wales, Radio Wales and Radio Cymru are vitally important ingredients in the media scene. No other radio services services deliver more than a fraction of the speech content of these two, and it is important that their distinctiveness is not diluted by budgetary constraints. If anything, a more focused proposition for the BBC as a whole, should require the same enhancement of crafted speech content as has been promised for Radio 2.
35. However good these services may be, it will avail nothing if they cannot be delivered to the audience across Wales at a reasonable standard. The BBC should note the deep concern in Wales – one that is shared by the Ofcom Advisory Council for Wales – that the push into DAB is being made without regard for the different circumstances created by Welsh topography. Completion of a full review of the situation of radio in Wales is urgently required.
36. DAB is far less well suited to Wales than FM, and UK services have been given a priority on DAB in Wales, that is seriously disadvantaging our own national radio services. DAB coverage for the BBC UK services in Wales is 88 per cent, and for Radio Wales and Radio Cymru only 40 per cent, with little early prospect of radical improvement. This is compounding an already unacceptable situation where FM coverage for Radio Wales reaches only 62 per cent of the Welsh population. This needs urgent rectification.
BBC Wales programmes for S4C
37. The BBC’s commitment to S4C should be sustained in volume and quality, but in the light of S4C’s primary funding through the DCMS, it falls to the BBC to ensure a level of English language service in television that delivers demonstrably greater equity. The current low level of English language spend is not to the BBC’s credit, and will ultimately be harmful even to the S4C by encouraging a sense of grievance and undermining public support. The answer does not lie in cutting the S4C spend.
38. The Strategy Review’s proposed 25 per cent reduction in spend on online services would be of deep concern if it is proposed that this be implemented uniformly across all services. Uniform cuts across both network and regional services have always been more damaging at the regional level where budgets have always smaller and services more fragile. That is particularly true of online services in Wales, where there is also a far lower level of Wales-oriented material in the commercial sector. While the BBC may have been right not to proceed with its hyper local service some years ago, a 25 per cent cut in the existing online service would do disproportionate damage.
39. While we have applauded the work done by the BBC on the decentralisation of production, nevertheless, the omissions in the Strategy Review point to an organisation that that is still wedded to intensely centralised management and governance structures. The BBC would benefit from a degree of decentralisation in both that, we believe, would have benefits in speeding decision-making as well as improving the accountability of the BBC within the nations.
40. The BBC is able to act unilaterally in this direction, but we believe there would be greater benefits if it were also conducted in the context of a wider devolution of responsibility for some aspects of broadcasting. It should be perfectly possible to achieve a sharing of functions between the centre and the nations, within a sensible new UK framework.
41. In the case of the BBC, we believe it should aim at a quasi-federal structure in which the present Advisory Council for Wales – which, we believe is not fit for purpose - would be replaced by a BBC Trust Wales, directly responsible for its own secretariat, and with specific deliberative functions. It should be responsible for defining a national service licence for the BBC in Wales that would encompass all its programme and online services, as well as the BBC National Orchestra of Wales, and for allocating funds between those services. That national service licence should be funded by block grant determined not by BBC management but taken directly from the licence fee on the basis of a formula endorsed by both the UK Government and the devolved administrations.
42. Such a change would be represent a powerful re-balancing of authority and would provide a much stronger basis for accountability within Wales. It would also make for a fairer and more adult relationship between the centre and Wales and the other nations.
 Media in Wales: serving public values, by Geraint Talfan Davies and Nick Morris. IWA, May 2008
 Communication and content: the media challenge for Wales, a report by the broadcasting advisory group to the Minister for Heritage. Welsh Government, November 2008.
 Future of Welsh Broadcasting, transcript of an Ofcom/IWA seminar. May 2008.
 English is a Welsh language: television’s crisis in Wales, (editor) Geraint Talfan Davies. IWA, March 2009.
 Ibid. paragraphs 2.4-2.7
 Media in Wales - Serving Public values, IWA, 2008. p52