Submission to the National Assembly Broadcasting Committee

May 2008

Introduction

1. Equity is a trade union representing over 1,500 performers and other creative personnel who work across the whole spectrum of entertainment in Wales in both languages. Our members work in a range of media and the creative industries including visual broadcasts, sound recording and film. Members work predominantly in drama, comedy and entertainment programmes.

2. Equity, therefore, welcomes the Assembly instigating this Inquiry into Public Service Broadcasting (PSB) in Wales at a key moment for the industry.

Background

3. It is probably necessary to quickly define what Public Service Broadcasting means in the digital age. The BBC Charter was recently updated to re-assess the initial Reithian principles of "inform, educate and entertain”. It has now widened to include "sustaining citizenship and civil society, promoting education and learning, stimulating creativity and cultural excellence and reflecting the UK, its national regions and its communities.” It should bring the UK to the world and the world to the UK. Within this national region we would assert that it should bring the world to Wales, Wales to the world and more fundamentally Wales to itself.

4. Equity believes that plurality in the provision of PSB has been vital to its success and therefore welcomes the Committee’s desire to examine ways in which PSB is protected across a number of platforms "in order to enable a healthy plural media market”.

5. Plurality is important because not only does it create the conditions for competition to spur innovation and drive higher quality, but it also avoids an over reliance upon one sole provider.

6. The current system of PSB puts a high responsibility on the BBC and to a lesser extent S4C. However, we have to be aware that the other three terrestrial channels, ITV and Channels 4 and Five, also have statutory obligations. In the case of Channels 4 and Five, these have been less marked in Wales than in the rest of the UK as they have not been readily available. With the advent of satellite and digital technology, this will no longer be the case.

7. The proliferation of digital television channels will, however, put pressure on the methods of providing the PSB. As a result the system cannot and should not remain static. OfCom has recently issued a discussion document "A new approach to public service content in the digital age” and we welcome their commitment in that to securing a public service system for the future which continues to deliver the best elements of the previous model. We agree with OfCom’s statement that "the rationale for intervention in support of public service content is likely to remain in the digital world”

8. So, while the methods of delivery will change, the plurality should remain constant, even in a digital age. This will help to encourage, and enable the continuation of, original high quality programme making across a range of genres including drama, comedy, entertainment and children’s programming. The prospects for promoting plurality will also depend on appropriate regulatory and legislative support, so it helpful that Section 264(3) of the Communication Act 2003 provides OfCom with "an obligation, with a view to maintaining and strengthening the quality of public service broadcasting across the United Kingdom”.

9. This support for a broad range of PSB in a digital age will ultimately help users to differentiate providers of content on new platforms. Providers with a reputation for producing the best content are likely to achieve the greatest success in attracting an increasingly fragmented audience to the new technology and platforms. Therefore the success and popularity of new technology will depend heavily on the quality or original production - and especially programmes that feature the work of Equity members. Technology is nothing without content. In Wales this is a particular challenge for S4C, whose strength must lie in high quality niche broadcasting, not in trying to compete with English language mass market product.

The Situation in Wales

10. Equity made a detailed response to the OfCom Review of PSB Phase 3: The Nations and Regions in 2005. In that we endorsed OfCom’s broad view that the devolved nations have distinct cultural and political identities that need to be reflected in the PSB framework.

11. In relation to ITV Wales we supported OfCom’s proposal to reduce the cost of opting out of the network schedule. We saw this as a necessary practical approach if the respective national identities were to continue to be properly reflected, particularly in non news production.

12. Three years down the line we are not convinced that ITV Wales has made a sufficient case, either culturally or financially, to reduce further its obligations to making non news programmes. We believe that ITV should continue to exhibit some PSB responsibilities beyond the provision of nightly news and current affairs.

13. OfCom has consistently recognised the importance of S4C to the broadcasting ecology of Wales. However we still believe there is a need to actively address the future of S4C given the impact of digital only broadcasting and the inevitable pressure that will put on advertising revenue in particular.

14. We believe that S4C’s future lies in its ability to make and market the highest quality programming in the Welsh Language and we would guard against any inclination the broadcaster might have to try and copy or compete with Murdoch or similar multi national media producers.

15. In that respect they have put themselves in a very testing position with their decision to develop S4C2 as a children’s channel. Given the parlous state of UK made children’s programming, S4C’s initiative is to be welcomed. However, they have stated that this will be done with no additional request for resources. In order to fund it, will resources therefore be taken away from mainstream S4C programme making activities? There seems to be no other option, and this will be bound to affect both quality and output which in turn could affect audience figures and lead to more questions about the broadcaster’s viability.

16. We continue to believe that the present system of funding through the DCMS is the best method and we would dissuade any re-examination of the franchise or the top slicing proposal previously floated by OfCom

17. The success of the BBC in attracting high quality network programming around the Doctor Who franchise has been the major success story in Welsh broadcasting in the last five years. Long may it continue.

18. Where does that leave their PSB responsibilities? It is regrettable that the BBC has now pulled back to the point of near extinction on its indigenous drama output both on radio and television. In recent years the two Radio Wales and Radio Cymru "soaps”, Station Road and Eileen, have been axed and the highly popular Belonging has now also finished. Although there remains some drama output on radio, there is nowhere that Wales can see a refection of itself in drama terms, and it is the only part of mainland UK in that situation following the creation of River City in Scotland. That is to be regretted and we will continue to press for this to be addressed.

19. We understand that the Corporations plans to cut back by 10% on programme making output will be applied equally across all the Nations and Regions, and therefore Wales faces a disproportionate loss.

20. OfCom’s recent discussion document notably omits the notion of a PSP, with which we were, particularly in Wales, very uncomfortable. Instead it offers four possible models by which PSB may be funded in the future. Of these Equity favours the evolutionary process. We believe there can be discussions with ITV to uncover new funding models that can protect PSB within the commercial sector. Two of the other options involve bidding for funds. It is not clear where these funds will come from but we are opposed to any top slicing of the BBC License Fee to create what would in effect be a PSB "pot”.

21. We want to reiterate that the broadcasting industry in Wales is of vital importance to the country’s economy. Any threat to PSB would be a threat to jobs and to the wider economy through the many and varied facility and support companies that exist as a necessary and lucrative supply chain.

22. The continuation of a strong PSB sector is also important to the delivery of effective and co-ordinated training. The Creative and Cultural Industries in Wales have not be prioritised in this respect and we are looking to the current proposals through the two main Sector Skills Councils (Creative and Cultural Skills and Skillset) to be supported by the Welsh Assembly Government.

23. Equity believes it is essential for public service material to be widely available in all types of new media. Viewing habits are already changing and will continue to do so. The Union has proactively engaged with broadcasters and companies to provide a framework within which suitable rights can be delivered to the originating company while protecting the pecuniary interests of the performers who make it. We are keen to ensure that work is made available to as many people as possible across a range of new media. Recent discussions with the WNO and DECWL is evidence of this. It is important in our view that this is maintained. In the wider context, and however these services are delivered, Equity believes that certain non linear media services of this nature should be subject to the same common principles of regulation and minimum standards as traditional television broadcasts.

Conclusion

24. If Wales is to maintain a high quality broadcasting and media industry it has to maintain a well funded pluralistic PSB sector.

25. It may be necessary for the Assembly Government to consider a innovative approach to ongoing scrutiny of the sector by creating a Broadcasting Commission similar to that of Scotland which can look in more depth at other aspects of the industry not necessarily encompassed by a review of PSB. An alternative might be to create a Media Commission with a wider brief than merely broadcasting, as the advent of new media is something which will be utilised by many other organisations in the journalistic and educational field for example. The appointment of an independent Commissioner may be a consideration also.

26. We are happy and willing to provide further evidence in person if that is considered desirable.