Review of the BBC’s Royal Charter
Prelude
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 policy debates of the broadcasting and parliamentary communities in both Ireland, and in Northern Ireland.
The Broadcasting Committee of the Church of Ireland offers a broad welcome to the proposals it finds in the Review. In particular it applauds the decision to continue the licence fee as the method of funding during the period of the next Charter and also the roundly announced commitment to the ethos of public service broadcasting. More detail will emerge in our responses to the Review questions.
Question 1: Do you think it is helpful to define the BBC’s purposes in this way?
The Broadcasting Committee of the Church of Ireland believes so. It is helpful to have a short and clear statement of purpose.
Question 2: Are these the right purposes?
The Broadcasting Committee of the Church of Ireland believes that the purposes are correct. We applaud the fresh focus the role of the BBC in ‘bringing the world’ to the UK. We feel that in the globalizing context this is eminently desirable in a public service broadcaster.
Question 3: Are these the right characteristics?
The Broadcasting Committee of the Church of Ireland welcomes the characteristics which the Review delineates. We agree that that the programmes of a public service broadcaster should at all times be inspired by something other than (and in a democratic polity more than) the drive for ratings. We are also please to see, however, that the Review recognizes that the nature of the public service ecology means that not every individual programme within such a service needs to display each of the delineated characteristics all of the time. We consider that a balance needs to be achieved whereby the BBC is not regulated into making the kinds of lofty and worthy programmes that few will want to watch. To do so would be to imperil the need for the BBC to be present to the largest possible number of people encouraging and enabling the sustaining of democratically informed citizenship.
Question 4: Do you agree that the BBC should be at the forefront of developments in technology, including digital television?
The Broadcasting Committee of the Church of Ireland agrees that it is entirely sensible that the BBC, as a trusted brand, should take the lead in promoting technological development and in particular in encouraging the roll out of digitally based televisual technologies.
Question 5: Do you support the proposal for a further review of alternative funding methods, before the end of the next Charter period?
The Broadcasting Committee of the Church of Ireland applauds the proposal to retain the licence fee for the next period of Charter. However, it is not convinced that a mid–term review would be helpful. Reviews are distracting and extensive processes and the Committee believes it can sympathise with the often articulated views of other essentially voluntary interest groupings in noting that there is a real danger of ‘consultation fatigue’. To have another review of funding in 5 years time runs the double risk of excluding the participation of already exhausted voluntary groupings (like the faith communities) and of absorbing the institutional energies of the BBC which would really be better directed towards the creation of the kinds of programming patterned by the current review.
Question 6: Do you have a view on any aspect of the operation of the licence fee: concessions, its collection or its enforcement?
The Broadcasting Committee of the Church of Ireland agrees with the current exemption for the post–75 age grouping and indeed would like to see the lowering of the exemption to the post–65 age grouping. It recognizes that this is an aspirational project. Nevertheless it would like to see the serious discussion of exemption extension in any future review (mid term or otherwise). The Committee would envisage a compensatory rise in the level of the licence fee after 2016.
The Broadcasting Committee of the Church of Ireland also recognizes that enforcement and collection seems to be especially problematic in Northern Ireland. It regards this as a problem to be solved and not abandoned– its attempted solution is essentially consonant with the wider goal of sustaining citizenship in the Province.
Question 7: Have we defined the roles of the BBC Trust and the Executive Board sufficiently clearly?
The Broadcasting Committee of the Church of Ireland believes so. We also believe that regional representation will be vital. We find currently no explicit provision made for this but we would wish strongly to see such a provision in place.
Question 8: Is this the right way to define the public interest remit of the BBC Trust?
The Broadcasting Committee of the Church of Ireland believes so.
Question 9: How many of these options would you like to see adopted in the Trust’s statement of promises? Are there any other options that you would like to see considered?
The Broadcasting Committee of the Church of Ireland believes that the Trust might well be vulnerable to special interest lobbies. The net–based transparency might not sit too easily with something like the concerted campaign recently mounted around Jerry Springer: The Opera. Again we make the point of the need for regional representation in the proposed construct.
Question 10: Have you any views about how the BBC Trust should handle complaints?
The Broadcasting Committee of the Church of Ireland takes no view.
Question 11: How many members do you think the BBC Trust needs?
The Broadcasting Committee of the Church of Ireland cares not to suggest a figure beyond noting that the number should be small enough to be workable and large enough to deter lobby pressures.
Question 12: What skills and expertise do you think they need?
The Broadcasting Committee of the Church of Ireland recognizes the need for intelligence, commitment and integrity in the members of the Trust.
Question 13: Are there any particular communities or interest groups that you think the Trust members should represent?
The Broadcasting Committee of the Church of Ireland has already noted the necessity of strong regional representation. With regard to interested participants, it wishes to draw HMG’s attention to the recent formation of an ‘Audience Council’ by RTE, Ireland’s national broadcaster. This Council (very different in nature than the proposed Trust) recruits membership from two groups– the ordinary viewer and listener, and representatives of the ‘social partners’– civil interest groups such as the sporting lobby, the arts lobby, the faith communities, the business community, and the farming lobby.
Question 14: Do you think a ‘window of creative competition’ can be made to work? If not, would you support a raised quota for independent production in BBC television?
The Broadcasting Committee of the Church of Ireland thinks this to be a workable idea. It appears to open up competition while preserving the vertical integration of the BBC.
Question 15: Do you think a voluntary 10% quota for radio is sufficient? Or should the quota be increased or made mandatory?
The Broadcasting Committee of the Church of Ireland believes that a 10% mandatory quota should be established.
Question 16: Do you agree that the BBC should be able to propose changes to its range of services over the course of the next ten years?
The Broadcasting Committee of the Church of Ireland believes so, such is the pace of change to be anticipated in the period of the next Charter.
Question 17: Do you agree with our proposals for handling new services?
The Broadcasting Committee of the Church of Ireland agrees with these proposals which it understands to promote a greater consolidation of approach.
Question 18: How strictly should the BBC’s commercial services be restricted to those businesses that are linked to public purposes and public services?
The Broadcasting Committee of the Church of Ireland believes that the BBC’s creative entrepreneurialism should not be heavily stifled but lightly regulated.
Question 19: Is the existing fair trading commitment a useful addition to the arrangements for regulating the BBC’s commercial services? If not, what option do you prefer?
The Broadcasting Committee of the Church of Ireland would prefer the greatest simplicity in regulation.
Question 20: Do you agree that the case for a plurality of publicly funded broadcasters should be kept under review?
The Broadcasting Committee of the Church of Ireland believes in the plurality of public service broadcasting and is therefore very open to the possibility to the plurality of publicly funded broadcasters. The case of Channel 4 is an important one. We believe that the case for plurality must be kept constantly under review however we also believe that any review must take into account the importance of the scale of the BBC to the delivery of its PSB objectives. We would not wish to see a limited pot of money being distributed ineffectively among a plethora of channels (perhaps in the way that the recent Ofcom ‘PSP’ suggestion might be taken to imply.)
Conclusion
The Broadcasting Committee of the Church of Ireland would like to thank the Department of Culture, Media and Sport for the opportunity to comment which the Review enables. We are delighted to assist in any appropriate way in the future.
The Revd Dr AW McCormack
For and On Behalf of the Broadcasting Committee