Submission from the International Broadcasting Trust to the DCMS BBC Funding Model Review

Submission from the International Broadcasting Trust to the Communications and Digital Lords Select Committee Inquiry into the Future of News: Impartiality, Trust and Technology

Transparency and accountability in the Media Bill

The Media Bill will allow Public Service Broadcasters (PSBs) to meet their obligations through online video services. We are calling for much greater transparency and accountability.

We believe all PSBs providing online video services in the UK should be required to disclose details about their platform’s algorithm and operating principles to the regulator (Ofcom), in return for PSB status. Algorithmic transparency is essential if Ofcom is to adequately monitor how PSBs prioritise and promote content to audiences through personalised online services.

Towards a digital-first Public Service Media

PSBs are rapidly pursuing ‘digital-first’ strategies that place online video services, such as BBC iPlayer and ITV X, at the heart of their operations. Streaming platforms are no longer simple catch-up services. In today’s on-demand world, they represent the fulcrum of public service media distribution; prioritised for investment, innovation, commissioning and promotion.

New productions are frequently released online first (often weeks ahead of linear schedules) whilst some genres, programmes, and channels are only available online. Even the identities of streaming platforms are fusing with those of the PSBs. For example, the All 4 platform was rebranded as simply Channel 4 in 2023, whilst BBC trailers now urge audiences to “watch on iPlayer” without even mentioning the broadcast channel.

Media Bill accelerates the digital transformation

The Media Bill enables PSBs to further this digital transformation by establishing parity between online video services and traditional linear channels. PSBs will no longer need to broadcast public service content on television channels to meet their obligations. Making programmes available online will be sufficient.

It should be noted that such freedoms do not apply to news and current affairs, which will retain linear-only quotas, suggesting there may be concern within government that public service content will not be prioritised in an on-demand environment.

The Bill obliges PSBs to ensure public service content is ‘readily discoverable and is promoted by the service’ (28/1, 362AA/3b), but this protection only extends to content set out in the revised remit.

The new ‘simplified’ remit excludes many key genres that embrace public service values (international issues, documentary, science, arts, religion, etc.), leaving them unprotected and without the guarantee of being discoverable, let alone promoted.

A lack of transparency and accountability

Linear television channels enable PSBs to offer a balanced diet of content and genres that inform, educate, and entertain their audiences. Programmes covering important social matters are scheduled alongside programmes of mass appeal, helping audiences to encounter new issues, information, and perspectives.

By contrast, online video services use algorithms to provide unique and tailored user experiences; recommending content according to each person’s particular viewing habits and presumed interests.

PSBs may be willing and able to recreate opportunities for serendipity within online services, but the Media Bill establishes no obligations for them to do so.

Critically, the Bill does not give Ofcom the necessary powers to access, understand, and evaluate the algorithms used by PSBs. Unlike linear channels with published schedules, the regulator and wider civil society cannot monitor how content is prioritised, presented and promoted within streaming services.

There is no way to evaluate whether important content is receiving the online equivalent of primetime or being consigned to the virtual graveyard. Without access to the algorithm and operating principles, we cannot know whether the values and principles of public service media are being applied online, or not.

Algorithmic transparency

We believe that algorithmic transparency should be a prerequisite to obtaining PSB status. The Media Bill must include obligations on PSBs to disclose the operating principles behind their online video services, including the algorithms used to determine how content is served to audiences, to Ofcom.

The EU’s Digital Services Act requires large online platforms (search engines, social media sites, etc.) to disclose information about their algorithms to regulators and submit relevant data to independent auditors.

We believe the EU’s approach to ‘algorithmic transparency’ should inform the Media Bill in developing safeguards and appropriate regulation for the online delivery of public service media.

The International Broadcasting Trust (IBT) is proposing an amendment to the Bill requiring algorithmic transparency from all PSBs, and helping protect public service media in a digital-first environment.

Contact IBT

Gareth Benest (Director of Advocacy)

Mark Galloway (Executive Director)

The Media Bill and critically-endangered genres

The Media Bill will negatively impact critically-endangered genres across Public Service Media, including international coverage. Programmes on key global issues may disappear from our televisions unless there is urgent action to amend the legislation.

The International Broadcasting Trust has serious concerns regarding the Media Bill, as introduced to the House of Commons on the 8th November 2023. Our concerns are shared by all members of the Citizens’ Public Service Media Forum, see below.

1. Fighting for space

The Media Bill enables broadcasters to meet their obligations through either online or linear platforms. This leaves open the possibility that broadcasters will bury content that embraces public service values (international issues, documentary, science, arts, religion, politics) within their online services, whilst packing linear schedules with more commercially-viable programmes.

As the same commercial imperatives apply online, content that embraces public service values will face an impossible fight for space, prominence and promotion.

The government clearly recognises the risks as the Media Bill retains linear-only quotas for news and current affairs, presumably because it believes broadcasters would park this criticallyimportant content online, freeing up primetime schedules for commercial content. We are calling for this level of protection for all content that embraces public service values.

2. Transparency and accountability

There is a complete lack of transparency and accountability surrounding the use of algorithms by Public Service Broadcasters. Unlike linear schedules, Ofcom and other observers are unable to monitor how content is prioritised and promoted to audiences within personalised online environments.

It is impossible to know whether the values and principles of public service media are being adequately applied within the online world, which is predicted to grow ever further as the principal means of access.

Online platforms delivering public service media must ensure audiences are exposed to a wide variety of content, including genres that exemplify public service principles, to avoid reinforcing ‘filter bubbles’ and diminishing the societal value of diverse schedules that enable serendipity.

We believe broadcasters should be obliged to disclose their algorithm’s operating principles  how it serves and prioritises different content – to Ofcom, in return for public service status.

3. Oversimplification

We are pleased to see the government has responded to calls from IBT, and others from the Public Service Media Forum, to revisit the oversimplification of the PSB remit.

In its response (17th November 2023) to the CMS Select Committee’s report on the Media Bill, the government confirmed the Bill has been amended to specify that “the range of genres of audiovisual content made available by the public service broadcasters (taken together) constitutes an appropriate range of genres”. This is a significant improvement from the draft remit, which we welcome.

Nevertheless, we insist that genres exemplifying public service media need to be clearly set out in the legislation (as in the Communications Act 2003), and we reject any suggestion this would impede the government’s attempt to ‘streamline’ the remit.

IBT and fellow members of the Public Service Media Forum are calling for the government to take one step further, by including obligations on PSBs to provide education, entertainment, music, arts, science, sports, matters of international significance, religion and specialist interests.

Citizens’ Public Service Media Forum

The Citizens’ Public Service Media Forum is a unique collaboration of organisations dedicated to protecting and maintaining a vibrant and pluralistic public service media system in the UK.

Its members are: Voice of the Listener & Viewer (VLV), Campaign for the Arts, Sandford St Martin Trust, Children’s Media Foundation, Media Reform Coalition, Decentered Media, British Broadcasting Challenge, Grierson Trust, Better Media, and the UK Coalition for Cultural Diversity.

Contact IBT:

Gareth Benest (Director of Advocacy)

Mark Galloway (Executive Director)

Culture, Media and Sport (CMS) Committee Scrutiny of the Draft Media Bill

In this submission, we argue that the Government’s Draft Media Bill threatens the few remaining spaces for international coverage within the Public Service Media system. In particular, removing its obligation to cover ‘matters of international significance and interest’ will disincentivise and discourage outward-looking programme-making that brings the world to UK audiences.

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House of Lords Communications and Digital Select Committee on the future of Channel 4

In this submission, we argue that the Government’s proposal to privatise Channel 4 poses a significant risk to the channel’s commitment international content that is delivered through a range of genres including news and current affairs.

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DCMS consultation on the change of ownership to Channel 4

In this submission, we oppose the Government’s proposal to privatise Channel 4 as we believe that this change of ownership will threaten the channel’s historic commitment to international content, delivered through Channel 4 News, Unreported World and a range of other programmes.

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BBC consultation on BBC3

In this submission, we broadly welcomes the BBC’s proposals to bring back BBC3 as a TV channel. However, we are disappointed that there is no mention in the current proposals of the important role that international current affairs plays in the channel’s output. We strongly recommend that the BBC revises its plans for the channel to make clear its commitment to placing international current affairs at the heart of the schedule.

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Ofcom’s PSB review consultation

IBT considers that the public service broadcasters (PSBs) play an important role in engaging a range of audiences with international content. They have the unique ability to reach mainstream audiences and are a key source of information for all audiences about global events. Now that the UK has left the European Union, there is a real danger that we will become more inward looking as a nation. PSB has a vital role in engaging the UK public with the wider world.

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BBC’s public consultation on the age related licence policy

In this submission we give our support to the continuation of a free television licence for people aged over 75, but we argue that the government should be responsible for financing the licence fee exemption, not the BBC.

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Ofcom review of rules for prominence of public service broadcasters

IBT’s primary concern is that audiences should continue to have access to high quality public service broadcast content which engages them with and informs them about the wider world. IBT supports Parliament’s original intention to provide prominence for high quality public service content in return for responsibilities placed on the Public Service Broadcasters to provide certain types of content.

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Ofcom Children’s Content Review

IBT believes that high quality television which provides British children with an understanding of the world they live in and broadens their horizons towards the wider world is a basic right. (more…)

Ofcom consultation on holding the BBC to account for the delivery of its mission and public purposes

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Full Submission          Executive Summary

IBT proposes that Ofcom should include the volume of non-news international content the BBC broadcasts each year in its Performance Framework. This measurement should include international children’s programmes. Without measuring such content it will not be possible to fully assess the BBC’s delivery of its mission and purposes.

It is worth noting that Ofcom used to measure the volume of non-news PSB international content. Now that Ofcom has taken over regulation of the BBC, IBT believes it should re-introduce tagging of international content for all the PSBs because it is necessary to both assess BBC delivery of such content and to have an understanding of how BBC delivery compares with other public service broadcast provision.

DCMS on Channel 4’s regional impact

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EXECUTIVE SUMMARY

1. Broadcasting in the UK has a crucial role to play in making us aware of what is happening in the world and the UK’s position internationally. There is extensive evidence that engagement with the wider world leads to a more tolerant society which is able to do business with the wider world.
2. IBT members’ concern is with content which engages and informs us about the wider world, therefore we limit our comments in this submission to how the policy proposals under consideration will impact of the delivery of such content.
3. IBT’s research demonstrates that content on television is a dominant source of information about the world outside the UK and that for the past 35 years Channel 4 has played an important role in delivering such content which takes us beyond news headlines and engages us with the lives of people in other countries.
4. As many recent events have shown, our lives have the potential to be profoundly influenced by events and processes at the international level, and not just the local, regional or national levels. Therefore it is crucial that any requirements on Channel 4 to increase its impact in the nations and regions of the UK are balanced with a need to ensure audiences remain fully engaged with events in the wider world.
5. IBT’s primary concern is that C4C should be able to continue to deliver its remit with integrity and invest its surplus in public service content instead of it being diverted by infrastructure projects, such relocating to a base outside London. IBT does not want C4C’s existing operating model to be undermined by any change which might weaken its ability or incentive to provide high quality content which engages us with the wider world.
6. IBT considers that the issue of where Channel 4’s offices are based is a matter for the Channel 4 board and not a matter for government. Channel 4 needs to be able to fulfil its creative vision by being based in the best place to do so and IBT considers that London is the best location for Channel to be based because it is the centre of the creative industries in the UK. Additionally, a move out of London wouldn’t guarantee any extra commissioning for independent production companies outside the South East, which seems to be the Government’s objective, and it wouldn’t guarantee any greater representation of the regions of England and the Nations of the UK on screen.
7. If Channel 4’s quotas for out of London original productions are increased, this will limit Channel 4’s ability to commission the best ideas and deliver its creative vision. Additional regulatory conditions will also impose more compliance requirements on Channel which will divert funds away from production. It is IBT’s view increased nations and out of London quotas will overburden Channel 4 and undermine its ability to deliver its existing remit. Therefore IBT opposes the proposals in this consultation to increase Channel 4’s nations and English regions quotas.
8. IBT considers that the Indie Growth Fund has proved to be a success. It has provided an alternative source of income for C4C and support for small and medium-sized independent production companies. Therefore IBT would not, in principle, be opposed to Channel 4 taking larger stakes in production companies in excess of 25% as long as these were under 49%.
9. IBT believes that if the government decides to increase Channel 4’s out of London or nations quotas, that this policy should also apply to the commercial PSBs otherwise it will put Channel 4 at a commercial disadvantage.

Ofcom on the regulation of the BBC for impartiality and accuracy

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Executive Summary

 

1. IBT’s primary interest is in Purpose 1 of the BBC in the Charter, to provide duly accurate and impartial news and information, which includes factual programmes and Purpose 5 to provide impartial, accurate and fair news for audiences around the world.[1]

 

2. We limit our response to this consultation to the proposal to regulate the BBC for impartiality and accuracy according to Section 5 of the Broadcasting Code.

 

3. IBT has a number of concerns about this consultation which arise as a result of the process by which Ofcom is having to consult on numerous changes required to the regulation and governance model of the BBC. We understand that Ofcom is planning to devise an Operating Framework[2] which will set out the regime for measuring the BBC’s delivery of its purposes and mission. This Framework has not yet been prepared and without knowing whether it will include measures related to impartiality and accuracy additional to the proposals in this consultation, it is difficult to assess the current proposal.
4. The proposal under consultation to limit regulation of the BBC for impartiality and accuracy to broadcast news and impartiality in broadcast programmes on matters of political or industrial controversy and to current public policy represents a significant reduction in the regulation of the BBC. The BBC is currently externally regulated across all content for impartiality and accuracy.
5. While we understand that Section Two of the Broadcasting Code (Harm and Offence), which is being consulted on by Ofcom separately, also provides redress in the case of factual content which is considered harmful because it is materially misleading, this provision does not regulate for impartiality in such content and therefore the current proposal still constitutes significantly less external regulation than exists currently whereby all BBC content is regulated for impartiality and accuracy.

 

6. Broadcasting and online content play a vital role in engaging us with the wider world because they are the main source of information for people in the UK about what is happening in the world. The BBC is the most trusted provider of such content in the world. IBT considers that all BBC such content should continue to be externally regulated for impartiality and accuracy, as it has been since 2006, in order to maintain trust in the BBC and its services.

 

7. Any reduction in the regulation of BBC content for impartiality and accuracy could run counter to the ambition of the Government in the new BBC Charter and Agreement for the BBC to be held to account more robustly for its content standards.[3]

8. IBT would like to know whether Ofcom plans to implement further measures to assess the BBC for the impartiality and accuracy of its output, in addition to the rules in Section 5 of the Broadcasting Code. Such regulation needs to include online content, the World Service and content in genres other than news, such as documentaries, current affairs, children’s, and sport which we consider crucial in delivering the BBC’s Mission and Public Purposes.
9. IBT believes that all BBC content should be regulated for being duly accurate and impartial in order to maintain trust in the BBC across all genres. We understand under the new regulatory model that this responsibility will fall on the BBC board in the first instance and while we do not oppose this model per se, there are no details available as yet on how the board will handle complaints, therefore it is difficult to know how effective it will be. Therefore we support the BBC Trust’s suggestion[4] that Ofcom must be able to consider complaints about editorial standards which result from breaches of the BBC’s Editorial Guidelines across the entirety of the BBC’s output in the UK and abroad.
10. IBT expects Ofcom to propose rigorous methods within the Operating Framework to ensure that all BBC content is assessed for accuracy and impartiality as it has been in the past, otherwise this will represent a significant loss of accountability towards audiences.

 

 

[2] BBC Agreement,  Clause 5 (2), November 2016

[3] Ofcom’s preparations for regulating the BBC, Para 2.2

[4] BBC Trust Response to the DCMS Charter Review Consultation, Technical Annex  F, November 2015, para 52.

House of Lords Communications Committee on the sustainability of Channel 4

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EXECUTIVE SUMMARY

 

1. Broadcasting in the UK has a crucial role to play in making us aware of what is happening in the world and the UK’s position internationally. There is extensive evidence that engagement with the wider world leads to a more tolerant society which is able to do business with the wider world. These wider social benefits of international content which reaches a mass audience are IBT’s primary concern.

 

2. IBT’s research demonstrates that television news and current affairs are the dominant sources of information about the world outside the UK and that, as a result of their focus on wars, conflicts and disasters, UK audiences have a distorted view of the world. This perception needs to be balanced with content which provides us with deeper understanding of the lives of people in other countries and the forces shaping our future.

 

3. For the past 34 years Channel 4 has played an important role in delivering such content which takes us beyond news headlines and engages us with the lives of people in other countries.

 

4. IBT views Channel 4 as an essential element in the broadcasting ecology of the UK. Its cross-subsidy model provides output which reflects a diverse range of alternative voices, as well as voices from around the world.

 

5. IBT believes that C4C’s existing operating model and remit are sustainable for the duration of its current licence which expires on December 31^st We would not want C4C’s existing operating model to be undermined by any change which might weaken its incentives to provide high quality content which engages us with the wider world.

 

 

6. Channel 4 and its portfolio provide a range of content which is distinctively different from the other UK public service broadcasters and which appeals to a different audience. The C4C portfolio of channels is successful at attracting a broad range of viewers, especially those harder to reach groups: 16-34 year olds and the BAME audience.

 

7. IBT agreed with Ofcom’s conclusion that C4C is effectively delivering its media content duties in 2015 and should be financially sustainable during the period of its new licence.

 

8. As things stand, we do not believe that the long term decline in viewing to the main channel undermines the sustainability of C4C. It appears to have reversed this trend in the recent past, which is welcome news, and as long as any future losses in reach are balanced by growth to its portfolio channels, VOD and other services, we believe the corporation will be sustainable.

 

9. Assuming C4C retains adequate commercial and regulatory flexibility so that it can be adaptable, innovative and ground-breaking in this area, we believe it will be well equipped to deal with the challenges posed by new technology and changes in viewing habits.

 

10. IBT does not believe the C4C remit should be either relaxed or tightened. We consider that if there were any relaxation of the remit, as a result of privatisation, this would be detrimental for UK society because it is likely that the most challenging commitments in the remit would be those which are relaxed and it is these which lead to the most ground-breaking, socially valuable and innovative content.

 

11. In light of the role the C4C portfolio plays in delivering C4C’s remit, IBT agrees that it would be sensible to explore whether the current PSB benefits should be extended to apply to the whole of the C4C portfolio, however if this were to happen there should be regular assessments to ensure that C4C maximises the impact of its PSB content and is not allowed to move it onto platforms where it will have less impact.

 

12. IBT is convinced that C4C genuinely strives to deliver its remit and the current regulatory arrangements allow it suitable flexibility to find creative solutions when it appears there is a deficit in its delivery.

 

13. IBT’s primary concern is that C4C should be able to continue to deliver its remit with integrity and invest its surplus in public service content instead of returns being made to shareholders if it were privatised. If C4C were operated as a more commercially driven organisation, the cross-subsidy of loss-making PSB content such as its hour long weeknight news programme or international current affairs would not be commercially viable. It would no longer be able to justify taking risks with its commissioning strategy and its commitment to less popular content, such as international current affairs, would need to be watered down.

 

14. If C4C were privatised it would be inevitable that this would impact negatively on the independent production industry in the UK. There is a significant risk that a private owner of C4C would seek to reduce its costs and maximise its profits by making its own programmes.  Such a move would undermine the existing publisher-broadcaster model which has been hugely successful in both providing a range of public service content for audiences but also in supporting the growth of UK independent production sector over the past 30 years.

 

15. Following research and careful consideration the Government issued C4C with a new licence in 2014 for ten years. IBT believes that the Government should honour this licence and delay any discussions of C4C privatisation until the current licence is due to expire.

Puttnam Inquiry on the future of public service television

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Reflecting a Changing World: The value of television which engages us with the wider world

 

Submission to “A Future for Public Service Television: Content and Platforms in a Digital World” By the International Broadcasting Trust.

 

Introduction

A critical aspect of a functioning democracy is for citizens to be well informed in order to participate effectively in that democracy. One of the most important ways that people are informed is through mainstream media. The International Broadcasting Trust is concerned with the engagement of the UK public as not just UK citizens, but as global citizens. It is our view that television content which informs and interests mass audiences with the world outside the UK should be a key ingredient of public service television.

Those who are already interested in international affairs will be able to find such content on specialist platforms, in newspapers, online and on radio, but television has a unique ability to engage mass audiences which is why it is so important for civic society. IBT believes it should be the right of all citizens to be informed and engaged with international issues through a range of programming on mainstream channels at peak times, not just an elite who seek such content out.

IBT has been conducting research into the nature of international content on UK television since 1989 and the findings in this paper are based on that research. IBT’s research shows that as a result of the increased commercialisation of and competition within the broadcasting sector over the past 25 years, the opportunity for mainstream audiences to be engaged with informative, serious content about the wider world has been significantly reduced. Instead of broadening our horizons, it appears that public service television runs the risk of reinforcing stereotypes and disengaging us from the wider world.

Why international content matters

At a time when the impact of world events has never been felt more strongly, it is clear that it is important that we understand the external forces which are shaping our lives: global conflicts, international politics, emerging economies, climate change, our relationship with Europe, and the level of influence the UK has on the international stage.

If we want to live in a country which is outward-looking, interested in doing business with other countries, wanting to be involved in international debates and policy-making, then as a society we need to be well informed about what is happening in the wider world.

 

Television plays a vital role in engaging us with the wider world because, despite the growth of the internet, it remains the main source of information for people in the UK about what is happening in the world.[1] Content on television about the wider world includes both items in news bulletins but also other longer-form programming, such as factual, children’s, drama and entertainment output which are equally important because they provide a more rounded perspective of the world. If the scope, scale and financial resources of our public television services are reduced, this will lead to a further reduction in the quality and range of content which engages us with events beyond our shores and is likely to lead to a more insular UK society.

 

A narrowing range of content for UK audiences in a globalised world

Since 1989 when IBT and its sister organisation 3WE began conducting research into the coverage of international events on UK TV much has changed, but public service television does not reflect the global evolution of the last three decades.

 

We now live in a world where events in far off countries have a far more direct impact on our lives; companies operate multi-nationally; UK society has become more multi-racial; and the international political landscape is increasingly complex.

 

With increased globalisation, one would assume that public service broadcasters would dedicate more time and effort to engage audiences with international stories because they are more relevant today than ever before, however this is far from the case.

 

Non-News Content:

In 1989 there were 1037 hours of new international output on the four TV channels available in the UK; in 2014 there were 686 hours on the five main PSB channels. This drop is partly ameliorated by provision on the PSB portfolio channels, but these channels attract significantly smaller audiences and therefore have far less impact.

Alongside the reduction in the volume, the nature of international output has changed[2].  Serious factual programmes have been largely replaced by softer factual entertainment genres such as reality series, travel challenges, and property programmes. These programmes, while set in international locations, often foreground Brits abroad rather than engaging us with the country in which they are filmed. While they have a role to play and are popular, often they do not increase our understanding of other countries, other cultures, religions or ways of life.

The number of countries covered by public service television has also decreased[3] and the topics covered in those countries tends to remain the same year in, year out, so that North America, for example, strongly features crime-related programmes, the Middle East is characterised by conflict, and France and Spain focus on property and reality holiday shows.[4] IBT’s 2011 research highlighted the impact of this trend:

 

This research… reveals the extent to which some topics and some parts of the world receive little or no new coverage through factual, drama or entertainment programming. Most notably, new factual programming relating to the Middle East and North Africa was found to be almost entirely absent from UK television in 2010. Algeria, Bahrain, Lebanon, Libya, Oman, Qatar, Saudi Arabia and Yemen were not the principal subject of any factual programme in 2010. So, when popular uprisings took place in this region in 2011, the lack of previous television coverage meant that many people in the UK had little information about this part of the world.[5]

 

News

With the decline in informative international non-news content since 1989, our reliance on news as a primary source of information about the wider world has increased and this has also led to a narrowing of our understanding because news tends to present a view of the world dominated by disease, disaster, corruption and conflict. The international news agenda of the main news bulletins is relatively narrow: they have a strong tendency to cover the same topics, countries and stories and many bulletins reject all but the biggest international news stories.[6] Research in 2001 went as far as suggesting that the “media are engaged in the mass production of social ignorance”[7].and this limited representation of other countries on television effectively means that audiences are misinformed about the wider world because of the low level of explanation and context which is able to be given in a half hour news bulletin.

 

The Current Regulatory Landscape

Channel 4 has a commitment to provide international content in its remit and the BBC Charter includes a global purpose for the BBC to Bring the UK to the world and the world to the UK. Both channels make a significant contribution to our understanding of the wider world and IBT does not want their commitments reduced. We have recommended that both channels should make greater efforts to ensure that they find innovative ways to ensure that more non-news international content is made available to audiences.

ITV and Five’s content commitments in their existing licences are to provide news and current affairs about domestic and international matters without any specification of how much international content they should provide. The 2003 Communications Act includes a requirement on PSBs to broadcast content about ‘matters of international significance’ as a Tier 3 requirement but, along with the other Tier 3 commitments, this has not had a significant impact on their output.

As a result of light-touch regulation and the perceived diminishing value of the benefits of being a public service broadcaster, existing regulation does little to encourage more international content. In a world where discoverability is increasingly a challenge for broadcasters to ensure they maintain audience share, preferential EPG positioning is very valuable and it is IBT’s view that the commercial PSBs should therefore be encouraged to do more to engage audiences with mainstream content about the wider world.

 

The Future landscape – a narrowing choice

As the market becomes increasingly fragmented, competition for viewers will only increase. This trend is likely to mean the volume of less popular content, such as  international documentaries, is likely to diminish while the volume of popular content will increase as platforms try to maximise their income. This in turn will lead to less diversity, a narrower range of content and therefore less choice.

 

While there is much content available online, the reliability and trustworthiness of online information varies because this content is not regulated for accuracy and impartiality, which undermines its public value. And content on commercial channels and platforms is not commissioned with public interest as its motivation, therefore its public value is often less apparent than that produced by public service providers.

 

The move away from linear schedules towards the personalisation of content will also lead to a potential narrowing of choice. This is likely to lead to less serendipity and will mean that viewers will mostly watch content which will reinforce their existing interests and view of the world rather than expand them.

Funding public service television

The current PSB ecology of the UK is highly effective, allowing for a range of funding models for different broadcasters to co-exist and thrive. On the commercial PSB’s international content and other less popular content is effectively cross subsidised by income generated by other more popular genres. This is a crucial aspect of the UK’s successful public service television model whereby content which specifically provides social value but may attract smaller audiences is supported by content which is more popular.

Recommendations

In order to counter current stereotyping of other countries broadcasters need to think about the picture of the world they are presenting to audiences and be encouraged to  broaden our horizons rather than reinforce our preconceptions.

Public service television should be a platform for a range of voices and opinions which reflects the population of the UK and the wider world. This requirement should be reinforced by legislation.

The mixed public service television ecology of the UK should be retained and protected. Channel 4 should remain publicly owned and not for profit and the BBC should continue to be funded by a fee raised equitably across all households.

International content should be a key pillar of public service television, providing a range of programming outside news and current affairs, designed to attract mass audiences and engage them with the wider world. The current commitments in the BBC Charter and Digital Economy Act should be maintained and ITV and Five should be encouraged to find ways in which to engage us with the wider world.

About IBT

The International Broadcasting Trust is a media and education charity which has conducted research for over 25 years into the nature of international content on UK television and radio. IBT is primarily concerned with the engagement of UK citizens as global citizens. For more information visit www.ibt.org.uk.

 

Notes

[1] Television is still the most popular source of information in the UK: 75% of people use TV news as a source of information about world events and 82% of the public rank the most important purpose of broadcasting to inform ourselves and to increase our understanding of the world. (Ofcom) The five main public service broadcasters attract 78% of all viewing and 95% of audiences still watch live or recorded tv. (Ofcom)

[2] Losing Reality (3WE, 2002) pg 1, Reflecting a Changing World (IBT, 2015) pg 5

[3] Reflecting a Changing World (IBT, 2015). 2014-15 69% of new international content was focused on North America and Europe and Oceania (mostly Australia) pg 7.

[4] Reflecting  Changing World (IBT, 2015) pg 8

[5] Outside the Box (IBT,2011), pg 8

[6] The World in Focus (IBT,2009), pg 2

[7] Media coverage of the developing world: audience understanding and interest¹⁶, Glasgow Media Group, May 2001

Department for Culture, Media and Sport on the BBC charter green paper

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Full Submission          Executive Summary

1. IBT’s primary interest is in the existing global purpose of the BBC, To bring the UK to the world and the world to the UK. Television plays a vital role in engaging us with the wider world because, despite the growth of the internet, it remains the main source of information for people in the UK about what is happening in the world. However, it is IBT’s view that this content should not be provided only by news and current affairs which necessarily tend to focus on stories of disaster and conflict; it should also be provided through popular range of content which is engaging and entertaining.

 

2. It is our view that the BBC needs to remain of a scale to be able to effectively deliver its mission. IBT is concerned that if the BBC’s income, currently provided by the licence fee, is undermined further, that it will not be able to produce a sufficient diversity of high quality content which engages us as a nation, for a mass audience across a range of platforms and genres, bringing us together and helping to create a national identity.

 

3. IBT supports the public purposes as a framework for the BBC to deliver its mission: they help focus the BBC strategically and provide a basis upon which to analyse the BBC’s performance.

 

4. While we would like to see both aspects of the global purpose retained in the next Charter, IBT would recommend that there should be a separation of the two aspects of this purpose because the existing purpose is confusing; it involves two completely different tasks and two completely different audiences which are fulfilled by different commissioning teams within the BBC.

 

5. We question the suggestion in the Green Paper that audiences might be better served by a more narrowly-focussed BBC. We cannot see how this would be the case. It is only by being universal that the BBC provides social glue – unifying the population and providing content equally for all. If the BBC loses its universality this will be a precursor to a decline in the quality and quantity of international content available to us because with increased competition for viewers, content which is popular is likely to be prioritised.
6. …………..

The Culture Media and Sport Select Committee on BBC Charter Review

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Final Submission      Longer (orig) Submission

Executive Summary

 

1. IBT’s primary interest is in the existing global purpose of the BBC, To bring the UK to the world and the world to the UK.  Television plays a vital role in engaging us with the wider world because, despite the growth of the internet, it remains the main source of information for people in the UK about what is happening in the world.

 

2. 2. It is our view that the BBC needs to remain of a scale to be able to effectively deliver its mission.

 

3. IBT does not believe there is any convincing evidence that other UK broadcasters are failing financially as a result of the BBC’s over dominance.

 

4. We disagree that audiences might be better served by a more narrowly-focused BBC because this will lead to reduced audience reach and therefore reduced public benefit.

 

5. IBT welcomes the BBC Trust’s work in creating a framework to assess delivery of the BBC’s mission which has included consultation with licence fee payers. We would like this aspect of the Trust’s work to continue during the next Charter.

 

6. IBT believes that in general terms the BBC has the right genre mix across its services, however, we would like to see the BBC work harder to deliver the global purpose across a wider range of genres as is specified in the Charter and not be over-reliant on news, current affairs and documentaries to fulfil this purpose.

 

7. IBT opposes the process whereby the licence fee settlements of December 2010 and July 2015 were negotiated without any public or Parliamentary scrutiny.

 

8. IBT opposes the move to spend licence fee income on projects which do not directly support the delivery of the BBC’s public purposes. In future we would like there to be a statutory process to decide the nature of the BBC Charter and the level of the licence fee which would include full public and Parliamentary scrutiny.

 

9. IBT believes that the licence fee is the best way to fund the BBC for the coming Charter period. We would welcome further research to be conducted by DCMS on the household fee as a model to fund the BBC.

 

10. If it is decided that there is market failure in certain genres or content, IBT agrees it might be desirable to create an independent fund to pay for the provision of such content, but the resources to pay for this should be additional to the licence fee.

 

11. IBT does not see a convincing logic to full or part privatization of BBC Worldwide.

12. IBT’s primary interest is in the existing global purpose of the BBC, To bring the UK to the world and the world to the UK.

 

13. As UK citizens, we have needs, rights and interests in being informed and educated about both our own society and that wider international society of which we are part. This is especially so now that it is readily apparent that events and processes in the wider world have both direct and indirect impact on how we live our lives.

 

14. The current refugee crisis is an example of how we need to be aware of the international political, social and economic drivers at play to fully understand what our role and responsibility should be as a nation.

 

15. Television plays a vital role in informing us because, despite the growth of the internet, it remains the main source of information for people in the UK about what is happening in the world.

 

16. It is our view that the BBC needs to remain of a scale to be able to effectively deliver its mission.

 

17. A longer, more detailed version of this submission is available on the IBT website (www.ibt.org.uk).

The House of Lords communications committee on BBC charter renewal

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Executive Summary

1. IBT’s primary interest is in the existing global purpose of the BBC, To bring the UK to the world and the world to the UK.  Television plays a vital role in engaging us with the wider world because, despite the growth of the internet, it remains the main source of information for people in the UK about what is happening in the world.

2. IBT supports the public purposes as a framework for the BBC to deliver its mission: they help focus the BBC strategically and provide a basis upon which to analyse the BBC’s performance.

3. IBT’s most recent research demonstrates that while international content is in decline on the other main UK channels, the BBC’s delivery of it plays a hugely important role in engaging us with the wider world.

4. While we would like to see both aspects of the existing global purpose retained in the next Charter, IBT would recommend that there should be a separation of the two aspects of this purpose because the existing purpose is confusing; it involves two completely different tasks and two completely different audiences which are fulfilled by different commissioning teams within the BBC.

5. We warmly welcome the BBC Trust’s work in creating a framework to assess delivery of the BBC’s mission which has included consultation with the licence fee payers who fund the BBC.

6. It is our view that the BBC needs to remain of a scale to be able to effectively deliver its mission. IBT is concerned that if the BBC’s income, currently provided by the licence fee, is undermined further beyond the existing cuts it is seeing, that it will not be able to produce a sufficient diversity of such high quality content which engages us as a nation, for a mass audience across a range of platforms and genres, bringing us together and helping to create a national identity.

7. We question the suggestion in the DCMS Green Paper that audiences might be better served by a more narrowly-focused BBC.

8. IBT believes that market failure does not simply refer to whether or not there are other providers in the marketplace; it refers to a situation where regardless of the number of providers in the market, there isn’t a wide range of high quality, diverse and informative programming, especially in genres which may not be considered commercially attractive, such as content which tells us about the wider world.

9. While it can be argued that there is international content which tells us about the wider world on commercial channels and platforms, it is less reliably accurate, and it is not commissioned with public interest as its motivation, therefore its public value is often less apparent than that produced by the BBC.

10. If the BBC does not provide a universal service with a diverse range of content this would increase the democratic divide so that only those who are able or prepared to pay for high quality content about the wider world will do so.

11. IBT opposes the process whereby the licence fee settlements of December 2010 and July 2015 which were conducted hastily, without any public or Parliamentary scrutiny. Both settlements have diverted money from BBC budgets, and have undermined the BBC’s independence from government and its ability to deliver its mission.

12. IBT opposes the move to spend licence fee income on projects which do not directly support the delivery of the BBC’s public purposes. IBT therefore urges that, whatever the outcome of this Charter Review, there should be no more top slicing of the licence fee as part of this Charter Review.

13. IBT believes that the licence fee is the best way to fund the BBC for the coming Charter period although it should include catch up TV. We would welcome further research to be conducted by DCMS on the household fee as a model to fund the BBC.

The BBC Trust on its initial response to the green paper on BBC charter review

IBT RESPONSE TO BBC TRUST’S INITIAL RESPONSE TO THE GOVERNMENT’S GREEN PAPER ON BBC CHARTER REVIEW.

IBT agrees with much of the BBC Trust’s response to the Government’s Green Paper on BBC Charter Review issued in July 2015 with the exception of one point – we strongly disagree with the proposed new wording for the first public purpose, Providing news and information to help people understand the world around them. IBT believes the UK delivery aspect of the current ‘global purpose’, ‘bringing the world to the UK’, should be retained across all genres of programming.

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Ofcom on C4’s Review of its media content duties

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EXECUTIVE SUMMARY

 

1. IBT views Channel 4 as an essential element in the broadcasting ecology of the UK – with a cross-subsidy model which provides output which reflects a diverse range of alternative voices, as well as voices from around the world. C4C’s portfolio provides a variety of content which is distinctively different from the other UK public service broadcasters and which appeals to a wide audience.

 

2. IBT focuses its comments in this submission mostly on C4C’s role in inspiring and informing us with content which tells us about the wider world and the UK’s place in the wider world. This is because IBT’s expertise lies in the provision of international content.

 

3. There is extensive evidence that engagement with the wider world leads to a more tolerant society which is able to do business with the wider world. These wider social benefits of international content which reaches a mass audience are IBT’s primary concern.

 

4. IBT agrees with Ofcom’s conclusion that C4C is effectively delivering its media content duties, although we are concerned by the drop in the volume of international content on C4C services since 2010 and encourage Channel 4 to find new ways to engage the audience with international content.

 

5. IBT supports Channel 4 in the delivery of its public service remit, especially in its commitments to support and stimulate well-informed debate on a wide range of issues, including by providing access to information and views from around the world and by challenging established views and to inspire people to make changes in their lives.

 

6. IBT’s research demonstrates that news and current affairs are the dominant sources of information about the world outside the UK and that, as a result of their focus on wars, conflicts and disasters, UK audiences have a distorted view of the world. This perception needs to be balanced with content which provides us with deeper understanding of the lives of people in other countries and the forces shaping our future.

 

7. During the period of this review C4C has played an important role in delivering such content which takes us beyond news headlines and engages us with the lives of people in other countries, although, as noted above, we are concerned that the volume of such content has dropped on C4C platforms.

 

8. We believe that Channel 4 along with its portfolio channels is successful at attracting a broad range of viewers, especially those harder to reach groups: 16-34 year olds and the BAME audience.

 

9. We note there is evidence that the public are looking for more distinctive, original content and believe that Channel 4 and its portfolio channels play an important role in providing such content.

 

10. IBT believes that C4C’s remit to provide content for older children needs to be reconsidered. We are concerned because there is apparent market failure in provision of UK specific content for this age group, however we question whether C4C is able to deliver such content effectively on its existing broadcast platforms.

 

11. We recognise that in order to remain commercially viable and continue to deliver its remit effectively C4C must maintain its reach and impact across its portfolio of services and believe it is currently achieving this. We would want to see C4C to continue with its current operating model.

Ofcom on PSB Review

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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.

BBC Trust on the Speech Radio Review

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Executive Summary


1. IBT believes that, overall, the BBC’s speech radio services are of high quality and serve a range of audiences well. Their coverage of international stories and issues is generally of a high standard, both in their news output and throughout their schedules. This coverage plays an important role in delivering the purpose of ‘bringing the world to the UK.’


2. Radio 4 has, in recent years, successfully become more internationalist in tone and content. This can be seen particularly in its non-news content. Coverage of the wider world, outside news, plays an important role in providing audiences with a more rounded picture of life in other countries. We commend the efforts that Radio 4 has made in this area in recent years.


3. Radio 5 live covers international breaking news stories with verve and confidence and makes a notable effort to include international experts and news makers.


4. However, we believe that news coverage on the BBC’s speech radio services is too dominated by the big story of the day; space needs to be found for a wider range of stories which better reflect the wider world.


5. We note that there has been a significant change in the tone and content of foreign news coverage as a result of the merger between BBC News and the World Service. We welcome this and we don’t underestimate how difficult it has been to achieve. We congratulate those who have worked hard to achieve this transition.


6. However, whilst there have been efforts made by BBC Radio News to improve the diversity amongst reporters and presenters, we believe that there is still some way to go in addressing this issue in terms of contributors. We would like to see more experts from ethnic minority backgrounds featured across BBC Radio News.

BBC Trust on closure of BBC3 as a broadcast service

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Executive Summary

1. There is extensive evidence that engagement with the wider world leads to a more tolerant society which is able to do business with the wider world. These wider social benefits of international content which reaches a mass audience are IBT’s primary concern when encouraging the BBC to deliver its global purpose.


2. IBT’s research demonstrates that news and current affairs are the dominant sources of information about the world outside the UK and that, as a result of their focus on wars, conflicts and disasters, UK audiences have a distorted view of the world. This perception needs to be balanced with content which provides us with deeper understanding of the lives of people in other countries and the forces shaping our future.


3. BBC Three has played an important role in delivering the BBC’s global purpose for the past 12 years, providing an alternative model of international current affairs and factual programming. Its international current affairs content humanises many of the stories and issues we see on the news.


4. BBC Three attracts a younger audience than any other BBC television channel. This audience should not be deprived of content which is designed to engage them. If the BBC neglects this key sector of the audience, it is likely that they will migrate to other online platforms and any loyalty they had for the BBC will be diminished.


5. There is evidence that the public are looking for more distinctive, original and innovative content. BBC Three is the most distinctively innovative BBC television channel and therefore needs to remain on a broadcast platform which will provide reach and impact.


6. There is extensive evidence to demonstrate that live and recorded viewing is still the most popular means to consume audio visual content. If BBC Three’s content is moved to a primarily online platform it will have significantly less reach and impact than it does currently.


7. The proposals from the BBC Executive do not provide guarantees for the amount of new BBC Three factual and current affairs content or the retransmission of such content in a peak slot on either BBC One or BBC Two.


8. We understand that this proposal will not reduce overall expenditure by the BBC because the savings provided by moving BBC Three from its broadcast platform will be used to bolster other BBC services. IBT believes that the financial benefits which accrue to other BBC services from the closure of BBC Three as a broadcast platform are not significant enough to justify its closure.

BBC Trust service review of BBC One, Two, Three and Four

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EXECUTIVE SUMMARY

 

1. In general terms IBT highly commends the BBC’s performance of its television services: each of the four channels is distinctively different from the others it in its tone and content and has its own personality and they collectively engage audiences across a range of genres.
   
   
2. IBT will focus this submission on delivery of the global purpose, Bringing the UK to the world and the world to the UK. This is because IBT’s expertise lies in the provision of international content which informs us about the wider world.
   
   
3. IBT research has found that the when the global purpose is delivered through News and Current Affairs there is a tendency to focus on negative stories of disaster or misfortune which presents an imbalanced view of the wider world therefore we encourage the BBC to consider ways to ensure that this purpose is delivered across a wide range of different genres.
   
   
4. Our research demonstrates that many viewers who do not watch news and current affairs output are nevertheless interested in international stories in other genres, for example drama, factual entertainment and documentaries.
   
   IBT believes that BBC One and Two especially have an important role to play in helping UK citizens to make sense of the world and to learn about the lives of people in other countries.
   
   
5. It is IBT’s view that since the BBC Trust Review of BBC One, Two and Four in 2009/2010, the BBC’s current affairs strategy has been very successful. IBT believes that international current affairs content on both BBC One and BBC Two has improved significantly since 2009.
   
   
6. Since 2010 IBT has been delighted to see the success of some innovative factual strands on BBC Two, such as the Toughest Place to be a … series and Welcome to…(Lagos etc). We applaud BBC Two commissioners and producers for this output because it exactly addresses the concern we had in 2010 when we last submitted to the Trust on these channels.
   
   
7. With reference to drama which tells us about the wider world we would encourage the BBC Executive and Trust to consider whether there may be missed opportunities here to deliver engaging content about the world outside the UK to a sector of the audience which may not watch news and current affairs. We commend those dramas which have been set in foreign locations but would like to see more of such programming.
   
   
8. Despite recommendations from the BBC Trust following the Review of BBC One in 2009/10 that the channel should be more risk-taking, IBT does not believe that BBC One has become significantly more risk taking and innovation.
   
   
9. Factual entertainment – we would like to see BBC One take more risks and pioneer international factual formats of their own. BBC Two and BBC Three have grown a number of innovative formats which make connections for British viewers with what is happening in other countries and we would like to see BBC One adopt such strategies for its own audiences with engaging, peak time formatted factual entertainment.
   
   
10. As stated in our 2010 submission, IBT would still like to see the BBC One licence amended so that instead of the current wording, under the purpose remit ‘Bringing the UK to the world and the world to the UK’, which reads BBC One should play its part in contributing to this purpose the licence should instead read BBC One should make an important contribution to this purpose. If this change were made we believe it would help focus commissioners’ minds more on the global purpose and BBC One’s role in delivering it, not just in news and current affairs programming. 
    
    
    
    

BBC Trust on Review of News and Current Affairs

 

 

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Executive Summary

1. In general terms IBT commends the BBC for its delivery of news and current affairs.
   
   
2. IBT research demonstrates that BBC News, along with other UK News providers, tends to cover the same, relatively narrow, international agenda in terms of topics, countries and original stories and they adopt a similar treatment and use of pictures to report the biggest international stories. We would like to see the BBC widen its range of stories to include more original journalism and unique stories.
   
   
3. IBT research shows that both the Six O’Clock News and the Ten O’Clock News have maintained the number of stories in their bulletins and the number of countries they cover since 2009 and we welcome this.
   
   
4. However, the amount of air time dedicated to foreign stories on the evening bulletins has decreased.  We would urge the BBC Trust and Executive to investigate this further. One of the defining features of the Ten O’Clock News, in particular, over many years has been its international coverage; if this coverage is now occupying a smaller part of the bulletin on a regular basis, then this is a worrying trend.
   
   
5. IBT welcomes the integration of World Service staff into the main BBC News operation in the hope that this process will lead to an inherently more global perspective in UK news.
   
   
6. IBT would like there to be a greater diversity of voices on BBC News. Our research shows that experts and commentators are the dominant voices in BBC News bulletins and we would like the BBC to provide a range of opinions from people directly involved in a story and not just reflect the consensus of opinion.
   
   
7. IBT would like to see Newsnight provide an alternative source of information to the main bulletin at 10pm on BBC One, rather than primarily providing a platform for discussion of the main stories as covered in the news.  If it is going to cover one of the major stories of the day it needs to add public value to the BBC’s news provision.
   
   
8. IBT congratulates the BBC on its current affairs provision which has improved significantly since the BBC Trust Review of BBC One, Two and Four in 2009. IBT welcomes the strategy to broaden the appeal of current affairs by including both ‘hard’ current affairs (investigations such as Panorama’s Undercover Care) and ‘soft’ current affairs (Simon Reeve’s travel programmes) in its prime time schedule.
   
   
9. On BBC One Panorama is more engaging and the journalism and filmmaking of a higher quality than previously. BBC Two’s strategy to be the channel with the most distinctive international current affairs seems to be working well and we welcome this. And BBC Three continues to be the home of engaging, informative current affairs which provide an alternative to more traditional content in this genre.
   
   
10. We would like to see the strategy to engage a wider audience with a range of different types of current affairs programming which covers a range of subjects and countries to continue and encourage the BBC to do all it can to constantly innovate, question and be risk-taking with its current affairs output.

The CMS Select Committee on the Future of the BBC

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Executive Summary

 

1. IBT would like to see the BBC maintained as a content provider of large scale and scope, publicly owned, funded by the licence fee, which should rise in line with inflation.

 

2. Knowledge and understanding of international and global issues is an essential element of the communications needs, rights and interests of UK citizens. The BBC’s purpose should be to provide services which support these needs and interests.

 

3. All BBC channels and services need to demonstrate clear public service value.

 

4. Only licence-fee funding can guarantee a BBC of sufficient scale and scope. Funding from the licence fee should be protected for use by core BBC services and not diverted to other purposes.

 

5. UK citizens are currently under-served by the mainstream media with international content. The quantity and range of original non-news international programming on the PSB’s has been steadily diminishing and is now at its lowest level since 1989.

Ofcom on the renewal of the Channel 4 licence

 

 

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Executive Summary

1. IBT welcomes the opportunity to respond to this consultation by Ofcom on the
renewal of the Channel 4 Licence.

2. The International Broadcasting Trust (IBT) is a membership-based organisation.
The views in this submission reflect the concerns of IBT’s member agencies
regarding adequate common understanding of the world in which we live. These
concerns are shared by millions of UK supporters of these organisations. Channel
4 has always contributed significantly to UK understanding of the wider world
and is valued by our members.

3. IBT supports Channel 4 in the delivery of its public service remit, especially in its
commitments to support and stimulate well-informed debate on a wide range of
issues, including by providing access to information and views from around the
world and by challenging established views and to inspire people to make changes
in their lives.

4. IBT views Channel 4 as an essential element in the broadcasting ecology of the
UK – providing a platform for a diverse range of alternative voices.

5. IBT welcomes the report by Ofcom prepared for this consultation which usefully
lays out the context of this licence renewal and highlights aspects of Channel 4’s
performance which are relevant to the delivery of its public service remit.

6. IBT agrees with Ofcom’s conclusion that the licence conditions for independent
production, out of London production, originated programming and UK news
and current affairs are appropriate and should remain unchanged.

7. IBT supports Channel 4’s proposal that the out of England production quota
should be set at 9% in 2020.

8. We also support the maintenance of the Schools programming quota at 0.5 hours
per annum.

9. We agree that the term of the new licence should be for ten years.

BBC Trust on the draft Operating Licence for the BBC World Service

 

 

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EXECUTIVE  SUMMARY

• IBT welcomes the opportunity to respond to this BBC Trust consultation and broadly agrees that the draft Operating Licence for the World Service describes the characteristics and other features of the World Service as they currently exist.

 

• IBT endorses much of what is expressed in the accompanying BBC Trust Paper, BBC World Service: a licence fee funded service, especially the commitment to ‘ensure that the distinctive service offered by the World Service is protected and enhanced’.

 

• IBT perceives an inherent contradiction if the BBC World Service is primarily concerned with broadcasting content to audiences outside the UK but is accountable to the BBC Trust which represents UK licence fee payers. We highlight this issue in our submission.

 

• IBT has some concerns about whether the current organisational structure of the BBC is appropriate to ensure that the ethos and programme standards of the World Service are maintained. IBT urges the BBC Trust to ensure there is greater representation of the World Service at top management level within the BBC Executive to ensure its priorities are protected.

 

• While we welcome the availability of World Service content for UK audiences, we would like reassurances that no World Service budget will be spent in increasing UK reach because this is not a primary priority of the World Service.

 

• We suggest a re-drafting for World Service Objectives, Priorities and Targets because it appears that reputation is a more important priority and objective than the accuracy, impartiality and independence of the World Service.

 

• Should the overall governance of the BBC change, IBT would wish to consider ensuing implications for the World Service.
  
  
  

BBC Trust on its review of children’s services and content

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INTRODUCTION

 

IBT congratulates the BBC for its children’s output, as the dominant UK supplier of a varied schedule which includes factual, drama, animation and entertainment for children under 12 years old.

 

The Global Purpose

While IBT recognises that the six public purposes should not be seen as entirely separate aims but as parts of a whole, whose boundaries necessarily overlap, in this submission, we primarily focus on the delivery of the purpose remit, Bringing the UK to the world and the World to the UK (the global purpose) since this is IBT’s area of expertise. We focus on television provision CBBC and CBeebies because, again, this is where our expertise lies and do not address radio or online content.

Ofcom consultation on the Channel 3 and 5 licences

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In response to the request from Ofcom for comments on these proposals, the International Broadcasting Trust submits this paper.

IBT welcomes the fact that Channel 3 and Channel 5 have not proposed any changes to their national and international news and current affairs obligations. We also welcome that no changes have been proposed to the original production or independent production quotas by either channel.

Thus, in answer to Question 1 of the consultation, IBT agrees that the there should be no reduction in the existing obligations on Channel 3 and Channel 5 licensees in respect of national and international news and current affairs, and original productions should be maintained at their current levels. However, IBT would like to propose that Ofcom should monitor the delivery of international current affairs.

Ofcom used to monitor the amount of international content in general but stopped doing so two years ago. We propose that Ofcom should resume measuring the amount of international content – specifically analysing, as an element of this work, the amount of international current affairs. As well as being an explicit obligation in their licences, it is a statutory commitment in the Communications Act (2003), clause 279, that both Channel 3 and Channel 5 provide news and current affairs programmes which deal with international matters.

IBT is concerned that the obligation to broadcast a range of international current affairs programmes isn’t being adequately met at the present time. From recent research it is clear that there has been a decline in the spend on current affairs programming in general and a significant reduction in the amount international current affairs programmes.

House of Lords Communications Committee inquiry into media plurality

 

1. The International Broadcasting Trust (IBT) welcomes this opportunity to respond to the request for evidence from the House of Lords Select Committee on Communications as part of the Committee’s inquiry into Media Plurality.

 

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Executive Summary

 

2. While addressing some of the broader policy questions raised in this call for evidence, IBT’s focus is on the plural provision of broadcast content which tells us about the world outside the UK because this is where IBT’s expertise lies.

3. IBT is concerned by the decline in international content on mainstream UK television since 2005 and wants to ensure that a framework is in place to ensure the public has access to a diverse range of information about the world around them.

4. IBT urges the Communications Committee to consider how to ensure that there is range and diversity of content provided by the public service broadcasters, rather than focus primarily on plurality of supply which doesn’t guarantee plurality of content.

5. IBT believes that all genres should be covered by plurality policy.

6. IBT is concerned by a current failure of plural supply in international current affairs on the commercial PSB’s and this issue needs attention.

7. We wish to emphasise the importance of qualitative as well as quantitative analysis in establishing whether there is a plurality of content available.

8. We agree with Ofcom that there should be a periodic review of media plurality every four or five years.

9. One aspect of plurality which IBT believes needs to be addressed in this inquiry is the wholesale provision of news content.

10. Public service media such as the BBC and Channel 4 should be included in any assessment of media plurality.

11. It is IBT’s view that politicians should be removed from decisions on mergers and plurality. The final decisions in this policy area should be made by an independent media regulatory body such as Ofcom.

BBC Trust on its review of BBC Online and the Red Button Services

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Summary

The International Broadcasting Trust (IBT) welcomes this opportunity to respond to
the BBC Trust’s Review of BBC Online and Red Button services.

Introduction

1. IBT’s response to this review is focused on BBC Online and doesn’t include
any comments on the BBC Red Button service because we have no relevant
research or expertise related to this service.

2. It is IBT’s view that BBC Online broadly fulfils its remit to promote the BBC’s
public purposes by providing innovative and distinctive online content. It
offers UK users greater choice and control over how they consume BBC
content. It also provides potential greater range and depth for audiences than
they would have otherwise.

3. We especially focus our response on the iPlayer because we have research
about the iPlayer and its role in enhancing delivery of the purpose remit of
Bringing the UK to the world and the world to the UK.