Joint Committee on The Draft Communications Bill Appendices to the Minutes of Evidence


Memorandum submitted by 3WE (Third World and Environment Broadcasting Project)

  Theme:  the proposed statutory framework for content regulation, including the definitions of licensable content, broadcasting and public service broadcasting

  Key issue:  the need to include "international" programmes in Tier 3 of the public service remit for broadcasters


  1.  In this submission, 260 voluntary organisations working internationally for sustainable development argue that there is an overwhelming case, both in pubic policy and in the interests of the UK citizen, for non-news factual international TV programmes to form part of the public service mix required of the main five TV channels.

  2.  We urge the Committee to support our proposed amendment to Clause 181.5(e) of the draft Bill, inserting "and international" before "and social issues".

  3.  The broadcasters will not lose by this amendment, but the public will gain.

  4.  Conversely, without such an amendment, UK citizens could be deprived of access, through the media they most use, to high quality information and education about the wider world, which is now "essential to citizenship". TV broadcasters would be free to continue the trends identified in 3WE's research since 1989—decreasing international output and the replacement of "information and education" by entertainment. OFCOM could not invoke serious penalties.

  5.  By supporting this amendment, the Committee would simply return the Government to its promise in the White Paper, to include "international issues" as a Tier 3 "core requirement" for the five main channels.


  6.  3WE (the Third World and Environment Broadcasting Project) is a coalition of leading international development and environment NGOs, including ACTIONAID, CAFOD, CIIR, Christian Aid, Comic Relief, ITDG, International Broadcasting Trust, One World Broadcasting Trust, OXFAM, RSPB, Save the Children, UNA-UK, UNICEF-UK, VSO, and Worldaware. It works for sustained and imaginative coverage of global affairs on UK television.

  7.  This submission is also supported by BOND (the British Overseas NGOs for Development), a network of over 260 NGOs; and by Friends of the Earth.

  8.  3WE was formed in 1989 and has since lobbied government, broadcasters and regulators to ensure that public service television performs adequately against its responsibilities for factual international programming. 3WE has contributed at every stage of consultation on communications reform, starting in 1997.

  9.  From 1989-90 3WE's research project has regularly monitored the level and nature of non-news-and-current-affairs factual programming on international subjects generally, and developing countries specifically, on the five TV channels with pubic service obligations. The most recent published figures, for 1998-99, are found in "Losing Perspective" [IBT, 2000]. Figures for 2000-01 have been researched and are awaiting publication, and some of these are used to inform this evidence.

  10.  3WE is a steering group member of the Public Voice coalition which campaigns for "Communications Reform for All".

  11.  In this submission we deal with the single amendment required to Clause 181.5(e). Other concerns of 3WE about the nature of content regulation and the definition of public service broadcasting will be contained within Public Voice's written evidence to this Committee.


  12.  The draft Communications Bill is an attempt to re-regulate communications services for the age of digital convergence. A key aspect of the convergence era is that a "global information society" is being created, in which we are all citizens. Communications become global; and information exchange becomes a main driver of economics, politics and social interaction.

  13.  It is the express intention of government, by defining public service broadcasting in the Bill, to protect and promote the interests of citizens. Government has previously recognised[75] that in the information age, public service broadcasting is "as important, if not more important than ever before".

  14.  Every aspect of the lives of UK citizens is now intimately affected by events, trends and processes in the wider world. Jobs and livelihoods, environment and security, human rights, health and freedom, are all part of global interdependence. This realisation was given additional impetus by the events of 11 September 2001. As the Prime Minister subsequently noted in his speech to party conference in 2001: "Interdependence defines the new world we live in . . . What is the lesson of the financial markets, climate change, international terrorism, nuclear proliferation or world trade? It is that our self-interest and our mutual interests are today inextricably woven together." To achieve our full potential as citizens, therefore, requires access to high quality "information and education" on the wider world.

  15.  Public service broadcasting is the crucial provider of such knowledge. First, it is charged by parliament with the specific mission, codified in the draft Communications Bill, to provide "information and education" as well as entertainment. Second, it remains the most universally available and most-used service for citizens to access this knowledge. Third, the high quality, universal reach and "impact" of public service broadcasting content is critically important to drive the take-up of related information through other communications platforms.

  16.  For 85 per cent of people in the UK, television remains the primary source of information on developing countries, where the majority of the world's population live[76]. This figure has remained constant since the 1980s[77], despite the subsequent explosion of the Internet and new communications services.

  17.  From the point of view of citizens' interests, therefore, the case for factual international programming is overwhelming. Equally it is overwhelming from the public policy points of view. Government repeatedly argues for the public to recognise and become aware of their place in an interdependent world. In trade, employment and skills, education, environment, international development and foreign affairs the Government has polices which require the informed understanding of the UK public. It has, for example:

    —  ensured that issues of "sustainable development" are covered in all subject areas in the national curriculum for education;

    —  instituted strategies for international development that are dependent on the creation of an informed understanding among the UK public[78]; and

    —  established a documentary fund to enable imaginative TV programmes about developing countries to be researched and developed.

  The government rightly desires that its actions on the world stage be known, understood and debated by the people of the UK.


  18.  3WE recognises and welcomes the requirement in the draft Bill for all five public service channels to provide "comprehensive" news and current affairs, some in peak time, and including news "from around the world". We also welcome the requirement for the Channel 3 news provider to be given adequate investment to make a comprehensive and high quality service possible.

  19.  To strengthen these news requirements, 3WE agrees with the ITC's evidence to the Committee, that the requirement for a "sufficiency of news" in peak-time should be carried into this Bill from the Broadcasting Act 1990.

  20.  However, news snippets alone cannot provide a full, rounded, balanced and educative picture of the wider world. First, news is highly selective, in that it concentrates only on flashpoint events, and is heavily biased towards news from developed countries. Second, "foreign" news is always fighting for its place in the bulletins: since 1997, for example, BBC1 has had a policy of primarily covering domestic news in its Six O'Clock bulletin, while now many BBC journalists are concerned that international news may slip off the Ten O'Clock schedule onto News 24 and the BBC4 bulletin. Third, international news is easily undermined by budgetary restraint, as when the Channel 3 news provider budget was slashed by nine million pounds in 2001. Fourth, in the short snippets provided by news, many people lack understanding even of the basic terms used, such as "occupied territories" or "inflation", as well as lacking the context and explanation for news events[79].

  21.  Developing countries in particular are poorly represented in news. A study of television news content for DfID concluded that "in news output most developing countries were either not covered, or were mentioned only in the context of visits by Westerners, sport, or bizarre/exotic stories"[80] .

  22.  Current affairs programming does provide some further depth and context. However, except on BBC2, there is very little current affairs programming which covers developing countries. In 2000-01, BBC1 provided less than three hours, ITV less than six hours, Channel 4 less than four hours and Channel 5 only one hour of current affairs coverage of developing country stories[81]. (BBC2's "Correspondent" strand provided as many hours of current affairs on developing countries as the other four channels combined.)

  23.  Furthermore current affairs coverage remains reporter-led and news-focused. It does not allow for people from other countries to give direct accounts of their stories, lives and cultures. It does not include issues and processes, which are not suitable to the news agenda.

  24.  International charities and other organisations have therefore long argued for the importance of non-news-and-current-affairs factual programming, capable of explaining things which are not covered in news, of providing greater range and depth of subject, and of allowing people in other countries to explain their own way of life and the challenges they face.

  25.  The public also understands the need for such programming. In a recent survey, 78 per cent of people said our own future security depends on understanding other cultures better; and 55 per cent of people wanted more TV coverage of history, culture and everyday life in developing countries[82].


  26.  Clause 181.5(e) of the draft Bill deals with Tier 3 programming and currently states that the public service broadcasters "(taken together) include what appears to OFCOM to be a suitable quantity and range of programmes on educational matters and dealing with matters of specialist interest, religion and social issues".

  27.  The aims discussed above can be achieved by amending Clause 181.5(e), inserting "and international" before "and social issues". We urge the Committee to adopt this amendment in its report to the Secretary of State.


  28.  The Bill intends to be deregulatory and to devolve responsibility to the broadcasters. Yet at the same time it seeks clearly to benchmark the elements on which their performance will be judged. In this respect there is a balance between deregulation and the public good. Would our amendment affect this balance? Clearly the public can only gain from it, but will the broadcasters be threatened? We believe not.

  29.  In a survey of programme policy makers and commissioning editors for DfID, all stated unanimously that television "still has a role in informing people about the developing world" and that "there is a place on our channel for programmes made in or about the developing world[83]. Thus the channels themselves say they can live with this public service responsibility.

  30.  The BBC will always be expected to provide non-news factual international programming and has the infrastructure, personnel, experience and budgets to do so. It speaks proudly of its record in this regard, and its Director-General, Greg Dyke, recently told 3WE that the BBC should be doing even more. On 22 May 2002 BBC2 announced new commissions to "put foreign affairs at the heart of the schedule". The BBC will not lose from, and can easily live with, the international requirement.

  31.  Channel 4 has the word "international" in the remit encoded in its current licence. In its own submission to the ITC for the current review of that licence, the channel states that its "purpose . . . should include coverage of international and global issues". Channel 4 will not lose from, and can easily live with, the international requirement.

  32.  ITV states that it is a public service and that being one of the most-watched channels "gives us a responsibility to our audience to reflect and debate the world we live in"[84]. Under the regulatory system proposed in the Bill, ITV's individual remit recognises its different role to the BBC and Channel 4, and allows it the space to negotiate with the regulator as to the levels of expected performance against the general remit. ITV will not lose from, and can easily live with, an international requirement.

  33.  Only Channel 5 has stated that "we can't afford to have a public service ideal. We have no obligation to cover development . . ." [85]While 3WE does not find it acceptable that Channel 5 be exempted from the public service requirements, Channel 5 can be comforted by the individual remit provided in the Bill, and by the words "taken together" in Clause 181.5(e)—a clear indicator by the legislators that not all channels would be expected to provide this menu. Therefore Channel 5 can easily live with the suggested amendment.


  34.  The draft Communications Bill is intended to set the regulatory framework for broadcasting until 2014. The "international" amendment is required in order to future-proof the public service remit over that long period.

  35.  Broadcasters and regulators might argue that even if the Bill does not mention "international", the point can be achieved in the setting of licence conditions. 3WE does not regard this as sufficient protection of the public interest. The setting of licence conditions takes place between the regulator and the broadcaster and is not easily influenced by public interest. A relaxed, "hands-off" regulator and a "self-regulating" broadcaster may, at a future licence review, agree that the broadcaster shall not be required to produce international programming.

  36.  Even if licence conditions do mention "international", a broadcaster may decide, at some point within the next 12 years, not to provide such programming. While OFCOM might attempt to intervene, the broadcaster would be able to argue that the regulator could not enforce a type of provision, which is not specified in the legislation.

  37.  If the broadcaster then failed to heed OFCOM directives, OFCOM would be unable to activate the more stringent penalties within its powers, as these apply only to "serious" breaches of the broadcaster's obligations. Obligations not specified in the Bill would be unlikely to count in this category.

  38.  Importantly, there is existing evidence that lighter touch regimes encourage broadcasters to downgrade their commitments specifically in this area; while more specific regulation results in higher levels of programming. That evidence is drawn from 3WE's monitoring research since 1989.

  39.  The Broadcasting Act 1990 brought in a looser regulatory regime for ITV. This in turn affected the "ecology" of public service broadcasting as a whole. Between 1989 and 1999 the amount of non-news factual international programming on Channels 1-4 fell by 42 per cent; and the amount of programming specifically covering developing countries fell by 50 per cent. ITV was the worst offender, cutting its coverage of developing countries by 74 per cent over the decade.

  40.  As a counter-example, tightening regulatory statements in this area encourages broadcasters to fulfil their responsibilities. Channel 4's coverage of developing countries fell by 56 per cent from 1989 to 1999, despite its remit to cater for interests not already covered by other channels. However, towards the end of that period its remit was reviewed by the then Culture Secretary, and the word "international" inserted for the first time. After the regulators were urged to enforce this more closely, both the quantity and quality of Channel 4's commissions rose. In 2000-01 it was again out-performing BBC2 on developing country coverage, and its output included one of the most imaginative pieces of programming on other cultures ever seen on UK TV—the season of peak-time programmes on the Indian festival of Kumbh Mela.

  41.  Unpublished research by 3WE on the year from September 2000 to August 2001 inclusive shows that the overall number of factual programme hours filmed internationally on Channels 1-5 recovered from its 1998-99 low to the more respectable levels of 1996-97. But coverage of developing countries recovered much less.

  42.  More disturbingly, however, within these figures clear trends emerge showing entertainment genres displacing programme categories capable of "informing and educating" people about other countries and cultures. These entertainment genres include: travel programmes; "docu-soaps" typically focusing on Brits abroad; crime and police series mainly set in the US; and so-called "reality TV" game shows. The numbers of programmes touching on the history, politics, conflict and disaster, development, environment and human rights of the majority of the world's population continued to fall—to unprecedented low levels. This expression of the broadcasters' understanding of their responsibilities for what the Bill calls "information and education as well as entertainment" should be of serious concern to legislators, regulators and the public. Without our suggested amendment to Clause 181.5(e), we strongly believe these trends will continue. The amendment refers to "international issues" and therefore makes it more difficult to pass off entertainment programming as an adequate response.


  43.  Finally, would the suggested amendment go beyond the Government's policy objectives in communications reform? The answer is no, and the evidence is in the White Paper, "A New Future for Communications", December 2000.

  44.  The White Paper placed repeated emphasis on the importance of the international element. It stated that public service broadcasting would be expected to: "guarantee the availability of full and balanced information about the world at local, regional and global levels . . . the key foundation of an open, balanced public debate"[5.3.10]

  45.  The White Paper then stated, in a paragraph specifically covering the Tier 3 (non-news) regulatory category, that: "the BBC, S4C, Channel 4, ITV and Channel 5 will continue to be required to produce a mixed and high quality range of programmes, variously including educational material, children's programmes, religious programmes and coverage of arts, science and international issues"[5.8.2]

  46.  The Rt Hon Chris Smith, MP, who as Culture Secretary published the White Paper, has recently written to 3WE[86] about the dropping of the "international issues" requirement, stating: "I agree with you that this is an unfortunate omission—and I cannot imagine it to have been deliberate. I presume you yourselves are raising this with the Joint Committee now examining the Bill?"

  47.  By recommending the adoption of 3WE's suggested amendment, therefore, the Joint Committee would be returning the Government to its original intention and protecting and promoting the interests of citizens.

May 2002

75   Green Paper, 1998. Back

76   Viewing the World, DfID, 2000. Back

77   Harris survey, 1989, found the figure to be 84 per cent. Back

78   DfID White Papers, 1997 and 2000. Back

79   Glasgow Media Group, various. Back

80   "Viewing the World", DfID, 2000. Back

81   3WE, unpublished research for September 2000 to August 2001 inclusive, fully checked with the broadcasters. Back

82   "The Live Aid Legacy". VSO, 2001. Back

83   "Viewing the World", DfID, 2000. Back

84   David Liddiment, Director of Programmes, ITV, in ibid. Back

85   Chris Shaw, Controller, News, Current Affairs and Documentaries, Channel 5 in ibid. Back

86   Private letter, 27 May 2002. Back

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