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 1989decreasing 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.
ABOUT 3WE AND
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
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
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
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
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.
This figure has remained constant since the 1980s,
despite the subsequent explosion of the Internet and new communications
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;
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.
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"
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
(BBC2's "Correspondent" strand provided as many hours
of current affairs on developing countries as the other four channels
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.
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.
Thus the channels themselves say they can live with this public
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".
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
33. Only Channel 5 has stated that "we
can't afford to have a public service ideal. We have no obligation
to cover development . . ." 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
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 TVthe 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
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 fallto 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
46. The Rt Hon Chris Smith, MP, who as Culture
Secretary published the White Paper, has recently written to 3WE
about the dropping of the "international issues" requirement,
stating: "I agree with you that this is an unfortunate omissionand
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.
75 Green Paper, 1998. Back
Viewing the World, DfID, 2000. Back
Harris survey, 1989, found the figure to be 84 per cent. Back
DfID White Papers, 1997 and 2000. Back
Glasgow Media Group, various. Back
"Viewing the World", DfID, 2000. Back
3WE, unpublished research for September 2000 to August 2001 inclusive,
fully checked with the broadcasters. Back
"The Live Aid Legacy". VSO, 2001. Back
"Viewing the World", DfID, 2000. Back
David Liddiment, Director of Programmes, ITV, in ibid. Back
Chris Shaw, Controller, News, Current Affairs and Documentaries,
Channel 5 in ibid. Back
Private letter, 27 May 2002. Back