CMF Action: Consulting on the Contestable Fund
This month the CMF authored a formal response to the DCMS consultation on the Public Service Broadcasting Contestable Fund. It was based on discussions with the CMF Board and Executive group, and opinions expressed at a public event held by the CMF on February 2nd.
The DCMS is proposing a Fund of £60m spread over 2 - 3 years, and potentially aimed at a number of genres and audiences, such as children's arts, religion, diversity and regional. The aim is to in part replace funding lost when commercial public service broadcasters (ITV, C4 and Five) retreated from what had previously been mandatory inclusion of some of these genres.
Deregulation in the 2003 Broadcasting Act, reflecting the decreasing value of the "gifted spectrum" which underpinned the commercial PSB's public service status, meant that the range of content offered in key genres such as children's diminished significantly.
The proposed Fund aims to redress this.
Clearly the CMF's aim is to maximise the benefit of the fund to the children's audience, especially under-served groups such as older children. We also stressed the need to create a future-proofed Fund, and not focus solely on broadcasting or broadcasters. We are concerned that after the three year pilot is completed, if the Fund is successful, then future financing might be taken by "top-slicing" the Licence Fee. This makes no sense since what we want to see is more money in the system, not the same money diluted.
Key points from our response:
- The CMF believes the £60m Fund should focus solely on the children's audience. Our reasoning - the pilot needs to be kept simple for ease of assessment, so a single category approach will help. The children's genre suffers most from market failure - the low value and regulation of advertising in the children's sector being the primary cause.
- The other genres listed in the proposal such as coverage of arts, diversity and regional matters could be reflected in the children's content supported by the Fund.
- Audio and interactive content should feature.
- There should not be restrictions on which operators, in broadcasting or VoD, could take the content but it should be free at the point of access on at least one platform.
- New market conditions require a completely new framework for the public service nature of the Fund - hence the suggested inclusion of operators, such as Netflix or Sky Kids outside the free to air spectrum.
- The consultation names the commercial public service channels (ITV, C4 and Five) and YouTube as potential partners. But YouTube should not be considered the only answer for VoD delivery.
- Projects could be co-financed by a range of partners, with the producer putting together deals similar to those in the international market – though aimed at domestic product. Content could then be "windowed" on pay platforms with subsequent windows on free-to-air.
- A Public Service Platform for kids should be considered - a possible extension of the BBC's recent iPlay concept, opening it up to public service content financed or part-financed by the Fund.
- If the Fund is to invest in content alongside broadcasters and VoD platforms, rather than top up funding after the broadcaster commitment is clear, then it will need to have a commissioning function, though this will add to running costs. To mitigate this we suggest the creation of a new children's commissioning unit within the overall administrative backup of the BFI.
- After the pilot, the Fund's future finance should not be taken from the Licence Fee, but from a mix of sources, including general taxation, platform profits (e.g. retransmission fees), levies on non-participating commercial PSB's, levies on platform providers such as YouTube and Netflix and the Lottery Cultural Fund.
CMF has been campaigning for a dedicated Children's Fund since 2011. Despite our reservations about the size and concerns about its administration, we are confident that if it is dedicated to the children's audience, it will provide them with greater range, variety and competitive plurality, contributing to the well-being of British children and young people, while also stimulating the UK’s creative economy.
You can read the full consultation response on our website.