The Children’s Media Foundation (CMF)

Regulation and Research

Professor Jeanette Steemers of Westminster University attended the Round Table, representing the Voice of the Listener and Viewer

Jeanette takes a fresh look at the round-table discussions in the context of the subsequent publication of the Clementi Review of Governance and Regulation of the BBC...

Culture Secretary John Whittingdale’s invitation on 23rd February to a number of producers and children’s media campaigners to attend a roundtable discussion on the BBC was a useful and rare opportunity to inform politicians of what is at stake for the production of children’s content.  Everyone is in agreement that the funding situation for UK-originated production for children has become very difficult with the virtual exit of commercial PSBs from commissioning in recent years.

So there is merit in persuading the BBC to safeguard funding for UK originated public service children’s content in order to protect a fragile production ecology, but it’s not the job of ministers to specify budgets or percentages.

This observation makes the March 1st publication of Sir David Clementi’s proposals on Governance and Regulation of the BBC all the more interesting, because they give us some idea of how the BBC commitment to children might be handled under a new regulatory regime headed up by Ofcom.  Clementi recommends that Operating Licences (with obligations, quotas and metrics) should  replace the current BBC Service Licences, which have always specified overall budgets and some transmission quotas.  The new Operating Licences would be issued by Ofcom and Clementi suggests there could be just one operating licence for all the BBC’s children’s services.  Yet he also clearly states that the new Operating Licences would not include budgets which are ‘a function of governance’. Setting budgets would remain the responsibility of the new Unitary Board of the BBC - who would need to priorise those budgets to deliver annually against the obligations laid down in the Operating Licences set by Ofcom.

Clementi’s proposal that Operating Licenses cover ‘genres’ such as children’s, rather than channels, offers greater flexibility to incorporate new initiatives with public service value, such as the proposed online portal, IPlay. IPlay meets the demands of an evolving market, and could offer new opportunities to content creators, becoming an important catalyst for innovation, especially with access for third party suppliers and appropriate terms of trade.

The devil of course is in the detail and the degree to which Ofcom would feel minded to intervene if it felt, for example, that obligations had not been delivered because budgets were inadequate.  Another major concern is the extent to which governments will pack the 13-strong unitary board with their own supporters, allowing unprecedented influence on editorial decision-making.  Under Clementi’s proposals only 2 or 3 BBC executives would sit on the Board which sets the editorial direction of the BBC.  Looking at the bigger picture this suggests a less independent  and politicized BBC and that would not be beneficial to the public, including children, at all.

Hardly anyone supports top-slicing of the BBC licence fee to establish a contestable fund, as set out in the Government‘s July 2015 Green Paper, because of the risk of the BBC doing less with less funding, and the uncertainties of establishing a fund without a clear idea of who would administer it and where content would find a home in a rapidly evolving and highly competitive market place.

There is no problem with supply in the children’s sector.  The issue is with demand as other broadcasters (ITV, Channel 4, commercial channels) and new players (Amazon, Netflix) are barely commissioning any new material. If the government wishes commercial PSBs to do more, this will need regulatory intervention, because there is no economic incentive for them to commission what they see as loss-leading content.

If there is consensus that there need to be alternative commissioners to the BBC for the sake of plurality, then there has to be more clarity about how UK children’s content can be sustainably funded in future across a range of platforms – not just broadcasting.   The government has several options for alleviating the funding situation.  A possible revision of Channel 4’s licence is one possibility, but other options (the re-imposition of quotas on ITV; the use of retransmission fees; or the imposition of levies on other players) seem unlikely from a government, which is instinctively deregulatory.

Evidence from other markets suggests that government interventions (quotas and subsidies in Canada, France, Australia, New Zealand) are under pressure in much the same way as in the UK.  The Children’s Media Foundation has proposed a feasibility study into new funding options for UK originated public service content for children. It is crucially important that any such study also researches the broader social and cultural value of UK children’s content, how children are ‘viewing’ content in new ways, and how the content funded by the new system will reach its audience. Any solution for public service children’s content, geared to the UK, needs to be long-term, culturally relevant and capable of reaching significant numbers of children on a wide range of platforms.

Note Professor Jeanette Steemers is currently working on a short study on how locally-produced children’s content is funded, administered and regulated in other countries.  This is supported by the Children’s Media Foundation and will be published in May.

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The Children’s Media Foundation (CMF)