Meeting the digital challenge

A NIACE response to the Ofcom review of public service television broadcasting Phase 2 –

Published: November 2004

1. The National Institute of Adult Continuing Education (NIACE) is pleased to comment on this consultation paper. NIACE works to encourage more and different adults to engage in learning of all kinds. Its functions include research, development and consultancy; advocacy to inform and influence public policy; information services and dissemination; campaigning for, and celebrating the achievements of, adult learners. Established as the British Institute of Adult Education in 1921, it is an independent non-governmental organisation, a registered charity (No. 1002775) and company limited by guarantee (No. 2603322). Its corporate and individual members come from all sectors concerned with adult learning: colleges; local authorities; universities; voluntary and community organisations; churches; broadcasters, employers and unions.

2. NIACE’s broad aim is to advance the interests of adults as learners and as potential learners. Its strategic plan commits the organisation to "support an increase in the total numbers of adults engaged in formal and informal learning in England and Wales; and at the same time to take positive action to improve opportunities and widen access to learning opportunities for those communities underrepresented in current provision".

3. NIACE’s initial views on the first phase of the Public Sector Broadcasting (PSB) review were submitted to Ofcom in January 2004 and can be found on our website. The following comments continue to articulate our perspective as an education-focussed organisation seeking to contribute to a diverse, inclusive, informed and active democratic society.

4. This response focuses on the position of educational programming within public service broadcasting. Education has until now been accepted as one of the three Reithian principles underlying public service broadcasting. Indeed it has been frequently described as its cornerstone. The present debate appears to assume that consumer preference is all-important and that national educational or social needs are less so. Of course public service broadcasting will be taken advantage of through individual preference but its provision should also respond to national social and educational need.

5. We agree with the view (para 2.12) that PSB should in future `be defined in terms of purposes and characteristics, rather than in terms of specific types of programmes or the output of certain institutions’. Indeed, educational programming has always been defined by its purpose! The definitions contained within the Communications Act Clause 264 (6) for public service broadcasting are therefore appropriate in our view, as is the detailed requirement for services to include `what appears to OFCOM to be a suitable quantity and range of programmes on educational matters, of programmes of an educational nature and of other programmes of educational value (264.6.e).

6. We wish to reinforce Ofcom’s point in Annex B18 Page128 that different broadcasters are able to reach a wider range of viewers in different demographic and socio-economic groups. …and different TV channels provide content attractive to different audiences even within the same genres’. This is why we argue for channel-specific requirements not just for commercial companies but also for the BBC.

8. In particular we note that the explicit `educational’ dimension of PSB seems to have been omitted from the reformulation. While Ministers and Parliament have repeatedly reaffirmed the importance of education in broadcasting policy, we note that the word seems to have slipped away in the descriptions given in this document. Other phrases (‘inform’; ‘understanding’; ‘strengthen our cultural identity’; ‘stimulate our interest in and knowledge of’ and ‘make us aware of’) are not, in our opinion, adequate substitutes. Neither is the lone mention of ‘informal learning’ in the second bullet point of 2.12 and A.23. NIACE wishes to see ‘education’ and educational programming firmly reinstated in any definition of PSB by the third phase of the Ofcom review.

9. Whatever definitions may be suggested by consultation respondents, Ofcom must give precedence in interpreting its responsibilities to the terms of the 2003 Communications Act.

10. Much of the Phase 2 discussion has focused on the medium to long term. NIACE is concerned that the immediate short to medium term challenges, which are discussed only in Annexe A, may in fact be neglected in favour of the discussion of later developments. The degree of financial pressure on Channel 4 may be premature. We suggest that OFCOM should not be too proactive in forecasting decline and in reducing some of the protections for existing provision since this, in itself, may pre-empt the future. While newer technologies may have been introduced into the market and take-up of some applications is very fast, the time scales for full-scale adoption are always longer than anticipated. That is why we have always argued for the maintenance of a proper array of educational programming on all existing terrestrial channels until switchover.

11. At some point in the future when multi-channel access is widespread, much educational programming for specific target groups may be delivered on niche channels and sometimes may even use conditional access. However, this will not be adequate for programming aimed at the major purposes of informed citizenship and social inclusion and such issues as health education, basic skills and political and media literacy. Neither will it reach enough older people for well over a decade, if then. Universally available television has to reach people, engage their interest, increase their confidence and `act as a call-bird’ for more specific areas of content. A similar role has to be is played for arts and culture programming. The showcase South Bank Show is a key example.

12. Another important parallel can be drawn between arts and religious programming. Television can take people to places they cannot personally visit. It brings arts performances to those who cannot get to towns or cities, or indeed out of the house. As Bridget Plowden memorably observed when Chair of the IBA:broadcasting is democratic: there are no reserved seats’. It also allows people to participate `virtually’ in religious occasions and observance.

13. Education is not alone in slipping off the agenda because of the new formulation of PSB: The arts and religion are also less visible. The research question reported in Phase 1 about the importance of different components of PSB was related to `specialist educational programming for children and adults’. This is not an adequate question to ask about such a broad area of programming. Most people automatically equate education to schools programmes which are already protected under Tier 2 regulation. Adult and Lifelong Learning is a strategic national priority, covers a much broader canvas and numerically many more people than schools. There are, indeed, more people aged over 60 than under16.

PSB as a whole.

14. We are happy to see recognition of the importance of informal learning within bullet point 2 of the revised purposes but would be concerned if this was to be seen as an alternative to `education’ rather than simply a helpful addition to the more comprehensive provisions set out in the Communications Act.

15. Educational programming is, of course, more or less relevant for different people at different stages of their lives: parenting and skills for young adults, health and leisure activities for older people. Religion is quite a different case: either people are concerned and/or believers or they are not! These audience numbers are never likely to be very large. Arts is yet another case as `the arts’ covers a large number of different creative arts and people are likely to be interested in particular creative arts, but not necessarily all of them.

16. However, in its subsequent analysis, Ofcom then composites a number of different categories of PSB, notably those apparently scoring low in importance, as above, and decides to treat them conceptually as if they form a homogeneous group, equally (ir)relevant to the population as a whole and which can then be treated in the same way. This approach is not justified. Education is an area of purpose-driven programming which is not adequately measured by ratings alone. Audience impact measures and follow-up surveys looking at the overall impact of series which will frequently have a sequential `curriculum’ and a cumulative impact are also necessary.

17. Much of this discussion applies, very importantly to Channel 4, whose educational remit is specifically written into Section 265 3(c) of the Communications Act. The requirement is…makes a significant contribution to meeting the need for the licensed public services to include programmes of an educational nature and other programmes of educational value. This contribution also has to be distinguished from their schools contribution, originally transferred from ITV together with its educational liaison and backup to form 4 Learning and now positioned under Channel 4’s profit-making arm, 4 Ventures. It is branded for the youth market rather than for the full public service range of lifelong learning, Channel 4’s original remit. It is, however, vital that Channel 4 maintains its broad array of on-screen programming for adults as it has done since its inception. Inter alia Channel 4’s educational contribution has provided an important element of competition and stimulus to the BBC.

18. On the matter of plurality of PSB provision (Para 2.14), we agree that it is not a good idea for the BBC to be the only PSB broadcaster: competition from ITV and then Channel 4 had a beneficial effect on the BBC’s PSB output when each came on air. NIACE continues to regret the loss of educational programming from ITV under the 1990 Act. ITV had built up an important network of Community Liaison Officers which allowed the ITV companies to come together with national educational campaigns, as well as backing local and regional programming. In this way ITVs successful campaigns both challenged the BBC to improve and complemented it by reaching different audiences.

19. We are also concerned by the suggestion that regional non-news output is suggested to be cut. Regional companies have been strong supporters of educational programming and have run some of the most memorable `Social Action Campaigns supported by their network of Community Liaison Officers. We note, after all, that much ITV advertising spend is regional which could well benefit by some regionally related programming support.

20. The PSP proposition is an interesting one, but, of course, requires a lot more fleshing out. In particular since educational programming would be likely to be a major stream of content, it is worth noting that such programming requires planning with its audience in mind and a guarantee of appropriate scheduling. It is the guarantee of scheduling that is most likely to be difficult to deliver in a separately commissioned and ratings led scenario. Presumably channels benefiting will required to fulfil appropriate quotas of prescribed provision.

21. Finally, NIACE made many of these points in our response to Ofcom Phase 1, but we have seen little mention of them in the Phase 2 report. We would like to see some recognition of them in Phase 3.

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