Written evidence submitted by Together TV

The Future of Public Service Broadcasting

The Digital, Culture, Media and Sport Committee

1. Executive Summary

1.1 As Public Service Broadcasting reaches its centenary we should recognize, value and invest in its contribution to the UK’s societal, cultural and economic life, being an exemplar in news, creativity, culture, community impact, learning, innovation and informing the public – in the UK and globally.

1.2 The concept of public service broadcasting is still highly valuable and valued by the 95%+ of the UK population who engage with PSB content weekly, and the function of public service broadcasting remains a vital public good that we should treasure and invest in growing.

1.3 The regulatory framework is a compact that provides guaranteed prominence and distribution for the PSBs in return for obligations regarding public purposes – needs to be strengthened and redrawn for the new decade to put more emphasis on digital content and prominence, local to global impact, and to enable the PSBs to innovate and compete with agility. Commercial SVOD should be included in the regulatory framework. Free to air TV and PSB prominence on TV and SVOD should be ensured in return for content obligations.

1.4 Representation: A new PSB settlement should ensure that representation across content, staff, suppliers and audiences should be objective for the PSBs. The PSBs should have a clear remit to widen their reach to younger audiences, to be an inclusive resource to all UK citizens, across, and representing our nations, regions and localities.

1.5 Accessibility: It is essential that everyone in the UK – regardless of income, geography or age – has access to universal and free news and public service content. Until there is free universal broadband to every home the current TV distribution platforms should remain in place. Ability to pay should not disenfranchise viewers from accessing PSB content on any platform.

1.6 Impact: Public service content, delivered via broadcast and digital, inspires societal, cultural, economic and behavioural positive impact, at a time when other public services are under enormous strain. We should do more not less of this do drive social impact through our public service channels, supporting them with prominence on TV and on SVOD.

1.7 Looking ahead: Each PSB faces constraints strategically (obligations, market impact, ownership, scale), and we need them to have the scale and resources to survive the massive structural shifts and changes to the competitive landscape over the coming decade. They should play an ongoing vital role in our societal, cultural and economic structures. We need to reframe how the PSBs deliver their purposes, how this can be done effectively, and expand the definitions of PSB content and services to new platforms, technologies and consumption patterns. The PSBs need a regulatory framework that can enable them to swiftly compete. Supporting this delivery we must consider overhauling organizational structures to remain competitive and viable. Bold thinking is required for the PSBs to remain champions of UK news, arts, lives and culture and communities into the 2030s.

2. About Together TV

2.1 Together TV is the UK’s leading broadcaster for social change, inspiring people to make positive change in their lives and communities. Launched in 2000 as the Community Channel, Together TV is watched by 4 million unique viewers a month; our Facebook page reaches 2 million a month. We show entertaining content that focusses on wellbeing and creativity. We champion

diverse voices, and communities. We open our audience’s eyes to opportunities around them and motivate them to take part. 2.2 As a result of watching, our viewers change attitudes, gain confidence and do more for themselves and their community, from volunteering for a charity to getting involved in a creative project, from fundraising for a cause close to their , to getting help and support.

2.3 During lockdown, as with the PSBs, our audiences increased significantly, and we were able to help isolated and vulnerable people across the UK, connecting people with local community support via our broadcast, telephone, text and online channels.

2.4 We are the world’s only national channel run as a charitable organization and owned by its supporters. We have worked in partnership with the PSBs, platform operators, commercial channel groups and news publishers throughout our history. We partner with broadcasters and charities to add reach and impact to their social action campaigns. The PSBs and platform operators are on our board of trustees.

2.5 The wider media and digital industry provide donated bandwidth and carriage, namely Sky, Arqiva for Freeview, and , along with content, marketing and expertise from the BBC, ITV, , Discovery, Sky, Viacom, Facebook, and print newspaper groups.

2.6 We recognise the value that universal and free public service media delivers to the national fabric of UK life - culturally, economically and democratically, and argue that the UK should treasure and invest in public service broadcasting to grow both its impact and sustainability at a local, regional, national and global level.

3. Regulation

3.1 The concept of public service broadcasting is still highly valuable and valued by the 95%+ of the population who engage with PSB content weekly, and the function of public service broadcasting remains a vital public good even as the mechanisms for distributing and accessing it changes. Regulation, statutory and regulatory obligations have been and remain key to delivering impact and reach for PSB.

3.2 The regulatory framework for the PSBs has remained stable and subject to incremental changes since the last Communications Act, with the major change being the BBC being brought under Ofcom regulation. The interests of citizens have been largely balanced with those of the consumer, though there has been a disappointing weakening of obligations on local TV broadcasting.

3.3 This framework – the compact that provides guaranteed prominence and distribution for the PSBs in return for obligations regarding public purposes – needs to be strengthened and redrawn for the new decade to put more emphasis on digital content and prominence, without losing the balance and ecology between citizen and consumer, and to ensure the commercial non-PSB media and SVOD platforms do not unfairly disadvantage our valued PSBs.

3.4 New commercial entrants have benefitted the public as media consumption has increased and new entrants have created and addressed new audience habits. However new platforms have also brought misinformation, fake news and declining trust. In times of crisis people go back to trusted news sources, and in this recent time of crisis viewers, including 16-34s, have (temporarily) gone back to the PSBs who have been reporting on and reflecting the UK back to viewers.

3.5 The value of prominence cannot be underestimated. Prominence and distribution are huge drivers of linear audiences, and top-page EPG prominence helps deliver substantial in-built audiences. The EPG has been the ‘shop window’ for TV channels for the last twenty years. This must continue for at least another decade until all UK citizens have access to adequate and affordable broadband.

3.6 The new shop windows are the home pages of BBC iPlayer, the other catch-up services, SVOD platforms and new devices (e.g. Amazon Fire, Chromecast, AppleTV, smart TV app stores). Discoverability within these services determines how well content performs and strengthening PSB prominence across on-demand apps should be supported and enabled.

3.7 A priority for PBSs is for the public to recognize that they create unique, distinctive programming, take creative risks and support British talent and wider social wellbeing. If this investment, both financially and creatively, loses all brand attribution for the broadcaster then it becomes harder to justify the BBC licence fee and wider PSB.

3.8 SVOD services should be brought under the Ofcom Code to ensure requirements around fairness, impartiality and due accuracy for current affairs, investigative or news content. This would require a UK licencing regime as some may fall outside of jurisdiction. Beyond this there are areas of divergence that need to be addressed, largely around content labelling and discovery, and potentially commercial references (e.g. product placement).

4. Representation

4.1 There have been some clear steps to address the London-centric nature of the PSBs over the last 15 years, with major production centres moving to other UK cities, increasing wider representation of UK citizens, which we welcome. We would like to see further investment in local content creation, production and reporting.

4.2 We would not want any changes in the PSB model to reduce commitments to regional bases, regional content, local radio and local news, including digital and social media content. An increased emphasis on partnership between PSBs and content creators could increase representation of the UK’s diverse communities across all ages.

4.3 Many commercial new entrants in online news publishing have struggled to find workable business models and are being sold off cheaply, having their valuations written down massively, retrenching or folding – and the legacy news players seem to have found a path through this.

4.4 There is an opportunity to reimagine local news provision in the coming decade, with opportunities in radio, smart speakers, podcasts, streaming services and addressable TV.

4.5 The broadcasters, PSB and commercial, acknowledge they have a long way to go to truly represent the UK’s diverse communities both on-screen/air and in the workforce. Digital I’s Mind the Viewing Gap report from 2017 shows how BAME viewers are underserved by the PSBs and are not watching as much as white viewers. Likewise representation of people with disabilities should be stronger.

4.6 In the new PSB settlement audience diversity and inclusion should become a new objective for the PSBs. They are here for the whole UK but not serving all our communities.

5. Accessibility

5.1 It is essential that everyone in the UK – regardless of income, geography or age – has access to universal and free news and public service content. Until there is free universal high quality (1gb) broadband in every home it is likely that the current TV distribution platforms – DTT, DSat and DCab – will need to remain in place. Ability to pay should not disenfranchise viewers from accessing news, national sporting and cultural live events, local content and major television series that shape the national conversation.

5.2 We argue for a long-term commitment to Freeview / DTT as the main free TV platform. A future of universal access to IP-streamed channel delivery is still a decade away and will require a huge ‘digital switchover’ to get all homes a) able to access affordable broadband, some at low or no cost and b) owning an IP-enabled, connected set top box or TV set.

5.3 Universality of access is key for our social, democratic and educational aspirations – as important as access to our roads and rail, to our schools, hospitals and town halls. We have seen the ‘news deserts’ in towns and rural areas in the USA, the huge swathes of American inner-city areas without access to broadband. We have seen what happens in countries that do not invest in the ‘public good’ – whole layers of the population lose access to health care, participation in sport and the arts, and crucially access to the range of content that all UK citizens can currently access through this unique combination of the licence fee, commercially-funded PSBs, universally

accessible broadcast television, PSB obligations, and content that delivers public service through a wide range of genres.

5.4 Until this point we believe the UK government should support the free TV offer, to protect consumer choice, sustain media literacy, reflect our communities and nations, and ensure that the public can access plurality of opinions and views. 6. Impact

6.1 There are clear benefits from the PSB ecology in terms of national GVA to UK GDP, along with huge cultural and societal value. The economic case for PSB investment in content is well made by PACT, describing the PSB system as a large R&D lab for Independent Producers to try out new ideas and formats, which leads to international licencing and sales.

6.2 The cultural impact of the PSBs across our nations and regions is enormous, and reaching increasingly wider audience across age, class, background and geography. The societal and economic benefits of a strong cultural and creative PSB tradition are proven.

6.3 Societal benefits of the PSBs run across all their content, whether the obvious impact of news, sport, food, health, information, and democracy through to the more sophisticated behaviour change civic movements. The impact of the major event-based content has been ground-breaking in attitudinal and behaviour change. Public service content, delivered via broadcast and digital, inspires societal, cultural, economic and behavioural positive impact, at a time when other public services are under enormous strain. We should do more not less of this do drive social impact through our public service channels, supporting them with prominence on TV and on SVOD.

6.4 The public broadcasters also provide a projection of cultural and soft power around the world through programming and international services (including the World Service) and commercialization of UK-originated intellectual property. As Britain finds its new role in the world, the halo effect of this cultural can help secure inward investment (e.g. into production, technology), tourism (e.g. the Peaky Blinders / Game of Thrones effect) and trade, alongside wider societal and cultural values.

6.5 The PSBs can uniquely bring local, national, UK-wide and global communities together to create impact, through a unique competing ecology to entertain, inform, educate - and engage. Without Channel 4, BBC 2, 3 and 4 would not have become so innovative and cutting edge. The PSBs in turn drive the commercial channels to innovate in content that drives positive social impact. We lose this impact at our peril. We need to measure and evaluate the impact of the PSBs and do more, not less, of what works at an economic, cultural and societal level.

7. Looking Ahead 7.1 There is a limit to how successful the PSBs can be even with their strongest content, solid digital products, great user experience and extensive marketing. They fundamentally lack scale versus the new entrants and have limited strategic options available around ownership, consolidation and have regulatory constraints on launching new services.

7.2 There are few levers available to fund original productions – one is around finance (co-production models, further deficit/debt financing) and another is to reduce the number of original productions to focus on fewer, more high-profile / HETV titles that deliver longer-term value and IP. This would be offset by repeating new series more in the schedule, recent content repeating more in the schedule or moving out of original content for acquired content in some day-parts. Another option would be to revise the BBC and ITV Terms of Trade tilting back towards broadcasters so that PSBs take a stronger rights position. Netflix and the US TV/cable networks take aggressive rights positions to the detriment of the production companies, so changes to the Terms of Trade could be damaging to the independent production sector and international sales/format exports.

7.3 Collaboration between PSBs is possible and has been shown through several joint ventures and consortia. The regulatory and competition framework will need to reframe the market tests used to assess these kinds of collaboration. SVOD services straddle what was DVD/Home Entertainment and the TV market. Ofcom and the CMA should be open to increased collaboration by the PSBs.

7.4 With additional investment in local commissioning, production, and local independent production, the PSBs can return to being an economic catalyst for cities, towns and rural areas across the

UK, reinforcing their relevance to communities, civil society, cultural, educational, sporting and democratic infrastructure. Diverse journalists and content makers can learn and hone their creative, production and digital skills in communities while starting new creative businesses to regenerate urban and rural areas, and drive engagement, accountability and a sense of value for PSB.

7.5 The PSBs already have a great track-record of partnership – with independent producers, cultural, arts and sports, with each other and with commercial partners. We would argue that this could go much further still, at a local level to directly involve a much higher proportion of the population, particularly young people, in creating public service content at regional and national levels. The PSBs should have an ambition to engage with local business, arts and sports organisations, with entrepreneurs and social entrepreneurs, with community groups and charities, town halls and local courts.

7.6 The PSBs, together, can build on their unique ecology of partnership to create even stronger valued brand positioning with UK citizens, even stronger economic value across our four nations, and be a driver for public wellbeing – in physical and mental health, education and entrepreneurship, culture and creativity.

7.7 As the BBC’s Centenary approaches we should reclaim public service broadcasting as a national good. We should treasure and shout about our PSB story, and invest in re-positioning it, in the same way we re-positioned the Olympics and Paralympics in 2012, against all odds, and regenerated our museums, galleries, and parks. We should revitalise the UK’s unique mix of creativity, entrepreneurial spirit and public service to ensure the PSBs are at the heart of our culture, our social purpose, our wellbeing and our future.

7.8 If serious steps are to be taken then Ofcom and DCMS need to initiate a wide-ranging review of the PSB model, ultimately make their commitments viable for this new reality. This could include  supporting high-quality news output, local content and live events that drive distinctiveness  revisiting the Terms of Trade to make them work for both broadcasters and producers  commitments to reverse declining programming budgets across the PSBs (potentially by reducing commitments to serve many genres thinly, loosening commercial advertising constraints, encouraging new forms of programme financing and co-productions)  reorienting PSB commissioning to include bigger, better HETV to compete with SVODs  increasing resource in reaching audiences on new digital/social platforms and invest in audience acquisition / marketing needed to compete  shifting from a linear-first to digital-first approach by default to build for the future  exploring how the BBC can refine its organisational structure to unify activities split across divisions and to enable better partnerships with external organisations.

Thank you for reading our submission, we hope it contributes usefully to this important consultation.

Caroline Diehl Executive Chair

Alexander Kann Chief Executive Together TV