Organisation (if applicable): Matchlight Limited Additional comments: Matchlight Limited is a Glasgow based TV production company. We produce factual television programmes and series for the BBC, ITV and Channel 4. We are wholly owned and operated from Scotland but the majority of our output is commissioned by and first broadcast upon the UK-wide networks. Recent programmes include: Joan of Arc: Gods Warrior - BBC Two, Spring 2015 Suffragettes Forever! - BBC Two, 8pm BBC Two, 8.00pm Feb & March 2015 Darcey Bussell's Looking for Audrey Hepburn - BBC One, 10.30pm, Dec 2014 Russell Brand: End the Drugs War - BBC Three, 9pm Dec 2014 Matchlight is grateful for the opportunity to submit this paper to the Ofcom PSB review. Question 1: Do you agree with our assessment of the context in which the PSB system operates, and how the trends identified might affect the PSB system? In particular, do you agree with our analysis of the independent production sector: Question 2: Have we identified the key differences in Northern Ireland, Scotland and Wales?: Question 3: Do you agree with our assessment that the PSB system remains strong overall?: Question 4: Given the resources available, to what extent is the system meeting the needs of as wide a range of audiences as practicable?: Question 5: Given the resources available, does the PSB system deliver the right balance of spend and output on programming specifically for audiences in Wales, Scotland and Northern Ireland and programmes reflecting those nations to a UK-wide audience?: While the volume of UK-wide first-run network production made in the nations may have been rising we believe that the cultural and economic impact of this trend has been exaggerated and the public service strategic aim of the quotas subverted by the BBC and - more recently - Channel 4. Much of the increase in output from Scotland has been achieved by displacing elements of the production of programmes devised and developed within the M25 to Scotland. High volume BBC commissions including (for 2013 - the last period for which data has been published) Question Time, Waterloo Road, Eggheads, The National Lottery: In It to Win It and Snooker: The Masters 2013 all counts as "Scottish" but were devised and sold in London by London based producers before elements of their production were outsourced to Scotland. [N.B. C4 has more recently moved elements of the production of the pre-existing format, 15 to One, to Scotland in its first significant example of such displacement.] This outsourcing of elements of production is known as "lift & shift". We would argue that it defeats the strategic, public service purpose behind the Nations quotas as it simply displaces elements of production (as little as 10% of the overall budget in some cases) to Scotland. The crucial commissioning decisions are still "London to London". As much as 50% of the production budget for these "Scottish" projects can still be spent within the M25; stability and growth of the indigenous production sector in Scotland suffers as a result; the PSB purpose of the quotas is subverted and "business as usual" continues. A recent meeting of the Scottish Parliament's Economy, Energy and Tourism Committee considering the Economic Impact of the Creative Industries heard evidence from the BBC on the value of network output from Scotland. The Corporation stated that £90million was spent by the BBC on first-run network production from Scotland in 2013 (the most recent period for which data has been published). 20% was spent on in-house BBC Productions output, the remainder, £72million, on output sourced from "Scottish" independent and non-qualifying producers. The best estimate available for BBC spend on first-run network production via indigenous Scottish production companies - independent and non-qualifying - suggests that no more than £25million (and likely less) was spent with producers genuinely rooted in Scotland (managed and controlled in Scotland, developing ideas from Scotland, retaining IP and profits in Scotland). The rest, circa £45million (likely more) was still spent by the BBC via production companies head quartered within the M25. If the £90million overall network spend figure provided by the BBC represents circa 9% of first-run network spend by the Corporation and around 50% of this total is spent on displaced, lift & shift projects then the BBC's claim to have met its 9% network spend target for Scotland is, at best, undermined. Output can qualify as "Scottish" provided the production company concerned has a "substantive base" in Scotland and as little as 10% of that part of the project budget allocated to production talent is spent on talent who have their usual place of employment in Scotland (provided at least 50% of the total production talent spend is spent outside the M25). This further undermines the "value" calculation. 100% of the cost of production is counted as Scottish but only a small portion of that cost need be spent here while 100% of the profits and IP continue to flow elsewhere. While an element of lift & shift may be justifiable at times we would suggest that an intervention by Ofcom is now required to ensure that a better balance is secured, the public service purpose behind the Scottish quota (and other Nations based quotas) is achieved, diversity of supply maintained and stability in the indigenous production sectors of Scotland, Wales and Northern Ireland delivered. Question 6: Is declining investment affecting the quality of PSB and is it a cause for concern?: Question 7: Do you agree with Ofcom?s provisional findings in the Review of C4C?s delivery of its media content duties?: Question 8: To what extent do you agree with our assessment of the degree to which the non-PSB services play a role in helping to deliver the public service objectives? In doing so please set out your views on the delivery by the PSB portfolio channels, other non-PSB channels, on-demand and internet services and also radio services separately.: Question 9: How likely are we to see steady evolution and have we identified all of the potential alternative scenarios and risks to the system?: Question 10: How might incentives to invest change over time?: Question 11: Have we identified all the relevant ways in which the PSB system might be maintained and strengthened?: Question 12: Does universal availability and the easy discoverability of PSB remain important and how might it be secured in future?: Question 13: Should we explore the possibility of giving greater flexibility to PSB institutions in how they deliver public service content, including examining the scope (in some or all cases) for regulating by institution, not by channel?: No. Question 14: Do the current interventions in relation to the independent production sector need to change in light of industry developments?: Given the desire to ensure diversity of supply we would suggest that whatever else is decided some form of protection - in the form of quotas by volume and value - be provided to truly independent producers. By this we mean those producers with a turnover of less than £20million (individually or aggregated across the group of companies to which they belong) who qualify for independent status. Such companies should continue to operate under the current Terms of Trade. The level of the quota should remain above the European minimum of 10% from the independent sector, ideally at the current 25%. The current arrangement whereby the independent quota for the Channel 3 Licence holders (ITV, UTV and STV) is aggregated and satisfied by ITV's commissioning alone should be ended. Corporately ITV, UTV and STV are separate and they each now operate in distinct "national" markets. Each originates content separately. Each should be required to commission at least the European minimum of 10% of its first run output from the independent sector. Question 15: Have we identified the right options when considering potential new sources of funding, are there other sources of funding which should be considered, and which are most preferable?: .