Written evidence submitted by the BBC DCMS Committee inquiry – The future of public service broadcasting Introduction The BBC exists to serve all audiences. Paid for and owned by the British public, the BBC is a universal service – as everyone pays, everyone gets something in return. 91% of UK adults use the BBC every week and this rose to 94% in March during the COVID-19 pandemic.1 On a single day – when the Prime Minister announced the lockdown – close to 45m UK adults came to the BBC. No other public service in the UK can reach that many people at one moment. The BBC’s universal, public service mission has proved more important than ever in the COVID-19 crisis. The BBC has informed, educated and entertained the nation during this time of need, as it has for nearly 100 years. We have delivered trusted news to millions in the UK and worldwide – Ofcom research at the start of lockdown shows that 83% of people trust coverage on BBC TV.2 We have ensured every child in the UK can follow their nation’s curriculum. And we’ve kept the UK entertained, brought people together and supported the wider industry. It will take time to emerge from the challenges the country faces, but the BBC is uniquely placed to help lead Britain through the challenges caused by COVID-19. We support creative economies all over the country and will help accelerate getting TV, radio and digital production back on its feet. The current crisis has highlighted the unique role of the UK’s public service broadcasters. While other providers (e.g. global streaming services) also contribute to consumer choice, their offer and the scale of their investment in the UK is fundamentally different. The public service broadcasters have an unequivocal commitment to the UK, a range, breadth and quality of services and universal mission that is unmatched by other providers. Audiences agree – despite the explosion in choice, the concept of public service broadcasting retains large scale public support. The UK’s public service broadcasters are the engine rooms of the nation’s creative success. PSBs’ £2.6bn investment in the UK delivered 32,000 hours of original, home-grown content last year – compared to just over 210 hours of UK-produced content on Netflix and Amazon Prime. The BBC is the single biggest investor in UK content and has production bases across the UK, including in Cardiff, Glasgow and Salford. PSBs investment in the UK is long-term. In contrast, The Crown’s producer Andy Harries asked “how quickly do you think Netflix or, indeed, Amazon will roll back the spend in the UK if the world changes?”3 1 Usage peaked at 94% week beginning 16 March 2020 as social distancing began. Source: Ipsos MORI, BARB, BARB Establishment Survey, RAJAR, Adobe Digital Analytics (DAx) 2 Populus for Ofcom, 2,232 UK online adults (Ofcom Coronavirus Survey, week 1, 27-29 March 2020) https://www.ofcom.org.uk/__data/assets/pdf_file/0031/193747/covid-19-news-consumption-week-one-findings.pdf 3 Evidence given to the House of Lords Communications Committee inquiry, Public service broadcasting in the age of video on demand: http://data.parliament.uk/writtenevidence/committeeevidence.svc/evidencedocument/communications-and-digital-committee/public- service-broadcasting-in-the-age-of-video-on-demand/oral/102660.html PSBs make a vital contribution to the UK’s culture, society and democracy. Culturally, the BBC is one of Britain’s strongest brands, reaching almost 430m people globally every week, investing in UK content and bringing the nation together in shared moments such as the VE Day commemorations. Socially, the impact of PSBs is more apparent than ever, with the BBC’s The Big Night In raising over £70m for those affected by COVID-19 and BBC Local Radio supporting communities through the floods and the pandemic. And democratically, record numbers are turning to the BBC news offer for the accurate, impartial and trusted news they need to navigate current events. For PSBs to continue to thrive and serve all audiences in the face of changed viewing habits, it is vital they have the right regulatory and financial environment. We ask the Committee to support changes to: Ensure recommended updates to prominence legislation are enacted without further delay to cover the ways people are accessing TV content today; Consider how similar regulation might benefit the UK’s news providers and how global tech players might be encouraged to help combat disinformation for example by giving greater prominence to news apps and other news products from the UK’s PSBs and other trusted quality news providers; Recommend legislation so that PSB channels and players are included (or ‘carried’) on all major content distribution platforms; Recommend changes to the listed events regime to ensure that UK audiences can continue to enjoy the “crown jewels of sports” on universally available services from the UK PSBs – including free-to-view digital services; Strengthen Ofcom’s duties to support public service broadcasting and public value; and Modernise the PSB and BBC regulatory regime to enable them to operate successfully in a fast-paced online, on-demand marketplace rather than a slower broadcast linear one. While the Committee does not ask in depth about funding, we also argue that stable, universal funding is the bedrock upon which PSBs’ success has been built. If we want the BBC to continue to be a universal service, dedicated to serving all UK audiences, this should be the foundation for any funding model. Looking ahead, the digital age strengthens the case for a strong PSB system. In a digital world awash with misinformation and disinformation, citizens need trusted, impartial news about the UK and the world. In an increasingly global marketplace, British audiences want programmes and services about their lives and their culture. And in difficult times, it’s never been more important to reflect, represent and invest in every part of the UK. We set out more detailed comments below in line with the areas of interest outlined in the Committee’s call for evidence. Regulation - Are the current regulations and obligations placed on PSBs, in return for benefits such as prominence and public funding, proportionate? - What (if any regulation) should be introduced for SVoDs and other streaming services? We agree that to deliver for the UK, PSBs should receive benefits and be regulated in return. In the broadcast world, this balance has driven a virtuous cycle of near-universal reach, funding and a high level of investment in UK content. This has made the UK a world-leading creative hub and incentivised others to invest here. We believe these benefits are worth sustaining in the digital age. But, the current regulations and obligations placed on PSBs, as well as regulatory benefits like prominence are rooted in the past. They require modernisation so they are proportionate and fit for a digital age. We also wonder whether Ofcom’s duties to support the PSB system in the UK should be strengthened particularly taking in to account their public value and the role they play to deliver benefits across the UK culturally and economically. Public value can sometimes be undervalued in the broader consideration of how markets work and the positive additional benefits the PSBs can bring to the UK media ecology compared to purely commercial organisations should be recognised. The PSB system has created a more dynamic and competitive environment for broadcasting and media than is seen elsewhere around the globe. For example, where the BBC takes risks, invests in new talent both in front of and behind the camera or microphone, the wider industry benefits. Similarly, the BBC’s promotion of niche interests creates new audiences and de-risks investment by others which benefits the UK economy. Finally, the PSB system stimulates competition for quality by investing in high quality, British content that shapes and expands consumers’ demand and encourages the industry to respond in innovative ways. Strengthened duties should require Ofcom to create the right regulatory and market conditions to ensure the benefits of PSB are being delivered. This could be similar to postal services where Ofcom has a duty to secure the provision of a universal service. Currently Ofcom’s duties extend only to “having regard” for delivering “the purposes of public service television broadcasting.” Given the strategic, cultural and export importance of public service broadcasting to the UK and given that the PSBs are the primary way in which the “purposes of public service television broadcasting in the UK” are met these duties should be strengthened. Modernising BBC regulation The BBC’s regulatory environment, and that for other PSBs, is to a large extent left over from a linear era. In the past, many argued that the BBC occupied too big a place in the market; that regulation was necessary to promote proper competition. Today the BBC faces increasing competition from all sides. Many of the harms the BBC’s regulatory framework was intended to guard against are no longer relevant. The issues it seeks to remedy do not reflect the realities of the global, digital age. The licence fee enables the BBC to deliver public and wider economic value to the UK. The aim of regulating the BBC is to strike the right balance between protecting the BBC’s ability to deliver this public value and fulfil our PSB mission, while ensuring that the licence fee does not mean we are restricting competition. Instead, regulation has in some cases been a break on innovation and competition. Netflix CEO Reed Hastings described regulation as “the best protector of Netflix in the world”, citing the decision to stop Project Kangaroo.4 The BBC is regulated as if its work harms competition but, far from stifling competition, the BBC forces competitors to raise the bar.