Public service broadcasting in the age of video on demand
MG ALBA welcomes the opportunity to make this contribution to the consultation being held by the House of Lords Select Committee on Communications.
Introduction to MG ALBA and BBC ALBA
MG ALBA is short for Meadhanan Gàidhlig Alba (Gaelic Media Scotland) and is the operating name of Seirbheis nam Meadhanan Gàidhlig or the Gaelic Media Service.
MG ALBA’s statutory purpose is set out in section 208, Communications Act 2003:
“to secure that a wide and diverse range of high quality programmes in Gaelic are broadcast or otherwise transmitted so as to be available to persons in Scotland”
“…and a reference to being available to persons in Scotland includes a reference to being available both to persons in Scotland and to others”
Governance oversight of MG ALBA is exercised by Ofcom, who appoint members of the board of MG ALBA subject to the approval of Scottish Ministers.
MG ALBA is funded by the Scottish Government. Since 2014/15, MG ALBA has enjoyed annual funding of £12.8m from the Scottish Government and a total of £2m funding from the UK Government (in 2014/15 and 2015/16). In the year to 31 March 2018, the BBC put a total value of £10.7m on its in-kind contribution to BBC ALBA.
BBC ALBA
MG ALBA funds and operates BBC ALBA (the Gaelic language television channel) in partnership with the BBC. BBC ALBA is the first partnership television service to operate under a BBC licence.
BBC ALBA fulfils the UK’s obligations for Gaelic television under Article 11 of the European Charter for Regional or Minority Languages and is an important part of the Scottish broadcast ecology, commissioning a large proportion of all independently produced TV content in Scotland.
1) What is the value of public service broadcasting? Is the concept becoming outdated? Does public service broadcasting do enough to reflect and serve the demographics of the UK? In answering respondents may wish to consider characteristics such as: a) age, b) gender, c) ethnic background, d) the nations and regions of the UK, e) mental and physical ability, f) ability to pay for services.
Public service broadcasting retains a strong and valuable place in today’s ever-changing media world. As a media organisation representing one of the UK’s autochthonous languages, the PSB model is a unique and highly valuable one, by which both popular programming and social benefit can be generated. That social benefit is immeasurable: PSB content on a national, free-to-air channel is pivotal to the revitalisation of Gaelic. The very existence of a PSB channel signals a status for the language, which continues to be very much under threat. Its content seeks to both reflect the lives of speakers of Scottish Gaelic, young and old, and to normalise Gaelic for non-speakers.
The evidence provided in the Ofcom Public Service Broadcasting Report 2017 strongly supports the contention that there is significant demand from viewing audiences for PSB channels and shows this across a wide variety of demographic groups.
The role of public service broadcasting is especially important for indigenous minority language broadcasting in the UK. The television channel BBC ALBA, which is funded and operated by MG ALBA in partnership with the BBC, is the fulfilment of the UK’s commitment to Article 11 of the European Charter for Regional or Minority Languages in regard to Gaelic television, and in that respect its value for users of Scottish Gaelic in the UK is highly significant. Further, some 10% of the viewing audience in Scotland view BBC ALBA each week, demonstrating that its value is for the whole of the nation beyond the linguistic community.
PSBs provide a well-regulated and high-quality platform for media content. Public service broadcasters do face a significant challenge as to how they currently and will in the future adequately service those audiences who prefer to access content on non-linear platforms, and they should be supported in facing that challenge. Despite the strength of competition from video-on-demand services, they have a strong foundation on which to build given the information provided by Ofcom that “overall, almost eight in ten adults say they are satisfied with PSB”.
2) What are the consequences of the rise of on-demand providers and the decline of linear television viewing for the production of original UK content for UK audiences?
The rise of on-demand providers increases the number of channels for the distribution of original UK-produced content and this could potentially improve the economic health of the UK media production industry. In order to ensure that the original content produced in the UK is viewed by UK audiences, it is imperative that PSBs are supported and given appropriate prominence not only on linear channels but also on non-linear platforms such as on devices with internet access (e.g. smart TVs, smartphones).
The increase in availability of alternative platforms, and the movement of audiences to these other platforms from linear PSBs puts the PSB funding model itself under strain – e.g. fewer willing to pay the licence fee/reduced advertising spend. This in turn undermines the ability to offer the full range of public service content and the function of public service content in informing and educating, as well as entertaining, is at risk. In the case of minority content such as BBC ALBA’s, any diminution of BBC contribution to the service risks undermining Gaelic itself, which is a cultural asset that enriches all of the UK.
With this in mind, the trend of migration of audiences from linear television to non-linear platforms should be monitored closely, particularly to understand any detrimental impacts it might have on the appetite of citizens to pay the Licence Fee or advertisers to promote their products and services on commercial PSB television channels.
One key area to be addressed is how best to ensure appropriate prominence for PSB content on non-linear channels and on devices and technology regularly used by citizens and in UK households. Appropriate prominence will support high consumption levels, which will in turn help sustain the appetite of citizens and advertisers to continue to fund PSB content at current levels.
It is important to note that producers, especially those in the UK, value the trust which UK audiences place in UK PSBs and consequently in their media content. This is equally true for minority language channels such as BBC ALBA where audiences trust the channel to provide high quality content in Scottish Gaelic both on linear television and on non-linear platforms.
3) What has been the effect of changes in the market on the UK television production sector more widely, including on training, job opportunities and the business models of independent producers?
The rise of VOD and decline of PSB linear television viewing risks affecting the supply chain. The VOD platforms currently enjoy very large budgets, which are used to create high impact content, including dramas. These dramas are produced by companies of scale. This forces a concentration of companies to ensure they have the capacity to deliver at the level required by VOD platforms. This concentration alters the ecology of the supply sector – this can have creative and economic consequences. In places like Scotland, which has relatively little drama production capacity, this risks creating a greater polarisation with few companies of scale capable of supplying VODs, and PSBs without the budget to commission drama. The creative economy of Scotland then narrows, representation of all of the UK’s diverse communities by broadcasters and VOD platforms diminishes, and the creative resources on which these broadcasters/platforms depend are in turn reduced.
Where there is inward investment in the form of a large scale production (e.g. Outlander), training and job opportunities are created. It is essential that national arts agencies, such as Creative Scotland, adopt a strategic approach to training support in large-scale production, to ensure that there is a legacy of creative personnel, particularly in the creatively critical roles of directors, writers and actors. In addition, a more collaborative, strategic approach by the PSBs would ensure that nations and regions in particular are diversified in terms of genre spend, so that nations and regions supply sectors are equally primed to benefit from the opportunity to supply VODs.
The scale point is relevant too in terms of development of ideas: in order to generate the many ideas required to supply potential platforms, scale is required. Without the scale to generate commissions, companies can’t create the scale to sustain on going supply of ideas.
4) Are the obligations on public service broadcasters appropriate? Does the regulatory regime allow them to do so?
The obligations on public service broadcasters are appropriate and have proven successful in providing the UK with trusted, well made content. It may be useful to use this opportunity to request that regulatory bodies support PSBs to further their prominence in a crowded market. It may also be of value to suggest that the non-linear platforms now available to view by UK audiences be monitored more appropriately given the huge increase in demand and viewing to provide a fair but competitive market for all broadcasting channels to work with.
5) Have public service broadcasters responded adequately to market changes?
Public Service broadcasters have responded positively to market changes and shown great innovation despite budgets that are smaller than those of many non-PSB brands and organisations. PSBs have led the way in developing “catch-up” services, which has proved very useful in maintaining audience access and confidence, but they must also adapt further to compete adequately with the most successful video-on-demand platforms.
6) How can commercial public service broadcasters fund original productions for UK audiences at a time of declining advertising revenues? How might public service funding regimes—including the BBC licence fee—be adjusted?
The Licence Fee is an effective way to raise revenue to maintain high quality linear PSB television services for the UK as well as the associated video-on-demand platform, the iPlayer.
MG ALBA is clear that it does not support subscription as an option for PSB delivery. Subscription will not enable the BBC to deliver content that provides social benefit as opposed to commercial return.
Funding for public service autochthonous languages such as BBC ALBA should be protected, not least because the UK would otherwise risk being in contravention of its treaty obligations under the European Charter for Regional or Minority Languages (ECRML). As noted, BBC ALBA is the mechanism by which the UK Government implements its international obligations under Article 11 of the ECRML.
7) How important is prominence for public service broadcasters? Can it be maintained in the face of rapid technological development and greater personalisation of content?
PSB prominence in a multiplatform age is critical, and all the more so for minority language broadcasters such as BBC ALBA. BBC ALBA is a remarkable success story: it reaches 60% of the Scottish Gaelic audience, 10% of the national Scottish audience, and has over 75,000 plays on the BBC iPlayer every week. Part of that success is due to the channel’s accessibility: without prominence on the Electronic Programme Guide, the channel, and therefore Gaelic and its associated culture, would not enjoy the improved status it currently does.
That access is important in the context of the importance of future proofing the prominence of public service broadcasting, in particular Gaelic broadcasting.
The ongoing prominence of PSB in general, and Gaelic broadcasting in particular, is very important in the context of connected TVs and increased On Demand viewing. This is because: (i) prominence is an inherent part of the ‘compact’ that underlies public service broadcasting; (ii) there is a particular value to minority language services such as BBC ALBA, because as well as being extraordinarily useful to Gaelic users, prominence affords both access and status: these are powerful tools in the quest to revitalise the language. For MG ALBA, there are significant risks that Scottish Gaelic content, which is of such appeal to audiences beyond the linguistic community, will simply not be discoverable unless mechanisms exist to provide prominence. The financial means to “buy” prominence through home page presence on devices, for example, simply does not exist for us. It is important that PSB content, especially that of minority languages, is given similar prominence on non-linear platforms to the prominence bestowed by PSB status for television.
It is imperative that solutions are found through regulation to future proof prominence of PSBs, including BBC ALBA.
8) Should there be new regulation of on-demand services? Does the revised Audio-visual Media Services Directive provide appropriate measures to ‘level the playing field’? How could on-demand services be encouraged to produce more content in the UK?
In terms of incentivising UK-produced content, tax incentives are a useful lever. Currently High End TV tax relief is an effective incentive, this could be extended by reducing the spend requirement (currently £1m cph) and for example by a regional tax incentive (e.g. to film in economically fragile areas). An indigenous language tax incentive would also be useful and extend further the economic value of existing public funds going into indigenous language broadcasting.
9) What should the relationship be between public service broadcasters and on-demand platforms? What are the risks and opportunities of collaboration, for example in coproduction?
Collaboration through co-commissioning is possible as long as PSBs ensure such co-commissioning does not cannibalise their own offering on channel/Players.
10) What are the implications of ‘Britbox’? Is there scope for more collaboration amongst public service broadcasters? What more could PSBs do to compete with on demand services?
Britbox is a necessary, if belated, attempt to create the scale of offering required by consumers. The PSB players alone do not offer the depth of content required. It ensures a USP around UK-made content. More collaboration among PSBs is likely to be the only way they will survive.
26 April 2019