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Written evidence submitted by Dr Caitriona Noonan, Senior Lecturer in Media and Communications, Cardiff University


Interest Statement: The opinions expressed in this memorandum are solely those of the author based on her own professional judgment and research expertise.




I am submitting this evidence to the committee as a researcher in the area of television production in small European nations, including Wales. More information about my research can be found at: . This submission draws on my own peer-reviewed research outputs and those of credible third-parties. The submission outlines some context which is relevant to this inquiry before discussing funding, the privatisation of Channel 4, and the future of PSB. It also makes some recommendations to the inquiry.


I thank the committee for the opportunity to submit evidence to this inquiry.


Broadcasting in and from Wales: a brief context


The broadcasting sector in Wales has grown as a result of several strategic interventions including the long-term investment in the independent sector by the UK’s PSBs.  In Wales this structural capacity includes large-scale productions for publicly funded broadcasters such as Doctor Who and His Dark Materials, and mid-sized returning series (e.g. Pobol y Cwm, Casualty). Global successes like His Dark Materials and Y Gwyll/Hinterland are important to the economic growth of the Welsh television industries and the worldwide visibility of Welsh culture, talent and landscapes. Our research also found that while mid-sized dramas and soaps are more likely to be for a domestic audience, they play a vital role in up-skilling workers and giving financial stability to production companies and freelancers (McElroy and Noonan 2016; 2019). This stability is essential in a sector characterised by precarity and inequality. Therefore, it is critical that policy interventions continue to support and maintain a diverse broadcasting capacity in Wales which includes different genres, scale and talent.


The recent experience of the Covid-19 crisis demonstrated how critical the investments from public service broadcasters are within national and regional creative economies. As production ground to a halt, there was a substantial knock-on effect for the freelancers across the UK, including the 40,000 freelancers working in the Welsh creative industries.  Research by Creative Cardiff (2020) reported that 85% of freelancers reported that their work either decreased sharply (25%) or, most commonly, dried up completely (60%) immediately after the announcement of the lockdown. Public funding, via PSBs and arts councils, became a vital and welcomed resource for many companies and freelancers. Rapid and substantial interventions by all the PSBs were a much-needed investment in the sector at a time of crisis and directly contributed to the ongoing recovery of the creative sector. Therefore, a resilient and thriving creative sector in Wales is reliant on policy inventions like well-funded PSBs.


Impact of funding in Wales


The public service funding model has adjusted considerably over the last decade. Portions of the licence fee have been re-directed in support of government priorities including digital switchover, local reporting, and licences for the over 75s, along with the funding of S4C. A robust approach to the future funding of PSBs is essential in terms of cultural diversity, but also it offers tangible economic return. In real terms when taking inflation into account, PSBs are functioning with decreasing resources. This is a trend that can be observed across the EU (EBU 2022). Efficiencies gains have been made by all the UK broadcasters, but these necessitate job losses or cuts to spend on programming and services, both of which have a knock-on effect on the range and diversity of content available to audiences. They also have an impact on the independent sector and on freelance labour market.


Developing an effective on-demand service to compete in the current market is not cost neutral. It requires substantial investment from all PSBs in areas such as securing digital skills and in building the infrastructure for on-demand media. Therefore, PSBs have the responsibility (and additional financial burden) of delivering both high-quality linear and user-friendly on-demand services.  PSBs will have to deliver linear and online services for a considerable period of time, absorbing these as long-term costs. As the experience of Covid19 illustrated, there is immense importance in creating shared and free public spaces which overcome some of the digital inequalities that exist in the UK but, at the same time acknowledging that for some audiences, online services will be their main route to accessing  content. Therefore, the immediate future represents a challenge for PSBs to continue to do even more with even less. 


Financial sustainability within the broadcasting market is needed even more in Wales. Part of this relates to the specific media market in which most people in Wales rely on UK wide media or England-based media to receive their news. This has caused confusion around devolved matters, such as during the pandemic and the local lockdown measures in place (see Cushion and Carbis 2022). In relation to television the importance of the one and only Welsh language television channel, S4C, also needs to be highlighted at every possible opportunity.  It is vitally important that the Welsh language is a visible and vibrant part of the television system in the UK.  Welsh language broadcasting offers Welsh speakers and learners the opportunity to hear Welsh being spoken both formally and informally within a range of contexts and on a day-to-day basis. S4C’s slate of original commissions contributes directly to Wales’ capacity for delivering high-quality drama while offering content that feels uniquely Welsh (e.g. Y Gwyll (Hinterland), Un Bore Mercher (Keeping Faith) and Craith (Hidden)). The unique contribution of S4C to the UK’s creative and social identity, and the challenges it faces in fulfilling that remit, must be taken into account during discussions of funding arrangements. Both policy and public discussion of the licence fee often overlooks both the current funding arrangements for S4C and the BBC’s contribution to Welsh-language services through services like Radio Cymru, Radio Cymru 2 and Cymru Fyw.


Regarding the current system of the licence fee, four of the five biggest TV market in Europe rely predominantly on licence fee revenue (France, Germany, Italy and the UK). This makes the licence fee the main source of PSM income in Europe, even if it is no longer the most widespread (EBU 2022: 11). However, it is right and proper that the suitability of that mode of funding in the current market is considered. Several alternatives have been proposed including: advertising, funding from subscription, government grant, contestable funding, a levy on households, greater financial obligations on SVODs, or a portion of tax. Comprehensively reviewing these options, the House of Commons DCMS inquiry on ‘The Future of Public Service Broadcasting concludes that ‘[n]one of these are sufficiently attractive to justify recommending, for the next Charter period, that they replace the current licence fee model, not least given the disruption and expense of doing so and on balance, the licence fee remains the preferred option for that period’ (2021: 52).


If a new system is built or the current one adjusted, some principles are worth ensuring:

-          That the system is fair: in ensuring that there is a level playing field, all services must contribute, this includes global SVOD services who have relatively free access to the market currently.  Across Europe several member states have chosen to implement a financial obligation on SVOD services in order to deliver parity to the market. As outlined by the European Audiovisual Observatory (2022) some states have opted for a direct contribution to production or rights acquisition, either mandatory or voluntary; others apply a mandatory tax or levy payable to a media fund, either through a contribution to production or rights acquisition, in some cases in addition to a production investment obligation. Any contributions collected in a system like this should be reinvested fairly across the UK’s screen sector, including Wales.

-          That the system is transparent: Negotiations around the setting and revision of any funding are done in an open way in order to maintain trust in the system. This also ensures that audiences and creators in Wales get a voice in the negotiations.

-          That the system is appropriate: That it preserves a competitive and diverse marketplace, in which levers for accountability remain. It should ensure that the gains made through previous policy imperatives (e.g. out of London commissioning, diversity, green production practices) are not lost.

Whatever system may be adopted, it is critical that its impact on Welsh broadcasting is fully accounted for and any necessary adjustments built into the mechanisms for distributing funding.


Impact of the privatisation of Channel 4 on Wales, its audiences and local talent


It is my view that the privatisation of Channel 4 will have an adverse impact on the broadcasting market in the UK, including in Wales. The current public service system in the UK is unique. There is a mixed ecology of providers each bringing a different tone, style and business model to the market.  Combined, they provide a vital group of buyers for television content from independent producers. Combined, they also add to the cultural diversity of television content.


For example, our research into the market for arts programmes concluded there is both cultural and economic need for the large-scale programmes that the BBC provides and the more diverse and irreverent content that Channel 4 provides (Noonan and Genders 2018).  Channel 4’s long-term contributor Grayson Perry and his television Art Club exemplifies some of this difference and also the success possible. 


In Wales the privatisation of Channel 4 could have a negative impact on both local production and representation. The economic dynamics of the screen industries globally and the associated economies of scale needed to compete, means that it is likely that a buyer will have to prioritise less risky and less locally specific content in order to appease their commercial ambitions. The issue will be that smaller production companies, especially those outside of London, could find themselves ‘out in the cold’ as a new owner will prioritise providers that have had substantial commercial success in the past, thereby marginalising the many smaller production companies that make up the Welsh creative sectors. Audiences in Wales are less likely to see themselves and their stories on screen as certain formats, genres and audiences are prioritised.


Channel 4 supports several Welsh indies directly through their spend including Afanti Media, Yeti, Chwarel and Cardiff Productions, who each provide it with innovative programmes and formats. The channel is actively collaborating with S4C to deliver Gogglebocs Cymru in Autumn 2022, which will bring a very recognisable and popular format to Welsh audiences. Channel 4 and S4C have also jointly commissioned the first ever musical adaptation in the Welsh language from Afanti Media and OPRA Cymru. The channel also transmits content which showcases Wales including ‘Wondrous Wales’, a six-part series about the people who live and work in and around Wales’ three National Parks. These collaborations, programmes and investment would be at serious risk within a commercially focused Channel 4.


One of the advantages of the current PSB system is that there are levers of accountability which policymakers and regulators can use to ensure that spend and coverage is at appropriate levels for and in Wales. Whilst I strongly argue in favour of Channel 4 to remain in public hands, it would be advantageous to see some changes which could build on the relocation of parts of the broadcaster to the nations and regions; albeit in the case of Wales, Bristol is our nearest hub:

-          Greater commitment of spend to Welsh indies building further on its previous investments. As Welsh-based indies grow in capacity, the scale of commissions from C4 should keep pace.

-          As part of its relocation plan, Channel 4 emphasised its commitment to education and training in Wales to address talents and skills gaps in the market.  The realisation of that commitment should be examined, and its efficacy evaluated in due course.

-          Further investment in programming should see Wales, Welsh stories and local talent on screen during primetime or in prominent places on its All4 service. Relegating content to off-peak slots or to the edges of content menus, does little to enhance the visibility of Wales within and outside its borders.

It is within the scope of regulatory and policy powers to insist such measures are monitored and reviewed. A commercially owned Channel 4 would have no such responsibilities. 


The Future of PSB


To summarise, local commissioning, public accountability, and structured training opportunities are just some of the ways that PSBs contribute economic value to Wales.  The diversity of content and voices, the provision of local news services and the representation of contemporary life in Wales are some of the ways that PSB contribute to the cultural life within Wales. Through their programming and support of local talent, PSB also contribute to the visibility of Wales and Welsh stories globally. Any changes in the funding of PSBs will have a significant and direct impact on the sustainability of the broadcasting market in Wales. This includes the independent production sector and creative freelancers.


There are several issues facing PSBs in Wales, some of which are summarised here:



Why it needs to be addressed

Possible Solution

Prominence of PSB

Content needs to discoverable in an increasingly busy digital and anglophone marketplace. There is a risk of digital extinction for Welsh culture and language.

Legislation and regulatory interventions as per the Media Bill.

PSB to build digital infrastructures which allows for diversity of content (i.e. a public service algorithim)

Decreased or stagnant funding of PSBs

EBU (2022) research highlights that properly funded PSBs perform better in their markets. Wales’s creative sector benefits directly from the investment of its PSBs.

A funding system is adopted which allows for long-term strategic planning in competitive markets.

Threat of privatisation of C4

As above, C4 makes an important contribution to the economic and cultural sustainability of Wales.

Plans to privatise Channel 4 are scrutinised regarding the specific impact in and on Welsh audiences and talent.

This needs to be done quickly and comprehensively in order to ensure evidence-based policy making.

Audiences are increasingly, though not entirely, migrating to digital services.

High quality linear and digital services are needed to ensure the core principle of universality is protected.

Appropriate funding is required to deliver a dual system.

Regulatory changes are needed (e.g.  to the Public Interest Test) to allow PSBs to compete in a more agile way with online services.


Next Steps

-          A publicly owned Channel 4 to state its commitments to Wales in tangible terms and for these to be evaluated over the next 5 years.

-          That spend on Wales-based productions returns to its pre-pandemic levels from all PSBs.

-          That spend on first-run content for viewers in Wales across all genres and services returns to its pre-pandemic levels.

-          That all PSBs address their training and development commitments in Wales to the specific demographic profile of Wales (e.g. increased access for those from poorer socio-economic backgrounds into broadcasting).

-          BBC fulfils its commitment (Ofcom, 2021: p28) that over the next six years to enhance online personalisation ensuring Welsh language content and content local to Wales is more prominent and easier to access.

-          Prominence of PSB is addressed as per the Media Bill to ensure that content is discoverable in the current marketplace

-          PSBs in Wales lead the way on innovative measures for environmentally sound and socially-just production practices and commissioning requirements as part of their commitments to the Well-being of Future Generations (Wales) Act 2015.




Dr Caitriona Noonan is senior lecturer in Media and Communication in the School of Journalism, Media and Cultural Studies at Cardiff University.  In 2019 her co-authored book Producing British Television Drama: Local Production in a Global Era was published by Palgrave.  Caitriona is currently principal investigator on an AHRC funded project 'Screen Agencies as Cultural Intermediaries', a project that examines the strategies for economic and cultural sustainability adopted by publicly funded screen agencies within small nations ( 








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EBU (2022) Funding of Public Service Media: Public Version.


European Audiovisual Observatory (Cabrera Blázquez F.J., Cappello M., Talavera Milla J., Valais S.), Investing in European works: the obligations on VOD providers, IRIS Plus, Strasbourg, May 2022


McElroy Ruth and Noonan Caitriona (2019) Producing British Television Drama: Local production in a global era. London: Palgrave Macmillan.


McElroy, Ruth and Caitriona Noonan. (2016) ‘Television Drama Production in Small Nations: Mobilities in a Changing Ecology’. Journal of Popular Television 4, 1: 109–127.


Noonan, C. and Genders, A. 2018. Breaking the generic mould?: Grayson Perry, Channel 4 and the production of British arts television. Critical Studies in Television 13(1), pp. 79-95. (10.1177/1749602017746355)


Creative Cardiff (2020) “COVID-19 Self-Employment Income Support Scheme: How will it help creative freelancers in Wales?” 20 April 2020. Available:

Ofcom (2021) Media Nations: Wales.


16 August 2022