Culture Minister Jeremy Hunt’s open letter that kicked off the Communications Review put the entire processes in the context of the Plan for Growth and industry development. The academics who responded basically reject that approach. Some state it bluntly and others demonstrate it less directly throughout their answers, but they are certainly interested in seeing the protection of citizens and consumers, or the public interest, as a larger part of the process.
Right off the bat, academics challenge the assumption that de-regulation is good and desirable, and that it will lead to growth. Steve Barnett rejects it outright, while others, such as Samantha Lay, simply point out that de-regulation should only be one among several options. One of the primary concerns is the potential impact further de-regulation may have on UK media. Lay suggests that it may be harmful to smaller domestic production companies, pushing them out in favour large international corporations. Des Freedman and Natalie Fenton point out that local news provision in particular is already severely at risk and that focusing on de-regulation is a major flaw in policy making.
Plurality in media offerings and media ownership is important to many of the academics responding, all of whom find the current system of the public interest test prior to mergers or buyouts inadequate. In this area there are some concrete suggestions. George Brock wants to see a change in the way public interest in media plurality is measured, and Rachael Crauford-Smith suggests taking the competition commission out of the process and placing full authority with Ofcom. Damian Tambini argues that instead of testing for plurality only when ownership changes, there should be periodic market reviews because dangerous concentrations can develop.
Another concrete change in policy that some of the academics propose is a reversal of the transmission fee arrangement under the ‘must carry’ rules that require PSB to be carried on cable and satellite platforms. I must say that when I moved to London I found it shocking to learn that BBC, ITV, and Channel 4 all pay a transmission fee despite their very large audience shares. Though only a few of the academics mention the issue, those that do, Steve Barnett and Sylvia Harvey among other, adamantly argue that the arrangement does not acknowledge the value of these channels in the market and should be reversed. Multi-channel subscription services should pay BBC or ITV in order to provide them to their customers, not the other way around, a move that could also generate more money to fund UK original content.
Many of the questions posed in Hunt’s letter focused on growth in the UK production sector, such as how to encourage the creative industries and how to increase exports of UK content. Academics seem to have mixed opinions as to the role of the BBC. A few say it is the cornerstone of UK content production and others argue that UK content is only one of several things the BBC should be doing, or that more of the onus of producing UK content should be put on others in the market. One common position that emerges is that intervention and regulation is still needed in order to encourage and protect UK content production. Another is that investing in UK content is not just about growth in the production sector or creative industries, but about ensuring that there is content that meets the needs of citizens in the UK. As Damian Tambini warns, efforts to make UK content more attractive for export should not be done at the expense of the UK public interest.
Several of the respondents see growth in UK content production to be about more just than the major broadcasters and production companies. The gaming industry and online content are also seen as important areas for investment, for which improved infrastructure and, as Samantha Lay points out, revision of educational and vocational training programmes is needed. However, ensuring technical and human capacity is not enough. Alison Powell, Damian Tambini and others argue that upholding the principle of net neutrality is fundamental to encouraging growth and creativity.
Finally, one more point, though not mentioned by everyone, comes across clearly in the academic submissions – the need to invest in media literacy. The Oxford Internet Institute makes the strongest case, but several others also comment, that media literacy is crucial to encouraging investment in broadband infrastructure. The argument seems simple, take up of broadband depends on people’s ability to make use of services and the opportunities it provides. This argument fits in with the general message that seems to come from academia: in the Comms Review the needs of the citizen and consumer, the public, should not be forgotten.