Realizar el aseguramiento de la calidad

available to other providers to deliver public service content?

Summary

Ring-fencing parts of the licence fee for certain activities undermines the BBC’s independence, and contestable funding would put at risk the level of BBC investment and reduce accountability to the licence fee payer.

Evidence suggests there are better ways to spread the benefits of the licence fee in ways consistent with the BBC’s purposes and leaving the licence fee within the BBC’s control.

Ring-fencing

135Over the three most recent licence fee settlements (2006, 2010, 2015), the BBC has

taken on obligations to fund projects at the Government’s behest. Some, like helping fund the digital switchover help scheme, have had a direct link with the BBC’s own mission or Public Purposes. Others however, such as the roll-out of broadband or helping fund Local TV stations, have been Government projects with little or no link to the BBC and the arrangements have muddled accountability for delivery and value for money. Furthermore, taking on these projects or accepting any other form of Government funding has proved to be problematic for the BBC – drawing it into the Government Spending Review in 2010 and the Budget in 2015.

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Case study: Local TV

As part of the 2010 licence fee settlement the BBC was required to help with the Government's policy of establishing local TV channels by making up to £25 million

available to build a local television multiplex and up to £5 million a year from 2014-15 to acquire content. This means that by the end of this Charter period, up to £40 million of licence fee payers’ money will have been spent on local TV. In 2012, Ofcom licensed a private company to build and operate the multiplex, and the BBC has paid a grant to that company (from licence fee payers’ money) to fund its construction. To date Ofcom has licensed 34 local TV channels to operate on that multiplex, although only 20 stations are actually operating at present.

Local TV has multiple stakeholders and interested parties but no single body responsible for ensuring its success, and no clear accountability back to the licence fee payers who are paying for it. In effect, it is a Government policy which falls to be implemented by a combination of Ofcom, the BBC Executive and the BBC Trust, and the individual

companies licensed to provide the multiplex and the channels. The Trust was given objectives such as ensuring value-for-money and benefits to local communities but was not set up to administer grants and has been reliant on indirect controls (such as scrutiny of applications for grant, and audit rights) to try and ensure that the licence fee is

properly and efficiently spent. Thus, the BBC does not determine overall policy; nor does it either manage or regulate the companies that are directly responsible for spending licence fee payers’ money.

136The agreement for the licence fee to fund local TV ends in 2017. We also welcome the

decision to phase out licence fee funding for its broadband programme, but are concerned by the Government’s suggestion that it might want to ‘protect’ or ring- fence a proportion of licence fee funding in future. This applies both to projects outside the BBC but also any sense that the Government or any body other than the BBC (except possibly its regulator) would ring-fence the BBC’s spending on certain types of programmes or content – it is a critical plank of the BBC’s independence that such decisions are made by the BBC itself.

Contestable funding

137We also have some significant concerns about the idea of a contestable pot of funding

from the licence fee that any broadcaster can bid for to provide programming in particular areas - on both principle and practicality; not least as experience shows that creative and editorial decisions are best left to editorial and creative leaders, as

opposed to technocratic committees. Of course, it is difficult to comment with

precision or test this concept with audiences in the absence of a specific proposal, and our efforts to do so found no clear consensus among audiences, although in

qualitative research groups there was a degree of concern and confusion about how any contestable fund would be implemented, who would take the decisions and

whether there would be damage to the BBC and the quality of its output44_.

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138Indeed, the Green Paper itself highlights many of the pitfalls with contestable funding.

It would add uncertainty to the BBC’s funding and be costly and bureaucratic to administer. These risks are highlighted by Ofcom’s statutory review of the Public

Service Broadcasting system, published in July45_{, which highlights challenges of}

“uncertainty of funding, undue bureaucracy in implementation, reducing the actual funding of PSB content” amongst others to be resolved. It is also not clear what demand there would be from other broadcasters given that such output would still be funded by the licence fee: audiences would expect it to abide by the same editorial standards as content shown on the BBC, would expect it to be high-quality and distinctive, and those that acquired contestable funding would need to be able to demonstrate its value for money to licence fee payers. Finally, given the BBC’s

broader funding constraints there are risks that taking money away for such purposes would not necessarily increase the overall funding for a particular genre. In summary, and basing our judgement on research, we do not believe contestable funding would benefit licence fee payers.

An alternative approach to top-slicing

139The Government may feel there is a need to specify funding protections for certain

services or genres. If implemented, we would consider this to be a very concerning step towards editorial interference. There are, moreover, ways to achieve this while leaving decisions about the spending of the licence fee within the BBC’s control and retaining direct accountability to licence fee payers. We believe that this latter point is of paramount importance in the stewardship of licence fee payers’ money.

140In the past interventions have been made so that more of the licence fee is used to

support the wider creative economy. For example, the introduction of guarantees for levels of spend for independent production companies, and the window of creative competition, were interventions which diverted the licence fee into the creative economy, promoting competition for the best creative ideas while keeping financial control and accountability within the BBC and benefiting audiences. Similarly, another emerging example is the BBC’s proposal around local journalism, which it announced

in September46_{, and we are now consulting on}47_{, and which has been developed to fit}

within such a framework. We believe that this type of approach – where the BBC is given a clear mandate to achieve a certain outcome that is in keeping with its own business and Public Purposes – could conceivably work without compromising the BBC’s accountability or independence. However, we would want to consider the merits of any such proposals, including gathering licence fee payers’ views, on a case-by- case basis.

45 _{Ofcom, Public Service Broadcasting in the Internet Age, July 2015 (paragraph 6.15.4)} 46_{https://downloads.bbc.co.uk/aboutthebbc/reports/pdf/futureofthebbc2015.pdf} 47_{https://consultations.external.bbc.co.uk/bbc/future-ideas/}

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Q13 Has the BBC been doing enough to deliver value for