Memorandum submitted by the Institute of Welsh Affairs (BW 9)

1. We greatly welcome the Committee's decision to inquire into the present state and future prospects for English language television in Wales, since there are grounds for considerable concern about the current and future decline of English language television made for the Welsh audience.

2. We believe that this represents a major cultural crisis for Wales, and have addressed the issue in a publication - English is a Welsh Language: Television's crisis in Wales - in which 17 contributors have set out a range of issues related to the English language service as a whole as well as the importance of particular programme genres. It will be published on 15 April 2009.

3. We have appended to this short note the introductory chapter written by our chairman, Geraint Talfan Davies, who has edited the volume. This chapter expands on the issues we raise here. A copy of the book will be sent to the committee in the week beginning 6 April 2009. We have also submitted a copy of the IWA's audit of Welsh media, commissioned by the Welsh Assembly Government early in 2008 - Media in Wales: Serving Public Values.

4. The capacity of television to reflect Welsh society back to itself is being severely diminished, and will diminish further unless government action is taken. There is a danger that, in the words of one contributor, a 'mantle of invisibility' is about to be cast over Wales in terms of its presence on television This process is entirely at odds with the current needs of Wales.

5. The IWA has welcomed many parts of both Ofcom's final report on its review of public service broadcasting and Lord Carter's Interim report on Digital Britain. However, we have very serious reservations about its relegation of general programming in the English language to an optional provision to be decided' in the light of competing priorities'.

News services

6. We note that both documents recognise that the case for securing an alternative news service to the BBC within Wales has been made, and that this can be secured by a combination of partnership arrangements between broadcasters and possible third parties, and additional public funding.

7. Partnership arrangements alone will not be enough to secure the quality of news service that Wales needs to serve the developing Welsh polity.

8. The uncertainty surrounding the future of ITV as well as ITV Wales's position as a cost centre within ITV plc, leads us to believe that the best way of securing the news service is through an open contestable process, with ITV simply guaranteeing the slots for transmission. This would provide for much greater transparency. Such a process could also be applied to a wider range of programmes.

9. The proposal put forward by S4C for tendering a news service to be broadcast on ITV Wales has considerable merit. However, S4C's parallel proposal to dispense with the Welsh language news service provided by BBC Wales could have serious implications for English language television. The latter proposal should be considered not simply in the context of news provision but in terms of its impact on whole ecology of Welsh broadcasting.

General programming

10. We regret that both documents - Ofcom and Carter - have created a false hierarchy between news and general programming made for the Welsh audience. News programming is not the only necessary, or even the truest reflection of our society, given the fundamental changes in the Welsh polity that have come about in the last decade.

11. Pluralism is not defined simply by securing two suppliers. The object of pluralism in broadcasting is to guarantee a range of expression. That is done not only by having more than one supplier, but also by guaranteeing a variety of programme form and purpose.

12. Even within the journalistic function greater range of expression is guaranteed by the existence, parallel with television news, of well-resourced current affairs programmes and well-resourced radio journalism than by merely proliferating television news programmes - programmes that can too often seem cloned.

13. True pluralism of expression expands exponentially if it is extended beyond journalism to dramatists, documentary makers, comedians, satirists and artists of all kinds.

14. Public support for this wider kind of pluralism is also necessary to ensure a more equitable dispensation for both the Welsh-speaking and majority anglophone audience in Wales. No arrangements for news provision should be agreed that would have any direct or indirect effect on either Welsh language or English language general programming.

15. We support the view of the Welsh Assembly Government's Broadcasting Advisory Group about the importance of enlarging the volume and range of general programming in the English language in Wales. We agree with its conclusion that "the current English language provision in these areas is not a defensible provision for a developed national community that brings to the table the sort of cultural legacy that Wales commands." Even the current inadequate provision is threatened both by ITV's withdrawal and from regional programming and financial cuts at BBC Wales.

Funding

16. Within the totality of funding - public funding and advertising - for public service channels across the UK, which now amounts to not far short of £3bn., we do not believe that the funding support sought by the Assembly Government - c. £50m - is an unreasonable amount to counter-balance the culturally homogenous 20 channels provided by the four UK public service television broadcasters.

Governance

17. We support proposals put forward both by the Assembly Government and by Ofcom's own Advisory Council for Wales for the establishment of a Wales Media Commission. We would, however, go one stage further. We believe that such a commission should operate on a bilingual and multi-media basis, allowing for contestable funding across the whole range of media activity outside the BBC. It would subsume the S4C Authority.

18. We believe that this approach would be in line with the Assembly Government's policies on bilingualism, would avoid duplicating functions, would provide a critical mass of expertise within one organisation, and be an economical and flexible way of managing media development in Wales in a period of technological change. It would also allow for a holistic approach to the needs of both linguistic communities within Wales.

19. This need not jeopardise in any way the Welsh language service on S4C. The channel's programme funding could still be ring-fenced, even while providing a healthier separation of the management of the channel from the S4C Authority's regulatory functions.

20. The establishment of such a commission would give Wales a much stronger decision-making capacity in the media field while still operating within a UK framework.

Radio

21. We are yet to be convinced that conditions can be created that would justify the migration of all radio in Wales to DAB. There is a need for a review of radio in Wales that takes full account of our topography, as well as the small scale and fragmented nature of the Welsh market. Successive reviews of the radio scene at the UK level have so far failed to do this.

Broadband

22. We welcome the proposal in the Digital Britain interim report for the creation of a universal service obligation for broadband delivery. While recognising that the universal provision of a 2Mbs service may be practical starting point, we note that the report foresees that much faster speeds will be essential to preserve the UK's competitiveness. In that context the competitiveness of all parts of the UK must be secured as technology develops.

March 2009