English is a Welsh Language

In the golden years of ITV’s monopoly regional broadcasting was its crucial distinguishing feature but, despite the rhetoric, not its primary commercial driver. The juicy financial fruits of the monopoly masked the intrinsic tension between public service and the commercial imperative. For 10 of the 15 companies – the smaller ones – what they made was not what they sold. They made programmes, they sold advertising. Regional broadcasting was little commented upon by the commentariat, either within the trade press or further afield, even though the 15 ITV companies consumed large quantities of food and wine nursing their regional groups of MPs and bored journalists. This would usually come to a head during the passage of successive Broadcasting Bills, as well-briefed peers and MPs rose to extol the virtues of their home patch and its television company, in the process signing up to a coalition of support for the company’s next franchise beauty contest run by the Independent Broadcasting Authority.

This began to unravel in the late 1980s, as advertising took its first downward turn for a decade and as Margaret Thatcher resolved to reform what she called ‘the last bastion of restrictive practice’. By this time the first siren voices calling for consolidation of ITV network into fewer companies had begun to be heard, giving the Thatcher government, perhaps inadvertently, the green light to swing the pendulum decisively away from public service towards the commercial imperative by auctioning the ITV franchises. The minister at the time, David Mellor, invented a fig leaf called the ‘quality threshold’ but the genie was out of the bottle, public service was henceforth to be on the back foot. The resulting auction payments – HTV had to pay £21m annually for its licence – comprised the largest tax on knowledge since the newspaper taxes of the nineteenth century. Thatcher had, at a stroke, weakened ITV at the very moment that it needed all its strength to face competition from Sky and the birth of multi-channel television. Regional broadcasting was to be the biggest casualty.

In Wales although the programming made specifically for the Welsh audience by HTV rose to its all-time peak of 12 hours per week by the late 1990s, costs were driven down. While much of this was a necessary efficiency gain that took advantage of new technologies, there is little doubt that it also placed a severe curb on programme ambition. There was no room for millennial euphoria. Soon some budgets were reduced to a level at which several independent companies decided that commissions were not were the candle. In one inadvertently poignant series two presenters introduced clips from the archive of programmes the company could no longer afford to make. More and more programming became extensions of newsroom operations. Craft skills atrophied. Soon, the hours of output also began to shrink inexorably, although, miraculously, those programmes that were above the breadline and retained a peak-time slot still won large audiences, proving that demand had never been the issue.

Ownership had also changed. In the wake of the first auction in 1991 – there was never to be a second – the consolidation virus had taken hold. HTV passed through various hands faster than down a Welsh three-quarter line. Along the way Granada and Carlton abolished all regional on-screen logos in 2001, three years before the creation of ITV plc swallowed up the whole of England and Wales. In 2004 Wales became the only one of the UK nations to be an ITV cost centre, rather than an independent franchise holder. Scotland, Northern Ireland and the Channel Islands still preserved their autonomous companies. Arguably, that autonomy, partial though it may be in practice, has given Scotland and Northern Ireland more influence than Wales in recent debates.

Perversely, in 2004, during the first term of both National Assembly and the Scottish Parliament, the architecture of the new converged regulator, Ofcom, ignored the nations at the most senior level. Parliament, taking a cue from policy advisors, consciously rejected the notion of representation on its board for Scotland, Wales and Northern Ireland, despite the precedents of Ofcom’s predecessors – the IBA and Independent Television Commission, the Broadcasting Standards Commission and, if belatedly, the Radio Authority – not to mention the BBC. The three nations had to make do with a single representative on Ofcom’s subsidiary Content Board and Consumer Panel.

By the time that Ofcom came to embark on its first public service broadcasting review at the end of 2003, evidence of the attrition affecting ITV’s revenues and regional output was already apparent, though it has to be said that this was as much a result of the mismanagement of the ITV network as of the fragmentation of audiences and the growth of internet advertising. The ITC, in its last years, had cobbled a cosmetic initiative – a Charter for Nations and Regions – which traded a reduction in regional hours against a promise of an increased investment of £1m, ostensibly in order to safeguard quality. Events would move the argument on before anyone could stop to measure whether the investment had taken place. The pattern was to be repeated several times, although never again with the promise of investment. This is what brought general programme hours for Wales down gradually from seven hours a week, first to four, then to three, then in January 2009 in Wales to a mere 90 minutes.

Ofcom took much flak for agreeing to ITV’s repeated requests for reduction in its obligations. It generated a lot of heat at public meetings and conferences in Cardiff. The regulator had some right to feel aggrieved that its critics were ignoring what was happening to ITV’s revenues in a multi-channel world. The attacks upon it were signs of frustration and impotence.  The fact that ITV in Wales was a cost centre within ITV plc rather than an independent plc, as in Scotland and Northern Ireland, did not help. It gave us no transparency on costs or other leverage.

At the end of its first review of psb, when it had to complete a hasty additional consultation in the nations before publishing a postscript statement four months after the main report, Ofcom allowed ITV to reduce its non-news programmes in the nations to four hours a week. It also allowed them to show their own current affairs programmes in peak in place of the networked current affairs programme presented by Trevor Macdonald. For Wales it also called for a new strategic partnership between the BBC and S4C ‘driven by three core principles: transparency, financial commitment and editorial control’.[i] Such an agreement was signed in October 2006, pledging the BBC to increase its spend on programmes for S4C from just under £22m in 2006-07 to more than £25m in 2008-09. The agreement runs to thirty-three pages, rather more than the eight pages that suffice for the agreement on a similar arrangement in Ireland between RTE and the Irish language channel TG4. Whether the different lengths reflect different levels of trust, or simply British legalism is an open matter.

Ofcom is obliged to carry out a review of public service broadcasting every five years. However, the speed of events, and particularly ITV’s decline, persuaded it to bring forward its second review, publishing its Phase 1 report in April 2008. Conducted through ‘the prism of audience needs’[ii] it would attempt to answer ‘the very big questions – is further intervention needed? If so, on what scale? Why does, plurality and competition really matter in public service broadcasting?’

In Wales many of us shared a sense that much more was at stake this time. Ofcom would have to answer many of the questions it had raised but not resolved in its first review. Early in 2008 the then Welsh Heritage Minister, Rhodri Glyn Thomas, commissioned the Institute of Welsh Affairs (IWA) to carry out an audit of the media in Wales[iii], followed by a round table discussion of interested parties arranged jointly with Ofcom, a transcript of which was published[iv]. Ofcom and the IWA then conducted public meetings in Llandudno, Aberystwyth and Cardiff to encourage responses as part of the Phase 1 consultation. Following publication of Ofcom’s Phase 2 document, Thomas’s ministerial successor, Alun Ffred Jones, convened an advisory group to help shape the Assembly Government’s response.

The IWA’s media audit, which deliberately included print and online within its purview, underlined how much more research is needed to get at a true picture of what is happening to the media in Wales. The annual Ofcom market reports are usually high level econometric analyses, and do not allow you to trace changes in the texture of what is delivered to audiences. Change happens below the public radar. Whole genres of programmes can disappear unremarked. There are no tracking studies of Welsh media output, comparable with some of the content analyses that have been done for UK broadcasting, such as the work for Professor Tony King’s report for the BBC Trust which exposed the London-centricity of news services. Commercial radio content, in particular, is virgin territory. The premature death of James Thomas at Cardiff University’s Centre for Journalism Studies robbed us of someone whose sharp focus was on Welsh media. It is a gap that needs to be filled.

Although audience measurement is done by one main organisation – BARB, the Broadcasters’ Audience Research Board – the use of the resulting data is in the hands of individual broadcasters, and is rarely consistent by the time it surfaces in public. Different measures can be chosen for cosmetic effect. It is no surprise that annual reports by broadcasters are a mix of bullish public relations and hesitant accountability. Methodological changes from year to year make tracking over time difficult.  As with ITV Wales, commercial radio data is locked within group structures. On the print side, information about the sales of London newspapers in Wales, their arrangements for regional editionising across the UK, and the profitability of individual titles within Wales, are buried deep.

Despite the obstacles we were able to pull together a fuller picture of the media landscape than ever before, though still sensing that it should be a work in progress. It was not a pretty sight. The decline in ITV Wales output was well known, the scale of the BBC’s savings targets over the next five years less so. Beyond the public service broadcasters, Wales appears weaker than Scotland and Northern Ireland in almost every media aspect. It has the weakest commercial radio sector, is the only country where none of its commercial radio stations is indigenously owned, and is the only one whose ITV franchise holder was absorbed into ITV plc. It was the country that had the lowest population coverage for its disappearing analogue transmission systems, and will still have the lowest population cover for the new digital systems in television and radio. It also has the lowest take-up of broadband. It does not enjoy the benefits of Scotland’s scale or any comparable to that which Northern Ireland derives from all-Ireland transmission from the south as well as Irish newspapers. In print, Wales has the poorest provision, with few newspapers of its own and, unlike Scotland, no special editions of London newspapers. The audit unearthed the remarkable fact that of three million daily newspaper readers in Scotland, only 100,000 were reading papers with no Scottish content. Of two million daily readers in Wales, 1,760,000 were reading papers with no Welsh content.

In the wake of Ofcom’s Phase 2 report published in September 2008, the Assembly Goverment convened an advisory group late in October, and it completed its work in time to produce a report that the Cabinet endorsed in time for submission to Ofcom as part of the second consultation. The group was chaired by Huw Jones, the former chief executive of S4C.

Like Ofcom’s own Advisory Council for Wales, it argued the case for plural provision in news, an extension of general programming in English, and the creation of a Welsh Media Commission that would allow for and manage a degree of contestability in the public funding of television, as well as facilitating some flexibility to respond to technological change and changing patterns of consumer consumption. The WAG advisory group also envisaged that the commission would share operational facilities, probably with S4C, at marginal cost. It thought that the restoration of past and foreseeable lost value of £25-30m in English language broadcasting for Wales should be the minimum policy objective, but that full implementation of its recommendations might cost around £50m.

It concluded that the ‘democratic and cultural deficit described in this report is of sufficient seriousness for it to command a very high level of priority and urgency in the formulation of Government policy, as it considers the future of PSB…[and] that it would be wholly unacceptable if government policy were confined to protection of the current resource base of Channel 4 and the BBC, with appropriate provision being made to address the deficits we describe’. Its proposals were summarised in Ofcom’s final report, but the report fell well short of an endorsement, offering it up as something that the government should consider in the light of competing priorities. In the days before publication of the Ofcom report there seemed to be a flurry of activity to reconcile the Ofcom document, particularly in relation to Channel 4, with Lord Carter’s Digital Britain interim report that was to be published a week later.

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One word has peppered the debate more often than any other – pluralism. Usually, it has been shorthand for the need to have something other than the BBC. That is not an unreasonable view, but the nature of pluralism needs a little more examination for it is not just about a number greater than 1. The object of pluralism in broadcasting is to guarantee a range of expression, but range of expression is guaranteed not only by having more than one supplier, but also by variety of programme form and purpose. Any viewer of ITV Wales’s Wales Tonight and BBC Wales’s Wales Today will be struck not by difference but by similarity: the same stories covered at much the same durations and often the same interviewees. This is not surprising when you take into account the nature of modern journalism.

The proliferation of outlets, the relentless 24-hour drive of television and the internet, as well as the assault on production costs, has created a news processing culture in which, it has been argued, 70% of news output in broadcast, print and the web, begins with a public relations source[v]. The lower the cost of a news service, the lower the scope for original investigation and the greater the pervasive influence of public relations and the similarity of the end product. In this situation it is not surprising that two similarly resourced newsrooms, in similar time slots, chasing similar mainstream audiences, working to much the same set of journalistic values, will deliver programmes differentiated more by the presenter’s clothes than by anything else.

This is not to argue that, therefore, we can make do with one news programme for Wales – at the very least doubling up manages risk – but rather that we need to address issues of journalistic resource and purpose. One shining example of real difference in television news is seen not by comparing the BBC with ITV but by comparing both with Channel 4 news, perhaps the only British news programme to break the conventional mould. As broadcasters in Wales discuss various partnering options – BBC/ITV, S4C/ITV, BBC/S4C/ITV/ANO? – we need to remember that we will end up no better off if discussion is restricted to just how cheaply can we deliver an alternative news service. In fact the sharing of material across broadcast institutions, even across languages, should increase the onus on news producers to differentiate their products in much more substantial ways. It should be at the forefront of consideration in the process of rescuing ITV’s news for the nations.

In the meantime, it seems to me to be beyond argument that greater range of expression is guaranteed by the existence, parallel with television news, of well-resourced current affairs programmes or even well-resourced radio journalism than by simply proliferating cloned television news programmes. We have to guarantee different forms of journalism, even within Wales – daily news, daily and weekly current affairs, the single investigation, the studio interrogation and studio debate, with or without an audience.

But this is to restrict consideration of range of expression to expression by journalists. Range of expression expands exponentially if you extend it to dramatists, documentary makers, comedians, satirists and artists of all kinds. Different forms allow different truths to emerge. Which tells us more about the life of a single mother on a council estate in south Wales – a handful of television news reports or Karl Francis’s film Streetlife, a drama in the same lineage as Cathy Come Home? It is for these reasons that securing a range of general programming with Wales as its focus is no less important than securing competing news programmes.

The Assembly Government’s broadcasting advisory group summarised it thus: “We cannot hope to see Welsh talents bring genuine diversity to UK networks, if there is not the space for them to develop their own voice at home in the language of their choice. Drama lies at the heart of most high quality television services, yet is all but absent from English language services in Wales. Welsh society and politics lacks the regular challenge of comedy and satire in both languages. Light entertainment taps only a fraction of Wales’s deeply rooted performance culture. The exposure given to the diverse arts of Wales, at a time when arts organisations themselves are seeking new partnerships, is fitful.”

The Presiding Officer of the National Assembly for Wales, Lord Elis-Thomas, once reminded us that ‘English is a Welsh language’. So what is the state of programme services, in the language of the majority, designed for their own national community – since 1999 one of Britain’s internal emerging democracies?

It is this area of general programming that is currently at greater risk than the ITV Wales news service, and whose entire loss from ITV, coupled with retrenchment at BBC Wales, promises the anglophone Welsh audience a diminished and diminishing service in the years to come unless something is done. The WAG Broadcasting  Advisory Group calculated that the value of English language television output in Wales will have dropped by more than £20m by 2013, even if ITV Wales maintains its current investment in Welsh news. If ITV withdraws entirely, its spend in Wales will have dropped in that period from £12.9m to nil, while BBC Wales is currently at the start of a five year period where it will have to cut its programme spend across all services by £3m. per annum.  Taken together this is a major reduction in a service that was already far from the full programme service that the anglophone audience in particular, and the Welsh polity in general, deserves and needs.

This focus on general programming clearly causes bemusement in some, though not all quarters, in Ofcom. Its justification for relegating general programming, in contrast to news, to a ‘nice to have’ rests on the primacy that the public seems to have accorded to news in Ofcom’s research. The tone of Ofcom’s final document may have had a regretful touch, coloured by a realisation that this is just about the worst moment in history to be asking government for money, but there are serious questions to be asked about the hierarchy of public value that Ofcom claims to detect.

There is no doubt that whatever questions are posed to the public about programmes, the importance of news always comes near the top. That is certainly the case when considering programmes made specifically for one region or nation. But it is not the case that the public puts the black spot on general programming for ‘my nation’ or region. For instance, in Ofcom’s research[vi] 78% of respondents across the UK told them that ‘providing good quality news about my area was important’, while 61% said the same thing about ‘other good quality programmes about my nation/region’ – 5 percentage points more, mark you, than for ‘high quality soaps or dramas made in the UK’ (56%). The fact that ‘other good quality programmes about my nation/region’ could have scored so highly, even after years in which both volume and production quality declined, says something for their enduring appeal. If the public have a gripe it is about the gap between the perceived importance of these programmes and their satisfaction with what is delivered. The public may like a bargain, but they despise the cheap.

Similarly, while 91% in Wales thought it was important to have news of Wales on more than one channel, 71% thought the same should apply to other programmes for Wales.[vii] This is hardly a half-hearted endorsement of programmes made for the home patch. In an era when single party government can get elected by less than a third of the electorate 71%, or even 61%, might be thought a landslide victory. By what reasoning is something supported by six or seven out of every ten people to be cast aside, just because they thought something else was even more important?

If there is a consistent gap between news and ‘other programmes’, is it really surprising? Regional news is the only portion of regional programming that has been guaranteed a high profile, early evening slot in the ITV schedule for the past forty years. It has had time, exposure and stability to register in the minds of the individual and the community. Other regional programmes have had a much tougher time pushing their way into the schedules. On ITV they have usually had to make do with the 10.30pm slot after News at Ten or even later. Most of BBC Wales’s programmes for Wales appear on BBC2, rather than BBC1. Of the 1,105 hours made and broadcast by BBC Wales in 2006-07 only 26 hours appeared in peak hours on BBC1. Only 184 hours out of the total appeared in peak across BBC1, BBC2 and BBC2W. It has hardly been an even contest.

But there is something depressing about resting one’s case in the cultural sphere on opinion polls. Are we really to throw aside all deeper assessments of cultural value, the tomes that have been written about the connection between the media, culture, and identity, the role of television in the self-validation of communities? The authors of Ofcom’s final report seem to have forgotten the wisdom contained in its statement on the nations and regions, following its first PSB review.

Countering critics who denied that Ofcom’s research showed that viewers in the nations valued their programming more than in the English regions, it pointed to a ‘wide range of studies conducted over many years’ and added the following wise observation[viii]: ‘Our rationale is not exclusively based on audience research. It is based on the observation that regional programming is required to meet the complex and challenging requirements of a devolved society with diverse cultural identities. These requirements generate a right to ongoing dedicated provision (my italics), which is not necessarily or exclusively dependent on the majority’s views at a particular point in time.’ What has changed?

There is no mention of ‘a right to ongoing dedicated provision’ in the Ofcom final report. Although it does set out the ambitions of Wales and Scotland, as envisaged by the Welsh Assembly Government and by the formidable reports of the Scottish Broadcasting Commission, it does not endorse them. The Digital Britain interim report makes no mention whatsoever of general programming for the nations, gliding seemlessly from the issue of news for the nations, to network production quotas and UK children’s programming. In its own severe calculus rights don’t come into it. The unstated implication is that general programming for the nations will be an unavoidable, if regrettable, casualty of changed market circumstances. Invidious choices have to be made in straitened times, and this will be one of them. This will be one market failure that will not be corrected.

This is to conceive broadcasting within the nations as simply a costly departure from a UK norm. The Scottish Broadcasting Commission’s proposal for a Scottish television network at a cost of £75m per annum or the claims for a fuller service in Wales, assessed variously at £40-50m., are regarded as hopelessly ambitious. They would certainly be major advances on the status quo. But are they really so outlandish in the context of a total spend by the five main psb channels of more than £2.5billion and their ability to extend their service at the UK level to no less than 20 channels[ix].  Indeed, such claims seem positively modest when you also remember that in 2007, of the 16,585 hours of programmes produced by only five of these 20 channels – BBC1, BBC2, ITV1, C4 and Five – only 413 hours (2.5%) were made outside England[x]. The challenge for government may not be how to enlarge the cake, but rather how to rebalance British broadcasting as a whole across the nations.

The only re-balancing contemplated to date has involved UK network programming. There has been a lot of pressure to increase network commissioning outside London, and outside England, with the BBC leading the way with its target of reaching 17% of total output delivered from Scotland, Wales and Northern Ireland – at least equal to their population share. If the BBC has come late to this issue, at least it is now addressing it with energy and commitment. ITV doesn’t want to play at all and Channel 4 is stronger on rhetoric than action.

But network quotas address only a re-balancing of production. There is no evidence that they are making any difference to the cultural diversity of UK networks, or to the cultural representation of the three smaller national entities. Those who expect such a change are almost certain to be disappointed. As channels fight for survival in a fiercely competitive environment, we are likely to see a greater homogeneity of output – witness the erosion of Channel 4’s distinctiveness. Rightly or wrongly, commissioners are under immense pressure to find the widest common ground. Network commissions and quotas are about a fairer distribution of the spoils, they are not the answer to a national community’s desire for cultural self-realisation.

In making the argument for a fuller English language service at the decision-making centre, time and again you will come up against the argument that Wales is already supremely advantaged in television because of the investment in S4C. Its more limited value to non-Welsh speaking viewers is discounted. In this particular debate the elephant in the room not the BBC, it is S4C. It is not an easy argument to deal with, since time has eroded the perception that S4C was as much a political settlement as broadcasting one – in William Whitelaw’s famous phrase “an investment in social harmony”, following one of the most determined and successful campaigns of civil disobedience in the UK in the 20^th century.

Only a handful of rabid letter writers to the Western Mail would question the need for a Welsh language channel, even today when the broadcasting environment has made it infinitely more difficult for it to make its mark with the audience. Personally, I have always been proud of the work that we did at HTV at the inception of the channel in 1982 in creating current affairs and rural affairs programmes – Y Byd ar Bedwar and Cefn Gwlad – that still survive today. Successive Controllers of BBC Wales, including this one, have taken pride in the fact that the BBC has provided S4C with core strands that have made a disproportionately large contribution to the channel’s audience. The case for S4C is still strong, as the only television expression of the Welsh language in the global cornucopia of the digital age, even if, like the BBC’s Radio 3, it is a public good supported by more people than actually use it. S4C has delivered a wider public value, as well as an institutional value in being the only fully autonomous broadcasting organisation in Wales.

But that is no reason for the institution or the politicians or the public to shield their gaze from some of the consequential effects – a too common practice in Wales. For instance, within the BBC in the 1990s I found it difficult to make headway with the case for more funding for English language broadcasting in Wales because the BBC looked at total investment in the nation, rather than at parity of service. In that sense, there was no escaping the conclusion that, to some extent, the investment in Welsh language television and radio, was being bought at the expense of the English language services. In 2007-08 BBC Wales and BBC Scotland both spend around £50m a year on television within their respective nations – Scotland £50m and Wales £47m[xi]. Yet if you look at spend on English language television, a huge disparity opens up – Scotland £48m, Wales £24m., only £1m more than BBC Northern Ireland at £23m.

Of course, the gap cannot all be laid at the door of the need to provide in two languages. The fact that the BBC is a bilingual operation creates its own countervailing synergies that benefit both Welsh and English language programmes. But the gap does help explain why BBC Scotland is able to produce some 93 hours in the drama, comedy, music and arts categories against BBC Wales’s 32 hours, despite the fact that output in news, sport and other genres is broadly comparable. This is not likely to change. It is difficult to foresee the BBC increasing its investment in output for the nations in the current period of retrenchment.

Within Wales, the difference between S4C’s comprehensive standalone service – clearly a model for Scottish aspirations – and English language provision is also stark, a factor that has created much frustration in the creative sector. Following the reduction in ITV Wales output from January 2009, 67% of the total output in English across BBC Wales and ITV Wales will be accounted for by news and current affairs, another 17.5% by sport leaving only 15% to account for all other programming. If ITV withdraw from everything other than news in 2010 the imbalance will be even more severe. That imbalance is created by three factors: the existence of two news services, the dominance of sport where live action demands time, and the restricted volume of other programmes. Even if you discount the news duplication, the proportion devoted to other programmes.

Although one might make a case for mirroring S4C in English, one does not have to go that far to establish that there is room for increased English language. There is always likely to be a larger provision in Welsh on S4C since it is the sole television broadcaster in that language, but the volume and range of its output does put the low volume of English language output into perspective. For instance, in drama in 2006-07 S4C broadcast 187 hours, while in English there were only four hours of drama for Wales. In music and arts S4C broadcast 193 hours, against only 31 hours in English. In light entertainment, S4C broadcast 98 hours, against eight hours in English[xii]. At the very least it underlines the potential for extending and enriching the diet in English. But it also calls into question the fact that in recent years the BBC spend on S4C has been increasing – under the terms of the strategic partnership – while the spend on English language has been decreasing and is set to do so for the next five years.

The scale of the disparity cannot but create long term risks for S4C, risks that would be significantly mitigated by a richer programme provision in English. That is why it has been profoundly disappointing that our one fully autonomous Welsh broadcaster has not itself elaborated a public case for better English language provision across the board, as well as arguing the case for is own service. It makes the totality of S4C’s recent intervention in the broadcasting scene in Wales difficult to understand.

There was a considerable flurry in the Welsh dovecote when Ofcom’s final report revealed that S4C had proposed that it might tender a contract for an English language news service to be broadcast on ITV, hand in hand with commissioning for the first time a news service in Welsh for its own channel, in the process dispensing with the new service it has received free of charge from the BBC since 1982. The proposal that S4C should offer itself as the tendering agent for a news franchise is a good one. Many would argue that if we are to channel public money into safeguarding Welsh news on ITV it would be better done through a third party than through ITV plc, if only in the interests of transparency. Some have seen the S4C offer as in opposition to the BBC’s initiative in offering a partnership arrangement with ITV to reduce infrastructure costs, but both initiatives can just as easily be seen as complementary and mutually supportive. It is possible to envisage a three-way partnership.

S4C was extraordinarily coy about its proposals, becoming the only public broadcasting authority not to publish its evidence to the Ofcom review, and refusing Freedom of Information requests to do so after Ofcom and Carter referred to the basic proposal. It was only some six weeks later – on a day when the BBC, S4C and Lord Carter gave evidence to the National Assembly’s Communities and Culture Committee – that S4C published its evidence, and then only in a heavily edited format. It left readers intrigued about the precise content of the sections that had been deleted, and it left major questions about how the S4C Authority, as opposed to its management board, interprets public accountability. No other quango in Wales could have got away with such an approach to a statutory public consultation.

It remained hard to fathom why S4C should have wanted to mar the reception of a valid and sensible proposal in relation to ITV’s Welsh news by proposing to ditch  BBC Wales’s news service and to use its own cash to commission its own. In doing so it has tarnished its initiative regarding the ITV news with accusations of institutional one-upmanship, clouding the shine of any wider public interest. It seems an odd thing to have done, unless it is an astonishingly bold and risky negotiating ploy in a year when it is having to renew its strategic partnership agreement with the BBC – a Welsh equivalent to teasing Putin with NATO missiles in Eastern Europe. It has created a deal of public confusion and not a little uncertainty for affected employees, things public authorities usually seek to avoid.

The issue becomes very relevant to the future of general programming in English for Wales, when you trace through the possible consequences of such a decision. The argument runs like this: If S4C wishes to use its public cash to commission a news service, rather than to receive one free of charge from the BBC, then presumably it will have to divert that cash from its other programming, threatening some loss of value for Welsh-speaking viewers and, presumably for the independent production sector. At BBC Wales a withdrawal from Welsh language television news, would have the effect of pushing up the cost of English language news, as synergies across the two services are lost. This will risk creating more pressure for economies in BBC news.

Moreover, since the BBC is statutorily bound to supply S4C with not less than 10 hours a week, it will also have to replace nearly 300 hours of news – about half its total output for S4C – with other programming which, on past experience will be between 50% and 100% more expensive.  Under the current BBC licence fee settlement there is a real danger that any additional cost is likely to have to come out of BBC Wales’s other services, primarily English language television, but also Radio Wales and Radio Cymru. If this were to transpire it would produce a net transfer of value out of the English language and into the Welsh language television service, hardly what is required under current circumstances. The public does not know whether S4C sees it differently, but it would be interesting to know whether this possible eventuality was debated at the S4C Authority. One can but hope that S4C is not actually seeking this gain for its own service, regardless of the consequences for other services in Wales.

Its intervention has put an interesting and useful proposal on the table for safeguarding news of Wales on ITV, but the nature of its intervention and the reaction to it has had other consequences: it has done serious injury to working relationships between it and the BBC, it has unsettled both the DCMS and Ofcom and, perhaps most significantly of all it has opened the door to greater public scrutiny of itself and possibly to the devolution of responsibility for the channel to Wales – something it has always devoutly wished to avoid. When you shake the pillars some of the masonry is bound to fall on your own head.

S4C’s self-inflicted dispute with the BBC is also diverting public debate away from  the other issues that need to be debated urgently. What would be the nature of the tender for ITV Wales news? For what period would it be tendered? Would it be an open commercial tender, or would it have a list of selected bidders? Would there, or could there be any requirement for a degree of local ownership? Will the cross-media ownership rules affecting newspapers be relaxed in time for newspaper organisations to participate? Will there be scope for a not-for-profit consortium? Will there be a quality threshold, and if so how high will the bar be set? It also raises issues that go beyond news. If such an arrangement is possible for news, will it be extended to allow current affairs and general programming to survive on ITV? Would ITV play ball?

There is too much at stake for these issues to be settled by consenting adults in private, they must be debated openly. They go to the heart of the cultural life of the Welsh nation, they affect the quality and texture of our living and put at risk that good will between the Welsh speaking and non-Welsh speaking community that has been so hard won. In broadcasting they also blur the historic boundaries of linguistic responsibility, albeit in ways that could be beneficial if handled properly.

S4C clearly wishes to extend its responsibilities into the English language domain. In so doing it makes the case itself, not necessarily for a bilingual channel, but for a bilingual public broadcasting authority outside the BBC. That would be something that many people, including myself, would support. What would be deeply contentious in the Wales of today would be the management of a significant part of English language media in Wales by an organisation drawn predominantly from the Welsh language community. The obvious answer would be to mutate S4C into a bilingual Welsh Media Commission with a remit that could cover all media – television, radio, online and perhaps even print..

I have detected some warmth at Ofcom to the notion of a Welsh Media Commission, but also a worry that, if it existed in parallel with S4C, we could be building an impossibly expensive superstructure for Welsh broadcasting. As it was put to me, succinctly and ironically, “How many people does it take to run television in Wales?’. There is substance in the implied charge. But a bilingual, multi-media commission would be a much more cost-effective proposition. It need have no visible effect on S4C’s service. The channel could be run as a franchise from the commission, with its funding still ring-fenced by statute. In fact, it would allow for a healthier separation of the current management board and regulatory functions, creating both greater managerial freedom and more transparent regulation. But there are more imaginative possibilities.

The commission could encourage initiatives that cross both media divides and language divides. It might offer other franchises in the English language. It might even manage the WAG funding now given for Welsh language online journalism, currently managed, rather inappropriately, by the Welsh Books Council. It could have a close relationship with the lottery-funded Film Agency for Wales, providing back office functions or more, and creating more fruitful dialogue and active collaboration between the agency and broadcasters. It might offer tenders for collaboration between broadcasters and arts organisations or higher education.

Above all, it would assemble a critical mass of expertise that would be able expertly to monitor quantitative and qualitative change in Wales’s media environment (preferably including the BBC), informed by its closeness to the audience as well as the industry. It would allow us greater influence and effective autonomy, while still operating within a UK framework. Many in London believe that the reluctance in Wales to contemplate the transfer of responsibility for broadcasting, and S4C in particular, from Westminster to Cardiff is rooted, not in a principled belief in broadcasting as a UK reserved power, but in fear. A bilingual Welsh Media Commission would allow us to grow up.

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[i] p4 Statement on programming for the Nations and Regions, Ofcom, 2005.

[ii] p1 Ofcom’s Second Public Service Broadcasting Review – Phase One: The digital Opportunity,             Ofcom, 2008.

[iii] Media in Wales – Serving Public Values, Geraint Talfan Davies and Nick Morris, IWA, May 2008

[iv] The future of Welsh broadcasting, Proceedings of an IWA/Ofcom seminar, IWA May 2008

[v] Flat Earth News by Nick Davies,

[vi] p44 Ofcom’s Second Public Service Broadcasting Review – Phase One: The digital Opportunity,             Ofcom, 2008.

[vii] p153, The Digital Opportunity – Research Annex 5, Ofcom, 2008

[viii] p14, Statement on programming for the Nations and Regions, Ofcom, 2005.

[ix] BBC1,2,3,4, CBBC, CBeebies, BBC News 24 / ITV1,2,3,4 / Channel4, More 4, E4, Film4 / Five,             Fiver, Five USA

[x] Nation and Regions Production Trends, PACT, November 2008. The figures             exclude news and the             output of GMTV.

[xi] Annual Reports 2007-08, BBC Wales, BBC Scotland.

[xii] This calculation is the best estimate that can be made given the different way in which broadcasters             report on programme categories.