Appendix to the reply
Comments of the Steering Committee on
the Media and New Communication Services (CDMC)
The CDMC warmly welcomes Parliamentary
on “The funding of public service broadcasting”. The
recommendation is well-timed, coinciding as it does with the revision
of the European Convention on Transfrontier Television and the recently
published European Commission Communication on the Application of
State Aid Rules to Public Service Broadcasting.
2. The timing of the recommendation is particularly apt given
the current global financial crisis and recession. In member states
where there is either mixed funding or the public service broadcasters
rely solely on state subsidies, governments may be tempted to see
public service broadcasters as fair game for cuts in their subsidies
and indeed, in some member states this has already happened.
3. The CDMC appreciates the Assembly’s reinforcement of the importance
of public service broadcasting and the vital role it plays in a
democratic society through the maintenance of a plurality of opinion,
the provision of unbiased information, educational and cultural
content that private broadcasters could not be expected to provide
without public funding.
4. Similarly, the CDMC notes the Assembly’s recognition of the
need for public service broadcasters to make full use of all the
technologies and platforms currently available and those of the
future in order to provide high quality programming to the widest
5. The recommendation rightly points out the need for public
service broadcasters to provide value for money and for them to
be fully accountable to the public they serve.
6. The reference to developments in the European Union with regard
to public service broadcasting (paragraphs 10 and 11) is a poignant
reminder of the essential difference between the two organisations (Council
of Europe and European Union). Although not specifically mentioned
in the recommendation, the European Commission Communication on
the Application of State Aid Rules to Public Service Broadcasting has,
in the drafting process, highlighted the friction between public
services and private media and was seen by some as a concerted attempt
to weaken the position of public broadcasters and an encroachment
on the member states’ right to determine their own media policy.
Paragraphs 10 and 11, while tactfully formulated, are, nevertheless,
an unambiguous exposition of the problems faced by those Council
of Europe member states that are also bound by European Union rules.
7. Having regard to Recommendation Rec(2007)3 of the Committee
of Ministers on the remit of public service media in the information
society, the CDMC considers that public value in respect of public
service broadcasters or more broadly public media services can only
be assessed if they are considered as an integral whole, rather
than as discrete and disconnected features of public service. More
particularly, public service media cannot be confined to a subsidiary
role, characterised by offering services that do not feature highly
on the agendas of commercial broadcasters.
8. The assertion in paragraph 12 that “public acceptance of funding
public service broadcasting is decreasing” in view of greater content
becoming available on other platforms is, perhaps, to overstate
the case. It might be truer to say that the public has become more
demanding in terms of quality programming and value for money when
it comes to paying either indirectly through taxes or directly through
licence fees. However, this does not detract from the message of
the paragraph in that public service broadcasting is of particular importance
in smaller states.
9. Paragraph 16 calling for action by member parliaments is not
only a useful reminder of what member states have already subscribed
to by way of various instruments but also points out that part of
the public service remit may be allocated to commercial broadcasters
as is already the practice in some member states. Indeed, commercial
organisations may also enjoy the status of being public service
broadcasters, as noted in the Explanatory Memorandum.
10. The CDMC notes the Parliamentary Assembly’s endorsement of
the Ministerial Conference (Reykjavik, 28-29 May 2009) Action Plan
(paragraph 17) and the invitation to ministers to reaffirm their
commitment to it at the national level. The CDMC would, however,
draw attention to part 3 of paragraph 17, which speaks of Europe-wide
co-ordination of national policies for public service broadcasting.
Neither the Council of Europe nor the CDMC is responsible for co-ordinating
national policy and indeed this runs counter to the spirit of paragraph
10 of the recommendation. The CDMC fully supports international
co-operation in the setting of standards but it is the role of the
member states themselves to determine national policy.
11. The Action Plan does not foresee the co-ordination of national
policies but speaks of the possible elaboration of “a policy document
containing guidance for member states on governance approaches for
public service media”. (This task is also within the terms of reference
of the CDMC Ad hoc Advisory Group on Public Service Media Governance
(MC-S-PG). With a view to preparing the work of the latter, a consultation
meeting on the matter was held in Strasbourg on 17 and 18 September
2009. One of the main conclusions of the meeting was that governance
approaches for public service media should respond to technological
and socio-cultural changes; at the same time, principles of openness,
transparency and accountability should be fully respected).
12. The Assembly rightly calls on the Committee of Ministers to
forward the recommendation to the institutions it concerns (ministries,
regulators and the broadcasters) and it might be assumed that the
reference to requesting assistance from the European Audiovisual
Observatory (paragraph 18.2) is the follow-up action or future review
of developments in the funding of public service broadcasters that
is very necessary. The Observatory has recently published a most
valuable edition of IRIS Plus “The public service remit and the
new media” with much information that directly concerns this recommendation.
13. Finally, the CDMC considers this recommendation to be a timely
and useful addition to the arsenal of instruments elaborated by
the Council of Europe in support of public service broadcasting.