[cma-l] Submission from Community Media Association re Local Media Action Plan

[Phil Shepherd]

Dear Jeremy Hunt and colleagues

LOCAL MEDIA ACTION PLAN

 This letter outlines Community Media Association¹s (CMA¹s) commitment to
community empowerment through locally owned and controlled broadcasting,
reflecting the debate within our membership around how this could be
achieved with television.  Our position is informed by the community media
charter, the first article of which (promotes) Œthe right to communicate, to
assist the free flow of information and opinions, to encourage creative
expression and to contribute to the democratic process and a pluralist
society¹. 
 
The letter details an initial summary of CMA member views in relation to the
Local Action Plan. It is intended to inform government thinking as
Expressions of Interest for the network spine are under consideration. It
follows that CMA will not be submitting its own EOI for the spine service.
As a membership organisation with a broad base of support it would not be
appropriate for us to do so given that there are various member group and
individuals who are involved with EOIs with whom we would then be in
competition.   
 
We are aware of groups from all over the UK who are taking a keen interest
in this digital terrestrial development and wish to be involved.   We are
aware too that slightly different circumstances pertain in Scotland and
Northern Ireland hence slightly different solutions are called for.   The
networks exist across the UK voluntary and community sectors for these
strands to be pulled together very quickly given a workable opportunity.
Many of these groups are from rural areas who are likely (in the main) to be
the last communities to benefit from the roll out of broadband in the
future.  Some but by no means all will be contacting you today under
separate cover.

The key points we detail below are

* a vision for local TV which is about promoting active citizenship through
local participative production

* a vision of local ownership and engagement and the economic sustainability
and positive social cohesion derived from this

* our concerns about the relationship between the network spine and local
providers. 

*  a relationship driven not simply by commercial logic but by a real
understanding of local needs and politics, culture and history - how will
communities be empowered without genuine engagement ?

*  our concern that the spine model undermines the viability of the
local providers through making it impossible for a locally based federation
to attract national advertisers, the revenue from whom will inevitably first
be required to sustain the spine

*  how truly owned local TV can offset the opportunity cost of selling off
the spectrum and the income that can generate

* the importance of prominence on the EPG

* it is not only local news that has been lost from mainstream commercial TV

* what matters is the integrity of content, and the context from which it
emanates

*  the local media we envisage has the capacity to go beyond the mainstream,
to connect with its audience in a way that a mainstream approach cannot hope
to achieve.  But we need to get the model right
 

The CMA has been long engaged with developing arguments for local TV in the
UK and has provided the secretariat for the United for Local Television
(ULTV) group since its inception.  ULTV is an informal grouping of local and
community TV interests.
 
ULTV has created a vision for local TV which is about promoting active
citizenship through local participative production, enhancing the provision
of underserved public service content, particularly around children¹s,
educational, arts, cultural and religious programming. The ULTV vision is
one of local ownership and engagement and the economic sustainability and
positive social cohesion derived from this.  The vision is also about
facilitating exchange of local information and discussion, providing healthy
scrutiny and discussion of local democracy and local issues, offering a
meaningful and interactive relationship with readers/viewers, and promoting
cross-cultural understanding.

This is a vision for which there is a proven demand.  Many of us know this
from our own experience of creating local and community programmes on a
daily basis around the UK - where the demand is real enough but almost
always inhibited through lack of an accessible platform for the work.
 
So while we welcome the Action Plan as a significant step forward toward
achieving local services we do have real concerns about how the network
spine will work. It is the relationship between the spine and local
providers that will be all-important. It needs to be a relationship driven
not simply by commercial logic but by a real understanding of local needs
and politics, culture and history.  Communities will not find meaningful
engagement without a sense of ownership and this will prove difficult if not
impossible with a spine predicated largely on commercial rather than
educational and public service lines.  Without engagement how will the
desired empowerment be achieved?  Whether niche sections of communities or
whole communities, boroughs, housing estates, villages or towns - is it not
through a real sense of ownership that these will become empowered?
 
We are concerned too that the spine model undermines the viability of the
local providers through making it impossible for a locally based federation
to attract national advertisers, the revenue from whom will inevitably first
be required to sustain the spine. We expect of course that the local car
dealer, the local insurance man, the local restaurant chain would all
advertise on services if they were cheaper and truly local but national
advertising needs to be an essential part of that mix too.  We take a view
that as the local provider is the reason for the spine's existence so the
spine must be under the joint control of the local providers.   Those
providers need to be free to choose how they fill their airtime, indeed
satellite TV shows us that this ability to trade airtime lies at the heart
of a viable business plan.
 
We share your view that eventually IPTV will provide much of what we need
for local delivery but the universality of this technology is some way
ahead.  There are, as you know 10 million people who are still not online at
all; and that figure is proving hard to shift, especially in rural areas. We
are platform neutral at ULTV of course welcoming the ever expanding value of
the internet, but maintaining the view that while the TV in the corner of
the living room remains the most universally available medium we have, and
while we have spectrum released through digital switchover, it seems
inappropriate to say the least that some of that spectrum isn¹t made
available for the wider public purpose. This is what the big society talks
about, and certainly keys into the Conservative manifesto commitment to Œput
power in the hands of citizens and to decentralise power, to hold local
authorities to democratic account¹.
 
We agree then with Nicholas Shott when he says that services need to be on
Freeview, because public service broadcasting needs to be universal
otherwise it risks defeating its own purpose.  We don¹t however agree that
all spectrum should be sold to the highest bidder.  We are aware of the
opportunity cost of selling off the spectrum and the income that can
generate, but we would point to the money government spends on the many
things that go wrong with our society at the moment, issues that could be
partially addressed by putting something on air that¹s socially cohesive and
influential in the way truly owned local TV could be.
 
We share your concerns too about where the local network will sit on the EPG
and we consider it important that we are positioned with the main channels.
Channel 6 on Freeview needs to be local, wherever you are in the country.
 
The action plan emphasis on news is important ­ especially the opportunity
to explore local perspectives on national and international events ­  but it
is not only local news that has been lost on mainstream commercial TV. There
are significant other areas of popular content which can enrich and educate
­ through which local issues can be articulated with real local knowledge
and understanding.  Alongside the largely unseen wealth of community and
user generated content, local can re-instate a much needed platform for
independent film/video producers as well as promote local enterprise and
business development.   It is also worth noting that experience of the
analogue licences tells us that viewers would expect most content to be
local, so repeating the local content would not just be acceptable but would
be preferable to using network fillers.

We note from the plan a concern about quality.  Again from experience of
analogue local TV, we consider that this argument can be over-rated.  What
matters is the integrity of content, and the context from which it emanates.
Community media organisations up and down the country are anyway winning
many national and international prizes for their content, and they do so
because the work is often excellent ­ and yet largely lacking an audience
beyond Youtube and DVD.
 
The potential here is for nothing less than a new paradigm of broadcasting,
exploring universal themes through local stories. Informed by the evolving
language of interactive media this is a bottom up vision for local as an
inclusive and powerful agent for community and individuals¹ betterment, for
improving of self-confidence via participation in training and production,
for the acquiring of transferable skills, for the experience of teamwork,
for the increase in readiness for the job market
 
At its heart, the local media we envisage  has the capacity to go beyond the
mainstream, to connect with its audience in a way that a mainstream approach
cannot hope to achieve. What better way to reduce powerlessness, isolation
and social tensions and to foster integration than to work with government
and partners to offer communities the opportunity to participate in the most
powerful communication medium available to us, which remains for the
foreseeable future, television.  But for this to work we need to get the
model right.  We hope very much we can work closely with you to achieve this
goal.

Yours sincerely

Phil Shepherd      

Chair of Council
Community Media Association