The Welsh Media XII (a): Public Service Broadcasting in a Digital Age


This final part has been broken up into three separate pieces all posted at the same time – simply because it’s too much for one single article. This one looks at public service broadcasting, the second (Part XIIb) at how to finance public service broadcasting (future of the licence fee etc.) and the final piece (Part XIIc) looks at how broadcasting might be set up after independence (channels etc.).

Defining Public Service Broadcasting (PSB)

The boundary between public service broadcasting and general/commercial broadcasting has become increasingly blurred as public service broadcasters (like the BBC, S4C) expand digital services, while commercial broadcasters produce programming which by most definitions would be considered PSB.

There are also signs of potential market failures, as licence requirements are relaxed (particularly concerning the Welsh language on the radio) and things like local news programmes are threatened or reduced in length.

Traditionally, PSB has included all non-commercial broadcasting; as the BBC often puts it, material which “informs, educates and entertains”.

This PSB requirement isn’t just restricted to publicly-funded broadcasters like the BBC and S4C. Commercial broadcasters like ITV, Channel 4 and Channel 5 have PSB remits within their broadcasting licences or in some cases through legislation. These might relate to local news services (with respect ITV regions) or having a clear remit to produce niche programming (in the case of Channels 4 & 5).

In Wales, S4C – as a commissioning body – has its own PSB obligation to commission Welsh language programmes from independent production companies (similarly to Channel 4 in English), rather than produce programmes themselves. BBC and ITV are also under an obligation to produce programming for S4C.

With an explosion in choice, broadcasters are under more pressure than ever to fill schedules with shows that boost ratings, advertising revenues or redirect more users towards their particular digital services. The BBC has regularly been accused of “empire building” through their expansion online – which has been seen as a threat to commercial broadcasters, who don’t have the safety net of the licence fee.

Ofcom reviews PSB roughly every five years. The latest reviews were published in March 2018 (pdf) and July 2019 (pdf). The key findings were:

  • The five key characteristics of PSB – by Ofcom’s definition – are originality, high quality (in terms of funding and production), innovation (new ideas or re-inventing existing approaches), making viewers and listeners think and being widely available.
  • PSBs should explore new ways of working with global online streaming companies (Netflix, Amazon etc.) to secure investment in original programming produced in the UK.
  • PSB should be easy to find (i.e. should be high in electronic programming guides and displayed prominently on smart TVs and streaming devices).
  • PSB services must be available on-demand.
  • “At the heart of PSB is trusted and impartial news, UK-originated content that speaks to the different communities and nations of the UK, and distinctive programmes.”

How would PSB be defined in a Welsh context?

(Pic: S4C)

The specifics would be a task best left to any future media regulator (Part X), who would publicly consult on charters and broadcasting licences, including specific requirements for individual channels and stations.

If you could define PSB in broad strokes at present, it probably includes the following.

Welsh language obligations – A principle that Welsh-speakers are entitled to  the same services as English-speakers. There are arguments about what format that should take and the ratio of spending on English vs Welsh language broadcasting. Broadly-speaking this should include programming aimed at Welsh learners and could include policies such the use of English subtitles (rather than dubbing) when Welsh-speakers feature on predominantly English language programming (i.e. news bulletins) to normalise its use.

Content for children and young adults – Children’s programmes have largely disappeared from morning and tea-time schedules (except S4C and Channel 5) having migrated to their own dedicated digital terrestrial channels. This shouldn’t be used as an excuse to fill TV and radio schedules with repeats and not invest in new programming aimed at children and teenagers. Though with younger audiences more likely to stream or use online services, “content” ought to be defined in a much broader manner – including short-form videos on Youtube, games and interactive programming.

Schools/educational programming – Again, there are arguments about what format this could take. Scheduled schools programming – once shown on BBC2 and S4C during term time weekday mornings – has largely disappeared, or moved to overnight broadcast or online. With on-demand and IPTV services, there’s the prospect that these could be brought back cost-effectively and aimed at all ages. Recorded university lectures and seminars (for broadcast) and short-form content similar to that produced by Youtube channels like Crash Course, but relevant to the Welsh curriculum (or even adult learning), might be one way to approach it and it could be used as “fillers” during blank spaces on TV and radio schedules.

Promote and help sustain Welsh arts and culture (in both languages) – There are two parts to this. The obvious ones: maintaining the National Orchestra of Wales, playing Welsh-originated music on the radio, covering major national events like the eisteddfodau and other major Welsh cultural events like Artes Mundi, Welsh Book of the Year, Cardiff Singer of the World and the Eurovision Song Contest. Then there’s the less-obvious part: programming that reflects modern Welsh life be it via daytime shows, comedy, drama, film etc.

Programming for minorities and under-represented groups – This could include: the disabled (including the mandatory provision of subtitles, audio description and possibly, in some circumstances, signing for PSB programmes), ethnic minorities, LGBTs, speakers of languages other than English and Welsh, first and second-generation immigrants and religious programming (the obvious Welsh example being Dechrau Canu, Dechrau Canmol). Ideally, this will all be mainstreamed through programme commissioning decisions, but in cases where it’s inappropriate to use a box-ticking exercise, commissioning programmes by, and dedicated to, religious, minority and marginalised groups can make up for it. Commitments to the fair representation of women and a rejection of gendered and racial stereotypes could also be included in PSB licences and various codes drafted by a Media Commissioner (Part X).

A minimum proportion of broadcast hours set aside for Welsh-produced programmes – You would expect most of the burden to fall on public broadcasters and it doesn’t have to be puritanical – perhaps as little as 2-3 hours of first-run programming a day (excluding sport, news and current affairs) with Welsh-originated programming also featuring prominently on-demand. Canada, Australia, New Zealand and the UK all have quotas to varying degrees. We could be more flexible with broadcasters, allowing them to import popular foreign shows to boost advertising income. Co-productions involving Welsh broadcasters or films with a predominantly Welsh cast could also be counted as “Welsh-produced”.

Respecting the watershed – At the moment, mature content can only be broadcast between 9 pm and 5:30 am under the Broadcasting Code. A move to a Sky-style 8 pm watershed on free-to-air television could be introduced, with 18-rated films/programmes broadcast after 10 pm (Part X). Due to the increasing use of things like parental controls, maybe the watershed is becoming irrelevant – but it still has a place for the foreseeable future.

Keep the public informed – This translates as: minimum commitments to impartial news, current affairs and weather forecasts; public information films and government campaigns; balanced and comprehensive election coverage; party political broadcasts/time set aside for political parties,  as well as things like alerting the public during local and national emergencies via some form of emergency alert system (see also: Defending Wales – Civil Defence) and covering major national civic events like state funerals, investiture of a Head of State, opening sessions of the Senedd, Remembrance Day, royal events (if Wales retains the monarchy) etc.

Protecting the “sporting crown jewels” – The crown jewels of sport are events reserved to free-to-air broadcasters, divided into Category A (full broadcast on free-to-air) and Category B (available to pay broadcasters with significant coverage on free-to-air). You can certainly make a strong case for the (men’s) Six Nations, Autumn Internationals, Welsh men’s national team football games and the Rugby World Cup to be Category A events in Wales when at the moment they’re either Category B or not reserved at all. Wales could also create a special “reverse” category to ensure full and free broadcast of major women’s and disabled sporting events.

How could public broadcasting in Wales work?


Cross-border broadcasters aren’t that uncommon. (Pic: RTL Group).


1. BBC as a cross-border PSB (with Welsh opt-outs)

In essence, a continuation of the status quo. Any licence fee income (the price of which would be set by the BBC itself) – Part XIIb – would go to the BBC and would, in turn, be used to fund BBC services across Great Britain and Northern Ireland, with the Welsh Government providing any additional funding to S4C. The advantages are that it would cause the least disruption and opt-outs for Welsh programming could be expanded (particularly for news, current affairs and sport); Welsh audiences would retain access to BBC TV, radio and (presumably) on-demand services. The disadvantages are that with less than 5% of the audience, any current problems facing PSB services in Wales are likely to continue as Welsh voices and commissioning decisions could be overruled. Short-term it can work immediately upon independence, but it would require a longer-term solution.

2. The federalisation of the BBC

Under this option, BBC Wales would become a stand-alone entity/franchise as part of a pan-GB&NI BBC (operating similarly to RTL on mainland Europe or PBS in the United States). Wales would have greater control over programming, scheduling and commissioning, possibly with a separate Welsh licence fee and separate BBC stations for Wales (along the lines of BBC Scotland). However, Wales would continue to opt-in to some BBC radio and television services. The advantages are we would have far more flexibility to pursue a genuinely Welsh broadcasting policy, whilst retaining BBC expertise and branding. The disadvantages are possible tensions over funding (particularly S4C) and whether there would be an unnecessary duplication of services. We would probably be expected to make a proportional financial contribution towards the upkeep of BBC stations to continue to receive them.

3. A Welsh Public Service Broadcaster

Establishing a separate Welsh public service broadcaster (or public service broadcasting system) would be the nuclear option, but the underlying architecture is already there in BBC Wales and S4C. There shouldn’t be any technical or expertise problems in establishing a Welsh broadcaster and it would probably be far easier and quicker than it was in the Republic of Ireland. The advantages are we would be completely independent in terms of broadcasting policy and can shape it however we want to. The disadvantages would include setting the right budget for Welsh PSB, rights access to BBC and other former-UK programming (it wouldn’t be popular if programmes like Eastenders disappeared overnight – but it’s a problem which can be overcome), establishing new radio stations and a Welsh version of iPlayer (possibly evolving from S4C’s Clic service).

Under options 1 & 2, there’s likely to be little difference to how things are done currently, so you can probably disregard most of the rest of this article and parts XIIb and XIIc if that’s your favoured option….

….but I’m willing to bet for most people reading this you would prefer Option 3.

A completely new public service broadcaster would present opportunities to take current trends in viewing habits and the new media into account to create a set-up that’s radically different to what we’re used to.

The Boring Option – The boring, but safe, option would be to create a Welsh equivalent of the BBC (for the sake of argument, I’ll call it Cwmni Darlledu Cymreig/CDC), with broadcasting, editorial decisions and commissioning taking place under the same roof. “CDC” would collect the licence fee (or whatever method we use to fund the service – XIIb) and subsequently distribute it to TV channels and radio stations under its control. Presumably, it would absorb S4C’s functions and would provide PSB in both Welsh and English, though an editorially-independent S4C (or a retained S4C brand for Welsh language broadcasting) is certainly possible and perhaps desirable.

Separate broadcasting from commissioning – Under this scenario, programme commissioning and funding decisions (in both languages) would be taken independently of the broadcasters (similarly to how the system works in New Zealand – see Part IX). A body similar to NZ On Air would be set up and would use a proportion of licence fee income or government grants to commission specific Wales-focused PSB programming – whether from independent production companies or in collaboration with major streaming services etc. The body could also directly fund an independent public news agency (Part XI) similar to The Netherland’s NOS.

The broadcaster(s) would simply manage the schedule on their TV channels and radio stations based on their specific PSB remit/charter drafted and approved by the Media Commissioner (Part X). Once any quota for Welsh-sourced and PSB programming is achieved, they’ll be able to fill any additional air time however they see fit – such as syndicated/imported programming, commissioning their own programming (where finances allow) or using rights to other broadcaster’s content. They would also retain any advertising or other commercial income they would be able to raise, perhaps with some grants from the government to cover certain costs, like distribution. The channels themselves could also be partly state-owned.

This might sound unnecessarily complicated, but the key advantage is that we might avoid a situation where a Welsh public broadcaster becomes too dominant in terms of journalism (Part XI) – potentially opening the door for radio and TV news to be provided by multiple sources (such as commissioning Welsh language news from someone other than the BBC). It would also create opportunities for more innovative and experimental programming in both languages by  encouraging creativity, providing Welsh PSB with greater breadth and depth which might better reflect Wales.

There could also be a digital-first strategy, where the main television stations become a glorified highlights reel; radio would probably be unaffected regardless. Major screen productions could be broadcast first on a Welsh equivalent of iPlayer (similarly to what the BBC are doing with certain dramas like Killing Eve and Fleabag). Longer-term, once the technology allows, we could probably phase-out television stations (as we currently know them) altogether – though, again, radio is unlikely to be affected. There’ll be more on this in Part XIIc.

So instead of having a “public service broadcaster”, we would have a broad public service content service, commissioning independently-produced programming and other content from multiple sources for TV, radio and online.

Wales could even move towards having a Dutch-style system, where membership-based, task-based and community organisations share facilities to produce PSB content and receive a ring-fenced number of broadcasting hours on state-owned PSB channels based on the number of members they have. This could introduce an element of democracy, direct public ownership and further plurality to public broadcasting.

So, for example, you could have separate membership-based public broadcasting companies dedicated to sports broadcasting, the arts, religious programming, minority programming etc.