8 August 2020 The Irish Film & Television Network
IBEC's Audiovisual Federation's Submission to the Forum on Broadcasting
20 May 2002 :
The Audiovisual Federation has submitted this report to the Forum on Broadcasting. "This submission has been prepared by IBEC's Audiovisual Federation. The Federation is the representative body for companies and organisations engaged in all aspects of the audiovisual Industry. This consensus view has been formed across a diverse group of companies with significant stakes in the development of the Irish audiovisual sector.

The Irish audiovisual sector has contributed significantly to Ireland's economy. IBEC's report on 'The Economic Impact of Film Production in Ireland 2000' puts a value of €209.5 million on the sector in 2000. Expenditure in Ireland, the key to generating domestic employment was €129.3 million. Flowing from that direct Irish employment (full time equivalents) was 1,742, while indirect employment resulting from spending on goods and services by the industry and it's employees totalled 2,167. Support for the audiovisual industry has proven to be a good investment for Ireland and we believe this can continue.

The Audiovisual Federation's main aim is to encourage the development of the sector in Ireland. We believe that strong indigenous production companies, capable of sustaining employment, are essential for the sector. The production of high quality programming with a honed creative edge will enable the industry to compete Internationally and develop as a key sector in the Irish economy. Public Service Broadcasting has a key role in supporting the indigenous sector and in realising these objectives.

The Federation defines Public Service Broadcasting, as carried out by RTE and TG4, as the creation and promotion of a uniquely Irish public service schedule and not the support of individual programmes. The Federation acknowledges and supports both funding methods used to support the industry:

1. Funding from licence fee contributions. 2. Direct funding from government

Are there distinct roles for public and commercial / independent broadcasting services in Ireland?

Yes, there are distinct roles for different broadcasting services in Ireland. Broadcasting, in its various modes, is at the heart of our society and as a result plays a number of important roles.

Commercial broadcasting cannot support the varied services associated with public service broadcasting due to the relatively small market in Ireland and the need for financial returns. Irish Public service broadcasting serves a number of functions, including:

  • Provision of a strong schedule to ensure programming relevant to an Irish audience is well promoted and accessible
  • Ensuring a platform for quality indigenous programming
  • Free to air, universally-available service to all citizens on an equal basis
  • Serving the entire Irish audience as its main responsibility
Within these purposes there should be a number of guiding aims:

  • To promote a robust and diverse indigenous production sector
  • To set and maintain production quality and high journalistic standards
  • To include innovative programming which may risk ratings
  • To cater for non-commercial yet important niche audiences
  • To provide support services for the visually and hearing impaired audiences (see appendix 1)
  • To present news and current affairs with a distinct Irish influence
  • To nurture new indigenous talent
  • To support and facilitate vocational training for the industry

Commercial broadcasters should be encouraged to address the current shortfall in indigenous content in order to maintain a recognisable Irish voice in an increasingly globalised digital maze. The growing commercial broadcasting sector in Ireland has been successful in realising a number of benefits for the Irish consumer and should continue to do so by:

  • Offering a genuine choice to consumers
  • Providing a quality alternative programme schedule
  • Prompting realistic competition and innovation
  • Encouraging better all round performance of the sector.

Clearly both commercial and public service broadcasting have distinct and important roles within the Irish industry. Given the central role and influence of broadcasting in Ireland it is essential that public funding and appropriate regulation for broadcasting be given a sufficiently high priority by government.

What arrangements should exist for determining and managing the allocation of public funding for public service broadcasting?

The Federation believes that direct government funding and license fee based funding are essential and that both should be augmented. The current shortfall in funding is causing a deterioration in schedule quality and endangering the independent production sector.

Funding methods must not dampen the required commercial thrust of broadcasters and should include transparency as a prerequisite for any increased funding. The Federation supports progressive actions currently under review to achieve transformation in RTE.

A transparent and accurate collection process is needed in order to maximise revenue and to manage benefits from licence fee based funding. The current collection system is facilitating a high level of evasion and an estimated loss of revenue in the region of €20 million per annum. As such the collection system is in need of urgent revaluation and a public tender should be issued for the service.

Determining and managing the allocation of public funds must be seen to be transparent and broadcasters receiving funding should be accountable for its appropriate use. Public broadcasters should be required to be transparent in relation to expenditure in terms of: audience requirements, services, efficiency (including total programme costing) and cost of content. Such a transparent system combined with a commitment to commissioning indigenous content will underpin the Irish audiovisual sector as a whole.

What is the role of the independent audiovisual production sector?

The Audiovisual Federation seeks to strengthen the indigenous audiovisual production sector. Increased commitments from Irish broadcasters to commissioning Irish content is needed to enable the sector to reach its full potential.

Independent producers currently supply many of RTE's most popular programmes and almost TG4's entire schedule. The sector is cost efficient, innovative and highly competitive.

The independent audiovisual production sector is well placed to deliver cost effective, high quality programming as an alternative to in house production. The sector contributes to the economy through direct employment and synergies with related sectors leading to further jobs and revenue for the exchequer (see appendix 2)

Public service broadcasting plays an essential role in fostering and sustaining the sector. The development of strong, indigenous companies that are capable of competing on international markets should be a key aim for developing the industry. Policy interventions that assist companies to consolidate and grow to a sufficient scale to breach new markets are required.

The independent production sector favours a publisher/broadcaster model as being the best way of delivering public service television broadcasting going forward.

RTE to date have operated on a mixed producer/broadcaster basis. A decision on the proposed future structures and organisational model for RTE is imminent and we await the outcome.

The dual objectives of strong, internationally competitive, independent producers and the provision of quality indigenous programming for Irish audiences can be best achieved by the strategic development of the independent sector. Broadcasters have the key role in enabling such development.

Are there distinct roles for public and commercial / independent broadcasters in the provision of services at (a) national, (b) regional, (c) local levels?

Commercial and Independent broadcasters are playing an important role at national level as TV3 and Today FM have proven. A nation-wide Digital Television service would make regional opt-outs possible and promote services at a local level. Cable operators who service a particular area could also provide tailored services for their subscriber area and include locally oriented content. While the Federation believes these services are desirable, the size of the advertising pool at local level makes their commercial viability questionable.

The success of local radio confirms that radio broadcasters have distinct roles at regional and local levels. Innovative programming and potential talent can flourish at this level. Local broadcasting also helps ensure a throughput of talented, skilled people for the sector at large.

5. What responsibilities should different broadcasters have for development and broadcasting of programme content in the Irish language?

The development and broadcasting of programme content in the Irish language should play an important part in Irish broadcasting. The success of TG4 and its important role in developing and funding independent television production is the most tangible proof of this. Their success has also led to greater regional diversity by the use of production companies based throughout the regions.

Public service broadcasters should have a remit to include Irish content as a condition for funding. Development of Irish content in commercial schedules should be considered as a possible area for funding. This would need to be predicated on 'non-marginal' schedule slots and would ensure exposure to a wider audience.

Current dedicated Irish language services have been a great success. They should be retained as the primary outlet for Irish language content. TG4 in particular should be provided with the necessary public funding to enable it to build on its initial success and to contribute to the development of the overall audiovisual sector.

Given that Irish language content will be produced in Ireland there will be benefits to the audiovisual sector as a whole and will further develop the indigenous industry.

What responsibilities should different broadcasters have for development and broadcasting of cultural content?

In answering this we need to define cultural content. Moving away from the elitist ideas of 'high' and 'low' forms of culture and developing a sense of local popular culture should be the aim of all broadcasters. Public service broadcasting should not focus solely on popular content and must maintain services for niche audiences in areas such as the arts.

Any reference to local culture must be based on culture currently evident in an area and not that historically associated with the area. Ireland now comprises a diverse range of ethnic backgrounds that must be included in any conception of Irish culture.

Public service broadcasting should not be a vehicle for some notional elitist requirement. It should aim to challenge and stimulate the audience and extend their judgement and knowledge of culture in the broadest sense. The promotion and fostering by government of local cultural content would be welcomed.

What are the responsibilities of different broadcasters to make and conserve national audio-visual heritage?

All national broadcasters should contribute to producing and conserving Irelands audio-visual heritage. Broadcasters ought to maintain their programming and make its continued use possible to a wide audience. The storage and retrieval of an accessible archive should be a priority for government and as such should be assisted, perhaps via the digital hub. This is essential in order to safeguard our audio-visual heritage for future generations.

Appendix 1
An essential aspect of Public Service Broadcasting is to includes making adequate support services available to:
a) the deaf and hearing-impaired
b) to the visually impaired

a) can be achieved through the provision of Subtitles to allow the deaf or hearing impaired understand what is being spoken on screen and at the same time to be aware of what other sounds, music and sound effects are contained in a programme.

b) is achieved through the process of audio description. This enables visually impaired audiences to follow what is happening visually on screen by way of a separate audio description track. This facility will have greater potential in future due to the availability of additional channels provided by digital television services.

I. Total number employed during all productions in that year
II. Based on a 38-hour week and a working year of 232 days. The 38-hour average is taken from a 39-hour week average for manual workers and a 37-hour week for clerical, professional and technical workers. The 232 day working year is derived as follows: 365 minus 104 days (weekends) minus 9 (public holidays) minus 20 days (average annual leave days) = 232.

Audiovisual Federation Submission

The Audiovisual Federation calls on all political parties to ensure that the policies of the next government contain an ongoing commitment to the development of the indigenous sector.

The Irish Audiovisual sector has contributed a great deal to Ireland's economy. The value of production of the industry in 2000 was €209.5 million. Expenditure in Ireland, the key to generating domestic employment and income, was €129.3 million. Flowing from that direct Irish employment (in terms of full time equivalents) was 1,742, while indirect employment resulting form spending on goods and services by the industry and it's employees, totalled 2,167. Support for the audiovisual industry has proven to be a good investment for Ireland and we believe this can continue The success of the Irish animation industry in securing two Oscar nominations should now be built upon to strengthen the audiovisual sector as a whole.

To achieve this Audiovisual Federation recommends adoption of the following measures:

1. A broadcasting policy that outlines a clear development strategy for the sector, allied with appropriate funding for public broadcasting i.e. RTE and TG4, should be developed in consultation with the industry.

2. A tax based incentive for investment in film, currently addressed by section 481, is a fundamental support for assisting film production in Ireland. This measure expires in 2005 and a similar incentive needs to be put in place up to 2010 to give long-term stability to the sector.

3. Co-production agreements between Ireland and the UK as well as other EU countries, e.g. France, Germany etc., covering film, animation and TV production should be enacted as an immediate measure. This measure would have no cost implication for the government and is currently prevalent in Europe.

4. Funding for the sectors 'not-for-profit' cultural organisations e.g. Film Institute of Ireland, Filmbase etc. should be extended. The Federation strongly suggests the appointment of a film representatives to the Arts Council.

Irish Film and TV Production Buoyant but Concerns over Ongoing Competitiveness

Total expenditure in the sector up 13% to €210 million in 2000
Net gain for the Exchequer of €16 million, continuing a 5 year trend to 2000
Irish employment in the sector up 12% in 2000 to 1,792 jobs

The year 2000 saw continued growth in the audiovisual industry in Ireland with an increase in expenditure, an increase in employment and a continuing net gain for the Exchequer. The figures were announced by IBEC's Audiovisual Federation at the launch of their report, "The Economic Impact of Film Production in Ireland – 2000", in IBEC today, Thursday 13th December. Concerns were raised however about the ongoing competitiveness of the industry with calls for changes to the tax relief scheme for film production as a partial solution.

The productions included in the report included international 'block busters' like "The Count of Monte Cristo", "The Magnificent Ambersons" and "The Tailor of Panama;" staring Pierce Brosnan. The animation film Duck Ugly and the international TV series Ballykissange were also included, as were indigenous productions such as "Open House", "It's a Family Affair" and "Ros na Rún".

Total funding for the sector in 2000 was €210 million, up form €184 million in 1999. Irish funding in 2000 was €116 million, up from €114 million in 1999. Total Irish expenditure for 2000 was €129 million, up from €117 million in 1999. Direct Irish employment (in terms of full time equivalents) in 2000 was 1,742 (a 12.1% increase on 1999), while indirect employment resulting from spending on goods and services by the industry and its employees, totalled 2,167 (a 10% increase on 1999).

For each year between 1996 and 2000 the return to the Exchequer has exceeded the tax foregone through Section 481 tax relief, rising from €8 million in 1996 to €16 million in 2000.

Tommy McCabe, Director of IBEC's Audiovisual Federation, commented "AF welcomes these generally positive indicators. The Audiovisual industry in Ireland contributes to Irish life both culturally and economically. However, AF maintains the opinion, expressed in last year's report, that the current incentives on offer in Ireland for TV and film production are significantly less attractive relative to a large number of other EU member States. Ireland is therefore less competitive as a location for film and TV production vis-à-vis its European counterparts and this could have implications for the ongoing development of the industry. One partial solution to this problem would be the introduction of 100% tax relief under the Section 481 scheme (as is the norm with other EU member States' schemes), from the existing 80%, for indigenous productions, especially for those under €5 million."

John Cummins, Chairman of the Audiovisual Federation, and Managing Director of Agtel, stated "AF is of the view that the establishment of a Co-Production Treaty with the United Kingdom that covers feature film, television production and animation would benefit the sectors involved. We welcome the expansion of the Irish Film Board and note the Government's intention to increase the Irish Film Board's funding to €12 million in 2002 as proposed by the Kilkenny Report. However, there is concern in the industry that some of the Kilkenny Report's recommendations have not yet been implemented and we are of the opinion that a reassessment of the implementation of the recommendations is required."

Audiovisual Federation
Irish Business and Employers Confederation
Confederation House
84/86 Lower Baggot Street
Dublin 2
Website: www.ibec.ie
Email audiovisual.fed@ibec.ie

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