The existing regulation of broadcasting is not just content regulation. It is vital to recognise that content cannot simply be separated from the underlying structural aspects of the broadcasting sector. In particular, the issues of market power, vertical integration and concentration of ownership are elements which cannot be ignored if we wish to retain a broadcast media that is democratic and pluralistic. We would therefore propose that any future broadcasting regulator should have a clear remit to deal with concentration of ownership, media cross-ownership and all issues arising from any EU initiative on pluralism and concentration. Other structural aspects concern the economics of original programme production.
Broadcasting is currently far from being a free market.
There are specific regulations on the proportion of independent production, of original production and of European-originated production. These regulations are structural rather than content-related, but we believe it will be equally important for future broadcasting regulators to retain responsibility in such areas. In recognising the reality of technological convergence, we believe it is essential to realise that this does not automatically or necessarily imply a convergence of the services provided. On the contrary, we believe that broadcasting will remain for the foreseeable future a separate sector requiring a separate regulatory approach. Rather than a minimalist approach geared to competition rules and primarily economic criteria, we see a strong and continuing need for broadcasting regulations reflecting the aims and values of public service broadcasting.