Broadcasting Committee06 Oct 04

Consultation on the proposed Ofcom Broadcasting Code: A Response from the Church of Ireland Broadcasting Committee

Consultation on the proposed Ofcom Broadcasting Code

Date of publication: 14 July 2004

Closing date for responses: 5 October 2004

A Response from the Church of Ireland Broadcasting Committee

1. Narrative

The Church of Ireland is an Anglican church operative in the two
jurisdictions of the island of Ireland. Through the Broadcasting Committee
of its General Synod it seeks to make appropriate interventions in
the debates of the broadcasting policy communities in both Irish and
British contexts.

The Broadcasting Committee of the Church of Ireland welcomes this
consultation and the opportunity for comment that it affords. In what
follows we have tried as far as is possible to respond to the actual
questions asked. At the outset however we are obliged to record that
our Christian faith informs at each stage our attitude towards public
policy formation.

In our earlier representations to Ofcom (Consultations on the Annual
Plan and on PSB Phase 1) and indeed in our early response to the
founding white paper of the Communications Act 2003, we have consistently
articulated our belief that the liberalisation of the audiovisual
market may paradoxically require more and not less regulation. We
have called for RE-REGULATION, not DE-REGULATION. We believe that
the audiovisual market can never become a ‘normalised’ market
because it bears so directly and so powerfully on the life and formation
of the human person.

We recognise that this perspective forms in direct relationship
with the confessional world that we inhabit but we do not believe
that such a confessional commitment is the only route towards such
a perspective. The human person is to be viewed in an important way
as a ‘citizen’ whose
appropriate and informed functioning within a democratic polity must
be cultivated and protected by the regulatory agencies of that polity
because it is upon such functioning that the health of the polity
finally depends. We therefore believe that our viewpoint has a right
to be heard in secular policy discussions, quite apart from the right
that it clearly has as a view that informs a substantial proportion
of the British populace. This distinctive perspective will make its
presence felt in our various responses to Ofcom.

It seems to us that in the recent past there has been a discernable
lowering of content standards across the audiovisual sector. It consequently
seems to us that Ofcom must focus on the issue of content standards
in the business of sector re-regulation. We find that the crux of
the Ofcom regulatory method to be contestable. It seeks to base judgments
on ‘generally acceptable standards’ (themselves potentially
fluctuating with each new batch of Ofcom research) and thereby risks
a certain circularity.

The key idea of regulating for the protection of minors depends
on a view of the persuasive power of the audiovisual sector which
logically extends to adults as well as to children and young people. ‘Generally
acceptable standards’ then risk being defined by a group that
is already exposed to an audiovisual product that influences that very
definition. We find that the regulator must have a concern for the
protection and information of the ‘citizen’ that supercedes
a concern for the interests and demands of the ‘consumer’ or,
for that matter, of the broadcaster.

It has been well observed that ‘there is a large difference
between the public interest and what interests the public’ (Cass
Sunstein) – it seems to us that the regulator must prioritise
the regulation of content above nakedly commercial factors. The Communications
Act 2003 requires Ofcom to hold in balance a number of commercial
and non-commercial imperatives but we call for the delineation of
a hierarchy within these competing demands that prioritises the non-commercial
as a higher order good.

The Broadcasting Committee of the Church of Ireland is concerned
with the health of our society. Freedom of expression, we agree, is
an essential human right, but freedom can never be equated with licence,
and rights are inalienably connected with responsibilities. Freedoms
must we feel be balanced by the conscientious and dynamic activity
of the regulator. We applaud all that the Code proposes for the protection
of the young and the vulnerable but we maintain that the insight upon
which these protections are founded (the insight of a hugely influential
medium) is an insight that applies much more extensively within our
society than the Code might be taken to suggest.

Broadcasting policy should always have the information enrichment
and the democratic enabling of the public in prior view. As one specific
means to this end, and as a consequence of the ‘lighter’ form
of regulation that is being proposed, we call for Ofcom to advance
a strategy of public media literacy. We make two immediate suggestions-
the copper-fastening and standardising of the watershed and the widespread
implementation of embedded content labelling in the case of potentially
problematic programme types. Ofcom must then pursue the development
and implementation of a wider strategy of public media literacy with
considerable urgency. This we believe to be consonant with Ofcom’s
statutory duty as expressed in the Communications Act 2003 Part 1.10
and with Ofcom’s announced intention in the Annual Plan 2004/05
8.7 E2.

2. Specific Responses to Ofcom’s questions

Ofcom Broadcasting Code Introduction

Question 3a:

Does the introduction appropriately set out the purpose and background
of the Code and does it achieve the right balance between giving
broadcasters creative and editorial freedom while protecting listeners
and viewers?

The Broadcasting Committee of the Church of Ireland agrees, within
limits that will be subsequently articulated, that it does.

Question 3b:

Should there be one Code or more than one Code? (Please see the
RIA in section 14 of this consultation for further information.)

The Broadcasting Committee of the Church of Ireland favours the introduction
of a single, unified code and recommends additionally that the code
be accompanied by a Plain English version.

Question 3c:

Is the approach suggested by Ofcom the best approach to the proposed
new Code/s? If not, is there a better approach and, if so, what?
(Please see the RIA in section 14 of this consultation for further
information.)

The Broadcasting Committee of the Church of Ireland feels that
the proposed approach has within it the potential for great flexibility
and latitude in regulation. Unfortunately what is flexible risks
also being unclear and uncertain. We agree with the observation in
14.2.36 that ‘the loss of explanatory narrative… may be viewed
as a genuine loss in the quality of advice attached to the code’.
We expect that a vast amount of Ofcom time will be devoted to single
case adjudication. We suspect that in many instances Ofcom will be ‘making
rules by whim’(cf.1.2.3) or at least reserving to itself an inappropriate
right of definition. We do not agree with the observation later on
in 14.2.36 that ‘increased flexibility could also have the effect
of reducing regulatory uncertainty’- this we can imagine only
within the undesirable limits of a form of regulation that is so ‘flexible’ that
it is in truth no regulation at all.

In our opinion what must not be allowed to suffer are content standards.
Ofcom must give due heed to the research approach it is committed to
and due heed also to the vulnerable social groupings whose interests
and whose freedom from harm and offence it is duty bound (by the Act
and by the TWF directive) to defend. There is a balance between the
stimulation of commerce and creativity in the audiovisual industries
and the protection of the vulnerable. In seeking this balance the Broadcasting
Committee of the Church of Ireland maintains that there should always
exist a bias in favour of the interests of the vulnerable.

Question 3d:

Should the Code differentiate between different types of services
with different rules for different services, or does the proposed
approach allow sufficient latitude for services to interpret the
rules appropriately for their audiences? (Please see the RIA in section
14 of this consultation for further information.

With the aforementioned reservations, the Broadcasting Committee
of the Church of Ireland believes that the proposed approach does allow
sufficient latitude for different types of services to interpret the
rules.

Section 4

Protecting the Under Eighteens

Question 4a:

Are the principles, rules and meanings necessary, consistent,
proportionate and achievable? If not, can the wording be improved
and if so how?

The Broadcasting Committee of the Church of Ireland generally agrees
with what is found here. We are uncertain that the BBFC age delimitations
are the best ones for use in the Code- it seems to us that a good case
can be made for defining a child as a human person under 16, not 15.

In addition to appropriate scheduling we believe that all audiovisual
material of a nature inappropriate to its consumption by children or
young people should be identified by clear verbal and visual warnings
before the commencement of the programme and by an on-screen symbol
during the full duration of the broadcast. On radio we believe that
a labelling mechanism must also be devised in partnership with the
industry.

We defend strongly the notion of the watershed as a universally recognised
and observed rule but we anticipate its declining effectiveness in
a technologically changing world. We find that content labelling to
be necessary as a direct consequence of technological advance. Children,
young people and the otherwise vulnerable need to be protected and
we believe that embedded labelling is a valuable tool in this respect.

Question 4b:

Are there any principles, rules or meaning we have not put here
which would achieve the intentions of the Communications Act and
other applicable legislation and be necessary, consistent, proportionate
and achievable?

The Broadcasting Committee of the Church of Ireland thinks not.

Question 4c:

Are the proposed definitions of children and young persons appropriate?

The Broadcasting Committee of the Church of Ireland prefers to define
a child as a human person under 16, not under 15.

Question 4d:

Do we need rules regarding violence and dangerous behaviour,
smoking, drug taking etc as proposed in the Code or are such matters
already covered by other rules?

The Broadcasting Committee of the Church of Ireland believes that
rules are needed- in the protection of the young and the vulnerable
the code must not fall foul of its innate potential for unclarity.

Question 4e:

Which of the options described in the RIA regarding the watershed
on premium subscription services is the best option and why? (If
a new place is proposed for the watershed, what is it, and why?)
What technical and other protectionscan broadcasters and
platform operators put in place to protect children?

The Broadcasting Committee of the Church of Ireland prefers Option
2. We believe that the establishment of the watershed at 21.00 would
offer a greater consistency of approach. The notion of the watershed
is one that we defend though realising the likelihood of its declining
effectiveness in future years. We defend it because it is currently
a successful part of a ‘media literacy’ approach- the UK
public’s knowledge of it is well established by Ofcom research.
It seems to us that a renewed commitment to a (standardised) watershed
might then give added impetus to the other pillar of a media literacy
strategy we have already suggested- clear embedded content labelling
for potentially offensive programming which we believe should apply
on all TV channels.

Question 4f:

Which of the options described in the RIA on the scheduling of programmes
regarding the paranormal is the best option and why?

The Broadcasting Committee of the Church of Ireland prefers Option
1. This is consonant with a strategy that attempts to buttress the
notion of a watershed and promote afresh the strategy of public media
literacy. We wonder at the evidential basis for the original distinction
between children watching PSB and children watching other TV services.
Perhaps the watershed in this respect should be extended to other channels?
This would meet some of the expressed worries of the PSBs. We would
ask also for the issue of embedded content labelling to be explored
in relation to all such programming.

Question 4g:

Should cash prizes be specifically forbidden in children's programmes?

The Broadcasting Committee of the Church of Ireland proposes that
cash prizes be forbidden in children’s programmes. It agrees
with Ofcom in finding no reason for separate codes for Radio and
TV in this respect. It further regards the ad absurdum example
given in background point 46 as patterning a most unlikely scenario.

Question 4h:

Should there be rules linking the scheduling of films to the BBFC
classifications?

The Broadcasting Committee of the Church of Ireland believes that
the BBFC classifications provide some assistance in the matter of film
scheduling.

Section 5

Harm and Offence

Question 5a:

Are the principles, rules and meanings necessary, consistent, proportionate
and achievable? If not, can the wording be improved and if so how?

The Broadcasting Committee of the Church of Ireland has already
drawn attention to the methodological circularity which it believes
is present in the approach. It further wonders whether ‘harm and offence’ is
in fact any more objective than the older idea of ‘taste and
decency’. It finds the determination of ‘potential’ harm
to be excessively problematic. The introduction of ‘context’ as
a potentially mitigating factor we believe will involve the regulator
in making intensely situated judgments which may prove difficult
for any anticipatory process of compliance.

Question 5b:

Are there any principles, rules or meaning we have not put here which
would achieve the intentions of the Communications Act and other applicable
legislation and be necessary, consistent, proportionate and achievable?

The Broadcasting Committee of the Church of Ireland refrains from
comment.

Question 5c:

Should a rule on hypnosis be included and if so what evidence of
harm or potential harm is there regarding the use of hypnosis on television
or radio audiences?

The Broadcasting Committee of the Church of Ireland refrains from
comment.

Question 5d:

Is the inclusion of R18 and R18 standard material compatible with
the TWF Directive which requires that nothing is included in licence
services which might seriously impair the physical, mental or moral
development of minors?

The Broadcasting Committee of the Church of Ireland finds a dissonance
to exist between the requirements of the TWF directive and the scheduling
of R18 and R18 Standard material.

Question 5e:

If the answer to 5d is yes, then are there technical and other protections
that broadcasters and platform operators can put in place to protect
the under eighteens, who should not, and adults, who may not wish to,
access R18 and R18 Standard material? (the Act section 319(2)(a)(f)
and 319(4))

N/A

Question 5f:

Which of the options described in the RIA regarding R18s, and R18
Standard material is the best option, and why?

The Broadcasting Committee of the Church of Ireland appreciates
Ofcom’s
attempt to keep in balance the periodically competing demands of freeing
the sector from unnecessary regulatory burden and protecting the public
from harm and offence. In a mature society citizens must be allowed
to exercise freedom of choice where the results of that choice do not
cause harm or offence to other citizens, or otherwise adversely affect
healthy democratic functioning. It is apparent that the technologies
of conditional access can provide a secure means for the exercise of
a citizen’s choice in viewing R18 or R18 Standard material.
A wider and more difficult question (related to the question of the
portrayal of the violent) is whether the viewing of R18 and R18 Standard
material actively diminishes the ability of the viewer to relate
normally and socially to other members of the public.

The Broadcasting Committee of the Church of Ireland would then
be unhappy with any approach to R18 and R18 Standard material that

viewed the issue solely as a question of protecting minors and those
disinclined to view such material. If this is the only question to
be asked then we agree that a technological solution is at hand.
We urge however that the wider issue of how vulnerable and other
groupings are to be protected from the potential social (ie ‘context’) effects
of such viewing needs to be researched more extensively by Ofcom and
discussed more fully by all interested parties before any regulatory
change is effected. Ofcom establishes ‘context’ as an important
factor in its decision making process- we hold that a considerable
body of evidence and analysis exists which suggests that ‘social
context’ is influenced and effected by the audiovisual material
that individual citizens may choose to expose themselves to. If this
is in fact demonstrable then the availability of such a choice might
reasonably be the subject of continuing social regulation and prohibition.

Question 5g:

Should the restrictions in place regarding transmitting 'adult' sex
material on certain premium subscription services, PPV and PPN services
be changed, and if so what restrictions should be in place, and on
which services?

The Broadcasting Committee of the Church of Ireland on balance thinks
not at this stage though subsequent discussion and research as suggested
above should be implemented.

Question 5h:

Should there be a prohibition on the transmission of films, videos
and DVDs refused a BBFC certificate. If not should there be any rule
and if so what rule?

The Broadcasting Committee of the Church of Ireland thinks that there
should be such a prohibition.

Question 5i:

Can a lesser level of technical intervention achieve the same protection
for those with photosensitive epilepsy?

The Broadcasting Committee of the Church of Ireland refrains from
comment.

Section 6

Crime

Question 6a:

Are the principles, rules and meanings necessary, consistent, proportionate
and achievable? If not, can the wording be improved and if so how?

The Broadcasting Committee of the Church of Ireland refrains from
comment.

Question 6b:

Are there any principles, rules or meaning we have not put here which
would achieve the intentions of the Communications Act and other applicable
legislation and be necessary, consistent, proportionate and achievable?

The Broadcasting Committee of the Church of Ireland refrains from
comment.

Section 7

Religion

Question 7a:

Are the principles, rules and meanings necessary, consistent, proportionate
and achievable? If not, can the wording be improved and if so how?

The Broadcasting Committee of the Church of Ireland agrees that they
are.

Question 7b:

Are there any principles, rules or meaning we have not put here which
would achieve the intentions of the Communications Act and other applicable
legislation and be necessary, consistent, proportionate and achievable?

The Broadcasting Committee of the Church of Ireland thinks not.

Question 7c:

Which of the options regarding appealing for funds for religious
programmes and/or services described in the RIA, section
14 of this consultation should Ofcom include in the Code and why?

The Broadcasting Committee of the Church of Ireland would support
the implementation of Option 3. This would have the advantage of
providing a greater consistency of approach and enable the development
of a religious programme culture that was perhaps more creative.
We note Ofcom’s
point that already religious television services that openly fundraise
are based outside the UK and yet are watched within the jurisdiction.
The creation of a level playing field would we believe be desirable.
We feel also that citizen consumers have by now reached a degree of
viewing refinement which is high enough to enable them to cope with
on-air religious appeals for money. This should not however preclude
Ofcom’s continuing activity in the development of public media
literacy.

Question 7d:

Should religious programmes on non specialist television services
be allowed to recruit?

The Broadcasting Committee of the Church of Ireland recognises that
there is a distinction to be made between seeking to raise money and
seeking to recruit converts. However, the protections proposed in the
Code (4.5 and 4.6) should prove strong enough for the job in hand.
The presence of embedded content labelling, together with a strategy
for the development of public media literacy which should be devised
and commenced with some urgency, we believe to be key in this matter.

Question 7e:

Does the final rule in this section provide sufficient protection
for children and susceptible audience members or is it, conversely,
too protective?

The Broadcasting Committee of the Church of Ireland believes that
embedded content labelling might enhance the degree of protection afforded.

Section 8

Due Impartiality and Due Accuracy and Undue Prominence of Views
and Opinions

Question 8a:

Are the principles, rules and meanings necessary, consistent, proportionate
and achievable? If not, can the wording be improved and if so how?

The Broadcasting Committee of the Church of Ireland thinks yes.

Question 8b:

Are there any principles, rules or meaning we have not put here which
would achieve the intentions of the Communications Act and other applicable
legislation and be necessary, consistent, proportionate and achievable?

The Broadcasting Committee of the Church of Ireland does not think
so.

Question 8c:

Does this section encourage imaginative and challenging programming
on controversial matters?

In general, yes. The Broadcasting Committee of the Church of Ireland
reckons that the health of our democracy is assisted when a genuine
plural ecology of opinion is enabled. We believe that our society is
mature enough to respond to programmes with a perspective and news
with an agenda. We would find however that Ofcom should again be diligent
in the development and implementation of a strategy for public media
literacy.

Question 8d:

In particular do rules 5.11, 5.12 and 5.13 and the associated meanings
of "personal view" and "authored" programmes
give broadcasters enough flexibility to produce challenging programmes
while ensuring that the Act is complied with?

The Broadcasting Committee of the Church of Ireland thinks so, again
the challenge for Ofcom will be to ensure the flourishing of public
media literacy.

Question 8e:

Would appropriate labelling help the UK audience understand the nature
of retransmitted news services (not primarily intended for the UK market)?

The Broadcasting Committee of the Church of Ireland is fully in favour
of the widespread use of labelling in partnership with the implementation
of a strategy for public media literacy.

Section 9

Election and Referendum Reporting

Question 9a:

Are the principles, rules and meanings necessary, consistent, proportionate
and achievable? If not, can the wording be improved and if so how?

The Broadcasting Committee of the Church of Ireland thinks so.

Question 9b:

Are there any principles, rules or meaning we have not put here which
would achieve the intentions of the Communications Act and other applicable
legislation and be necessary, consistent, proportionate and achievable?

The Broadcasting Committee of the Church of Ireland thinks not.

Section 10

Fairness

Question 10a:

Are the principles, rules and meanings necessary, consistent, proportionate
and achievable? If not, can the wording be improved and if so how?

The Broadcasting Committee of the Church of Ireland thinks so.

Question 10b:

Are there any principles, rules or meaning we have not put here which
would achieve the intentions of the Communications Act and other applicable
legislation and be necessary, consistent, proportionate and achievable?

The Broadcasting Committee of the Church of Ireland thinks not.

Section 11

Privacy

Question 11a:

Are the principles, rules and meanings necessary, consistent, proportionate
and achievable? If not, can the wording be improved and if so how?

The Broadcasting Committee of the Church of Ireland thinks so.

Question 11b:

Are there any principles, rules or meaning we have not put here which
would achieve the intentions of the Communications Act and other applicable
legislation and be necessary, consistent, proportionate and achievable?

The Broadcasting Committee of the Church of Ireland thinks not.

Section 12

Sponsorship

Question 12a:

Are the principles, rules and meanings necessary, consistent, proportionate
and achievable? If not, can the wording be improved and if so how?

The Broadcasting Committee of the Church of Ireland thinks so.

Question 12b:

Are there any principles, rules or meaning we have not put here which
would achieve the intentions of the Communications Act and other applicable
legislation and be necessary, consistent, proportionate and achievable?

The Broadcasting Committee of the Church of Ireland thinks not.

Question 12c:

Should the current rules for television sponsorship be changed to
allow non-promotional references to the sponsor in the programme they
are sponsoring?

The Broadcasting Committee of the Church of Ireland sees no problem
with the presence of editorially justified non-promotional sponsor
references.

Question 12d:

Should the rule restricting the content of sponsorship credits on
television be changed and is the proposed rule (9.17) in the draft
Code appropriate?

The Broadcasting Committee of the Church of Ireland supports the
introduction of 9.17 on the grounds of consonance with the TWF directive.

Question 12e:

Should Ofcom remove the 5 second limit on sponsor references in programme
trailers, and is it appropriate to replace it with a requirement that
sponsor references in trailers remain brief and secondary?

The Broadcasting Committee of the Church of Ireland has no objection
to the removal of the 5 second rule provided that Ofcom is indeed
determined in judgment to define and enforce where necessary the
meaning of ‘brief
and secondary’.

Question 12f:

Does the Code require a rule that contains more detailed description
of what is an acceptable sponsorship message than that proposed in
the Code (rules 9.8 and 9.9)?

The Broadcasting Committee of the Church of Ireland feels that the
rules as they are currently proposed are sufficient for the subsequent
business of discernment and interpretation.

Question 12g:

Should the restriction on the length of sponsorship credits for ITV,
Channels 4 and Five be removed?

The Broadcasting Committee of the Church of Ireland finds that
the restriction should indeed be removed. The original rationale
for the limitation –to prevent the channels from extending
their advertising revenue through sponsorship addition- has less
force in a future where spot advertising revenue is likely to be
severely diminished.

Question 12h:

Are the rules relating to credits (9.8 to 9.18) in the proposed Code
sufficient to ensure transparency and maintain separation?

The Broadcasting Committee of the Church of Ireland believes so when
the rules are partnered with the implementation of a strategy for public
media literacy.

Question 12i:

Is it appropriate to retain the prohibition on the sponsorship of
a whole TV channel or radio station?

The Broadcasting Committee of the Church of Ireland inclines towards
the view that such a prohibition might indeed be relaxed if public
media literacy can be sufficiently cultivated. Channel sponsorship,
with appropriate safeguards, might become an important source of industry
revenue in a future defined by a decline in more classical advertising
spend.

Question 12j:

How can the rules on sponsorship by betting and gaming companies
best be consolidated for radio and television?

The Broadcasting Committee of the Church of Ireland refrains from
comment.

Section 13

Commercial References and Other Matters

Question13a:

Are the principles, rules and meanings necessary, consistent, proportionate
and achievable? If not, can the wording be improved and if so how?

The Broadcasting Committee of the Church of Ireland thinks so.

Question 13b:

Are there any principles, rules or meaning we have not put here which
would achieve the intentions of the Communications Act and other applicable
legislation and be necessary, consistent, proportionate and achievable?

The Broadcasting Committee of the Church of Ireland thinks not.

Question 13c:

Should there be a rule for both radio and television relating to
how viewer and listener competitions are conducted, and should there
be a rule that limits the use of competitions with brand mentions to
within programmes?

The Broadcasting Committee of the Church of Ireland refrains from
comment.

Question 13d:

Are the rules for charity appeals appropriate and should they be
extended to include radio?

The Broadcasting Committee of the Church of Ireland thinks so and
thinks further that radio should be included.

Question13e:

Is the provision for community service announcements appropriate
and should it be extended to include radio?

The Broadcasting Committee of the Church of Ireland thinks so and
thinks further that radio should be included.

Question13f:

Should broadcasters be allowed to promote programme related material
wherever that is relevant and editorially justified in the programme?

The Broadcasting Committee of the Church of Ireland thinks so.

Question13g:

Should the rule prohibiting television services appealing for funds
to make programmes and fund services be removed, kept or altered? If
altered - then how should it be altered? Please see the RIA, section
14 of this consultation for further information.

As before, the Broadcasting Committee of the Church of Ireland prefers
Option 3.

Question13h:

If the rule referred to in 13g is removed, will this provide a complimentary
mechanism for raising funds or will it be a substitute mechanism?

The Broadcasting Committee of the Church of Ireland supposes that
the mechanism will be complementary.

Question13i:

Given the substantial market share held by some channels, would this
have a distortive effect, in which case should Ofcom use its competition
powers?

The Broadcasting Committee of the Church of Ireland inclines to the
view that the use of competition powers will be unnecessary: the multi-channel
reality and the accompanying diminution of classical advertising revenues
in any likely future, together with the PSB burdens currently laid
on those channels with substantial market share, makes an argument
for the removal of the 13g rule being understood as a form of justifiable
compensation.

Question 13j:

Should there be rules regarding merchandising or not? And if so what
rules? Please see the RIA in section 14 of this consultation for relevant
arguments.

The Broadcasting Committee of the Church of Ireland calls for the
creation of a level playing field through the removal of merchandising
rules.

Section 14

Regulatory Impact Assessment

Question 14a:

Has this RIA correctly identified the significant changes (as described
in the opening paragraph of the RIA) made in this consultation paper.
If not, what other changes are significant, and why?

The Broadcasting Committee of the Church of Ireland thinks so.

Question 14b:

Do you disagree with the assessment of benefits and disadvantages
drawn up in this RIA and, if so, how would you suggest it should be
altered?

The Broadcasting Committee of the Church of Ireland agrees within
the limits of its competence.

Question 14c:

Can you assist with information which will help us quantify the increased
costs or savings of the various options in this RIA?

The Broadcasting Committee of the Church of Ireland is unable to
assist in this respect.

The Broadcasting Committee of the Church of Ireland once again
thanks Ofcom for the opportunity to participate in this consultation.
The Committee has a pronounced interest in content standards and
in the development of strategies for public media literacy. We are
happy to assist in the future in any way that might mutually be felt
to be appropriate.

Membership of the Committee-

Mr Tony Fleck (Chairman)

The Revd Dr Alan McCormack (Secretary)

The Revd John McDowell (Treasurer)

Ms Janet Maxwell (Director of Communications)

The Revd Brian Parker (Media officer)

Ms Ruth Buchanan

The Most Revd Dr Richard Clarke

The Revd Michael Parker

The Revd Eileen Cremin

The Revd Tom Gordon

The Revd Dr William Crawley (Consultant)

Posted 6th October 2004