Submission in Response to the Media Reform Green Paper: Modernising Television Regulation in Australia

This submission, by a former television producer and senior academic and a leading Australian screen studies scholar, addresses and responds to key issues and consultation questions in the Green Paper and makes several recommendations. The submission is made in the interest of supporting Australian stories on screen, growing the volume of Australian content available across all commercial (and public broadcasting) platforms providing screen content, and ultimately maintaining an innovative, vibrant and robust local screen industry. This submission does not respond to all the specific sub-questions raised in the Green Paper, rather it addresses several key issues that are most relevant to the authors’ expertise. The key recommendations of this submission, are: • The public policy objectives outlined in section 2 of this submission should be considered as potential guiding principles around which reform to media regulation is developed and determined. • The new licensing arrangements for free-to-air commercial television multi-channels proposed in the Green Paper should not proceed. A new Green Paper embodying alternative approaches in this submission, and other submissions, should be developed and issued by the Department later in 2021. Instead, the authors suggest several alternative and complementary ideas for reform: • Establish a minimum 5-year moratorium on the sale of existing television broadcast spectrum for non-television broadcasting purposes. • Each of the existing commercial networks, Seven, Nine and Ten give up a multi-channel license to create “New Player” commercial licences to encourage innovation, competition and revitalisation of free-to-air television. Three “New Player” licenses with special conditions would be auctioned to the highest bidders. • Commercial multi-channels required to run higher levels of repeat Australian Content. • ACMA to commence planning and set a date for the introduction of 4K/UHD television broadcasting in Australia utilising the DVB-T2 and/or DVB-I standards, and ACMA to initiate a trial of DVB-I in Australia as soon as is feasible. • Budget to be allocated for one-off government financial support for investment in technology upgrades associated with transitioning to 4K broadcasting. • The Federal Government should reverse its decision to withdraw digital community television licenses and a new national community television license should be created. • The proposed CAST and PING Trusts should be established. • The ABC and SBS should retain their multi-channels and be subject to Australian Content reporting requirements.