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Australian Broadcasting Corporation submission to Screen Australia Television Funding A Review of Screen Australia’s Role and Objectives 2010 August 2010

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Page 1: Australian Broadcasting Corporation · 2014-07-28 · and broadcasting industries, including the national broadcasters, and an undertaking ... enabled the ABC to resume a leading

Australian Broadcasting Corporation

submission to

Screen Australia

Television Funding A Review of Screen Australia’s Role and Objectives 2010

August 2010

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ABC Submission to Screen Australia’s Television Funding Review 2010 1

Executive Summary The ABC proposes, in relation to Screen Australia’s current review, the following outcomes:

• A clear articulation of Screen Australia’s strategic intentions, in relation to production and broadcasting industries, including the national broadcasters, and an undertaking to explore with industry ways in which to increase transparency in relation to decision-making, funding and guidelines.

• Screen Australia should consider increasing partnerships with broadcasters in relation to feature film funding. Support for a 40% Producer Offset for high-end television drama, including children’s drama, and documentaries, subject to appropriate guidelines.

• Should Government agree to an enhanced Offset, a continuation of Screen Australia’s role in relation to terms of trade, with minimum licence fees becoming part of the certification process.

• If a 40% Producer Offset were to eventuate, Screen Australia should consider alternative ways to support the sector, including: (a) targeted development strategies for television drama, including resource-intensive

approaches, extended development and workshops; (b) more engagement with young innovators and innovation strategies for content

delivered to Australian screens; (c) an alternative approach to programs with artistic and cultural merit, which could

encompass broadcasts of live events.

• In the absence of a 40% Producer Offset, continue Screen Australia’s role as gap “financier”.

• Consider the meaning and funding available for Nationally Significant Programming in the context of national free-to-air broadcasting.

• Explore initiatives to fund a variety of nationally-significant Indigenous programs, and so continue to build the Indigenous independent film sector.

• Re-affirm and develop the relationship between the ABC and Screen Australia in relation to documentaries; review and formalise the funding split for domestic documentaries; acknowledge the importance of “slate financing” in the building of a sustainable sector; and recognise the ongoing benefits of the National Documentary Program (NDP) and tied funding.

• Screen Australia should maintain its current approach on minimum licence fees, and restate the case for free-to-air broadcasters and pay-TV in relation to the NDP.

• Acknowledge and act on the validity of the ABC’s concerns in relation to children’s programming, as they relate to branding, the necessity for holdbacks, and the need for pay-TV to make a stronger contribution to licence fees.

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ABC Submission to Screen Australia’s Television Funding Review 2010 2

Introduction The Australian Broadcasting Corporation (ABC) welcomes the opportunity to make a submission to Screen Australia’s review of its role and objectives in relation to television funding.

As a statutory corporation under the Australian Broadcasting Corporation Act 1983 (“the ABC Act”), the ABC seeks a presence on all major electronic media platforms. The ABC Act, which includes the ABC Charter, requires the Corporation to provide access to all Australians to a range of information, entertainment and other programming.

As a result, the ABC plays an important role in contributing to Australia’s screen culture. The ABC Charter requires that the Corporation broadcast programs that “contribute to a sense of national identity and inform and entertain, and reflect the cultural diversity of, the Australian community…”

Diverse, high-quality and innovative local content, which is of national significance and which engages with Australian audiences, is at the centre of the ABC’s Charter obligations, and such programming finds a home on ABC1, ABC2 and the recently-launched ABC3 for children.

The Corporation recognises the tremendous cultural benefits generated for Australians by government support for Australian content through a variety of mechanisms, including tax rebates, contestable direct funding, funding of the national broadcasters and regulations specifying minimum local content levels.

In particular, many ABC programs, such as documentaries, short-form mini-series and children’s drama programming, involve funding provided by Screen Australia.

The ABC plays an integral role in the broadcasting environment and is intimately involved in supporting and sustaining an independent production sector. From 2006–07 to 2008–09, the Corporation’s commitment to independent production across all genres was $144 million. This contributed to production budgets of $318 million, delivering almost 700 hours of Australian content to Australian audiences.

Historically, the ABC has been a leader in the delivery of innovative and high-quality Australian drama, although resourcing or funding issues have impeded its ability to do this in some periods. Significant increased funding for drama in the 2009 Federal Budget has enabled the ABC to resume a leading role, working with industry partners to develop, finance and produce Australia drama for delivery across an increasing range of platforms to the Australian community.

The Australian Government’s 2009 increase in ABC funding involved two significant outcomes:

• $67 million over three years for a new dedicated children’s channel, ABC3; and

• $70 million for local drama production over three years.

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The ABC‘s expects that over the current funding triennium—from 2009 to 2012—it will commit $238 million, generating over 1,000 hours of production ultimately worth over $400 million. This will include $82 million for new Australian drama, generating 133 hours of content and a total of $130 million in Australian production. It will also include $26 million for Australian comedies, generating 43 hours of content valued at $35 million. The ABC will allocate a further $48 million to Australian children’s programming over the three years, generating over 450 hours of production worth over $100 million. It will spend some $90 million for Australian documentaries, entertainment and factual programs, generating 405 hours of content and, ultimately, $150 million in production. The ABC will need to work with Screen Australia to reach these targets.

As a broadcaster closely involved with the independent production sector, with funding bodies, and with providing Australian content to Australian audiences, the ABC has a keen interest in and engagement with the cultural policy settings that apply to the creation of audiovisual content, and which are designed to promote and support the creation of high-quality local content for Australian audiences.

Accordingly, the ABC suggests that the following matters should be considered in relation to Screen Australia’s objectives and role, especially when considering television programming funding in what is now a rapidly-changing media landscape involving many new forms of content delivery and business activity, none of which has yet delivered a satisfactory business model for funding high-end television productions.

The Role of Screen Australia Strategic Intentions

The first term of reference for the Review is to:

1. Confirm the objectives and role of Screen Australia with regard to television funding, taking into account levels of investment and the role the agency has in developing and producing innovative and nationally significant television programming.

The ABC acknowledges and values the vital role that Screen Australia plays in supporting the development and sustainability of Australia’s independent production sector. The ABC and Screen Australia share a common interest in ensuring that Australian audiences have access to high-quality, innovative and culturally-significant Australian-made television content and, to that end, have engaged in various formal and informal partnerships to deliver these shared goals.

As a television broadcaster, the ABC naturally has a focus on television content, and on developing and refining an appropriate mix of measures to ensure that high-quality television content continues to be produced. There is currently a significant alignment between the ABC and Screen Australia in relation to policy and the funding of Australian television content. The ABC welcomes this Review as an opportunity to identify and confirm

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ABC Submission to Screen Australia’s Television Funding Review 2010 4

common goals and identify further opportunities for collaboration and partnerships, and so continue to leverage these synergies to deliver content.

This review also provides a timely opportunity for Screen Australia to define its objectives and role in relation to television funding. Broadcast television is, and will remain for the foreseeable future, the most significant source for the funding and delivery of Australian content to Australian audiences. In the ABC’s view, it is important for Screen Australia to articulate its strategic intentions with regard to its relationship to the independent sector and the broadcasting sector, especially the national broadcasters, in the context of its overall framework for funding.

The national broadcasters are another key source of direct government funding for Australian television programming, and it is important that Screen Australia presents a vision regarding the way it sits in the policy landscape, along with the national broadcasters, as one of the Government’s policy levers for such programming.

The ABC considers that Screen Australia should not decrease its funding of television drama programming below the current level of $18–20 million, and similarly should maintain at least its current level of funding for documentaries.

Transparency

The ABC believes that the industry would benefit from an increase in transparency in relation to Screen Australia’s funding decisions.

While the principle of the “lowest ask” is understood by the industry—and is understandable in relation to limited funding—it is important that television broadcasters and producers are in a position to understand the reasons why their projects were accepted or rejected and what additional features or aspects are required to make proposals suited to funding support from Screen Australia.

For this reason, the ABC believes that the industry would benefit from an increase in transparency in relation to Screen Australia’s funding decisions and Guidelines.

This could be done by holding formal discussions between Screen Australia, producers and the broadcasters to explore measures to improve transparency.

Specifically with regard to the Low Budget Drama Program and the Innovation Fund the ABC believes there is scope for greater transparency and clarity with regard to Screen Australia’s objectives and expectations of projects for those funds.

Recommendation 1: A clear articulation of Screen Australia’s strategic intentions, in relation to production and broadcasting industries, including the national broadcasters, and an undertaking to explore with industry ways in which to increase transparency in relation to decision-making, funding and guidelines.

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Partnering with television broadcasters

Screen Australia currently spends in the order of $18–20 million per year on television drama, including children’s drama. By comparison, it spends $22–26 million on feature films.

Television currently provides a much greater return in terms of audiences than theatrical release. This is one key performance indicator that should be considered in formulating Screen Australia’s policy approaches. With the decline of marketplace attachments worldwide for Australian features, the local broadcast market is a source that can and should be nurtured.

In other countries, partnerships between broadcasters, funding bodies and feature film producers are a matter of course. Examples include TF1 in France, Italy’s RAI, the broadcaster pre-sales required as part of the theatrical documentary initiative funded by Telefilm Canada and the Rogers Group of Funds, joint ventures involving the BBC and Channel Four in Britain and other examples from the European and Asian film industries.

In Australia, Samson and Delilah, which was supported by the ABC with a pre-sale, made around $2.7 million at the box office, but still managed to attract just under a million viewers nationally to its release on ABC1. It was eighteenth in the top thirty shows for November 2009.

The ABC, which similarly provided a pre-sale for the successful Bran Nue Dae, believes this kind of partnership represents an appropriate model for increasing the domestic visibility of Australian feature films. The ABC believes it could work with Screen Australia to ensure that a more television audience-oriented focus and better audience outcomes are brought to bear on at least some of its feature film slate.

Recommendation 2: Screen Australia should consider increasing partnerships with broadcasters in relation to feature film funding.

A 40% Producer Offset for Television Producers

As set out in its submission to the Government’s recent review of the independent production sector, the ABC believes that a 40% Producer Offset for high-end television drama (telemovies and miniseries, including children’s) and documentaries is an important first step in redressing the current imbalance in funding, and provides an important way forward for the financing of television programs. This increase should be funded through an increased commitment from Government, rather than a reallocation of existing funding resources.

The introduction of 40% Offset would increase the volume of television programming that is able to be made in Australia. Furthermore, a 40% Offset for high-end drama and documentary television programming, with guidelines designed to avoid misuse or abuse, would lead to orderly, modest growth, as it would be capped by market demands. An increase in the Producer offset for television to 40% would provide for a market-sensitive and sector-agnostic support mechanism for television production.

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In the interim and in a climate of limited funds, it is important that Screen Australia focus on maintaining, at a minimum, the funding currently available for television drama.

Screen Australia’s Role in relation to a 40% Offset

The ABC believes that the independent production sector and Screen Australia would benefit if the Producer Offset were increased to 40% for high-end television programming and that it should be supported by Screen Australia. The argument made by Government in relation to feature films—cited in the terms of reference for this review—applies even more readily to television program production:

“Because the Producer Offset can be the primary vehicle of Government support for many productions, Screen Australia will be able to invest more funding in activities not directly associated with production. These include individual and project development activities, and those activities which provide the wider Australian community, including regional Australians, with access to Australian audiovisual product.”

The current caps on Screen Australia’s available subsidy mean that the many viable businesses in the production sector are constrained. If the Offset were increased, Screen Australia would then have the resources to engage in more strategic, merit-based activities, for example to raise the bar of television drama writing and also more production-based initiatives designed to develop talent and encourage innovation.

Recommendation 3: Screen Australia should support a 40% Producer Offset for high-end television drama, including children’s, and documentaries, subject to appropriate guidelines.

Government Objectives and High-End Television Programming

Government has already played a significant role, via regulation and a long-term bipartisan support for indirect and direct subsidy models, in ensuring that high-end Australian television drama has flourished on the free-to-air networks.

In an environment characterised by platform convergence and audience fragmentation, it is essential that the Government continues to support diverse high-end content and diverse avenues for delivery to consumers.

Australian content on television, especially drama, has a proven track record, responsive audiences, and a substantial market component. Today, television provides the most accessible way for Australian audio-visual material to engage with Australian audiences, reflect Australian culture and tell Australian stories.

Moving the Producer Offset to 40% would reward producers with strong marketplace relationships, allow producers active in television to bypass bureaucracy, and encourage larger producers able to cash-flow the rebate themselves to directly run it into their finance plan. In contrast to feature films, which are heavily dependent on direct subsidy, as well as

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the Offset, and are usually made on an intermittent one-off basis, this would drive television production and help maintain it as the engine-room of the industry.

Any decision to increase the Producer Offset for television productions to 40% would be one for Government in the context of its cultural policy objectives. However the ABC believes that if a 40% Producer Offset were to extend to Screen Australia’s current television slate (other than its innovative strands), then a mechanism to set minimum licence fees should be maintained. Such an arrangement should be designed to support the long term viability and vitality of the independent production sector.

Should such a policy position be adopted by Government compliance with the minimum licence fees and rights ceilings set out in Screen Australia’s terms of trade should become a certification requirement for any content that would be subject to those terms if it were to receive funding from Screen Australia. The extent and scope of the terms of trade should remain as they are today with a focus on high end content and allow for flexibility in relation to projects aimed at new talent or meeting innovative objectives..

Recommendation 4: Should Government agree to a 40% Producer Offset, Screen Australia to continue its role in relation to terms of trade and minimum licence fees.

Screen Australia’s Role as “Financier” and “Umpire”

One of the main interventions for Screen Australia is to provide production finance for television dramas, often developed with the assistance of broadcasters, and documentaries, jointly developed by the broadcaster, the producer and Screen Australia.

Essentially, Screen Australia finances the gap between the licence fee and the production budget without, particularly for drama, engaging in an assessment of the cultural “merit” of the production. For drama Screen Australia’s funding guidelines make it clear that lower “ask” is an important factor in assessment. The provision of this gap finance is vital, as without it Australian content on television, especially high-end dramas, children’s programs and documentaries, would be limited to lower-budgeted genres or a few “tentpole” special event formats.

For the television industry this approach has been a largely successful one. Screen Australia facilitates the market to select those products that industry participants believe will best suit the needs of their audiences.

Although the provision of the gap is vital to secure a diversity of high-end Australian content, filling this gap could also be done through indirect subsidy (tax or offset), or by tied direct subsidy funding, as provision of the gap does not depend on a rigorous creative evaluation by Screen Australia of the programs to be made.

In relation to most of Screen Australia’s television slate, it is largely broadcasters that drive “the diverse range of Australian programs that deal with matters of national interest or

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importance to Australians or that illustrate or interpret aspects of Australia or the life and activities of Australian people”.

This diversity is achieved because Australia has a healthy, competitive and layered free-to-air broadcasting and pay-TV sector, which engages with a vibrant and competitive television production sector. As a corollary, it is arguable that the 10BA era witnessed the best era in Australian television drama, and that this was achieved without the intervention of direct subsidy.

If Screen Australia is largely an investor that relies on the joint judgment and expertise of broadcaster and producer on how best to entertain and inform Australian audiences, then its most significant intervention is not in the creative sphere but to ensure fair terms of trade, as a kind of umpire between broadcaster and producer.

Only with the NDP, the Special Documentary Initiative, Australian-focused children’s dramas and the Low Budget Drama program does Screen Australia offer a merit-based evaluative process. However, initiatives without broadcaster involvement (and therefore access to audience at a fair price) can be flawed, and assessment in the area of children’s drama reflects the limited amount of subsidy available.

The ABC believes that a merit-based approach works effectively in this limited set of cases, where the initiatives are intended to satisfy quite specific cultural policy objectives.

By comparison, it would be inappropriate if Screen Australia were to introduce an evaluative process more widely when assigning funding. Broadcasters rigorously assess projects designed to target their audiences before they are put to Screen Australia by producers for funding and often spend substantial amounts of development money bringing projects to the point where they suit the broadcaster’s demographic aims.

Screen Australia should not seek to replicate well-established broadcaster commissioning procedures for high end content, but should instead work in partnership with the broadcasting sector.

Recommendation 4: In the absence of a 40% Producer Offset, continue Screen Australia’s role as gap “financier”.

Screen Australia and Development Strategies

In the event a 40% Producer Offset were to be introduced, it is legitimate to ask how this might affect Screen Australia’s activities and what alternative strategies might be available for it to carry out its Government-designated role.

The ABC believes that there is a strong case to be made for targeted development strategies for television drama.

Currently, apart from documentary and innovative programming, Screen Australia provides a modest amount of development funding for television programming, in the expectation

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that the broadcasters, pay-TV, state funding bodies and the Australian Children’s Television Foundation (ACTF), in relation to children’s programming, can pay for drama development without Screen Australia subsidy. Additionally, pay-TV currently counts “pre-production“, i.e. development money, as contributing to its New Eligible Drama Expenditure (NEDE).

Expectations for “innovation” should be tempered as, in effect, the resources for this would come from Screen Australia’s small Innovative Fund and because television broadcasters, in the main, want drama and documentary formats that conform to audience expectations. Innovation is then viewed through the lens of audience engagement and audience satisfaction.

At a strategic and development level, it should be possible for Australian television production companies, with Screen Australia support, to focus on producing higher-quality dramas, following the example of US series such as The Wire, Madmen and The West Wing.

Considerable development money is spent on improving the craft of local feature-film scripts through workshops, state and federal initiatives and strategic emphasis. It would be appropriate to see some of the same or similar types of strategies employed to raise a well-performing sector to become an outstanding one.

The writing base required for this change exists. However, it needs professional opportunities and growth if Australia is ever able to develop the stables of writers that are necessary to achieve the calibre of writing achieved in sophisticated US dramas.

Conventional wisdom is that the networks should pay for the development of drama. However, with the strategic input of Screen Australia and programs designed to create writing teams, a higher standard of quality and diversity could be pursued.

The ABC believes that, if a 40% Producer Offset for television drama and documentaries were to be introduced, Screen Australia could shift its focus in the development area. This should not involve a move into project-based development funding—currently there is ample funding from broadcasters, state funding bodies and bigger companies able to part- or self-fund project development—but rather into a broader industry or initiative-based approach. As a result, Screen Australia would be able to provide funding for innovative approaches, for workshopping, for extended development or resource intensive approaches.

Recommendation 5: If a 40% Producer Offset were to eventuate, Screen Australia should pursue targeted development strategies for television drama, involving resource intensive approaches, extended development and workshopping, as a means of supporting the sector.

Screen Australia and Innovation

If Australian content is to thrive in an increasingly fragmenting world, emerging innovators must be encouraged to make the leap and, in the process, encourage broadcasters to adopt competitive models and ensure their position in the marketplace.

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This too is an area of funding already provided by Screen Australia, albeit on a relatively limited basis, through the Innovation Fund and has been a successful area for partnership with the ABC on a range of initiatives.

The Innovation Fund is focussed towards innovative multi-platform and single-platform interactive projects, with an emphasis on new applications and gaming. The ABC is interested in developing multi-platform and interactive content and would welcome an opportunity to work more closely with Screen Australia.

As stated above, the ABC believes the Innovation Fund could benefit from clearer guidelines, as part of a revised cultural remit for the funding body.

Increased clarity about how the interactive elements of television production funded out of general production funds are evaluated as opposed to those out of the Innovation Fund could help broadcasters define budgets and plans.

At the same time, innovative projects could benefit from the application of genre based expertise and a formalised assessment through or in partnership with genre “doors”. Such an arrangement could help identify the most efficient and effective allocation of funding to projects that promote diversity and innovation.

It can be difficult for broadcasters to understand just what projects or elements of projects are “innovative” enough to qualify for support. A review of the Guidelines, criteria and commission schedule for Innovation proposals may help to streamline the process and provide broadcasters with more clarity about the types of proposals that would fit within the Innovation remit.

Recommendation 6: Screen Australia should review its Innovation guidelines in order to provide applicants with greater clarity as part of a revised cultural remit and consider more engagement with emerging innovators and innovation strategies for content delivered to a range of Australian screens.

Screen Australia and Nationally-Significant Programming

A range of programs is required to achieve diversity of content, and the national public broadcasters and the commercial free-to-air broadcasters can be both competitive as well as complementary.

For example documentaries funded under the NDP that reflect Screen Australia’s diversity remit tend to be associated with the public broadcasters; action dramas such as Underbelly or Sea Patrol tend to find a home with commercial free-to-air broadcasters.

In a commercial environment, the definition of “nationally significant”, must be considered for both the creative or cultural value of the programming, as well as the availability of such programming to as wide an audience as possible. Something of genuinely national significance should be seen across the nation.

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In that context free-to-air and public broadcast television are logical marketplace partners for Screen Australia given the level of access they afford the Australian public and a “national” audience to subsidised “nationally significant” programming.

Direct subsidy is finite, so any decrease in the direct production subsidy available to the national broadcasters will necessarily result in a decrease in high-end content available to the 70% of Australian households that rely on free-to-air for their television viewing. In the area of adult television drama, the current structure of the NEDE provides an incentive for pay-TV to invest significant amounts in “tentpole” productions, especially mini-series and series which remain exclusive to pay-TV as an incentive to attract subscribers. However free-to-air commercial television, available to all viewers, continues to generate a diversity of high-end and low budget drama, from mini-series to series and serials, and so remains the engine room for the production of Australian content.

Recommendation 6: Screen Australia considers the relative reach of free-to-air and pay-TV services when allocating funding for Nationally Significant Programming.

Screen Australia, Nationally-Significant Indigenous Programs

Screen Australia plays an important role in the development of Indigenous film makers and Indigenous screen content through broad support, script development and targeted production investment. In the context of the Government’s current review of its investment in the Indigenous media sector Screen Australia’s support and commitment is even more significant.

The ABC notes that it has recently created an Indigenous Department to substantially increase the levels of Indigenous programming that it commissions, including prime time-dramas, short dramas and documentaries. The new department has been provided with an increased budget to develop such programs.

The ABC believes this is another important area of for potential partnership between Screen Australia and the ABC, which could help driving a diverse range of nationally significant and compelling programming, and where both parties help build the Indigenous independent film sector.

Recommendation 7: Screen Australia explores initiatives to fund a variety of nationally-significant Indigenous programs and so continue to build the Indigenous independent film sector.

Screen Australia and a diversity of programs Documentaries

Under s.6(3) of the Screen Australia Act 2008, Screen Australia is required to “[e]nsure the development of a diverse range of Australian programs that deal with matters of national

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interest or importance to Australians, or that illustrate or interpret aspects of Australia or the life and activities of Australian people” and to place and emphasis on documentaries.

Nowhere is there greater common interest between Screen Australia and the ABC than in documentary production; the relationship was significant with its predecessor bodies as well.

For example, it was the FFC and ABC which brokered the original accord and non-accord funding doors, which in turn are the genesis of Screen Australia’s current funding programs. It was the ABC which was selected by Film Australia for the output deal for its National Interest Program, and it was the ABC which partnered with Film Australia to ensure its “Making History” initiative first received funding in 2005-06.

The ABC’s brand is synonymous with high-quality Australian documentaries, such as documentaries on Australian history and significant national and cultural events. The ABC is an excellent destination for documentaries, as it has cultivated audiences and program-makers, built dedicated slots within its schedules for documentaries and provides effective promotion. In addition, the ABC commissions a diverse range of documentaries and pays extremely competitive prices for them. The ABC consistently provides prime-time positioning for Australian documentaries in key slots, resulting in overall solid audience numbers, with some exceptional peaks.

In the last four financial years, the ABC has commissioned 197 titles from the independent sector with a total budget value of $118 million (the ABC contributed $30 million to these budgets and Screen Australia and its antecedents contributed $39.7 million).

Over the same period, the ABC screened 228 Australian titles during prime-time on ABC1. Some programs demonstrated exceptional national audience figures—such as The Extraordinary Tales of William Buckley (1.1 million), Kokoda episode 1 (1.2million) and Voyage to the Planets episode 1 (almost 1 million)— In the fragmenting landscape, this is a demonstration of strong storytelling and the positioning and prominence which the ABC affords the genre.

The ABC’s commitment to documentary programming and its ability to provide access to that programming to the widest possible audience should be taken into account by Screen Australia when considering any potential change to documentary funding models and splits.

Recommendation 8: Screen Australia should reaffirm and further develop its relationship with ABC in relation to the production of documentaries and should consider the importance of audience access to programs when assessing funding for projects.

Issues in relation to the financing of documentaries

While the Screen Australia guidelines are explicit that there is no cap on the level of funding that any broadcaster can receive, in practice the organisation currently commits its domestic documentary funding (NDP and Domestic Door) on a 40/40/20 basis between the ABC, SBS and commercial free-to-air and pay-TV broadcasters.

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The ABC believes that the 40/40/20 split approach may well lead to a more sustainable production marketplace if Screen Australia were to formally allocate documentary funding to broadcasters at the start of the year.

If this commitment could be given, the ABC would support an upfront split approach. Each broadcaster would then have clarity and certainty about the amount of funding available and would be better placed to commission slates rather than apply for project funding on a one-off basis.

In addition the ABC believes there is merit in considering an up-front allocation across the “pool” of funding available from the NDP, Domestic Door and International Door. While the guidelines for each fund would remain separate and distinct the funding allocation split of 40/40/20 could be applied across the total funding available.

Such an approach would support Screen Australia’s objective of supporting sustainable businesses. There is waste and double processing in the current system, which if eliminated would increase production levels.

If the national broadcasters could commission slates, rather than one-off programs, this would be a significant boost to the sustainability prospects to many of Australia’s documentary businesses.

One of the attractions of a 40% Producer Offset for documentaries (and for other television programming), is that it would be available for documentaries pre-bought by pay-TV. Because the Offset is not capped, this would not deprive the free-to-air sector of subsidised programs. On the other hand, access to the Offset, both direct—who can claim—and in terms of beneficiary—who can deliver—is a decision made by Government. Government might require that any pay-TV program accessing the higher Producer Offset be able to demonstrate a secondary window for free-to-air viewing, but this would be a matter for Government, rather than a discussion of Screen Australia’s documentary funding model.

Recommendation 9: Screen Australia should reaffirm and further develop its relationship with the ABC in relation to documentary production.

Recommendation 10: Screen Australia should review and formalise the funding split for documentaries to support slate-based commissioning through allocations made at the start of each year.

The continuing importance of Documentary Programs

Assuming no changes in the current subsidy/Offset mix, it is important to maintain Screen Australia’s overall allocation to documentary. Documentary is the most cost-effective way of delivering Australian stories (and/or Australian perspectives) to Australian audiences.

The partnership of producers with television broadcasters, originally required by the FFC, also encourages the sector to develop relationships with the international documentary community and international broadcasters.

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Documentary producers who engage in the international marketplace are extremely skilled at putting together complex deals, and Screen Australia’s Enterprise Program is likely to allow some in this sector to reach their potential as sustainable businesses.

It is broadcast television that underpins the documentary business and Screen Australia’s programs for documentary should as much as possible focus on documentaries that have marketplace interest in the form of broadcaster presales.

The problem with initiatives that do not require an upfront commitment is that the broadcast market remains the main market for documentary, and the price a broadcaster pays for a completed documentary is far less than a pre-purchase secured at the financing stage.

Obviously the ABC and other broadcasters can benefit from this arrangement by acquiring programming cheaply. However it is worth noting that in the context of audiences seeking to connect to programming designed for them a broadcaster presale offers the best audience outcomes.

Children’s programming

Section 6(3) of the Screen Australia Act 2008 also requires Screen Australia to pay particular attention to, and place an emphasis on “programs of interest or relevance to children”.

There are a number of issues involved in Screen Australia’s policies and role in relation to the funding of children’s dramas, foremost amongst them the issue of pay-TV, dealt with later in this submission.

The launch of ABC3 has given the ABC the opportunity to evaluate the popularity of children’s programming, and while Australian drama programming for children is well received, other areas of programming made in Australia by independent producers are also popular.

The data clearly indicates the impact of the ABC in children’s programming:

Share and Reach

• Year to date to June 2010 weekly network reach is 13 million (58%)

• ABC3 has the highest total television viewing share amongst 5-12 year olds during daytime

• In the free-to-air market ABC3 leads with 20.6% share, followed by ABC1 (18.7%) then ABC2 (13.7%)

• Among all kids channels ABC3 leads with 12.7% share, followed by ABC1 (11.5%) then ABC2 (8.4%)

• YTD weekly reach for ABC3 is 3.0 million (21.0%) and for ABC2 is 1.4 million (9.7%)

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Australian content on ABC3

• Consistently at or above 40% since launch

Multi Platform

• ABC Kids websites had a reach of 405,000 in April 2010. This is above the 2009 July-Dec average of 295,000 and the 2010 YTD average of 357,000.

• Club3 reached 41,000 registered members at the end of May 2010.

• “ABC3” was the third most searched ABC term in external search engines in April 2010 (after ”iView” and ”ABC news”).

• Children’s programs count for four out of the top twenty programs on iView in April 2010 with Dead Gorgeous the fifth most popular program on iView.

A 40% Offset and Children’s Programming

If a 40% Producer Offset were to be introduced for high-end children’s drama production, Screen Australia would be in a good position to support innovative programming, as well as other more traditional and popular television genres which generate work for the independent production sector.

Accordingly, while children’s dramas is important to the ABC, the ABC encourages Screen Australia to use its Enterprise Program to ensure that children’s television producers supported by the scheme have a broad focus on children’s programming, and that the focus is not on drama alone at the expense of other formats.

There are many opportunities for commissions in the area of magazine, reality, infotainment and similar programs, which make up a large part of ABC3’s production slate and the ABC’s broader offering.

These non-subsidised formats should form part of Australian producers’ business plans, but at present the emphasis in funding skews slates and business plans to the extremely competitive area of children’s drama, where limited subsidy restricts the number of programs that can be funded in a year (with eight of the twelve Australian titles and all three of the co-productions for the 2008-09 year animated productions).

Similarly, the ABC encourages Screen Australia’s Innovation Fund to support interactive programs for children.

The ABC notes that, in recent years, state funding bodies and the ACTF have been responsible for assisting the development of Australian children’s drama. The ACTF, for example, has been moving away from mounting its own productions, and instead has been supporting the independent sector in the production of children’s programs, through script development and production finance. It has committed some $600,000 for script development to independent producers over a three-year period, mainly in collaboration with broadcasters.

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While such script and production finance helps support Australia’s top-performing children’s production sector, development finance for high-end children’s programming suffers the same kind of shortage that confronts adult television programming seeking to match the quality of shows produced by British, European and American producers.

A 40% Producer Offset would allow Screen Australia to focus on this area. The ABC notes that the independent Australian children’s drama production sector has flourished under government and regulatory support, has forged a strong and enduring relationship with constantly renewing young Australian audiences, and has also forged long-term relationships in the international market. Access to a 40% Producer Offset for high-end drama productions would take the sector to a new level of sustainability, while helping generate material that can be delivered to Australian children’s audiences by the ABC and other broadcasters.

In the interim, given the importance of children’s programming in the community, with ABC3 already successful with its target audience, and constantly in need of new quality programming, it’s appropriate for Screen Australia to at least maintain the current level of funding available for children’s programming.

Programs with artistic and cultural merit

Section 6(3) of the Screen Australia Act 2008 also requires Screen Australia to consider and place an emphasis on “programs with a high level of artistic and cultural merit.”

While programs with a high level of artistic and cultural merit can be those which fully exploit the television medium for dramatic purposes, such as The Wire, it is also worth noting that television programming can present other kinds of works involving artistic and cultural merit.

Commonwealth and state agencies involved in the arts generate large amounts of content, which can go unrecorded or which reach only limited audiences. For example, while performances by the Sydney Symphony Orchestra are streamed on the Internet, they are only available to Telstra subscribers.

In the past, filming such events has been circumscribed by rights issues, and the sector’s fears that, rather than acting as calling cards, such broadcasts might inhibit attendance at live events. However the ABC recognises viewers’ interest in such cultural events and has recently begun reviving broadcasts of major opera events, and other artistic activities.

Such content escapes the standard subsidy nets, which employ content definitions established in the early days of 10B and 10BA. Modernised definitions that allowed broadcasters to be funded to cover such events would:

• help ensure such events are made available to a wider audience;

• drive recognition of the brands and companies currently receiving government subsidy;

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• contribute to a wider recognition of such cultural activities and reward government subsidy by multiplying the availability of content; and

• act as an archive of such events for future generations.

A special fund could be set up to encourage outside broadcast recordings delivering content already subsidised by government to new and diverse audiences.

Alternatively, funding could plausibly be administered by Screen Australia, which as a body with a cultural remit, has no obligation to conform in all areas of its funding to QAPE definitions of specific formats for broadcast television.

Should either Screen Australia or a special fund take on the funding of the recording of such events, it would need to be spelled out that programs must be made available to the general public, and that funding should not be allocated to programming already capable of achieving free-to-air commercial television delivery, such as comedy festivals.

If a 40% Producer Offset were to be introduced, Screen Australia’s focus on programs with a high level of artistic and cultural merit would allow it to explore other funding opportunities.

Screen Australia would be in a position to play a broader role in the professional development of the television sector. It could assist in the development of new talent, and new areas and forms of content, and thereby extend the range and nature of programs with artistic and cultural merit.

Recommendation 11: If a 40% Producer Offset were to eventuate, Screen Australia should consider an alternative approach to programs with artistic and cultural merit, which could encompass broadcasts of live events.

Screen Australia’s Terms of Trade The second term of reference for the Screen Australia review seeks to:

2. Review Screen Australia’s funding eligibility requirements, including minimum licence fees, hold back provisions and market place attachments, and determine whether these levels and requirements remain appropriate;

Licence Fees

An important element of Screen Australia’s practice of setting and reviewing minimum licence fees is the transparency it provides: the minimum fees are published (other than for “secondary sales”, see below) and applied across the board on the basis of the genre and cost of product, rather than on the buyer. This adds to transparency and fairness.

The ABC would not consider an alternative pricing system based on attempting to differentiate between broadcasters to be equitable or appropriate.

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As noted earlier, the ABC acknowledges that, for producers, known floor prices takes them out of what may be protracted project-by-project negotiations, while also clarifying what the “non subsidy deficit” is in program financing plans.

The ABC believes there is merit in Screen Australia introducing a minimum licence fee for NDP projects that is transparent to industry. The flexibility that Film Australia sought to maintain for itself as a producer and executive producer actually has the effect of creating uncertainty for broadcaster’s seeking to develop projects.

The Corporation believes the NDP would benefit by having such as objective measure attached to its funding criteria along with (as stated above) a recognition of the importance of being able to provide national audiences with access to NDP supported content that is given appropriate prominence and marketing support by broadcasters.

The ABC also appreciates the flexibility permitted with “international door” documentaries that allows decrease in the domestic minimum where the international market place contribution is high. The ABC notes that this is not broadcaster-driven, but genre-driven, on the basis of programming with content of appeal to international audiences.

Recent criticism by ASTRA of the floor prices set by Screen Australia for adult drama has drawn attention to the issue of licence fees. However, it would be a poor policy outcome for the millions of Australians who do not subscribe to pay-TV to suggest that any drama subsidised by Screen Australia should be seen only on pay-TV. Attempts to pursue this outcome would need to be achieved at a greater cost to subsidy which is not sustainable.

The ABC acknowledges that pay-TV provides another door for Australian producers. However, for every program going to this new door, one fewer will be available to free-to-air audiences. There is no growth, only substitution, to a much smaller, subscriber-based audience.

Recommendation 12: Screen Australia to maintain its current approach on minimum licence fees.

Children’s drama and secondary pricing

Less transparent and less exposed to a vigorous annual review are the licence fees accepted by Screen Australia for second-run rights.

The ABC believes that there is a design flaw in the NEDE that allows pay-TV services to meet content-based legislative obligations while contributing relatively little by way of licence fees to the cost of new or original children’s drama programs.

Children’s drama commissioned by broadcasters, for which pay-TV pays an upfront licence fee for secondary runs, qualifies for the NEDE, provided the purchase occurs prior to the first broadcast. But the amounts involved are modest. Such a purchase at $5,000 to $10,000 an episode (and in rare cases up to $15,000) does not contribute to production costs in any

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significant way, and might comprise as little as around 2% of total production costs. Nonetheless these secondary prices qualify for the NEDE.

Free-to-air broadcasters pay a significant premium of $95,000 per episode. Relative to this, the amount contributed by pay-TV is marginal.

The way that the NEDE is currently structured provides little incentive for pay-TV to commission new children’s television drama productions, when for a modest pre-production commitment, channel operators can secure product. .

While the prices paid by pay-TV remain low, the only defence free-to-air broadcasters have at their disposal is to insist on holdbacks, a perfectly legitimate commercial response in the circumstances.

Screen Australia and Holdbacks

Broadcasters have the right to protect their brands and their investment in their programs and holdbacks are a legitimate mechanism for this. Holdbacks are used internationally and across all forms of media. Where a broadcaster is commissioning a program, and paying a premium that supports its production costs, it must be able to protect and claim the full benefits of that investment.

While it is understandable that Screen Australia wants to reduce its outlay, it cannot expect the broadcaster to both pay premium prices and then allow its competitors access at secondary prices. Holdbacks have only become a contentious issue for children’s drama, because, unlike adult drama, repeat programming is not an issue for child audiences, and the prior broadcast of children’s drama is not a disincentive to pay-TV’s interest in screening the program.

ABC Television’s policy in regard to holdbacks against pay-TV for children’s drama is guided by four general principles:

• Engaging with the audience: Television channels are defined primarily by their content; Australian pay-TV channels are strongly associated with programming produced by their US parent companies. Disney brands such as Hannah Montana and High School Musical, Nickelodeon’s Sponge Bob Square Pants and I-Carly, and Cartoon Network’s Ben Ten are central to the appeal of those channels. Major Australian drama series (such as My Place, Dead Gorgeous and Dance Academy) define ABC3 in the eyes of the audience, and the ABC is reluctant to sacrifice the differentiation so provided, neither do we seek to share major US program-brands with the pay-TV operators.

• International best practice: ABC Children’s Television ensures that its policies regarding exclusivity of content are consistent with those of other public broadcasters around the world. It consults regularly with colleagues at the BBC, KIKA, etc to ensure that it follows international best practice.

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• Building a sustainable production sector: ABC Television takes very seriously its role in building and sustaining a strong, vibrant independent production sector. It is notable that Australian children’s pay-TV operators do not commission much new children’s drama. Despite this, they have been allowed to share in the benefits of the considerable investment in children’s drama made by both free-to-air broadcasters and the Government (through the FFC and Screen Australia), and to do so at minimal cost. As such, the pay-TV operators contribute relatively little to creating strong drama producers and producing good drama, yet they expect to use Australian drama to strengthen their appeal to the local audience at minimal cost to themselves.

• Government expectations: The Government rightly expects ABC3 to deliver a good audience, and to differentiate its program offering from that offered by pay-TV children’s channels. The ABC seeks to achieve this through maximising Australian content, and the policy of exclusivity helps to achieve those aims. However, if the ABC were to share key drama programs with pay-TV in the future, the significant amounts of public money invested in these programs requires that we ensure that pay-TV operators pay an appropriate licence fee, which they are not currently prepared to do, and that there are appropriate windows to ensure non-pay-TV subscribers have access to the programs.

Historically, Australian commercial broadcasters have been willing to share programming with pay-TV because one of their main concerns in regard to children’s programs is to meet their quotas. As these quotas are primarily expressed in terms of the “first run” of each series, free-to-air broadcasters usually share their C-Drama with pay-TV following the first run on free-to-air.

However as well as the disadvantage free-to-air broadcasters suffer regarding the prices expected of them (the floor price of $95,000 per half hour versus fees as low as $5,000 per half hour), they are also disadvantaged in terms of repeats.

This anomaly involves the long standing terms of MEAA’s agreements with actors and voice talent, under which pay-TV operators are allowed to broadcast the same episode more than once in a 24 hour period and pay residuals for a single run. This advantage is not available to free-to-air broadcasters, whether analog or digital, with the result that pay-TV operators pay significantly less residuals than free-to-air.

During the analog era, free-to-air broadcasters, including the ABC, generally played children’s drama series once a year for a maximum of 7 years. However, the digital era has changed those practices, such that ABC Television now licenses 12 runs per year for its key drama series.

In a multi-channel environment, repeats are now a crucial way to engage with audiences. A lot of the potential audience will have missed the broadcast or bits of it and in any event children are not adverse to repeats – in much the same way that the multiple plays of programs on pay-TV also suits the child audience.

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In these circumstances, the traditional argument that free-to-air-commissioned children’s drama series must be shared with pay-TV in order that they can be viewed by all Australian children is no longer valid.

The ABC has adopted a policy of paying a premium (over and above the Screen Australia benchmark rate) to compensate the producer for the “foregone” pay-TV licence fee, and to avoid any perception that the ABC is misusing its market position.

As long as the pay-TV sector pays minimal fees for children’s drama, digital channels like ABC3 will continue to have a strong incentive to pay the premium necessary to retain exclusivity. If pay-TV operators contributed an appropriate amount to the funding of quality Australian children’s drama, and provided windows for non-subscribers, ABC Children’s Television would be in a position to reconsider its holdback policy. But this would require an overhaul in the operation of the current NEDE guidelines for pay-TV.

Children’s programming is a core genre for the ABC, not just on ABC3, but also on ABC1 and ABC2. Just as ABC3 was a policy initiative of Government, the ABC sees itself as obliged to make the initiative as successful as possible and engage in strategies to protect its programming and brand.

Accordingly, if Screen Australia is concerned in relation to the matter of holdbacks and licence fees in relation to children’s television programming in particular, the ABC encourages Screen Australia to insist on floor prices for pay-TV that recognise the value of the programming and pay-TV’s relative household penetration.

In the interim, holdbacks and paying small premiums for the right to preserve its brand are legitimate business practices that the ABC will continue to pursue to protect its substantial outlays in individual projects.

Recommendation 13: Screen Australia should acknowledge and act on the validity of the ABC’s concerns in relation to children’s programming, as they relate to branding, the necessity for holdbacks, and the need for the pay-TV sector to make a stronger contribution to licence fees.

Screen Australia and Marketplace Attachments

In relation to Screen Australia’s terms of trade for documentaries, the ABC also notes that marketplace attachments are fundamental to the financing of television programming and marketplace attachments, when made in the form of broadcaster presales, also secure the widest possible Australian audience and so are to be encouraged on those grounds. They also generate higher returns.

The ABC believes it would be unnecessary to introduce measures designed to intervene in the evaluation processes undertaken by the marketplace particularly Australian broadcasters. Evaluation has its place where there is no marketplace or where a precise mandate is to be achieved, as is the case with the NDP.

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Television funding is relatively non-controversial in Australia because of a robust and diverse broadcasting sector, transparent and consistent requirements for the marketplace, and the marketplace being allowed to decide what gets made. To introduce comprehensive evaluation processes on top of the commissioning practices of the broadcasters would create uncertainty.

The Documentary Initiative has resulted in the making of documentaries destined for television, but shelf prices are paid if the television commitment is not secured up-front. In terms of priorities, the ABC encourages Screen Australia to embrace programs geared to the participation of the Australian marketplace. Broadcaster engagement in projects is crucial to their success, and their ability to engage a wider audience, and thereby serve Screen Australia’s objectives.

Screen Australia and the NDP The ABC and the NDP

The final term of reference for the Screen Australia review seeks to:

3. Evaluate the funding allocation for NDP projects including the provision of program funding for particular television broadcasters or channels.

The NDP projects comprise the rebadged “national interest programs” that used to be produced or executive produced by Film Australia and includes the History Initiative, which is “tied money” made available by this and the previous governments.

The grant for the original “Making History” initiative (re-badged as the History Initiative) was made to Film Australia in 2005-06 to produce documentaries about significant events in Australia’s history. It was renewed in 2008 and is now administered by Screen Australia. The program was designed as a partnership with the ABC so that all of the documentaries produced under the program have been broadcast by the ABC, often with ABC financial development assistance, and with general editorial guidance.

The NDP ensures the production of an important body of work in the national interest and if it is in the national interest that it is made, then it is in the national interest that it be seen by as large an audience as possible, without barriers to prevent access. This is the case with the History Initiative which provides guaranteed access to all Australians by reason of Film Australia’s and now Screen Australia’s partnership with the ABC.

The ABC believes that any decision to promote pay-TV as the destination for NDP projects at the expense of the free-to-air broadcasters would deny those programmes to the majority of Australians.

The degree to which pay-TV should be able to access this scarce and finite resource, in effect reducing the number of subsidized documentaries available to the majority of Australians who do not subscribe to pay, should be considered. This debate has taken place with sport, but not cultural programming in receipt of subsidy, though the principle remains the same.

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In the case of NDP projects, there is such a clear alignment between the objectives of the ABC and Screen Australia that it justifies a high level of ABC participation. The only other appropriate destinations are other broadcasters, such as SBS, which embody similar cultural objectives.

The national broadcasters offer better destinations than commercial free-to-air networks, because the commercial scheduling/advertising model is not well suited to one-off programs or short-run series (the majority of NDP projects).

The NDP is intended to deliver programs that are in the “national interest” and reflect Australia’s “heritage” and “cultural ambition”. They attract higher budgets than other Screen Australia documentaries because of these attributes.

Furthermore, the financing of the projects occurs with far greater discretion on the part of Screen Australia than many of its other programs, reflecting the program’s origins in the merged Film Australia.

The broadcaster requirement in this category of programming should be confirmed on the simple and clear policy ground that programs made in the national interest must, in the clear majority of cases, be made available to all Australians. The rationale for making them in the first place is not satisfied if the majority of Australians have no access to them. Free-to-air television is clearly the most appropriate gateway for these programs for all Australians.

The Corporation believes there is no question that Screen Australia should continue with the NDP, as it has a Charter-based interest in ensuring the ongoing production of special-event, culturally-specific and nationally-relevant documentaries with appropriate production values.

However, the ABC does not believe that NDP funding should increase at the expense of other documentary programs. In the ABC’s opinion neither the domestic door nor the international door should see their allocations reduced to bolster the funding of the NDP, unless the History Initiative is not renewed.

Specifically with regard to the way the NDP is managed, as stated above, the ABC believes there is a good case for making an up-front 40/40/20 allocation to broadcasters in order to support sustainability and certainty of investment for industry. In addition the ABC believes there would be a real benefit to industry if Screen Australia were to make transparent the number of hours expected from broadcasters and the level of investment from Screen Australia at the time of allocation.

On the question of whether Screen Australia should introduce “evaluation” for its domestic door documentaries, the ABC affirms the need for the marketplace to decide programming. However, the ABC is always prepared to engage in discussions with Screen Australia and producers on how the domestic door documentaries can achieve higher KPIs.

In addition, the ABC would argue that evaluation is costly to overhead (in that it replicates the processes of the broadcaster) and may be at odds with the decision to reduce overhead by providing grants where commitments are lower than $200,000.

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History Initiative

On the matter of the History Initiative, the ABC contends that it is essential for this program to be housed with the one broadcaster, to ensure that there is no overlapping of program subject matter and to ensure that the programs achieve the highest KPIs available for such programming when broadcast domestically.

The ABC has now developed a substantial body of history documentaries, with outreach to a substantial and ongoing audience, and with an enduring legacy value which will see these documentaries reappear for additional broadcasts over many years.

The partnership between Screen Australia and the ABC to deliver this kind of documentary programming has been a clear success in terms of meeting the ABC’s, Screen Australia’s and the Government’s objectives.

This partnership and program is a commitment to documenting Australia’s history and providing a legacy for future generations. In light of its success the ABC would be concerned if Screen Australia recommended opening it up to other broadcasters.

Recommendation 14: Screen Australia should reaffirm marketplace-led funding for domestic-door projects, and restate the case for free-to-air broadcasters in relation to the NDP and domestic-door programs.

Screen Australia, targeted or “tied” money and building slates

Finally, the ABC believes that in this context, it is important to restate its support of Government use of “tied money” to achieve policy outcomes.

In the past the Commonwealth has driven high-end content by making available market place support on a “tied” basis, and it is notable that other countries, such as Canada, pursue this strategy in relation to the screen industries.

A revival of this mechanism would benefit both the production industry and broadcasters, and there is a case to be made that, in the event of a Producer Offset of 40% for Australian high-end television programming becoming a reality, there is then a significant role for “tied” or targeted money to play, designed to support either innovation, or formats which have to date fallen through “definitional cracks” or to support high-end formats by encouraging a direct relationship between broadcasters and independent producers able to use a 40% Producer Offset to cash-flow and complete finance plans for their productions.

The “Making History” initiative is a good example of the successful outcomes which can be achieved through targeted funding. The ABC believes that Screen Australia can follow this strategy in relation to slate funding, the best way forward to assist the independent sector in building sustainable businesses.

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Slate building would become feasible with a 40% Producer Offset, but in the interim, Screen Australia should consider re-calibrating its policy settings in order to facilitate slate building by broadcasters in association with the independent documentary production sector.

Conclusion The issues outlined in this submission should be viewed in the context of ongoing change in the digital era. The growth of digital multi-channels and online content delivery has led to an explosion of content, a significant proportion of which is sourced from international producers.

In this fast-changing environment, both the Government and Screen Australia must review policy settings in a way that will ensure that Australian stories and voices will continue to be developed, and to be seen on Australian screens.

New and viable business models for the financing of high-end content, to match these new delivery models, have yet to be devised, and subsidy continues to play a crucial role.

That said, the demand for high-end quality Australian television remains strong amongst Australian viewers, as shown by good ratings for much local content, and the simplest policy adjustment to ensure Australian content’s ongoing presence on television is to provide a 40% Producer Offset for high-end television drama and documentary production.

Additionally, there are a number of adjustments to policy settings that Screen Australia can make, which will facilitate the financing and production of quality Australian content, and its broadcast to as wide an audience as possible.

In the interim, the ABC would welcome a commitment from Screen Australia to maintain funding levels for documentary and television drama, including children’s drama.

The ABC, as an important partner with Australian funding bodies and the independent production sector, looks to innovative ways to ensure that the Australian public, and in particular Australian taxpayers, will benefit from an increased availability of diverse, well made, entertaining and informative Australian content on Australian screens, however those screens might receive the content.