On 22 June this year, Save Our SBS lodged a detailed submission to the ‘Inquiry into the Competitive Neutrality of the National Broadcasters’. A condensed version of the Save Our SBS submission is below, in which a number of chapters have been excluded and other text edited for quick reading. The full unedited evidence based original is here.

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Inquiry into the Competitive Neutrality of the National Broadcasters

Attaining a level playing field: SBS — commercial

Introduction

According to the Organisation for Economic Co-operation and Development (OECD):-

competitive neutrality means that state-owned and private businesses compete on a level playing field[1].

The Australian Government’s Competitive Neutrality Policy Statement states:-

Competitive neutrality requires that government business activities should not enjoy net competitive advantages over their private sector competitors simply by virtue of public sector ownership[2],[3].

In 1980, Bruce Gyngell, then Managing Director Designate of the Independent and Multicultural Broadcasting Corporation (the fore-runner to SBS) talked of a new multicultural multilingual television channel and said it would “complement and supplement” that seen on existing broadcasters. He was describing a service that was totally alternative to the ABC and commercial broadcasters[4]. His description was consistent with the principles of competitive neutrality and this was 16 years before Australia had published its Commonwealth Competitive Neutrality Policy Statement[5].

It would seem that if SBS were to satisfy competitive neutrality principles and fulfil the purpose for which it was established, then at the very lest it would need to complement and supplement the ABC, community, commercial broadcasters, and subscription services.

Due to its commercial outlook, SBS is now less inclined to take risks compared to earlier times when it was relatively commercial free.

SBS’s Chair from 1981 to 1999, Sir Nicholas Shehadie noted in his book A Life Worth Living:-

public broadcaster SBS should be run as a service, not a business[6].

Australia is incredibly fortunate to have two public broadcasters, a range of commercial broadcasters, and subscription services.

For many decades, SBS’s role was to serve the public, innovating with content that otherwise might be commercially unattractive, complementing and supplementing the ABC and commercial broadcasters. Under this umbrella, SBS would lead the way where other broadcasters did not.

The role of SBS as a public broadcaster has gradually changed as a consequence of it being granted the right to carry advertising. In its current hybrid state, SBS remains a public broadcaster increasingly dependant on commercial activities. This has blurred its role.

SBS is needed

While unpacking where SBS has come from and its future direction, the following dot points should be born in mind in respect of SBS’s part to compete on a level playing field.

Reliable data[7] from 2017 shows that of 1,176 people surveyed nationally:-

· 87% would be very concerned if SBS were merged with another broadcaster.
· 94% want the Australian government to invest a significantly greater portion of funding in SBS as security in a socially cohesive multicultural society.
· 94% say that SBS is very important to them.

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Furthermore, more recent data from a separate cohort in 2018 of 1249 people who were surveyed nationally, revealed that most thought SBS to be a valuable service (range per SBS outlet/platform: 58% to 88%)[8].

Programming impacts on competitive neutrality principles

In the nation wide 2018 survey of 1249 people, questions were asked about content screened on SBS ‘in recent years’. The text of the SBS Charter was provided to all survey participants which was open to anyone with internet access.

One purpose of the survey was to identify programs on SBS that were suitable for SBS reflective of its Charter, or were not suitable for SBS — that would be expected on commercial television.

The extent to which SBS has programs that are commercially attractive or not, can be summarised as follows:-

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Survey participants were invited to provide names of programs seen on SBS that were either— ‘fitting for SBS’ (one question), or ‘of the type expected on channel 7, 9, or 10 — not SBS’ (in another question). The published graph (above) is a representation of the 14 pages of data extrapolated in answer to the two questions[9].

The advantage or disadvantage of the public or commercial broadcaster is affected by the extent of public or private monies in the investment (i.e., content) determining the risk taken and likely return from advertising dollars.

Regardless, competing for advertising — which SBS does — will of itself drive up programming costs especially when 45% of SBS programs are of the content type expected to be seen on commercial TV[10].

Unlike its earlier years and according to the SBS annual reports, SBS now has the same advertisers as the commercial sector[11]. This alone somewhat detracts from SBS being seen as a ‘special’ broadcaster when even the ads are the same[12].

Free TV urges that SBS be required to deliver on its Charter, and cease—

competing even more directly for advertising and driving up the cost of commercially viable programming[13].

It goes without saying that SBS ought to be using public funds to purchase Charter focused content, programs that otherwise would not be available to viewers, as such would be a waste of public funds.

The Charter obligates that as far as practicable programs on SBS be “in their preferred languages”. Although SBS Radio very successfully achieves this with its ‘in‑language’ — languages other than English (LOTE) — programs, SBS television does not. SBS TV used to before SBS ramped up its commercial side.

Since 2013, Save Our SBS has discussed with SBS the notion of SBS creating a channel specifically in LOTE. We requested that one of the HD channels be used for that purpose. However, despite an almost total wipe-out of LOTE content from primetime, SBS has not created a LOTE channel and instead saw fit to place VICELAND on their then spare HD channel, in addition to the VICELAND SD channel, which carries the same program.

Before NITV, the Food Network and VICELAND, up to 66% of primetime was made up of quality imported LOTE content[14],[15],[16]. Now in primetime, LOTE has been replaced mainly by English language American and some British Anglocentric content. With few exceptions[17] SBS all but avoids 100% LOTE programs during the prime 8:30pm time slot. LOTE content has been mainly relegated to off-peak daytime or late night[18].

With nearly half of all Australians born overseas[19], it is absurd that SBS does not devote an entire free‑to‑air television channel to LOTE programming. Such is well within SBS’s remit and a “principal function” of its Charter.

In 2017 over a one-week period, 1176 SBS viewers from all Australian states and territories participated in a comprehensive national study answering some 47 questions about SBS. The study found that the two most wanted television programs on SBS in peak viewing periods were foreign language movies (subtitled) 77%, and foreign language series (subtitled) 58%. Some 71% of those surveyed said they wanted SBS to establish a new free‑to-air channel in which a very high proportion of primetime and other programs would be exclusively or predominantly in LOTE[20].

LOTE via SBS On Demand fails to fill the void of a fully-fledged LOTE free-to-air channel.

Now with the advent of multi-channelling, it is incongruous that no such channel exists on Australia’s national multicultural/multilingual broadcaster.

Effectively SBS has chosen not to observe the ‘programs in preferred languages’ and ‘multilingual’ Charter requirements in primetime to the extent it did prior to the introduction of in‑program advertising in late 2006.

Predicably, LOTE content in primetime would rate far less than English language content and therefore fail to attract the advertising dollars SBS seeks.

This is an example of advertising working against a core component of SBS: its “principal function”, its raison d’être, as set out in its Charter.

Mainstream

For many decades SBS was ‘special’ (as its name states), different, and distinctive. There was no other broadcaster anywhere in the world like it. However that all changed soon after late 2006 when SBS reinterpreted the law to disrupt programs with commercial breaks (mimicking the commercial television ‘look’). That is the origin of SBS adopting a commercially aggressive approach[21] and transition from alternative to mainstream[22].

The Programs on SBS survey 2018 (referred to earlier), not only found 45% of programs on SBS were of the type expected on commercial broadcasters, but —

70% said SBS currently has insufficient niche programming compared to more than 10 years ago[23].

By any measure, the evidence supports the assertion that SBS has become more mainstream and more commercially oriented to the detriment of delivering on its Charter. For SBS to be more mainstream — or less alternative — must by definition, threaten the public — commercial playing field and therefore the principles of competitive neutrality.

A one-week nation wide survey conducted in 2017 of SBS viewers in every State and Territory found that only 3.5% of the 1176 viewers studied thought that VICELAND was “appropriate” for SBS, and of the Food Network 68.23% said it was “a misuse of public resources and – – tokenistic to multiculturalism particularly when showing cuisine of non‑Anglo nations where the programs are in English”[24]. Most programs are in English.

More than 1,500 comments were received appearing in appendices to the 2017 survey. There were comments critical of too much American or British content on SBS and too little foreign language programs.

In 2017, 65.3% (35.7% + 29.6%) of those studied said that ‘SBS had become more mainstream than compared to 10+ years earlier’, 20.5% were undecided and 14.2% (8.9% + 5.3%) said it was now less mainstream[25].

A comparable finding was found in 2013 of 2,044 SBS viewers.

Before SBS commenced in-program advertising just over a decade ago (in late 2006), the broadcaster prided itself on being an “alternative” to mainstream media. The 1998-99 SBS Annual Report[26] reflected on this as quoted below:-

The latest [1998] study, in the final months of 1998, shows that SBS has further improved its favourable image and continues to be seen as a valued alternative to other free‑to-air networks. The survey found:

– 87.6% agreed that “It is important that SBS be available to provide an alternative to the commercial stations.”

– 76.7% agreed that “It is important that SBS be available to provide an alternative to ABC Television.”

– 85.2% agreed that “SBS has types of programs you would not see on other TV stations.”

– 62.4% agreed that “SBS has better coverage of overseas news than other TV stations.”

– 75.7% agreed that they “find value in SBS”.

Extrapolating the data of the two different research groups for the two different cohorts over two time periods (1998 and 2017), it may be said with a high degree of confidence that SBS has become more similar to the ABC and commercial television in 2017 than it was in 1998. SBS is now much less of an alternative to the ABC and commercial television than 20 years ago. The “alternativeness”[27] of these two time periods is reflected in the graph below.

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The shift from “alternative” to “mainstream” follows the transition from SBS being relatively non‑commercial (advertisements between program only), to it adopting a very commercial format. This is when SBS began to alter the public — commercial playing field.

There is clear evidence of a direct link to the introduction of in-program advertising in late 2006 (numerous commercial break disruptions in every program) and SBS adopting a more mainstream approach, thus thwarting the public commercial balance.

In 2013, 80.7% of 2,044 viewers from all States and Territories said that—

advertising ought to have no place on SBS but should be left to commercial broadcasters instead[28].

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The above graph indicates that public broadcaster SBS ought not delve into commercial territory, that viewers understand that advertising is necessary for commercial television but do not accept it for SBS.

Not only did 81% of 2044 viewers studied in all States and Territories in 2013 believe that advertising ought to be the exclusive territory of the commercial sector, but 69% of a different cohort of 1249 people surveyed nationally in 2018 said that SBS has a competitive advantage over commercial broadcasters purely by the fact that SBS carries advertising (on top of it being largely publicly funded)[29].

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This finding does not suggests that viewers favour or want advertising on SBS. They do not[30],[31],[32]. The graph above is a comment on the hybrid funding model for SBS.

The 2018 study indicates that the average reasonable person thought, in principle, there can be no level playing field while a public broadcaster has advertising because it is publicly funded too, whereas commercial broadcasters must largely rely on advertising revenues alone.

This goes to the core of the principle regardless of the dollars involved.

SBS: Australia’s 4^th commercial TV network by stealth

The first public admission by SBS that it had formed a commercially aggressive strategy to directly compete with the commercial sector, was in January 2007 when B&T[33] quoted Richard Finlayson, then head of SBS’s commercial arm, that the broadcaster was out—

. . . to position SBS as Australia’s fourth commercial network. Our long-term agenda is that we do not want people to just think about the three commercial networks but SBS as well. We are now taking a more aggressive approach to communicating our message and particularly with building our relationships with key media[34].

SBS re-confirmed this strategy a month later with Finlayson telling the Australian Financial Review that—

In the past SBS has been reluctant to carry some ads, such as hard-hitting, in‑your‑face retails ads. That’s changing[35].

The commercially aggressive approach of SBS and willingness to accept almost any type of advertisement, provided legal and regulatory requirements are met, caused the broadcaster to accept an array of advertisements that are not Charter compliant. The SBS Act does not provide for that, nor should it. Ads are supposed to comply with the Charter.

This strategy has seen a dramatic increase in SBS TV advertisers since FY06/07 and the introduction of in‑program advertising.

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Advertising growth

Since SBS introduced in-program advertising in FY06/07, the number of advertisers has increased by 65% with SBS now having the same advertisers as seen on commercial free‑to‑air (FTA) television, and SBS total revenues from advertising on all of its platforms grew by 123%[36]. This is shown on the graph below and the rate of growth from SBS ad revenues far exceeds the fairly flat growth rate of the commercial FTA for the same period[37]. SBS ad revenues saw a transient spike every 4^th year due to the FIFA Word Cup.

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The graph illustrates the impact of in‑program advertising on SBS and a fairly aggressive commercialisation policy which has tipped the previous relatively level playing field (prior to 2005 when SBS and commercial FTA tracked quite closely), into one that now is no longer level.

The flat commercial FTA rate versus the extreme ad growth for SBS where SBS bears no risk for that growth (as it is 71% government backed — via appropriations) seems contrary to competitive neutrality principles, given that the commercial FTA ‘risk all’ for a mere flat rate.

The test here is that of a principle — not to be confused with the total dollars of SBS or the commercial FTA. If SBS had not had access to public funds for which it purchased content that in turn accelerated SBS ad growth levels, then the principle would have been upheld.

The obvious solution for SBS and the commercial sector to compete fairly is to return SBS to its pre-2006 state (ads between programs only), or prohibit ads on SBS totally.

Advertising placement

Before advertising was legislated for SBS in 1991, it was permitted under Ministerial discretion only which rarely occurred. The Minister exercised his discretion before the 1991 legislation, in a quasi-trial period, to see how SBS would present advertising and gauge public reaction. In the trial period, SBS screened advertisements before and after programs (top and tail) only. Programs were not disrupted for commercial breaks and this presentation style appeared to calm public objection to advertising on the public broadcaster. Under this model SBS remained like that of a healthy public broadcaster. Programming did not really encroach into the commercial broadcasters’ territory.

More than a decade ago the advertisements on SBS were unique. Now, even 85% or more[38] of the ads are the same as commercial TV.

SBS’s re-interpretation of the law — to position commercial breaks in every program — means it now competes even more directly for advertising dollars than when ads were between programs only (because the value of an in‑program advertisement is significantly higher than if an ad were between programs).

The mechanism for correcting this imbalance is detailed in the discussion that follows.

Option 1 discussion

Advertising revenues fluctuate and with each new network or platform, total commercial revenue has grown.

Not only did the commercial broadcasters lobby against increased advertising on SBS[39] but there was massive objection from SBS viewers to a Bill to double the hourly advertising limit in 2015[40]. 62,000 petitioners opposed that Bill[41], and in 2017, 10,000 viewers’ directly emailed politicians also opposing a similar Bill[42]. Both Bills failed to become law. The Government has since dropped the policy to raise the hourly SBS advertising limit[43],[44]. No one wants more advertising and it appears contrary to competitive neutrality principles.

In 1988, The Review of National Broadcasting Policy recommended that SBS be opened to commercial advertising[45],[46]. In December 1991, SBS was corporatised and advertising introduced[47],[48],[49],[50],[51] with government appropriations guaranteed to continue[52].

The 1991 Hansard noted scepticism from major advertising agencies, that—

advertising ‘will never cover the cost of local production’[53].

With advertising revenues growing 123% since FY06/07, evidence of a measurable increase in first run Australian content[54] on SBS is lacking[55].

Australian content on SBS now accounts for only 7%[56] of its schedule with the balance being largely imported (often American) commercially attractive predominantly English language content. This is not how SBS was, nor envisaged or supposed to be.

Given that ad revenues have consistently been insufficient to adequately fund Australian content, and SBS now chases eyeballs with mainstream content to further increase its ad revenues which in turn increases commercially viable programming costs[57] undermining competitive neutrality principles, it is time SBS was fully-funded from the public purse (which SBS formally publicly requests[58],[59]), and as a logical step cease all advertising on SBS.

Option 1 allows SBS to focus on its important role, enabling content not driven by ratings, hence removing the reason to exploit an unfair advantage[60].

Option 2 discussion

Option 2 retains advertisements, positioned respectful of that intend by the legislators.

Although section 45(2)(a) of the SBS Act provides for SBS to broadcast advertisements:

before programs commence, after programs end or during natural program breaks (section 45(2)(a) SBS Act)

the Act does not define “natural program breaks” but when the Act was passed, the definition was understood. It was self-explanatory, articulated by the legislators consistent with community expectations limiting advertisements to between programs and half time in sport such as in a soccer match only[61],[62],[63]. SBS followed that understanding until late 2006.

However, between 13 January 2006 and 9 August 2006 inclusive, there were 152 pages of correspondence spread over 16 occasions between SBS and Mr Bret Walker SC on the question as to if SBS would be in breach of the SBS Act by broadcasting advertisements within TV programs. This included a 17-page opinion provided on 31 January 2006, a 7-page supplementary opinion on 16 March 2006, a 3‑page further supplementary opinion on 28 April 2006, and a 3-page opinion on 9 August 2006. These opinions have never been tested in a court.

On 1 June 2006 and before all the legal correspondence had concluded, SBS announced their intention to place advertisements within programs anyway, the same as commercial TV[64].

Arguments around natural program breaks and intent of the legislators have been conveniently ignored by SBS in their pursuit of tipping the public‑commercial playing field.

In 2008, SBS provided evidence to a Senate Committee that it had ‘forced’ about 6,000 commercial breaks over a 12-month period[65] — where no natural break existed — into programs delivered in unbroken format, e.g., in movies, BBC, and other programs from non‑commercial broadcasters. This blunt practice is ongoing and apparent to most viewers.

The phrase “natural program breaks” intended to limit the placement of advertisements is now disregarded by SBS so much so, that even a ‘forced’ break in a program is deemed by SBS to be ‘natural’ — when clearly it is not.

In two separate studies of two different cohorts, viewers of SBS overwhelmingly said—

most in-program advertising breaks [on SBS] look forced or artificially contrived and it would be misleading to describe these as natural program breaks[66],[67]
(91.7% of 2,044 SBS viewers in 2013, and 91.0% of 1,176 SBS viewers in 2017).

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In the 1991 Bill that legislated advertising on SBS, the Government and Opposition (House of Representatives, Senate, and Committees) all agreed on the same meaning of natural program breaks AND that advertisements would only ever be between programs — not in them — except in the natural half-time break in sport[68]. The relevant text (ignored by SBS today) from the Hansard is quoted below:-

• half-time in a soccer match … in effect what will happen is that advertising will top and tail programs[69] (Mr SMITH Liberal).
• natural program breaks, one would think that it is not too difficult to identify … clearly the half-time break in football and other sporting programs is a fairly common occurrence. The topping and tailing of programs so that good quality films are not massacred by advertisements is something that most people will readily identify with and recognise the breach of very quickly[70] (Sen ALSTON Liberal).
• natural program breaks will be so unobtrusive on audiences as to be almost undetectable[71] (Sen COLLINS Labor).
• advertisement—at the beginning and the end of the sponsored program. In that way the viewers were not disturbed and were not constantly interrupted, as is the case on some of the commercial television programs[72] (Mr LEE Labor).
• let us not try to get the advertising revenue that will make the SBS another commercial channel. If we do, again, that will change its character, and I do not think that is really what we are about[73] (Mr SINCLAIR National).

Considering all the evidence, if a definition had been placed into the Act, for SBS arguably it could have been that below:-

The intention of the legislators described above was honoured by SBS until late 2006. However, after SBS discovered a loophole in the law in 2006 that exploit has been used to insert in‑program commercial breaks into all programs.

SBS would have been less able to, consciously or unconsciously, challenge competitive neutrality principles if a definition of “natural program breaks” were in the SBS Act that reflected the text cited from the Hansard and summarised in the yellow box above.

Upon the introduction of in‑program advertisements, the then Shadow Minister said, it—

serves to erode the fundamental tenets of public broadcasting[74],

and later the Minister said, it amounted to—

reinterpreting the clause in the Act that refers to ‘natural program breaks’[75].

In three separate studies[76],[77],[78] over three different years of three different cohorts of SBS viewers nationally (2008 n=1,733; 2013 n=2,044; 2017 n=1,176), totalling 4953 viewers, 96.70% (in 2013) and 94.24% (in 2017) said that—

in-program commercial breaks [on SBS] are an impediment to the viewing experience.

Additionally, 76.80% (in 2013) and 76.65% (in 2017) thought that—

SBS is now subject to commercial influence or interference.

Furthermore, 96.30% (in 2008), 93.40% (in 2013) and 91.60% (in 2017) viewers said it was—

important or very important to remove in-program commercial breaks on SBS.

It is very clear from thousands of published comments[79],[80],[81] that there is a strong desire on the part of the public — and for the creation of a fairer playing field — to remove in‑program commercial intrusion on the nation’s public broadcaster.

Of the 4953 SBS viewers studied, upon reading the Charter, 72.60% (in 2008), 72.10% (in 2013) and 72.74% (in 2017) said—

SBS is less faithful to the Charter since it introduced in‑program advertising[82],[83],[84].

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The replication findings of the three different cohorts is not surprising considering the Department of Communications (the Lewis review) linked advertising with—

risks to the amount of Charter‑related content . . .

shifting the focus from viewer to advertiser creating—

. . . a greater pressure on SBS management to consider the trade-off of delivering on commercial expectations, against delivering those functions described in the SBS Charter[85].

Such is also consistent with a BBC study of public broadcasters carried out by McKinsey and Co in 19 countries, including Australia, which concluded—

dependence on advertising has led inexorably to a more populist and less distinctive schedule[86].

The 2006 unlegislated policy change — to interrupt every program for advertisements — was and remains the subject of massive community concern and objection:

. . . it would be unlikely that any audience would welcome any changes or the introduction of advertising of this type[87](SBS Managing Director, 2006).

Prior to late 2006, when advertisements were outside programs, the viewer was the client of SBS and SBS considered the needs of their client, the viewer, over and above that of an advertiser. However, when SBS began to disrupt all television programs for advertisements, the client of SBS became the advertiser, and hence SBS began to compete with commercial TV. Viewers of a commercial broadcasting transaction are a commodity, a product, to be on‑sold to the advertising client. This is a point of difference between the commercial operation that SBS has adopted, and a true public service broadcaster where the client would otherwise be the viewer. SBS now has an audience for sale but without risk due to public funds as back‑up. This helps to further explain why there is no longer a level playing field between SBS and commercial free-to-air broadcasters.

We recommend option 2 below in circumstances where the parliament insists on SBS rasing some revenue from advertising.

This option upholds first principles by removing the loophole exploited by SBS since late 2006 to interrupt all programs for commercial breaks, mimicking commercial TV.

Option 2 would permit SBS to transmit advertisements before or after programs only on its broadcast and streaming services, and display advertisements on its web pages and apps. Programs would not be disrupted for commercial breaks on any platform.

SBS would focus on content that audiences are currently denied, better fulfilling its public broadcasting role.

Options 2 may tend to attract advertisers who support SBS for its inherent value — what it stands for — rather than those seeking a higher return from ratings.

However, option 1 most likely would be more effective than option 2 in ensuring competitive neutrality principles are adhered to.

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The full version of the Save Our SBS submission then discussed in detail:-

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All up seven recommendations were made. They may be read in the full version of the submission. A summary of the main arguments was included in the Conclusion, which appears below.

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Conclusion

In the 1990’s with a sensitive and sensible approach, advertising between programs only served SBS well. From late 2006 with advertisements disrupting programs, the culture of SBS changed dramatically.

However, due to Australia’s growing migration and the importance of social cohesion, SBS is needed more now than ever before and it is essential it get back on track.

The 1988 idea, that SBS should be permitted to carry advertising — in order to make Australian content to the same level as commercial television — has never come to fruition. On current forecasts, it never will. Advertising appears not to be the dream once envisaged. The menace of disruptive commercial breaks has failed to bring benefits to the level sought. It is high time this destructive practice and questionable funding model for an Australian public broadcaster was overturned, as it has been in other parts of the world.

SBS ought to be funded as a public broadcaster, not a subsidised quasi commercial look‑a‑like. Let commercial broadcasters operate in their territory and keep SBS separate.

It may be easy to forget that SBS is a public broadcaster. It ought to be seen as such.

The only means by which SBS will ever achieve its full potential and commercial broadcasters operate free of an ever encroaching SBS in their space, is if advertising is curtailed or preferably prohibited on SBS by legislative amendments as outlined under RECOMMENDATION 1: option 1 or 2 in the Advertising placement section of this submission.

The commercialisation of SBS has caused it to loose its way by focusing too heavily on a commercial business model, forgetting that its real business — the business of any public institution — is to serve the public.

Setting aside the SBS growth in advertising of 123%[88] since the introduction of in-program advertising and acknowledgment from SBS that “some programs have absolutely nothing to do with the Charter”[89], it is no coincidence that in 2018 a statistically credible sample of nationwide viewers identified 45% of content on SBS “as the type expected to be seen on commercial TV, not SBS”[90], with 70% saying SBS now has “insufficient niche programming”[91], and the ‘alternativeness’ of SBS dropping from to 85% in 1998[92] to a mere 14% in 2017[93]. This deliberate strategy[94],[95], which is driven by advertising, is inconsistent with the purposes of SBS in particular and public broadcasting in general.

In an advertising free environment, SBS would fulfil its public broadcaster role and once again focus on unique and ‘special’ content that viewers might otherwise not see.

The current arrangement has skewed the playing field to the point that SBS no longer leads or acts like a public broadcaster and this never ending drive for more and more revenue — from in-program advertising and purchasing commercially attractive programs — places SBS in direct conflict with the principles of competitive neutrality.

The SBS hybrid funding model of itself was assessed by 69% of those studied nationally in 2018 as providing SBS with a competitive advantage[96]. This is staggering. Equally staggering is that 91% of two separate cohorts of viewers in 2013 and 2017 said “most in-program advertising breaks [on SBS] look forced or artificially contrived and it would be misleading to describe these as natural program breaks”[97],[98] . Clearly SBS fails the average reasonable person (Clapham omnibus) test in these matters.

That summarised above are the compelling reasons to either prohibit all advertising on SBS totally and fully‑fund it, or at least cease in‑program advertising completely (the pre-2006 model).

If only one recommendation in this submission were to became law, the single recommendation most needed to ensure a significantly fairer playing field and guarantee SBS fulfils its “principal function”, would be RECOMMENDATION 1 (option 1 or 2). If not adopted, the competitive advantage that SBS now enjoys and its failure to satisfy Charter obligations will continue — even if other recommendations were put in place — in the absence of RECOMMENDATION 1.

Additionally, considering that 84% of the 2017 cohort ‘objected to advertising on a public broadcaster’ and 94% said ‘advertising on SBS impeded their viewing experience’[99], it is high time for change as recommended.

Unquestionably, the public ethos and culture of SBS has shifted dramatically with it now operating more like a commercial broadcaster however with public funds.

The purpose of SBS is not to grow its commercial arms and exploit legal loopholes nor utilise its competitive advantage, but rather to foster our multicultural and linguistic identities, build and maintain a cohesive society without the contentious reliance on advertising apparent over the past 11 years especially.

Endnotes:

This submission may be published at:-

https://saveoursbs.org/wp-content/uploads/2018/06/Attaining-a-level-playing-field_SBS—commercial.pdf

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[1] OECD, 30 August 2012, Competitive Neutrality: Maintaining a level playing field between public and private business,
http://www.oecd.org/competition/competitiveneutralitymaintainingalevelplayingfieldbetweenpublicandprivatebusiness.htm

[2] Commonwealth Competitive Neutrality Policy Statement, June 1996, ‘Competitive neutrality requires that government business activities should not enjoy net competitive advantages over their private sector competitors simply by virtue of public sector ownership’, page 4,
http://archive.treasury.gov.au/documents/275/PDF/cnps.pdf

[3] Productivity Commission, Competitive Neutrality Complaints,
https://www.pc.gov.au/about/core-functions/competitive-neutrality

[4] IMBC, Gyngell, B, (talk to the National Press Club), Multicultural Television —The most exciting idea in broadcasting, in Australia, since 1956, 13 August 1980, page 4,
http://www.multiculturalaustralia.edu.au/doc/gyngell_sbs.pdf

[5] Commonwealth Competitive Neutrality Policy Statement, June 1996,
http://archive.treasury.gov.au/documents/275/PDF/cnps.pdf

[6] Simon & Schuster Australia, Shehadie, N, A Life Worth Living, 2003

[7] SOSBS, 26 April 2017, Survey 2017 about SBS, pages 3, 6, 32,
https://saveoursbs.org/wp-content/uploads/2017/04/Survey-2017-about-SBS.pdf

[8] SOSBS, 12 June 2018, Programs on SBS survey 2018, page 3 and 10,
https://saveoursbs.org/wp-content/uploads/2018/06/Programs-on-SBS-survey-2018.pdf

[9] SOSBS, 12 June 2018, Programs on SBS survey 2018, pages 8 and 14 to 27,
https://saveoursbs.org/wp-content/uploads/2018/06/Programs-on-SBS-survey-2018.pdf

[10] FreeTV, 29 January 2018, Submission on the economic and cultural value of Australian content on broadcast, radio and streaming services, page 43 (PDF 51), section 3.2,
https://www.aph.gov.au/DocumentStore.ashx?id=994bef16-3f10-4c14-8379-79449f56a3b9&subId=562862

[11] SBS, Annual Report 2017, Appendix 15, pages 151 to 153 (PDF 77 to 78)
http://media.sbs.com.au/home/upload_media/site_20_rand_224099426_sbs_annual_report_2017.pdf

[12] FreeTV, 15 April 2015, (submission) – Communications Legislation Amendment (SBS Advertising Flexibility and Other Measures) Bill 2015, “A list of advertisers on the SBS (sourced from the SBS 2014 Annual Report) compared with the Nielson Adex data demonstrates that at least 85% of advertisers on the SBS also advertise on commercial free-to-air television”, page 9 (PDF 10),
http://www.freetv.com.au/Media/Submissions/2015_0007_SUB_FINAL_Senate_Environment_and_Communications_Committee_SBS_Advertising_Flexibility_and_Other_Measures_Bill.pdf

[13] FreeTV, 29 January 2018, Submission on the economic and cultural value of Australian content on broadcast,

radio and streaming services, page 43 (PDF 51), section 3.2,
https://www.aph.gov.au/DocumentStore.ashx?id=994bef16-3f10-4c14-8379-79449f56a3b9&subId=562862

[14] SBS (WayBack Machine), 21 May 2009, Introducing SBSTWO, “SBSTWO is free and available to you from June 1, 2009”,
https://web.archive.org/web/20090521094437/http://www.sbs.com.au:80/article/109523/Introducing-SBSTWO

[15] SBS (WayBack Machine), 3 January 2010, SBSTWO National Schedule,
https://web.archive.org/web/20100102152958/http://www.sbs.com.au:80/schedule/SBSTWO

[16] SBS (WayBack Machine), 14 June 2012, SBS Sydney Schedule,
https://web.archive.org/web/20120613220233/http://www.sbs.com.au:80/schedule

[17] SBS, Adam Looking For Eve, 12 January 2018 at 8:30 PM to 9:30 PM on VICELAND,
https://www.sbs.com.au/guide/day/2018-01-12/location/NSW/sublocation/Sydney#

and via On Demand
https://www.sbs.com.au/yourlanguage/video/672841283513/Adam-Looking-For-Eve-Germany-S1-Ep1

[18] SBS, 16 November 2017, Complete Guide,
https://www.sbs.com.au/guide/day/2017-11-16/location/NSW/sublocation/Sydney#/

[19] ABS, 27 June 2017, Media Release, Census reveals a fast changing, culturally diverse nation, “Nearly half (49 per cent) of Australians had either been born overseas (first generation Australian) or one or both parents had been born overseas (second generation Australian)”,
http://www.abs.gov.au/ausstats/abs@.nsf/lookup/Media%20Release3

[20] SOSBS, 26 April 2017, Survey 2017 about SBS, page 3,
https://saveoursbs.org/wp-content/uploads/2017/04/Survey-2017-about-SBS.pdf

[21] Shoebridge N, 27 February 2006, FIFA world cup kicks off SBS ad sales, Australian Financial Review, quoting Richard Finlayson (then SBS sales) “In the past SBS has been reluctant to carry some ads, such as hard-hitting, in-your-face retails ads. That’s changing.”
http://afr.com/p/business/media_marketing/item_rMMJrPN43ehS62ripiXmkJ

[22] Dempster, Q, July 2007, Come Clean On Commercialisation, edition of the Walkley Magazine (archived from the Way Back Machine), quoting Richard Finlayson (then SBS sales), SBS is out “to position SBS as Australia’s fourth commercial network”. http://web.archive.org/web/20090322222338/http://magazine.walkleys.com/the_news/stories/come_clean_on_commercialisation_20070617104

[23] SOSBS, 12 June 2018, Programs on SBS survey 2018, pages 3 and 7,
https://saveoursbs.org/wp-content/uploads/2018/06/Programs-on-SBS-survey-2018.pdf

[24] SOSBS, 26 April 2017, Survey 2017 about SBS, pages 21 and 23,
https://saveoursbs.org/wp-content/uploads/2017/04/Survey-2017-about-SBS.pdf

[25] SOSBS, 26 April 2017, Survey 2017 about SBS, page 7,
https://saveoursbs.org/wp-content/uploads/2017/04/Survey-2017-about-SBS.pdf

[26] SBS, Annual Report 1998-99, page 20 (PDF 22),
http://media.sbs.com.au/home/upload_media/site_20_rand_121927656_sbs_annual_report_1998_99.pdf

[27] “Alternativeness” is a measure of the data derived from 14.2% (8.9% + 5.3%) of SBS viewers in the Survey 2017 about SBS (page 7) who said ‘SBS had become more mainstream than compared to 10+ years earlier’, and data derived from 85.2% of SBS viewers reported in the survey results in the 1998-99 SBS Annual Report (page 20 PDF 22) who said ‘SBS has types of programs you would not see on other TV stations’.

[28] SOSBS, A study of 2044 viewers of SBS television on advertising, Charter, relevance and other matters, 23 July 2013, pages 16 and 98,
https://saveoursbs.org/wp-content/uploads/2013/07/A-study-of-2044-viewers-of-SBS-television-on-advertising-Charter-relevance-and-other-matters.pdf

[29] SOSBS, 12 June 2018, Programs on SBS survey 2018, (The question asked was: “As SBS is largely publicly funded and commercial broadcasters are not, does SBS have a competitive advantage or disadvantage in carrying advertising?”), page 14,
https://saveoursbs.org/wp-content/uploads/2018/06/Programs-on-SBS-survey-2018.pdf

[30] SOSBS, 1 December 2008, One Minute Survey Results, Answers to questions 3), 5), 9),
https://saveoursbs.org/archives/332

[31] SOSBS, 23 July 2013, A study of 2044 viewers of SBS television on advertising, Charter, relevance and other matters, pages 11, 13, 15, 16, 18,
https://saveoursbs.org/wp-content/uploads/2013/07/A-study-of-2044-viewers-of-SBS-television-on-advertising-Charter-relevance-and-other-matters.pdf

[32] SOSBS, 26 April 2017, Survey 2017 about SBS, pages 3, 7, 9, 10, 13, 14,
https://saveoursbs.org/wp-content/uploads/2017/04/Survey-2017-about-SBS.pdf

[33] B&T (broadcasting and television advertising, marketing and media weekly magazine), January 2007

[34] Dempster, Q, July 2007, Come Clean On Commercialisation, edition of the Walkley Magazine (archived from the Way Back Machine),
http://web.archive.org/web/20090322222338/http://magazine.walkleys.com/the_news/stories/come_clean_on_commercialisation_20070617104

[35] Shoebridge N, 27 February 2006, FIFA world cup kicks off SBS ad sales, Australian Financial Review,
http://afr.com/p/business/media_marketing/item_rMMJrPN43ehS62ripiXmkJ

[36] SBS, Annual Reports, FY06/07 = $41.742m and FY16/17 = $93.1m which is 123% increase in total advertising revenues; Number of TV advertisers has moved from 404 to 665 in the same period (i.e. 65% increase),
https://www.sbs.com.au/aboutus/corporate/view/id/111/h/Annual-Reports

[37] Free TV Australia/Commercial TV Australia, media releases, Advertising revenue for commercial television networks, 2003 — 2016,
http://www.freetv.com.au/content_common/pg-free-tv-advertising-revenue.seo and
http://www.freetv.com.au/content_common/pg-media-release-archive.seo

[38] FreeTV, 15 April 2015, (submission) – Communications Legislation Amendment (SBS Advertising Flexibility and Other Measures) Bill 2015, “A list of advertisers on the SBS (sourced from the SBS 2014 Annual Report) compared with the Nielson Adex data demonstrates that at least 85% of advertisers on the SBS also advertise on commercial free-to-air television”, page 9 (PDF 10),
http://www.freetv.com.au/Media/Submissions/2015_0007_SUB_FINAL_Senate_Environment_and_Communications_Committee_SBS_Advertising_Flexibility_and_Other_Measures_Bill.pdf

[39] Free TV Australia, 15 April 2015, Communications Legislation Amendment (SBS Advertising Flexibility and Other Measures) Bill 2015 [Provisions] Submission 6,
https://www.aph.gov.au/DocumentStore.ashx?id=8879168a-2801-4871-94c5-3f6a876a07d2&subId=350333

[40] SOSBS, 15 April 2015, The commercialisation of SBS versus efficiency, Communications Legislation Amendment (SBS Advertising Flexibility and Other Measures) Bill 2015 [Provisions] Submission 5,
https://www.aph.gov.au/DocumentStore.ashx?id=e1ef7fcd-8542-49a2-84ea-8a38d06f7fd5&subId=350315

[41] CommunityRun & SOSBS (WayBack Machine), Pomeranz M & Dempster Q [petition], 2015, Preserve its Integrity! Don’t Increase Ads on SBS,
https://web.archive.org/web/20150811104506/https:/www.communityrun.org/petitions/preserve-its-integrity-don-t-increase-ads-on-sbs

[42] Kostakidis M & SOSBS (WayBack Machine), 2017, Preserve our media diversity: Don’t turn SBS into Australia’s fourth commercial TV network,
https://web.archive.org/web/20170529021252/https:/saveoursbs.good.do/mary/email/

[43] SOSBS, 18 May 2017, Government backs down on SBS advertising Bill,
https://saveoursbs.org/archives/5930

[44] Parliament of Australia, 10 August 2017, Communications Legislation Amendment (SBS Advertising Flexibility) Bill 2017, (Bill Home page),
https://www.aph.gov.au/Parliamentary_Business/Bills_Legislation/Bills_Search_Results/Result?bId=r5830

[45] Department of Transport and Communications, 1988, Review of National Broadcasting Policy,

[46] The Canberra Times (Trove), Sunday 11 June 1989, Advertising on SBS television, page 6,
https://trove.nla.gov.au/newspaper/article/122269118

[47] The Canberra Times, (Trove), 26 September 1988, SBS: we need ads, page 34, “a discussion paper on the subject [of SBS carrying advertising] is circulating at the moment, initiated by the then-Minister for Communications, Senator Evans, and SBS has made its views known. There is a need for more money to make the kind of programs the channel wants to produce, and advertising is one of the obvious ways of getting it. . . We need funds to make the kind of programs we want to specialise in – ones that encourage respect and regard for all Australians, whatever their background”,
https://trove.nla.gov.au/newspaper/article/102074515

[48] Hansard House of Reps, 14 October 1991, SPECIAL BROADCASTING SERVICE BILL 1991 Second Reading, Mr SMITH Liberal, page 1842, “The SBS claims that it [advertising] will give a major boost to the creative and cultural well-being of this country and that every dollar that SBS puts towards Australian production has a potential to draw another $3. . . But, if one of the consequences of going down this path is to provide greater Australian production, that certainly would be welcomed by me and the Party that I represent. . . a 1988 policy discussion paper, the Department of Transport and Communications estimated that $70m would be necessary if SBS television was to incorporate local content in accordance with ABT requirements”,
http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query=Id:%22chamber/hansardr/1991-10-14/0041%22

[49] Hansard Senate, 11 November 1991, SPECIAL BROADCASTING SERVICE BILL 1991 Second Reading, Sen ALSTON Liberal, page 2843, “It [SBS] currently spends very little on Australian production initiatives, and if it is able to raise additional funding by way of sponsorship and advertising that would seem, on the face of it, to be a desirable outcome because it will enable it to undertake more production activities”,
http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query=Id:%22chamber/hansards/1991-11-11/0083%22

[50] Hansard Senate, 11 November 1991, SPECIAL BROADCASTING SERVICE BILL 1991 In Committee, Sen COLLINS Labor, page 2862, “the sponsorship provision [will enable SBS to increase] the number of productions in which the SBS itself engages”
http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query=Id:%22chamber/hansards/1991-11-11/0109%22

[51] The Sydney Morning Herald, 10 June 1991, SBS and TV advertising, page 8, “There will be (or should be) more money available [from advertising] . . . for Australian-made programs.”

[52] Hansard House of Reps, 14 October 1991, SPECIAL BROADCASTING SERVICE BILL 1991 Second Reading, Mr LEE Labor, page 1857, “It is also important that we recognise that any revenues which SBS is able to attract through sponsorship or advertising will be in addition to the revenue which SBS now receives… That should be an encouragement to SBS to get out into the marketplace and seek to attract the extra revenue.”
http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query=Id:%22chamber/hansardr/1991-10-14/0047%22

[53] Hansard House of Reps, 14 October 1991, SPECIAL BROADCASTING SERVICE BILL 1991 Second Reading, Mr SMITH Liberal, page 1842,
http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query=Id:%22chamber/hansardr/1991-10-14/0041%22

[54] Unless indicated, Australian content refers to first run Australian drama, documentaries and other genres, excluding news, current affairs and sport.

[55] Although there appears to be a 1.8% decrease in Australian content on SBS over the period commencing FY06/07 (the start of in‑program advertising) up to FY16/17, this is difficult to confidently confirm as SBS substantially changed their tabulation method multiple times of reported data over the course of the period — what was included or excluded, and how categorised. The annual reports contain data and expressions that are incompatible and inconsistent year-to-year. Additionally a number of variables compound confusion, e.g., reports from earlier years referred variously to SBSi, General Production Fund, and the Special Production Fund but in later years these are absent with reports categorising by genre. In some reports, it is difficult to separate content broadcast versus future content budgeted or forecast. Furthermore, SBS now transmits 24 hours per day on four channels whereas in 2006 it only transmitted part of the day from one channel. Reports from some years do not adequately separate certain types of content from other content. In conclusion, it is difficult to assess changes in Australian content levels over the period against a benchmark.

[56] SBS, Annual Report 2017, page 119, 120, 121 [SBS 2.7% + VICELAND 1.4% + NITV 2.2% + FOOD NETWORK 0.92% = 7.22% = 1.7 hours per day],
http://media.sbs.com.au/home/upload_media/site_20_rand_224099426_sbs_annual_report_2017.pdf

[57] FreeTV, 29 January 2018, Submission on the economic and cultural value of Australian content on broadcast,

radio and streaming services, page 43 (PDF 51), section 3.2,
https://www.aph.gov.au/DocumentStore.ashx?id=994bef16-3f10-4c14-8379-79449f56a3b9&subId=562862

[58] SBS, Australian and Children’s Screen Content Review SBS response to the Consultation Paper September 2017, page 5,
https://www.communications.gov.au/sites/g/files/net301/f/submissions/sbs_0.pdf

[59] SBS, January 2018, Submission to the Environment and Communications References Committee Australian content on broadcast, radio and streaming services, page 9,
https://www.aph.gov.au/DocumentStore.ashx?id=1cb6a384-76bc-40cd-b47b-2a9c7de6a021&subId=563386

[60] SOSBS, 12 June 2018, Programs on SBS survey 2018, (The question asked was: “As SBS is largely publicly funded and commercial broadcasters are not, does SBS have a competitive advantage or disadvantage in carrying advertising?”), page 14,
https://saveoursbs.org/wp-content/uploads/2018/06/Programs-on-SBS-survey-2018.pdf

[61] The Age, Peak R, 7 June 1991, Advertisements to be allowed on SBS networks, page 6, Communications Minister Mr Beazley, “The limit on advertisements would ensure that it did not resemble commercial broadcasting.”

[62] The Age, O’Neil J & Burton T, 9 June 1991, SBS’ could get $30 million a, year on ads’, page 9, ‘natural breaks would apply to sporting programs where there were stoppages.’

[63] The Sydney Morning Herald, 10 June 1991, SBS and TV advertising, page 8, SBS advertisements “will be presented more discreetly and less frequently than on the commercial television channels.”

[64] SBS, 1 June, 2006, SBS to Bolster News and Current Affairs Increase Australian Content – media release (WayBack Machine),
http://web.archive.org/web/20070105112728/http://www20.sbs.com.au/sbscorporate/index.php?id=1215

[65] Senate Hansard, 12 February 2008, QUESTIONS ON NOTICE, Special Broadcasting Service, page 2135, Question 7 – ATTACHMENT A – Programs delivered to SBS without breaks (2007),
http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query=Id%3A%22chamber%2Fhansards%2F2008-06-16%2F0157%22

[66] Senate Select Committee, 10 December 2014, Scrutiny of Government Budget Measures Submission 52, SOSBS, Impact of budget cuts and increasing advertising on SBS in primetime, page 9,
http://www.aph.gov.au/DocumentStore.ashx?id=000b1891-1c2e-4408-ab68-1e0b0947765b&subId=302262

[67] SOSBS,26 April 2017, Survey 2017 about SBS, page 9,
https://saveoursbs.org/wp-content/uploads/2017/04/Survey-2017-about-SBS.pdf

[68] SOSBS, Natural Breaks, https://saveoursbs.org/natural-breaks

[69] Hansard House of Reps, 14 October 1991, SPECIAL BROADCASTING SERVICE BILL 1991 Second Reading, Mr SMITH Liberal, page 1842,
http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query=Id:%22chamber/hansardr/1991-10-14/0041%22

[70] Hansard Senate, 11 November 1991, SPECIAL BROADCASTING SERVICE BILL 1991 Second Reading, Sen ALSTON Liberal, page 2843,
http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query=Id:%22chamber/hansards/1991-11-11/0083%22

[71] Hansard Senate, 11 November 1991, SPECIAL BROADCASTING SERVICE BILL 1991 In Committee, Sen COLLINS Labor, page 2862,
http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query=Id:%22chamber/hansards/1991-11-11/0109%22

[72] Hansard House of Reps, 14 October 1991, SPECIAL BROADCASTING SERVICE BILL 1991 Second Reading, Mr LEE Labor, page 1857,
http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query=Id:%22chamber/hansardr/1991-10-14/0047%22

[73] Hansard House of Reps, 14 October 1991, SPECIAL BROADCASTING SERVICE BILL 1991 Second Reading, Mr SINCLAIR National, page 1860,
http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query=Id:%22chamber/hansardr/1991-10-14/0048%22

[74] Conroy S, 11 October 2007, SBS issues (email), PDF2,
https://saveoursbs.org/wp-content/uploads/2009/06/sbs-2007-election-policy-sosbs-emails-to-from-s-conroy-original-messages.pdf

[75] SOSBS, 26 August 2008, Minister responds to petition,
https://saveoursbs.org/archives/316

[76] SOSBS, 1 December 2008, One Minute Survey Results, Q3,
https://saveoursbs.org/archives/332

[77] SOSBS, 23 July 2013, A study of 2044 viewers of SBS television on advertising, Charter, relevance and other matters, pages 11, 13, 14,
https://saveoursbs.org/wp-content/uploads/2013/07/A-study-of-2044-viewers-of-SBS-television-on-advertising-Charter-relevance-and-other-matters.pdf

[78] SOSBS, 26 April 2017, Survey 2017 about SBS, pages 9, 10, 11,
https://saveoursbs.org/wp-content/uploads/2017/04/Survey-2017-about-SBS.pdf

[79] SOSBS, 23 July 2013, A study of 2044 viewers of SBS television on advertising, Charter, relevance and other matters, pages 23 to 97,
https://saveoursbs.org/wp-content/uploads/2013/07/A-study-of-2044-viewers-of-SBS-television-on-advertising-Charter-relevance-and-other-matters.pdf

[80] SOSBS, 26 April 2017, Survey 2017 about SBS, pages 37 to 90,
https://saveoursbs.org/wp-content/uploads/2017/04/Survey-2017-about-SBS.pdf

[81] SOSBS, 12 June 2018, Programs on SBS survey 2018, pages 28 to 79,
https://saveoursbs.org/wp-content/uploads/2018/06/Programs-on-SBS-survey-2018.pdf

[82] SOSBS, 1 December 2008, One Minute Survey Results, Q7,
https://saveoursbs.org/archives/332

[83] SOSBS, 23 July 2013, A study of 2044 viewers of SBS television on advertising, Charter, relevance and other matters, page 12,
https://saveoursbs.org/wp-content/uploads/2013/07/A-study-of-2044-viewers-of-SBS-television-on-advertising-Charter-relevance-and-other-matters.pdf

[84] SOSBS, 26 April 2017, Survey 2017 about SBS, pages 3 and 15,
https://saveoursbs.org/wp-content/uploads/2017/04/Survey-2017-about-SBS.pdf

[85] Department of Communications, The ABC and SBS Efficiency Study Report (redacted), April 2014, (pp 85)
http://www.minister.communications.gov.au/__data/assets/pdf_file/0003/63570/ABC_and_SBS_efficiency_report_Redacted.pdf

[86] London, Mimeo, McKinsey & Co, 1999, Public Service Broadcasters Around the World, page 29 (PDF 31)

[87] Hansard, STANDING COMMITTEE ON ENVIRONMENT, COMMUNICATIONS, INFORMATION TECHNOLOGY AND THE ARTS, 30 October 2006, Mr Brown (SBS MD), “We have had phone calls of complaint, as we expected. My recollection is that in the first two days they were running at about 400 complaints overnight”
http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query=Id:%22committees/estimate/9768/0002%22

[88] SBS, Annual Reports, FY06/07 = $41.742m and FY16/17 = $93.1m which is 123% increase in total advertising revenues; Number of TV advertisers has moved from 404 to 665 in the same period (i.e. 65% increase),
https://www.sbs.com.au/aboutus/corporate/view/id/111/h/Annual-Reports

[89] Environment and Communications Legislation Committee, 27 February 2018, Estimates, COMMUNICATIONS AND THE ARTS PORTFOLIO, Special Broadcasting Service Corporation, Mr Ebeid, page 66 (PDF 70),
http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;db=COMMITTEES;id=committees%2Festimate%2Fe7a8364f-1f69-4a4b-9f10-70eef15e6814%2F0006;query=Id%3A%22committees%2Festimate%2Fe7a8364f-1f69-4a4b-9f10-70eef15e6814%2F0000%22

[90] SOSBS, 12 June 2018, Programs on SBS survey 2018, pages 8 and 14 to 27,
https://saveoursbs.org/wp-content/uploads/2018/06/Programs-on-SBS-survey-2018.pdf

[91] SOSBS, 12 June 2018, Programs on SBS survey 2018, pages 3 and 7,
https://saveoursbs.org/wp-content/uploads/2018/06/Programs-on-SBS-survey-2018.pdf

[92] SBS, Annual Report 1998-99, page 20 (PDF 22),
http://media.sbs.com.au/home/upload_media/site_20_rand_121927656_sbs_annual_report_1998_99.pdf

[93] SOSBS, 26 April 2017, Survey 2017 about SBS, page 7,
https://saveoursbs.org/wp-content/uploads/2017/04/Survey-2017-about-SBS.pdf

[94] Dempster, Q, July 2007, Come Clean On Commercialisation, edition of the Walkley Magazine (archived from the Way Back Machine),
http://web.archive.org/web/20090322222338/http://magazine.walkleys.com/the_news/stories/come_clean_on_commercialisation_20070617104

[95] Shoebridge N, 27 February 2006, FIFA world cup kicks off SBS ad sales, Australian Financial Review,
http://afr.com/p/business/media_marketing/item_rMMJrPN43ehS62ripiXmkJ

[96] SOSBS, 12 June 2018, Programs on SBS survey 2018, (The question asked was: “As SBS is largely publicly funded and commercial broadcasters are not, does SBS have a competitive advantage or disadvantage in carrying advertising?”), page 14,
https://saveoursbs.org/wp-content/uploads/2018/06/Programs-on-SBS-survey-2018.pdf

[97] Senate Select Committee, 10 December 2014, Scrutiny of Government Budget Measures Submission 52, SOSBS, Impact of budget cuts and increasing advertising on SBS in primetime, page 9,
http://www.aph.gov.au/DocumentStore.ashx?id=000b1891-1c2e-4408-ab68-1e0b0947765b&subId=302262

[98] SOSBS,26 April 2017, Survey 2017 about SBS, page 9,
https://saveoursbs.org/wp-content/uploads/2017/04/Survey-2017-about-SBS.pdf

[99] SOSBS, 26 April 2017, Survey 2017 about SBS, pages 7 and 9,
https://saveoursbs.org/wp-content/uploads/2017/04/Survey-2017-about-SBS.pdf

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The text above is a short version of the Save Our SBS submission. The full version published on the SaveOurSBS.org website is here, and on the Department of Communications and the Arts website here. Other submissions to the Inquiry into the Competitive Neutrality of the National Broadcasters are here. An Issues Paper with the terms of reference is here. 

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