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Environment and Communications References Committee
Australian content on broadcast, radio and streaming services

FAIR, Ms Bridget, Chief Executive Officer, Free TV Australia

MITCHELL, Mr Ross, Director of Broadcasting Policy, Free TV Australia

CHAIR: Welcome. Information on parliamentary privilege and the protection of witnesses and evidence has been provided to you. We have a submission from you. Would you like to give us an opening statement?

Ms Fair : Yes, thank you. Thanks for the opportunity to be here today. Free TV, as you may know, represents all of Australia's commercial free-to-air television broadcasters—Seven, Nine, Ten, Southern Cross, WIN and Imparja. At no cost to the public, our members provide diverse channel offerings covering a broad range of genres, including drama, news and current affairs, entertainment and sport. Our members are the largest investors in Australian content in the country. Indeed, we are the home of local content, investing a record $1.6 billion in the 2017 financial year. The economic value of our industry is significant. Over 15,000 people are employed both directly and indirectly by our members, and this creates a contribution to the Australian economy of $2.8 billion every year.

Commercial television broadcasters are proud of our commitment to Australian content. We transmit over 23,000 hours of Australian content and over 420 hours of Australian drama every year and 430 hours of locally produced news and current affairs programming every week. Broadcasters are also subject to a vast array of Australian content obligations in the form of a 55 per cent transmission quota and additional obligations to provide adult drama, children's and pre-school programming, documentaries and local news in regional markets. This is an unparalleled commitment to Australian content, but this commitment is under threat, driven by seismic shifts in the advertising market caused by Google and Facebook. Over the last 10 years, online advertising revenue has grown by 460 per cent in real terms, while TV ad revenue has fallen 22 per cent. This has a direct impact on our capacity to keep supporting Australian jobs and producing high-quality Australian content.

We haven't sat still in the face of this challenge. Our members have invested in developing new, feature-rich offerings to meet the changing expectations of our audience. But, in order for this transformation to continue, we need to update the regulations that are imposed on our commercial broadcasters. In most cases, quota obligations have not been seriously reconsidered since the 1980s when we were operating in a very different environment. Indeed, this is a critical time in the history of our industry. It's no exaggeration to say that it's changed more in the past five years than at any time since the first broadcast in 1956. While this increasingly competitive environment is delivering greater choice for consumers, it is fragmenting audiences, particularly for children's content and adult drama.

In 2017 only one drama program had an average audience of over one million people. Marquee dramas like 800 Words, House Husbands and Offspring all had average audiences less than one million. In fact, in the time since we provided our submission to the committee, analysis of average audiences for adult drama series shows a further six per cent decline in average audiences year on year. Average audiences now sit at under half a million. Over the past 10 years, drama audiences have halved and costs have doubled. By contrast, in 2007 there were seven TV drama series that had an average audience of one million or more. Shows like All Saints, McLeod's Daughters and Thank God You're Here all had average audiences above 1.1 million.

For content made specifically for children the picture is far more dire. Despite the fact we make substantial investments in high-quality, award-winning children's programming, commercial free-to-air television is not where children are choosing to watch. In our submission to the committee, we reported that the average child audience for C and P programs was around 6,800. In the time since we made that submission, these average audiences have fallen further, to 4,700. That's a fall of over 30 per cent in only a 12-month period. Over 80 per cent of C and P programs are now broadcast to child audiences of less than 10,000. Clearly this is not commercially sustainable.

In response to the clear audience preferences, Free TV has proposed two distinct policy responses. First, on Australian drama, we have proposed some modest reforms to the operation of the quota system. We still see adult drama playing an important role in the broadcast schedules of networks into the future, but reforms are needed to increase the flexibility of commercial networks to follow their audiences. This includes recognising escalating production costs, drawing a distinction between originally commissioned and acquired shows and appropriately recognising the economic value of high-volume serials. We see these changes as the absolute minimum required to ensure that commercial networks can continue to invest in Australian drama.

It's worth remembering that the way audiences are engaging with Australian stories is changing. No longer is the scripted drama genre the only way these stories are told. Today Australian audiences are engaging in the telling of unscripted Australian stories through popular entertainment program formats like Little Big Shots, Australian Ninja Warrior, MasterChef Australia and many more. These programs are high-quality productions that employ thousands of Australians but, most importantly, they tell Australian stories. Contestants on these shows are drawn from a diverse range of backgrounds and all have their stories told in new and innovative ways that are resonating with Australian audiences. However, on children's content we've argued that we do not see a public policy case for the retention of the C and P quotas. Children are simply not watching these shows on commercial television, preferring instead to receive content via the ABC, YouTube or subscription services. We believe these quotas should now be abolished.

Our submission also sets out recommendations on the financial incentives that are crucial in the financing of Australian content. We have supported the increase of the producer offset for television drama to 40 per cent, to bring it in line with the current rate for feature films. We also support access to Screen Australia funding being opened up so that commercial broadcasters who are producing programs are on the same footing as other production groups, some of whom are international broadcasters, who can access that funding. Critically, the post, digital and visual effects offset, known as the PDV offset, must be retained in full. This is a crucial part of the funding mix for many of the most popular programs on commercial television, and any reduction would have a significant negative impact upon our ability to continue to fund Australian content.

Commercial broadcasters stand willing and able to play their part in meeting Australia's important social and cultural objectives. However, our members also need flexibility to remain relevant and competitive in the new media environment. Therefore they must be able to invest where they will provide the greatest social policy and economic benefits rather than being forced to continue to make content that is no longer valued by Australian audiences. The changes that Free TV has proposed would help ensure the Australian public continues to enjoy watching a large quantity of high-quality local content free on our broadcast networks. They will also ensure our members can continue to act as the cornerstone for the local production sector in a way that is relevant and sustainable. I thank the committee.

Senator URQUHART: Thanks, Ms Fair. The commercial television industry argued for the abolition of licence fees, successfully, on the basis that the industry would then invest in Australian content, yet then turned around and argued for the abolition of children's television quotas. Do you think that the free TV sector has an obligation to contribute to children's television in some way?

Ms Fair : Well, no. We actually feel that it's no longer commercially sustainable for us to do so and it's not actually delivering any cultural benefit, which was the purpose of these quotas. They are intended to be providing something to our child audiences. If they're not watching them, then clearly they can't be benefiting from them. So we just don't see a role for those quotas any further.

Senator URQUHART: If we put the quotas to one side, what options are there then for Free TV to contribute to children's television? What do you see as a contribution that you could make if you put those quotas to one side?

Ms Fair : I think importantly where we see child audiences and family audiences moving is to these entertainment programming formats that are being broadcast at around 7.30 at night. They're performing a very important role. They're the kind of programs that are bringing families together and delivering these Australian stories in new ways. So we haven't abandoned the child audience and the family audience; it's just that we're trying to provide programming in a way that they will want to consume it.

Senator URQUHART: You're talking about Home and Away and those sorts of shows, are you?

Ms Fair : Things like Ninja Warrior and even MasterChef. Older kids and some people are watching shows like The Bachelor, which may not be our taste necessarily here. These programs are often the starting point for conversations in families about how relationships function or other things. So there's a whole array of programming. When I was a kid I used to watch A Country Practice with my mum and I loved it. That was our time together, we'd sit there and that was good. But people are not doing that with Australian drama anymore; they are doing it with these other programs, and we see them having a very strong cultural value.

Senator URQUHART: What about contributing to a production fund?

Ms Fair : We are in the business of trying to run sustainable entities. We make significant contributions to Australian content—as I said, over $1.6 billion in the last financial year—and we're trying to do that whilst at the same time facing greater competition, declining revenues and higher costs. So we would not favour something which added to those costs, particularly where we weren't necessarily going to be benefiting from the output.

Senator URQUHART: Do you think it's a problem to concentrate all production within the ABC?

Ms Fair : I don't think anyone's suggesting that all production would be concentrated within the ABC. We're not walking away from our commitment to Australian content. We've suggested some changes to adult drama quotas and we've suggested some changes to children's, but we have maintained our commitment to the 55 per cent Australian content transmission quota. We've maintained a commitment to adult drama. We haven't suggested changes to documentaries. If we're having a conversation around the cultural benefit of these mechanisms, we should recognise where they're not actually delivering those outcomes anymore. If we want to have a conversation about industry support—that is, where will the production sector find its market?—that's an entirely different conversation, and we should have it in that form. But we shouldn't have an industry support conversation dressed up as a cultural conversation.

Senator URQUHART: Presuming it goes through, what does the Nine-Fairfax merger mean for Free TV?

Ms Fair : I don't see it making any significant difference to the operation of free TV broadcasters, but I'm not really across the details of that deal. If you have any specific questions I'm very happy to take them back to Channel 9 for answering, but I have no knowledge of the specifics of that deal.

Senator URQUHART: Do you think that it would mean that Free TV continues to be the relevant industry peak body for the new Nine company, or would that be the Press Council or both? How do you see that playing out?

Ms Fair : I see no reason that there wouldn't still be a peak body for free-to-air broadcasters. We've had other tie-ups in the past. People forget that—

Senator URQUHART: But what about for the new Nine company? Do you see that Free TV would continue to be that, or would it be a different peak body?

Ms Fair : I certainly see Free TV as continuing to represent the interests of commercial free-to-air broadcasters.

Senator URQUHART: And of Nine within that merger?

Ms Fair : Absolutely.

Senator URQUHART: The Liberal government has not undertaken the much-needed reform of the overall policy and regulatory framework for media and communications. I think there's been some criticism over other inquiries that we've had about it being a piecemeal approach and not a big package. In five years there's only been some deregulatory tweaks to the Broadcasting Services Act 1992, including the repeal of the two-out-of-three rule. Do you agree that the Nine-Fairfax merger means the update of the regulatory framework is becoming more urgent? Do you think that needs to be a wholesale update rather than piecemeal pieces?

Ms Fair : I'm obviously not here to talk about the Nine-Fairfax merger, but I think the point that we've been making as an industry for some time is that we are saddled with an array of outdated regulations, including content rules and all sorts of other things that I could talk to you about if we had the time. Yes, we do think it is time for us to be looking at an industry which is doing the heavy lifting in terms of supporting the Australian production sector and making sure that it's as sustainable as it can be. I'm not saying we're going to have all the same views with the production sector about where the emphasis should be, but at the end of the day we're inextricably linked. The health of commercial television broadcasters is fundamental to the health of our production sector.

Senator URQUHART: Do you think that the minister understands that the new Nine company will be subject to different regulatory frameworks for content depending on the platform, be it print, TV, radio or online? They all have different regulatory requirements.

Ms Fair : I can't really comment on the minister's knowledge of the implications of the deal, but I'm sure he would be aware of that. We're all certainly aware of that. That's the point we've been making. Even within our own organisations—we're now providing services that are both on a broadcast platform and in catch up and streaming services—we have different rules applying within our organisations for our own services.

Senator URQUHART: In terms of the content review, what does the Nine-Fairfax merger mean for FreeTV's position on the abolition of children's television quotas? Does it actually change things?

Ms Fair : No. We have the same position.

Senator URQUHART: Doesn't the creation of a large new commercial media company mean that they should be able to produce children's content as a social good, given the scale that they will have.

Ms Fair : I'm sorry to be repetitive. I can't comment on the implications of the Nine-Fairfax deal.

Senator URQUHART: You asked me to ask some specific questions, and that's what I'm doing.

Ms Fair : You'd like me to take those back to Nine?

Senator URQUHART: Yes.

Ms Fair : Sure. We can come back with those.

Senator URQUHART: That would be great, because you did ask for specifics.

Ms Fair : Sorry, I didn't realise that that was to be passed back. We will definitely take those on notice and come back to you with a response. My apologies.

Senator URQUHART: Lovely, thank you.

CHAIR: I think FreeTV's position has been quite clear around the idea that you don't support the continuation of the children's quotas. Is there an expectation, then, that there won't be children-specific programming on free-to-air broadcasters if that was the case? Or is there some other mechanism that you think would support that cultural significance, the importance of having that content there? Is it that you just don't want kids TV full stop or is it that the quotas aren't driving that cultural impact?

Ms Fair : The quotas are certainly not driving the cultural impact. We're basically producing hundreds of hours of programming every year that aren't being watched. That can't be a good thing. We haven't stepped away from our commitment to children in the sense that we are providing a lot of entertainment programming that the child audience is interested in watching—and the ratings numbers support that. So we've certainly still got that commitment.

Mr Mitchell : To have that cultural benefit you're talking about you need to have the children actually watching it. The two have to be linked. It's not that we're necessarily just walking away from it. It's that children themselves have already indicated, by not watching, what type of content they're valuing.

CHAIR: What do we do to help children access and have available to them appropriate content? If I'm really honest with you, it's hard to say that a children's drama that is written and produced specifically for a child audience, whether it's Dance Academy or something like that, is in any way the same as sitting down with mum and dad and watching Ninja Warrior. I'm not saying one is better than the other, actually, but they don't deliver the same purpose. If quotas can't deliver the ability for children to access children's content, what can? I feel that all the commercial TV broadcasters have done is put on the table 'scrap the quotas', with no kind of point of negotiation. Surely, there must be something else that you're prepared to come to the table to discuss about how we ensure that kids actually do have access to an important part of learning about their own world and the world around them.

Ms Fair : I would love it if my own kids read Charles Dickens, but they don't; they'd rather read The104-Storey Treehouse. They're not the same experiences in a literary sense either, but that's what they're choosing. We have to as a commercial business try and respond to what our audiences want. We're doing that, and we've shown a very strong commitment to programming material at that all important 7.30 family viewing time that children are going to watch. You're right: it isn't the same as watching a scripted drama but, if they're not going to watch it, there isn't actually any benefit being delivered. We've tried all these things. We've got programs that have been nominated for Emmys, and they're being shown to sometimes fewer than 2,000 viewers. The average is 4,007—that means some are a little higher; an awful lot are quite a lot lower.

ACTING CHAIR: Do you have any details about how you've promoted the accessibility of the kids programs on your multichannels? When those channels became available and you started moving kids television off the main channel and onto the multichannels across the various different broadcasters, was there a plan for how to help children and families know: it's not on the main Nine or Seven channel; it's over on GEM or GO!

Ms Fair : We can take on notice what sort of promotional activity there was around that time. However, I don't think, for instance, that the ABC spends a lot of time promoting ABC Kids either, and kids find it. The other thing I would say about the move of programming to multichannels on commercial television is that it has enabled us to have dedicated times that children can access that material. When those programs were being shown on the main channel, they were regularly subject to interruptions from news events and sporting events. We were always having to reschedule them and move them around, which was disruptive. They've now got a home on a particular multichannel, and children are still not watching them. ABC Kids would be one of the highest viewed sources of children's programming on television. People are finding it regardless of the fact that it's a multichannel, so I don't see programming on a multichannel as a disincentive.

ACTING CHAIR: I'd be interested to see what the ABC did originally to encourage people to watch ABC Kids. As somebody who has always relied on the ABC to have child-appropriate content as a parent, I trust that when I put my daughter or my niece in front of the TV it's going to be appropriate. If these quotas are abolished, what is going to fill the space on those multichannels?

Ms Fair : I don't actually know at this point. We'll be looking to what the available audience is and trying to deliver programs that that audience is going to want to watch.

ACTING CHAIR: It seems that there'll be an understanding that it won't be kids TV.

Ms Fair : I think it's unlikely to be kids TV, unless they start coming back to watching commercial television in numbers at those times of day that we haven't seen for some years.

ACTING CHAIR: You've got Seven, Nine, Ten, WIN, Prime and Southern Cross—does that mean there are five main channels and the rest are multi?

Ms Fair : Each broadcaster tends to have a primary channel, and then they will have four typically multichannels.

CHAIR: Is there any argument for a bit of a rethink around all these multichannels even being available anymore? Part of the argument to us as legislators is that audiences are looking for both Australian drama and kids TV elsewhere. Do we really need all these multichannels?

Ms Fair : People are watching them. From our members' point of view, they make commercial sense. In fact, when multichannels were introduced, they arrested some of the decline that we were seeing in the free-to-air audience. For us, they're very important.

CHAIR: So you think that there's enough content out there to pad them out. I'm reluctant to make you have to name some of the programs of your own members, but the reality is that a lot of that stuff on those multichannels is pretty rubbish or it's repeats or it's a shopping channel. It's not hardcore, highly produced content.

Ms Fair : I couldn't really agree with your characterisation of our programming. The fact that you and I might not find something to our taste doesn't mean that other people don't. These programs are clearly being watched by sufficient audiences to make those channels commercially viable, and therefore we think that there's a place for them.

CHAIR: Except for kids TV.

Ms Fair : You cannot broadcast a show to an average audience of 2,000 people in an environment where you have significant advertising restrictions. We don't get government funding. We don't have subscriptions. We are reliant on our business model for advertising revenue. When you're trying to advertise in children's programming, and you have a whole lot of rules that, possibly quite rightly, restrict the nature of that advertising, then you have a circle that means that these things become less and less viable. If we can't attract an audience that an advertiser isn't going to want to advertise to, we can't sustain that programming. Back in the eighties, it wasn't much different, except that (1) there were probably fewer rules and (2) we were in a much different position in our earning capacity. These things were seen as a cost of doing business. We're just not in that space anymore.

Mr Mitchell : The world has completely changed. Think about your own kids and whether they point and view anymore. Mine certainly don't. The ACMA research that came out last year talked about YouTube, and free services like YouTube, being the most heavily watched place that kids go to.

CHAIR: Absolutely. I guess that's why I'm asking whether it's time to have a conversation about whether we really need all these multichannels. If audiences are being so split and dispersed even on one broadcaster's channels, so much so that the numbers are now dwindling on kids television, for example, then I wonder whether every station really needs four channels to have to fill.

Ms Fair : They're not an imposition. They're a means of attracting across-the-board an audience so that we can have a sustainable business model.

Senator CHISHOLM: I was interested in advertising revenue. I noted a story in The Australian today that television advertising revenue has actually increased in the first six months to June 30.

Ms Fair : Yes.

Senator CHISHOLM: Is that something that is relatively new or is that something that has been a trend for a while now?

Ms Fair : No, that's a welcome reverse in the trend that I referred to in my opening remarks, which was that we've seen our advertising revenue decline by 22 per cent in real terms over the last decade.

Senator CHISHOLM: My understanding is that that data is purely based on the free-to-air channels.

Ms Fair : The three-ish per cent is a free-to-air channel number.

Senator CHISHOLM: Is that the first time there's been an increase in that period that you talked about?

Ms Fair : That's a six-month figure, as I understand it. They're released every six months, and it's been a while since we've seen any significant increase.

Senator CHISHOLM: Does that change any of the dynamics around some of the discussions that we're having, given that they have seen an increase?

Ms Fair : Well, the overall trend is moving in the opposite direction, so this might be the first one of a number of figures that are going to reverse that trend, and I sincerely hope that's the case. Then we might be having a different conversation, but right now we're having a conversation about where we are now compared to where we were when these rules were put in place.

Mr Mitchell : Just to add to that, that's one side of the equation. You've also got the cost side of the equation as well. If you take adult drama, for example, over the last decade costs have doubled there. So to the extent that revenue may well be swinging back—and we've got six months worth of trend, and we can't count it as a trend yet—we are still facing very strong headwinds on the cost side of the equation as well.

Senator CHISHOLM: When you say 'cost side', are you talking more about buying product rather than producing product?

Ms Fair : It's both. There's a market. Most of the original material that commercial broadcasters show is commissioned from independent production agencies, and, like everyone else's, their costs have increased.

Senator CHISHOLM: The free-to-air television channels that you represent all now have catch-up channels—or do all of them have catch-up? Do the main free-to-air ones have catch-up?

Ms Fair : All the metropolitan broadcasters do, yes.

Senator CHISHOLM: Do you represent those interests as well?

Ms Fair : They're services provided by my members, yes.

Senator CHISHOLM: But the streaming element—for instance, Stan, which Nine now have—are not something that you would necessarily represent?

Ms Fair : No, those SVOD services don't come under our umbrella.

Senator CHISHOLM: How important are the catch-up services becoming for the free-to-air channels in terms of revenue growth through advertising?

Ms Fair : They're an important part of the mix, and they can, particularly with something like a drama, maybe add 10 per cent to your viewing audience. But the main game in terms of revenue generation is still the broadcast platform.

Senator CHISHOLM: Are there any advertising figures available on the catch-up services?

Mr Mitchell : There were some quoted today.

Ms Fair : On the AVOD.

Mr Mitchell : Yes. But, to be precise, we'll take that on notice and provide those to the committee.

CHAIR: I just have one last question in relation to the rules around New Zealand content being classified as Australian. Do you think that's something that should change?

Ms Fair : My understanding is that the New Zealand content is a by-product of the Closer Economic Relations treaty between Australia and New Zealand, so that would really be a question for somebody—

CHAIR: Do you think it makes sense, though? Do you think Australian audiences expect that, if there is an expectation of Australian-made content, it's Australian, not just Australian or New Zealand?

Ms Fair : I just don't see it as a significant issue. In 2017, New Zealand content made up 0.12 per cent of the transmission quota on primary channels of my members. In 2017, all of my members met their minimum drama points requirement with programming that was Australian rather than New Zealand. On multi channels, the average amount of New Zealand programming in 2017 was around one per cent. So I really don't think that this is causing major problems for our production ecosystem.

CHAIR: So, if all of your members are being able to meet the current drama obligations, what's the problem? Putting kids' television aside—because we've had that conversation—if it's being met and there's no problem and there's no need to find loopholes such as the New Zealand situation, I really struggle to understand why there is such a push away from investing in Australian drama. What is really the underlying argument for it?

Ms Fair : In relation to New Zealand content?

CHAIR: No, I mean in relation to the recommendations from Free TV and your members to change the current regulations and the current rules.

Ms Fair : I wouldn't describe that as a push away from Australian drama. What we're saying is that the reality of Australian drama, the economics of it, is that audiences have halved and costs have doubled. Essentially, that means that the cost of making and commissioning those programs and our ability to recoup money by showing them is vastly different. We're asking for some flexibility so that we can recognise those facts whilst not stepping away from our commitment to adult drama.

CHAIR: What's happened to the money that the commercial broadcasters have been able to keep because there are free licenses? Where has that money been invested in from your members' perspectives.

Ms Fair : The case that we took to government and all parties in relation to licence fee cuts was that the competitive landscape for the industry was vastly different to when those licence fees were first envisaged in 1964, and that we were not able to sustain a tax on our operations, which was regardless of profit, on top of all of the other things that we do, including Australian content and other things. What's happened to that money? Well, what you didn't see was anybody putting out any special dividends and money being handed out willy-nilly into the community. That money has been reinvested into our ability to continue to make great Australian content, to diversify our services into things like catch-up and other ways so that we can provide our content in the ways that our audience wants to watch it.

Senator DUNIAM: This may be something I have to somehow go directly to the different broadcasters for, but I wonder whether Free TV has a view on this. In terms of sourcing content we're obviously a smaller market to source content from, but has that at all contributed to what has been picked up by free-to-air broadcasters and what's not been picked up? Is the offering not as diverse as, say, some of the international markets?

Ms Fair : Our content offering?

Senator DUNIAM: Yes. Any of the broadcasters that you represent.

Ms Fair : No. I think we've got an extremely healthy content offering from commercial television broadcasters here in Australia. If you travel anywhere you'd find that we hold our own with the best in the world.

Senator DUNIAM: Sorry, I meant in terms of the supply to broadcasters. In Tasmania we have a very limited number of people that produce content. We have Blue Rocket, who made the Logie award winning production Little J & Big Cuz, but there aren't a huge number that come out of places like Tassie, and I dare say that across the country it's broadly the same. In terms of sourcing content for your broadcasters, is that a difficult thing to do when it comes to trying to source Australian content that viewers wish to consume?

Ms Fair : I'll tell you what's happening: like everything, there's more competition for product, because we've got more platforms that are wanting to show it. Yes, that does, and I think that's one of the things that we're seeing in terms of the cost pressures on those pieces of content. There's obviously a finite supply and a growing demand.

Senator DUNIAM: Okay. That's fine. The only other question I had was in relation to digital, but your submission covers that pretty well.

Senator URQUHART: Earlier you quoted some rating figures for children's television. Is children's television the lowest-rating programming on commercial television?

Ms Fair : I'll come back to you on notice on that, but I'd say it's pretty likely.

Senator URQUHART: Okay. If you could take that on notice that'd be great. Are there any other programs on commercial television that rate as low as children's television?

Ms Fair : I'll come back to you on notice, but it's an extremely low number.

Senator URQUHART: So you think that probably sits at the lowest, but you'll come back and confirm that?

Ms Fair : Yes.

Senator URQUHART: You might need to take this one on notice: what is the next-lowest-rating program? What are those figures and how much of the schedule do they actually take up?

Ms Fair : We can definitely come back to you with that.

Senator URQUHART: Earlier you said that commercial television is delivering Australian stories in new ways, with children now watching family programs such as MasterChef, Ninja Warrior and even The Bachelor. What are those programs rated? Are they rated G, PG or M? I'm not sure, because I don't watch them.

Ms Fair : I'm also not sure, but I will check. Obviously they're very family-friendly programs in the main.

Mr Mitchell : My four-year-old watched Ninja Warrior this morning after the catch-up, so I'm going to hope I've been a good parent in showing him a G program.

Senator URQUHART: So you're hoping it's G.

Mr Mitchell : Yes, I hope so!

Senator URQUHART: Let's hope it's not M, then.

Ms Fair : They're definitely not M.

Mr Mitchell : We'll come back to you on that.

Senator URQUHART: I would have thought that The Bachelor was maybe M, but I don't know. I've got no idea, so if you could let me know.

Ms Fair : We can come back to you with some of those. Obviously something like The Bachelor doesn't usually get shown at 7.30; it tends to be a later slot.

Senator URQUHART: I was going to say that, given that children predominantly watch those programs on commercial television, are current advertising restrictions appropriate for the 7.30 pm timeslot?

CHAIR: 7.30 pm is bedtime in my house.

Senator URQUHART: It depends how old your kids are.

Mr Mitchell : That's why Ninja was watched this morning and not last night.

Ms Fair : You've pulled off a feat that many parents would admire, Senator.

Senator URQUHART: That's right, exactly.

Ms Fair : We have the safest platform for families and children to watch content of any of the places you can find. You're not going to find any ISIS ads on commercial television, I can guarantee that. We have a lot of rules around what can be advertised at certain times of the day and what classifications are required at certain times of the day. I think we're rewarded with a reasonably low level of complaint about the placement of commercials.

Senator URQUHART: I don't want to put words in your mouth, but can I glean out of that that what you're saying is that the current advertising restrictions are appropriate for that 7.30 timeslot?

Ms Fair : We believe so. I think it was last year that we did our code of practice—is that right, Ross?

Mr Mitchell : The year before.

Ms Fair : The year before. We have an industry code of practice that governs all of these matters. It goes through the Australian Communications and Media Authority and it also goes out to public for comment, so it's intended to satisfy community standards.

CHAIR: Thank you, Mr Mitchell and Ms Fair. You have taken some questions on notice, so the secretariat will be in touch about timeframes for that. If you want to correct anything or clarify anything, please do. Thank you.