Karen Pryosusilo Submission 20 June 2018. docx



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logo: australian government, department of communications and the arts.

Inquiry into the competitive neutrality of Australia’s national broadcasters

Submission – Karen Pryosusilo (20 June 2018)

Question 8: Considering the commercial activities of the national broadcasters (e.g. where they are selling or purchasing goods and services), is there evidence that they have taken undue advantage of their government ownership, to the detriment of competitive outcomes?

The ABC and SBS have not taken undue advantage of their government ownership to the detriment of competitive outcomes. To the contrary, they hold a higher standard to which others must meet through their thorough reporting for all Australians regardless of whether they live in the city or country.

Question 9: What is the differential impact of regulation on commercial and national broadcasters, and is there evidence of consequent adverse impacts on competition and outcomes?

The key difference is that ABC and SBS contribute to our well functioning democracy in a tangible way. Commercial entities are selling something.

Question 10: Is the reporting and accountability by the national broadcasters on their best endeavours to observe competitive neutrality adequate?

ABC and SBS are very accountable and they adequately observe competitive neutrality. Evidenced by the way that high-dollar value sports are broadcast on the commercial channels first.

Question 11: Are you aware of any specific instances where the ABC or SBS may have received any other competitive advantage, due to their public ownership, to the detriment of a private competitor?

The national broadcasters have not taken advantage of their position.

Question 12: The SBS Charter requires it to take into account the activities of the ABC and community television on radio and television. In the context of the competitive neutrality principles how in your view, is the SBS complying with this requirement? From your perspective does it adequately cover the activities of the SBS?

SBS does it’s job very well.

Question 13: From your perspective do the national broadcasters seek a balance between competing in the market and complementing the market? Is that balance the same for traditional broadcasting and for new digital platforms?

From my perspective the national broadcasters offer something which is guided by the need to contribute to the public good rather than commercial success per se. Sometimes the two come together, which should be celebrated.

Question 14: Do you have comment on these guiding principles?


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Inquiry into the competitive neutrality www.communications.gov.au

of Australia’s national broadcasters www.arts.gov.au Page of

www.classification.gov.au



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