SEVERAL responses to the Green Paper on Broadcasting suggest the need for some form of broadcasting regulator or commission separate from existing regulatory bodies but given the specific remit to protect or expand public broadcasting.

If such a body is proposed in legislation this year, it is important that the current sporadic debate on broadcasting provide a place on its agenda for discussion of its functions.

Should it pull together in one institution most of the current powers of the Independent Radio and Television Commission (IRTC) and the RTE Authority, as well as regulatory responsibility for licensing cable, MMDS and local television services?

Most importantly, should the licence fee collected by An Post be funnelled to this commission rather than, as at present, to RTE and then be disbursed by it to any station, public, private or community, which successfully looks for funding to support "public service" programming?

The argument for a quango to function much like an arts council is actually an import into Ireland from the British debate on broadcasting over the last 15 years. The "arts council of the air" concept had its origin in the free market think tanks which underpinned British government policy formulation for broadcasting in the Thatcher era.

It had a strong influence on the Peacock Commission, which recommended the establishment of a Public Service Broadcasting Council with the remit to give grants for "public service" programming, and it was promoted strongly throughout the 1980s by Rupert Murdoch personally.

This Murdoch campaign led to speculation in Britain that if the arts council idea were acted upon, and if certain fledgling commercial satellite channels found themselves in financial difficulties, they might be able to avail of licence fee funding for "public service" programming.

Rejected as "potty" by the then Tory broadcasting minister, David Mellor, the argument for an "arts council of the air" died a slow death in the Major administration.

AMONG all the responses to the 1992 Green Paper on "The Future of the BBC", re was an overwhelming consensus against the introduction of a quango to dispense public funds.

ITV and Channel 4, which might be the main beneficiaries, rejected the idea. Channel 4 argued that committees do not make good decisions about highly subjective matters like programmes and that such a funding system "would inevitably bring politicians and bureaucrats closer to decisions about individual programmes than is healthy in a democracy".

Channel 4 concluded: "We can find no argument that a public service broadcasting council would improve the quality of programmes on offer to the viewer; quite the reverse, it also risks impoverishing the BBC: it is simply a rotten idea."

The Arts Council of Great Britain (the real one) likewise rejected the idea of an "arts council of the air" because of the danger of conferring significant financial power on one organisation and the danger that it could lead to "a narrowing of the range of programmes, removing arts programmes from the broad programming mix in which they flourish".

Much of the debate in Britain is useful in Ireland as we contemplate how to provide appropriate funding for all our cultural institutions. Is the notion of an "arts council of the air" a good one for us, despite the British rejection of it?

Should a super authority be given power to disburse £50 million in licence fee income across radio and television stations, publicly owned, privately owned and community owned, including those that currently exist and new stations that may be launched under the impetus of digital transmission?

In seeking an answer, the following should be considered:

In a world of a la carte public service broadcasting, is it possible to agree on a definition of "public service programming" that will achieve a wide consensus and go beyond the subjective likes and dislikes of individual regulators? Is it not true that "public service" is a quality that inheres in a comprehensive broadcasting service as expressed in its' schedules, rather than an attribute of individual programmes?

An authority that disburses funds, for individual programmes (unlike, say, The Irish Film Board, which dispenses funds for individual films), would need to have power over broadcast scheduling, as well as production, to ensure that approved projects have a fair chance of reaching large audiences in prime time, rather than being consigned to the margins of the schedule.

Is it not, therefore, true that the twin powers of programming and scheduling will bring any new authority close to being itself a publisher/broadcaster? Apart from the political fact that this new regulator will have enormous editorial power to shape the content of radio and television, the change of status from super authority to super broadcaster has huge resource implications that need to be examined.

CAN we be sure that the dispersal of what was a single, concentrated stream of funding for programme making to a plethora of programme makers will produce better programmes overall than the present arrangement? Will licence fee payers warm to the scatter shot use of the fee to fund several new broadcasters or will they rebel against payment?

Sharing out the licence fee may have a hugely destabilising effect on RTE. How will it react? Will it be forced into the kind of dull, elitist, cultural ghetto that has weakened public broadcasting systems in the US and Australia, for example, abandoning programmes which attract large audiences to commercial broadcasters and, thus turning themselves away from making a major contribution to quality standards across a wide range of programmes in a pluralist broadcasting world?

Should we grant any new licences to commercial broadcasters on the basis of their argument that they can survive, even thrive, solely on the commercial appeal of their programme, if it is inevitable that in a few years from now they will go for the Murdoch option, that is, argue that they must have the same access as RTE to a dual funding arrangement?

By arguing that all broadcasters should be dual funded, are we not losing faith in the idea, propagated in the 1980s, that healthy competition between public and private broadcasters will benefit viewers and listeners by producing better programming?

To elide rather than preserve the funding differences between public and private broadcasting by increasing rather than reducing RTE's dependence on advertising income, means that the momentum of all broadcasters will be towards wholesaling audiences to advertisers, rather than providing programmes to viewers and listeners on the basis of crude numbers unrelated to intensity of demand.

Research shows that under such competitive conditions, the relationship between broadcasters tends to maximise total audience but restrict overall programme choice. This is the lesson to be learned from New Zealand, which has experimented with an "arts council of the air" since 1990.

The strength of RTE for the foreseeable future must be built on a dual funding foundation. This means that it will have to work to both public service and commercial goals simultaneously. Given the reality of this, the suggestion that we need the steadying hand of a national broadcasting commission is a good one. But we do not need another arts council spreading public funding ever more thinly over an expanding number of broadcasting services.