Advocacy » Recent submissions
Competitive Neutrality Submission
Submission to the Department of Communications and the Arts regarding the Inquiry into the Competitive Neutrality of the National Broadcasters.
Senate Economics Committee Submission
Submission to the Senate Economics Legislation Committee Inquiry into Treasury Laws Amendment concerning the 'Gallipoli Law'.
Skilled Migration - Temporary Skills Shortage Visa
Submission on the Skilled Migration Occupation List Traffic Light Bulletin. SPA notes that the number of proposed changes is much higher than the previous review. SPA also notes that no clear rationale has been provided to justify removal of these occupation.
Submission to the Senate Standing Committee
Submission to the Senate Standing Committees on Environment and Communications Inquiry into Australian Content on Broadcast, Radio and Streaming Services. SPA has made a series of recommendations that would improve the quality and quantity of Australian content and ensure that Australian and international audiences have greater access to Australian content.
Screen Producers Australia pre-budget submission
Screen Producers Australia has identified market failure for Australian producers of film and television content. In the market for television content, this market failure is an inherent feature of the market, which is set up by government itself through legislation (Broadcasting Services Act 1992).
Submission to Advance QLD 10-year Roadmap for the Screen Industry
Screen Producers Australia’s submission to Advance Queensland 10-year Roadmap for the Screen Industry. SPA supports the vision stated in the consultation paper, that is “by 2028, Queensland’s screen industry has doubled in value, is positioned globally, and makes a significant contribution to Queensland’s economy and culture”.
Submission to the Australian and Children’s Screen Content Review
Screen Producers Australia’s submission to the Australian and Children’s Screen Content Review. SPA has made 12 recommendations in response to the consultation paper.
Submission to Standing Committee on Communications and the Arts
Submission to the Standing Committee on Communications and the Arts Inquiry into Factors Contributing to the Growth and Sustainability of the Australian Film and Television Industry. SPA consulted with its membership, Policy Reference Groups and conducted the 2017 Screen Industry Business Survey, the results of which are referenced throughout the submission.
Submission to Final Report regarding IP arrangements
Submission to the Productivity Commission. Maintains opposition to fair use, the Commission’s “finding” that the term of protection is too long, and the recommendation to make circumvention of geo-blocking technology not an infringement of copyright.
Submission to Draft Report regarding IP Arrangements
Submission to the Productivity Commission. Rejects recommendations for a reduction in the copyright term, the removal of geoblocking restrictions and the adoption of a broader fair use system of copyright protection.
Submission regarding media ownership and reach reform
Submission to the Senate. Screen Producers Australia argues that media regulation must put Australian consumers first. Whilst these reforms address specific aspects of the ‘reach rule’ and ‘two-out-of-three rule’, consideration must also be given to the overall balance of obligations and regulations, including content standards.
Submission regarding the Trans-Pacific Partnership Agreement
Submission to the Joint Standing Committee on Treaties. Whilst unable to achieve a full cultural 'carve-out', Screen Producers Australia is pleased with the outcome for Australia's screen industry with the negotiation team able to preserve our existing rights with regard to spectrum mangement, quotas, subsidies and grants and the use of taxation measures.
Submission on rural and regional production and broadcasting
Submission to Senate inquiry. Screen Producers Australia recommends adjustments to the Australian Content Standard regarding the treatment of first release drama, targeted funding initiatives for ABC, SBS and Screen Australia and the expansion of local content obligations across streaming services.
Submission regarding ACMA reporting obligations
Submission to the Australian Communications and Media Authority. Screen Producers Australia does not object to changing the frequency of monthly reporting to annual returns by metropolitan commercial television broadcasters, however there remains very strong opposition to the removal of program-by-program data.
Submission on the future of Australia's games sector
Submission to the Senate inquiry. Screen Producers Australia argue that with the right balance of market-based incentives, games companies will grow domestically, creating jobs that build career pathways and retain highly transferrable skills. This, together with increasing inward investment, will ensure that this sector continues to make a significant contribution to Australia.
Submission regarding the ACMA review
Submission to the Australian Communications and Media Authority. Screen Producers Australia reiterates the importance of content regulations. Recommending that amendments to obligations and processes should be benchmarked internationally in conjunction with consultation and that the regulator needs to retain, and increase the frequency, of transparent reporting.
Submission on commercial free-to-air sub-quota flexibility
Submission to the Post-Implementation Review of the Broadcasting Legislation Amendment (Convergence Review and Other Measures) Act 2103. Screen Producers Australia believes that these amendments have made Australian programs harder to find, have increased downward pressure on the licence fees and are threatened by an increased reliance on New Zealand alternatives.
Submission on the impact of the 2014 and 2015 budget decisions
Submission to Senate inquiry. In response to the 2014 and 2015 Federal Budgets, Screen Producers Australia calls for more effective benchmarking of public broadcasters through greater transparency, offset reforms to drive productivity in local and offshore production and the protection of diversity of Australian content on free-to-air television.
Submission regarding industry assistance in Queensland
Submission to Queensland Competition Authority. Screen Producers Australia aruges that a balance of local and international production is needed to ensure a consistency of employment, career pathways and world-class services and facilities.
Submission to commercial television codes of practice
Submission to Free TV Australia's review of the Commercial Television Codes of Practice. Screen Producers Australia supports the request for more flexibility in classification zones, contingent on the ongoing commitment of broadcasters in retaining safeguards for younger views and meeting the requirements of the Australian Content Standard and Children's Television Standard.
Submission regarding the review of digital television regulation
Submission to the Communications Department's review of digital television regulation. Screen Producers Australia recommends that increases in viewing hours should result in a relative increase in Australian content. If commercial and public broadcasters are given the capacity for more channels these new channels should be subject to Australian quota obligations.
Submission regarding the draft Copyright Notice Scheme
Submission to the Communications Alliance's drafting Copyright Notice Scheme. Screen Producers Australia supports initiatives that will reduce the incidence of online copyright infringment. This scheme will form an important part of a holistic strategy, one that includes public education, promotion of legal alternatives and a pathway to stronger enforcement.
Additional information regarding ABC internal production
This submission includes additional information requested of Screen Producers Australia during the public hearing in Adelaide on 6 March 2015.
Submission regarding the review of the EMDG scheme
Submission to Austrade regarding their review of the Export Market Development Grants scheme. Screen Producers Australia comments focus on business clustering, certainty of payment, principal status, commissions, the export earnings test and review of Austrade decisions.
Submission regarding the BREA review
Submission to the Fair Work Commission regarding their review of the Broadcasting and Recorded Entertainment Award. Screen Producers Australia comments primarily focus on the removal of allowances payable for exploitation rights and better terms for time critical genres of production.
Submission regarding temporary visas in the entertainment industry
Submission to the Federal Government regarding changes to the Temporary Employment (Entertainment) visa (Subclass 420) and the Foreign Actors Certification Scheme. Screen Producers Australia is looking to Government for sensible reforms that embrace simplicity in design, structural flexibility and reflect the global marketplace.
Submission regarding the employment of children in NSW
Submission to the NSW Children's Guardian regarding the review of the Children and Young Persons (Care and Protection) (Child Employment) Regulation 2010. Screen Producers Australia encourages an educative response to managing compliance, rather than increased regulatory burden, given the low levels of non-compliance in commercially produced screen content.
Submission regarding internal production and local content on ABC
Submission to the Senate Inquiry into the ABC Amendment (Local Content) Bill 2014. Screen Producers Australia states that this Bill will harm the ABC, its audience and producers alike by reducing efficiency, editorial control, diversity, quality, hours produced, employment and economic impact.
Submission regarding deregulation and subscription broadcasters
Submission to the Standing Committee on Environment and Communications addressing the removal of auditing requirements for Australian content on subscription television. This submission argues that the relative costs and benefits have not been clearly communicated.
Submission to Screen Australia's 2nd Draft Documentary Guidelines
Submission to Screen Australia in relation to their secpmd draft guidelines for documentary programs. This submission reiterates our concerns raised in previous submissions, but acknowledges that a more balanced approach has been adopted in the revised draft and suggests further tweaks to proposed amendments.
Submission to the Online Copyright Infringement Discussion Paper
Submission that supports measures to mitigate sharing of screen content in violation of copyright. Such measures should include a code of practice to enforce a light touch graduated response framework to address peer-to-peer online piracy. This submission looks at extended authorisation liability, injuctive relief, the safe harbour scheme and implementation costs.
Submission to Screen Australia's Draft Documentary Guidelines
Submission to Screen Australia in relation to their draft guidelines for documentary programs. This submission reiterates our concerns raised in the response to the discussion paper and encourages further consideration of the commercial impacts of the proposed changes.
Submission to Screen Australia’s Enterprise Industry Draft Guidelines
Submission to Screen Australia in relation to their review of the Enterprise Program Industry draft guidelines, which retain elements of the current program while also identifying new ways to refine and refresh broader industry growth and renewal objectives.
Submission to Screen Australia’s Documentary Funding Discussion Paper
Submission to Screen Australia in relation to their discussion paper on Documentary Funding programs. This submission cautions against any changes to the underlying principles of the Screen Australia's current doucmentary funding guidelines, but outlines some changes in program design that could increase competition for established and emerging platforms.
Submission to Screen Australia’s review of the Enterprise Program
Submission to Screen Australia in relation to their review of the Enterprise Program. It outlines the need to maintain the program in some form as an incentive for growth, the need to increase transparency about program focus areas and provide more detailed feedback to limit cost to business and to consider investment in shared resources to grow capacity.
Submission to Developing an Arts & Cultural Policy, NSW
Submission to the NSW Government in relation to their development of an arts and cultural policy. It underlines the need for a holistic vision that unifies government and industry to drive productivity, capacity building through infrastructure, skills and business retention.
Submission to the Copyright and the Digital Economy Discussion Paper
Submission to the Australian Law Reform Commission. The terms of reference given regard to the extent to which copyright reform must reflect commercial reality and broader public policy objectives. In particular, potential changes to the way in which content is used in the education sector the impact this may have on revenue levels.
Submission to the inquiry into the Tax and Superannuation Laws
Submission to the House Standing Committee on Economics in regards to the treatment of 'documentaries and film tax offsets' and the extent to which the Producer Offset should adapt to changes in market demand and contemporary practice.
Submission to the inquiry into the Media Reform Bills Package
Submission to the Senate Standing Committee on Environment and Communications. Terms of reference relate to the impact on transmission quotas as contained in the Broadcasting Legislation Amendment (Convergence Review and Other Measures) Bill 2013. Considers this impact in relation to the objectives of the Australian Content Standard.
Submission to the Interactive Games Fund: Options Paper
Submission regarding new funds allocated to Screen Australia. The terms of reference consider the evolving screen sector and the way in which the expansion and collaboration of multiplatform production should be prioritised in the production of film, television, transmedia and games content. It also has reference to the long term need to tax incentives.
Submission to the inquiry into the ABC's commitment to regional diversity
Submission to the Senate Standing Committee on Environment and Communications. The terms of reference included the commitment by ABC to representing regional diversity in Australia and the impact of increased centralisation of television production in Sydney and Melbourne.