For at least a year, it has been clear that one of the key media battles of this decade will be between those who would like us to pay up-front for content (Murdoch, pay television and others) and free-to-air providers, with leadership for the free-to-airs being provided by taxpayer-funded broadcasters such as the ABC.

This is the context for communications minister Stephen Conroy’s promise of a regulatory shake-up, made in a speech to the Australian Broadcasting Summit yesterday.

The process of inquiry and review he foreshadowed is no surprise (the industry has been expecting, indeed gagging for it, for months) and also a sign of policy shortcomings.

Where is Labor’s media policy? It was promised before Rudd came to government, but never emerged. Now we are being treated to yet another Rudd review and consult exercise, which, while all very worthy on the surface, really reveals the lack of  thought and preparation.

The government has a broadband and technology policy — about delivery mechanisms — but virtually nothing to say about content, and local content in particular.

Conroy topped and tailed his speech yesterday with the claim that “content is king”. He even quoted Murdoch as saying “Content isn’t just king — it’s the emperor”.

And yet in between he had almost nothing to say about content, and how the government might ensure that the local production sector, or even Australian journalism, continues to thrive. Instead his speech was all about spectrum restacking and digital dividends and transmitters at Underbool  (true).

In the absence of a strong intellectual vision on content from government, the two thought leaders of the industry are Foxtel boss Kim Williams of Foxtel and ABC head Mark Scott.

In recent months Williams and the ABC’s director of television Kim Dalton have suggested that some of the digital dividend money government gets from selling off spectrum should be spent on a cultural fund to support Australian content. The two men differed on how that money should be divvied up, but they shared the focus on content generation.

Any reference to this from Conroy? No.

Meanwhile, the battle between pay platforms and free-to-air is hotting up, with some particularly interesting developments today.

Normally the debate is conducted in an atmosphere of fairly naked commercial self interest. After all, how will News Limited manage to erect paywalls around its content if the ABC is providing cover-all news for free? How will Foxtel ever achieve majority penetration in Australian homes if the ABC is providing niche content in competition?

But today Williams pitches the argument differently, and with power, in this piece on News Ltd’s The Punch.

Williams acknowledges the self interest in his position, but then adopts the mantle of the concerned citizen and takes the argument further, using the changing nature of media to argue for a different “take” on the role of a public “broadcaster”.

Before we had digital multichannels, Williams argues, commercial television was obliged to concentrate on similar programming designed to attract mass audiences. Only the ABC, free of commercial pressures, could offer really different programming “providing some market correction or rather a sense of balance with other perspectives and focus on things often omitted in the mainstream”.

Now, argues Williams, the intellectual content of the ABC has declined. What Scott should be doing, he suggests, is not spreading the existing content over ever more platforms, but “leading a 21st-century renaissance of Australian culture” with “more dramatised novels, more serious discussion of books and science, and more edgy ABC-made versions of The Wire and Mad Men.  This — improving content quality and scope — is where the ABC should be spending the $137 million in extra funding it is getting from the federal government.”

Now, some of this is unfair, because a fair bit of the increased government funding is tied to particular outcomes and government priorities.

I would also agree with Scott that if the ABC doesn’t move in to 24-hour news, it will become irrelevant, and that is not a good thing.

But what Williams is doing in this is not merely attacking Scott, but also hinting at an alternative vision for public “broadcasting” in the new media age. And that is a very powerful thing to do when all the old verities are being shaken up.

Williams becomes more predictable when he returns to the attack on the ABC’s leading role in Freeview — the industry association representing free-to-air television. He says that Freeview has as its “mission … to steal customers from subscription providers using publicly subsidised advertising”. Thus the ABC should not be involved.

Dalton gave some answers to this line of argument in his speech to the summit yesterday.

Dalton was engagingly frank, particularly in the context of some of the spin and PR bullsh-t that Freeview has tried to foist on media reporters over the past few years. He called a spade a spade, saying: “Quite simply Freeview is a branding exercise … Freeview’s vision is to maintain free-to-air terrestrial television as the pre-eminent viewing platform for Australians in the transition from analogue to digital and to continue to provide free, compelling television services to all Australians.”

And why should the ABC be involved? Because, argues Dalton, it is still free-to-air television that supports the local content making industry.

“In my view, being able to tell Australian stories to Australian audiences means that we need to have a healthy free-to-air television industry. And for the ABC to be able to access the creative resources of the local production sector the ABC has to play a role in maintaining the broader framework that supports local production.”

In other words, public broadcasting and commercial free-to-air share interests in this new media environment around the thing about which Conroy never speaks — content. Pay providers must also think, first last and in the middle, about content, and what the audience might be prepared to pay for. The only people NOT thinking about content, it seems, are those in government.

And this is despite other Rudd reviews into content-rich topics such as  innovation and government uses of Web 2.0 technology.

In this environment, Conroy plans to review anti-siphoning, local content obligations for broadcasters, ownership controls and all the rest, while at the same time reinforcing the government’s support for the ABC.

But where is the government’s intellectual thread? Where is its policy?

How nice it would be if Conroy actually had something to say about how content might be nurtured, rather than talking only about how it is delivered.