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Should the news media be a public service, subsidised by tax or licence fee?

And should the government step in to protect newspapers?

There are big questions around the funding of the media, with the economic downturn and technological change bearing down on them.

The business model that has sustained newspapers for centuries is broken.

Those that are successful in pushing online, and free to use, can lose out as a result in their print circulation and print advertising. That helps explain The Guardian's particularly poor sales figures.

Older commercial television stations are similarly troubled, as the fracturing of the audience across multiple channels takes away the advantage they once had and the "licence to print money", as Scottish Television was described long ago.

The new Secretary of State for Culture Media and Sport, Jeremy Hunt, has served notice this week that the ³ÉÈË¿ìÊÖ's licence fee is up for a tough negotiation, and that those of us who work in the corporation shouldn't assume we'll be protected from the pain being felt by those who depend on taxpayer funding.

El Spanish tele-shopping

With that background, it's worth noting what's happening with near neighbours.

Today, the European Commission has issued its approval for three schemes that subsidise public service media.

And while the pressure is on in Britain for the ³ÉÈË¿ìÊÖ to justify its privileged and (some might say) anomalous position, France and Spain look like their moving towards state funding in order to reach for parallel standards for which British viewers and listeners are envied.

In Spain, the public broadcaster RTVE has ditched advertising, teleshopping, merchandising and pay-per-view.

This leaves more space for genuinely commercial operators to step into those activities, while the state-backed broadcaster focuses on its "public service mission".

That state backing will include a tax on free-to-air broadcasters at 3% of revenues, and 1.5% of pay-TV broadcasters.

A tax of 0.9% is to be placed on the revenues of electronic communications operators, meaning internet providers, cable and satellite operators.

And up to £300m could come from a share of a levy that already exists on use of the radio spectrum.

Le service public

France Televisions is the country's largest broadcasting group, including six channels. Between 25 and 30% of its revenue has come from advertising. But not by the end of next year, when it will have gone.

The corporation is to get a subsidy from French taxpayers starting at £380m per year, plus Spanish-style levies on advertising and electronic communications.

Approval for this new funding mechanism from the European Commission is on condition that this taxpayer subsidy doesn't skew the market against commercial broadcasters, which means the money has to be spent on public service broadcasting.

That creates a difficult regulatory challenge: will European officials be monitoring programmes to make sure they fit that description? They say not.

In Sweden, the European Union has moved to curtail subsidy to the newspaper market. This system existed from 1971, before Sweden joined the European Union. That allows it special dispensation - just as the ³ÉÈË¿ìÊÖ's licence fee is not an issue for the European Commission.

Even though it's tough going in the newspaper market, it was reckoned that the subsidies needed pared back, but not abolished.

It's reckoned by the Commission that "traditional newspapers are still important for media pluralism and for the cultural, democratic and public debate in Europe".

So it's allowing Sweden to spend around £4m on aid for metropolitan papers, up to 40% of their editorial costs and 75% of costs for "low-frequency newspapers".

Journalism for free

These are just some of the ways European neighbours are protecting or being forced to alter the state's intervention in media markets.

And they're relevant to the British debate about sustaining its newspapers and commercial television.

The new Westminster government has axed Labour plans to charge a levy on broadband as a means of expanding its roll-out, and that retreat chokes off one French/Spanish means of funding media deemed to be of public value.

It has also axed the pilot plans to help rejuvenate commercial TV news in Scotland, Wales and north-east England.

But it hasn't yet said how those companies, including STV, are supposed to sustain their franchise commitments on news when it is widely acknowledged that advertising revenue has fallen far below the level required to pay for it.

Journalists at STV fear a cull of their output and jobs.

For newspapers, much hangs on the delayed plans of Rupert Murdoch's News International group to charge for access to online content - challenging the perception that journalism can be accessed for free.

The British approach to regulation of print news has traditionally been hands-off and subsidy-free, except to serve notice that cross-ownership constraints for local media may soon be relaxed.

That could see newspaper groups combine with local TV and radio, which they have not been allowed to do.

That may be one answer for companies such as STV, DC Thompson in Dundee, and Johnston Press, for which the share price is again in dismal territory - 44 pence last October, now at 13 pence.

The Edinburgh-based publisher, with The Scotsman and Yorkshire Post among its flagship titles, may already be looking overseas for answers to its problems.

It's just recruited a Norwegian specialist in media innovation, one Kjell Aamot, as its non-executive director. He's spent 20 years atop a Norwegian newspaper group, Schibsted, and is now involved with a publisher of freesheets in France.

Meanwhile, for commercial television, which is much more heavily regulated than newspapers, it's not so easy to find answers to the question of how diversity and quality can be sustained - but STV is among those companies looking forward to hearing what answers the new government is offering.