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Dame Elaine Kellett-Bowman (Lancaster) : Why does my hon. Friend think that it is an either/or situation ; we can have both.
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Mr. Bottomley : I am not sure that my hon. Friend can have been listening to me. I did not say that it would necessarily be an either/or situation.
Dame Elaine Kellett-Bowman : It is not.
Mr. Bottomley : In all humility, I should like to develop my own speech. I may be wrong, and my hon. Friend may be right. I merely want to ensure that we do not debate the matter without recognising the major influence of the hours of broadcasts that are valuable to all of us. I am sure that my hon. Friend the Member for Ealing, North (Mr. Greenway) would agree with that. I doubt whether Twyford high school would have been converted to a Church of England school without the background influence of national broadcasting, even though the majority of children at that school are not necessarily of a Christian denomination.
That important element, and the work that the Bishop of Liverpool does with the Central Religious Advisory Committee, should get more attention. I hope that, as the months go by, people will listen to the chairman and members of that committee, who do have a broad knowledge of what is going on. They may be able to prevent us from falling into the idea that religion is a minority interest rather than a most important part of our national life and our national broadcasting network.
Mr. Mellor : I am grateful to hon. Members on both sides of the House for their commitment to making progress with the Bill, and for their co-operation in achieving that aim. Perhaps it would be for the convenience of the House if I moved future amendments formally--not to avoid debate, but to avoid unnecessary debates. If there are then points on which I can assist the House, as I am sure there will be, I can respond to them. That may be preferable to my introducing at any length questions on which, given the consideration the Bill has already received, hon. Members may be perfectly content.
Hon. Members indicated assent.
Mr. Deputy Speaker (Sir Paul Dean) : From all the heads that are being vigorously nodded, I get the impression that that is a most welcome suggestion.
Mr. Mellor : Thank you, Mr. Deputy Speaker. That is a good start. The constituents of the hon. Member for Stoke-on-Trent, Central (Mr. Fisher) get a bit of balance in their lives, being represented by him in Parliament and having religious broadcasters in their midst as some compensation. When we set our hand to an expansion of responsible religious broadcasting, we did so advisedly, believing that some broadcasters would view responsibly the expansion that had been made possible, but knowing that there are some other groups--cults and American-style broadcasters, for example--that we would not want broadcasting here and for which the Bill provides no mandate. That is why the Bill is carefully drawn to permit the expansion of responsible Christian broadcasting while at the same time preventing irresponsible or exploitative broadcasting. Unfortunately, these are not self-defining passages. They require sensitive work on the part of the regulatory bodies--in this case the ITC and the Radio Authority. Frankly, I do not envy either of those bodies their task, but I believe that they are doing the best that they can to
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consult widely on their guidelines. I imagine that the reason why the Radio Authority has produced guidelines-- guidelines that neither I nor the Government have seen, but upon which comments have been made--is to ensure that, if they are unreasonable, they can be corrected before they are promulgated formally. If it is thought that the authority is being unreasonable even when the guidelines are promulgated, much as I am reluctant to call upon the assistance of my learned friends in these matters because I do not want to add to their work with this Bill, it would be a fitting matter for judicial review.If it is any help, we obviously considered these matters. It is not our job to be a regulator--I say that on constitutional grounds--but obviously, if something seems manifestly unfair, I dare say that comments to that effect would not be improper, if they were privately expressed.
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On the whole, we should have some sympathy with the regulators in their task. After all that we have been through, I do not believe that either UCB or Vision Broadcasting will find things very difficult. I am anxious that they should not--to use the old boxing parlance--squeal before they are hurt. We have to bear in mind the fact that the ITC has not yet even published its draft guidelines. Frankly, I cannot be expected to give reassurances about a problem that has not even arisen.
As I have already said, while I cannot anticipate the ITC's individual licensing decisions, I am quite sure that Vision Broadcasting will have nothing to fear under the new regime on programming grounds if its religious broadcasting is responsible and not exploitative. So far, I have no reason to believe that its output has been anything other than responsible, and it has not been exploitative.
Some of my hon. Friends are very keen, either because organisations are located in their constituencies or because they are involved with new and exciting opportunities, as is my right hon. Friend the Member for Selby (Mr. Alison). We must also bear in mind the cautious words of my hon. Friend the Member for Eltham (Mr. Bottomley) and of the Bishop of Liverpool, with whom I have discussed this topic. There is another view, which is that there are real dangers in allowing expoitative religious groups in by the back door. We have to accept that there is a role for the regulators in distinguishing one from the other.
I am keen to be absolutely sure that the regulations work properly. I am satisfied in my own mind but, by setting about the process of consultation with such care, in the end it will be possible for sensible people to come to terms on the matter.
Mr. Fisher : Hon. Members on both sides of the House are agreed that we do not want the high-pressure charismatic broadcasting that disfigures the American scene ; we are at one with the Minister on that.
The Minister must accept that his Bill places a responsibility on the Radio Authority and the commission to introduce guidelines. By taking the arm's- length view of the guidelines--that he has admitted to in his replies--he is distancing himself far too much from the creature and from the responsibilities that he has set up. I am sure that the Minister has listened carefully to the debate. The speech by the right hon. Member for Selby (Mr. Alison), speaking as a Church Commissioner, and
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those of other hon. Members should give him some cause for concern. Many of the guidelines that the Radio Authority and, probably, the ITC are working on are quite correct--for example, those on appeals for money on the air, on not denigrating other religions, and on limiting programmes about phenomena. It is not that all the guidelines are wrong. But I should have thought that the Minister would have heard enough in this short debate to realise that there is genuine concern about appeals, donations and the problem area of proselytising.The House would be reassured if the Minister gave an undertaking to get in contact with the Radio Authority and the ITC. He has required them to set up guidelines. If he entered into a dialogue at this stage, we could get things right before 1 January. That is not asking a great deal of the Minister. He has brought the guidelines and responsibilities into force, so he owes it to the House to take a little more interest in them, and to ensure that they are the sort of guidelines that all hon. Members want.
Mr. Mellor : I am grateful to the hon. Gentleman, but may I say to him in all kindness--and I mean that--that he must not allow the fact that one of these organisations is located in his constituency to blur his wider judgment. If I started to meddle with the regulatory bodies on other issues, he would be the first to leap up and say that that was constitutionally improper. As it happens, I believe that this is a perfectly proper matter on which I dare say we shall have discussions, but we must not be thought to be trying to lean on the regulatory bodies to prevent them from dealing sensitively with a difficult matter. I do not want worthwhile broadcasters to be trampled on. That will not, I believe, be the consequence. With great respect, however, to all concerned, since the Independent Television Commission has not yet published its draft
Mr. Fisher : There is also the Radio Authority.
Mr. Mellor : That is a separate body.
I return to the point that we have set our hand to expanding religious broadcasting. My right hon. Friend the Member for Selby (Mr. Alison) was kind enough to say that I have done it, but in five or 10 years' time, I do not want bitterly to regret having done it because we had levered the regulatory bodies into a position in which they were afraid to stand up against exploitative religious broadcasting.
I do not suggest that either of the organisations is exploitative ; I am perfectly satisfied that they are not. Anyone standing in my position, however, would be well advised not to say too much to the regulatory bodies that will be doing their best to deal with the problems they encounter. Nevertheless, in so far as there are words that with advantage might be changed to softer or better words, in accordance with the principles that we have followed throughout our consideration of the Bill, the officials will want to have discussions about them. I do not wish to appear to be condemning prematurely regulatory bodies that will be doing their best, but I shall convey with pleasure both to the ITC and to the Radio Authority the points that have been made in the debate.
Question put and agreed to.
Subsequent Lords amendments agreed to. [Some with Special Entry.]
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Mr. Mellor : On a point of order, Mr. Deputy Speaker, I think that we missed Lords amendment No. 110 to which the hon. Member for Stoke-on- Trent, Central (Mr. Fisher) wished to speak.
Mr. Deputy Speaker (Sir Paul Dean) : I had put the Question on that amendment but, in view of the speed at which I was moving, I shall gladly reverse engines and allow the hon. Member for Stoke-on-Trent, Central (Mr. Fisher) to speak.
Lords amendment : No. 110, after clause 34, insert the following new clause --
(".--(1) Any Channel 3 licence or licence to provide Channel 4 or Channel 5 shall include conditions requiring the licence holder-- (
(a) to make arrangements for promoting, in relation to employment by him, equality of opportunity between men and women and between persons of different racial groups ; and
(b) to review those arrangements from time to time.
(2) In subsection (1) "racial group" has the same meaning as in the Race Relations Act 1976.")
Mr. Fisher : I beg to move, That this House doth agree with the Lords in the said amendment. I understand that with this we are discussing Lords amendments Nos. 124 and 310.
I am grateful to you, Mr. Deputy Speaker, and to the Minister for your courtesy. The amendments were moving like a blur before my ears. I do not want to detain the House for long, but it is important to record the thanks of a great many people for the Minister's commitment on Report to deal with equal opportunities. In view of his doubts about that in Committee, it reflected well on the way in which he listened to the debate and considered it. Many people were extremely grateful to him.
The Minister received a delegation from myself and others including Cherry Ehrlich, the BBC's equal opportunities officer, Christina Driver, the industrial officer of the Broadcasting and Entertainment Trades Alliance and Sophie Balhatchet of the Independent Programme Producers Association. He listened, as is his wont, very attentively. We put it to him that a generalised commitment to equal opportunities would not achieve what he had sought to give as a commitment on Report. We told him that we were seeking a definite statement that Channel 3 companies should have a policy on equal opportunities and that it should cover employment, promotion and other training issues. We said that in order to ensure that the policy was effective, we would at least need to monitor the progress of each company and for it to publish its progress in its annual report. The Bill requires the companies elsewhere to produce annual reports. That would not be an onerous responsibility and would ensure that there was some accountability to the public and the work force that progress was being made.
The Minister heard our submission with great attentiveness and we went away believing that he was sympathetic to it. Therefore, it was disappointing to receive a letter from the Minister three or four weeks later saying that after further consideration and discussion with the shadow ITC he felt that this could best be achieved by a generalised statement in the Bill and guidelines from the
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ITC that would have non-statutory force. The shape of that argument is ironic when it is the reverse of the argument on impartiality that we had earlier in the evening. Perhaps such inconsistencies are a feature of these debates.I should be grateful if the Minister could put on the record why he feels that the very loose and generalised statement presented in Lords amendment No. 110 is satisfactory, and how the guidelines will achieve what I took to be his intention that each company should have an equal opportunities policy, monitor the progress of that policy and publish the results annually. That does not strike me as an expensive or arduous commitment ; it would also promote the skills of women, members of the ethnic minorities and people with disabilities. That last group seems to have disappeared from the clause, although the original intention was to include them. All three groups, however, have many skills to offer independent broadcasting-- skills that are not being fully represented now.
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The Minister knows the statistics ; they do not need to be laboured. Let me point out, however, that this is not simply an argument for equity and justice : if the skills that those groups have to offer are muted or unrealised, not only will the people concerned be disadvantaged or prejudiced against, but the rest of us will suffer too. We shall be the losers, because broadcasting will be less strong, skilful and various than it would otherwise be. I suspect that the Minister has considerable sympathy with the case that I am making. My point is that the Bill and the guidelines are unlikely, in their present form, to have the impact that we understood him to intend following the meeting in his office.
Mr. Mellor : I think that the key remark made by the hon. Member for Stoke-on-Trent, Central (Mr. Fisher) came at the beginning of his speech : having been rather dubious about it, we have put a clause clearly on the face of the Bill. There is, of course, always the danger of being outbid-- we cannot do everything that people want--but, having read the clause again while the hon. Gentleman was speaking, I feel that it represents a very real commitment. I am sorry if it did not emerge plainly enough at the meeting that what I envisaged would be couched in general terms, but I feel in any event that the best must not be the enemy of the good. This is, I think, a significant step forward.
Licence holders--that is, holders of licences for Channels 3, 4 and 5, domestic satellite services and national radio services--will be required to make arrangements to promote equal opportunities for men and women and for people of different racial groups, and to review those arrangements from time to time. The ITC and the Radio Authority will enforce the provisions through the licence conditions that they impose under the new clauses. They may require the applicants to set out their
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equal opportunities policies, and successful applicants would then be subject to an equal opportunities condition in their licences. That condition would take account of any undertaking that the applicant had made, and--this is relevant to one of the hon. Gentleman's points--the IBA has undertaken that the licence conditions should include a requirement for the holder to review progress on equal opportunities in the company's annual report.I recognise the strength of the case for the involvement of disabled people. I discussed the matter with the Department of Employment. The Department's view was that--as it is reviewing discrimination against disabled people, and has recently issued a consultation document, "Employment and Training for People with Disabilities", and as that consultation period does not expire until the end of the year--it would not be right to pre-empt the outcome of the review by carrying out a specific review relating to broadcasting. We have no sinister motive for not including such a provision ; we simply wanted to have regard to the fact that consultation is in progress.
I hope that what I have said about the way in which the regulatory bodies propose to deal with the matter strengthens the case for the clause, and convinces the hon. Gentleman that we are making a genuine effort. Even if it falls short of the ideal, it is still not bad.
Mr. Fisher : I accept that there are encouraging elements in what the Minister said, although he will understand that, when it is a question of the difference between "may" and "should", there is the possibility of misinterpretation. I hope that the right hon. and learned Gentleman will do all that he can to encourage the ITC to fulfil those aspirations and to introduce an appropriate requirement as part of the licence application.
People with disabilities will genuinely be disappointed with the Minister's remarks. They have few opportunities and are permanently discriminated against not just by the Government but in all walks of life, yet the Bill's equal opportunities clause excludes them. It is not good enough for the Minister to argue that because the Department of Employment has initiated a consultation exercise and produced a document--although it is not a bad document--there is no need to make provision in the Bill for people with disabilities.
Even if the Minister has not gone as far as we want, he has taken an important step forward by putting equal opportunities on the face of the Bill, and by placing a duty, albeit couched in gentle terms, on a particular group of employers. Still, to have missed the opportunity to represent the interests of people with disabilities will be gravely misinterpreted by them. I urge the Minister to think again, even at this late stage. That apart, I welcome the encouraging signs that he has given, and hope that he will pursue the point more fully.
Question put and agreed to.
Subsequent Lords amendments agreed to, [Some with Special Entry.]
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Lords amendment : No. 228, in page 66, line 39, leave out ("within a particular institution, or at")
and insert
("for a particular establishment or other defined location, or"). Motion made, and Question proposed, That this House doth agree with the Lords in the said amendment.-- [Mr. Mellor.]
Mr. Deputy Speaker : With this, it will be convenient to consider Lords amendments Nos. 229 to 235, 239, 240, 250, 251, 277, 300 to 309, 311 to 314, 333, 334 and 338.
Mr. Corbett : I shall not detain the House, but I wish to make a small point on amendment No. 313. We could spend many hours on the difference between "shall" and "may", but we will not do so. The amendment applies to when an announcement must be made about the results of a finding. The Minister accepted in Committee that a radio station should explain why an announcement was being made. I am interested, if he is able to help me, to know why their Lordships felt that they had to change "shall" back to "may". If he can assure me that the effect is the same, we can move on.
In Committee, the Minister was kind enough to be persuaded that we should make this mandatory and that we should use "shall" in that context. I wonder what has persuaded him to change his mind since Committee.
Mr. Maclennan : I have another point to make, although I should like to return to amendment No. 313.
Amendment No. 306, if I read it right, would permit companies that did not want to or were unable to live up to their service responsibilities to abandon them. The use of the word "substantially" is much too strong ; it allows considerable watering down of the schedules. Some explanation of that is called for, even at this hour.
I noticed the change, to which the hon. Member Birmingham, Erdington (Mr. Corbett) referred, from "shall" to "may" in amendment No. 313. I am seeking to protect listeners' rights. If an announcement is made, listeners are entitled to know whether the Radio Authority has found a station to be in error, to have done something that is unacceptable and, indeed, whether it is censoring the station. The listener can then make up his mind whether that is an effective remedy for a transgression.
I think that by this time there is a fair chance that the Minister will have a view about that.
Mr. Mellor : Yes, I have managed to acquire a view, and I am only too happy to give it to the House.
I begin with what the hon. Member for Caithness and Sutherland (Mr. Maclennan) said about amendment No. 306, which allows the Radio Authority more flexibility to let stations drop unpopular programmes or strands of programmes that have gone out of fashion. It makes it clear that the fundamental character of the station may not change, and I attach importance to that. I said in a public speech not long ago that it is very important that stations that have been given a licence on one basis should not be
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allowed to slither rapidly towards the middle of the pop market and stay there so that every time a listener flicks across the airwaves he finds the same old stuff.Mr. Mellor : I am reliably assured by my noble Friend Lord Ferrers that pop is something that goes thump, thump, thump. That was said not to be sophisticated enough for drafting, but for my purposes it seems absolutely right. In my long reign as Minister for the Arts, I intend to use that definition with monotonous regularity. Amendment No. 314 gives the authority the ability to impose a fine on licensees who fail to observe their promise of performance. That shows that no leniency is intended, but sometimes there will be a good reason why one set of undertakings is not appropriate. However, no one will be allowed gratuitously off the hook and, like the hon. Member for Erdington, I attach much importance to that fact. I am afraid that there is a problem with amendment No. 313. The hon. Member for Stoke-on-Trent, Central (Mr. Fisher) did rather well in Committee on 27 February. Nothing in his ensuing career has been anything like as glorious as that afternoon. The hon. Gentleman may recall that he was on something of a winning streak when, in one of our briefer exchanges, he proposed that "may" should be amended to "shall" and I said, "Why not?" I am afraid that when the matter got to the other place and the inconsistency between the television and radio provisions was tackled, the latter, rather than the former, was changed. I am sorry about that. Perhaps good comes out of bad, in the sense that we could have ended up with the right policy by going consistently the other way.
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On 27 February, the hon. Member for Caithness and Sutherland said :
"If a licence holder says that he has apologised because he must do so, that is a less powerful apology than one that simply states, I am apologising.' "--[ Official Report, Standing Committee F, 27 February 1990 ; c. 1072.]
There is something in that point. There is also the more general point that, under the Bill, the licensee is responsible for his programming output, as the ITC and Radio Authority are not broadcasting bodies. It is arguably more consistent on this principle for the licensee to be able to decide whether he should say that an apology or correction is being broadcast as a result of a regulatory direction.
I am sorry. By and large, this is the only occasion when something has gone wrong with an undertaking. We have honoured dozens of undertakings. I hope that the hon. Gentleman will allow me to slither off this hook.
Question put and agreed to.
Subsequent Lord amendments agreed to. [Some with Special Entry.]
Lords amendment : No. 344, in page 98, line 13, leave out ("and") and insert--
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("(aa)(for the purpose of the regulation by the Commission after the end of that period of services provided in succession to the DBS services provided by them during that period ; and")) Motion made, and Question proposed, That this House doth agree with the Lords in the said amendment.-- [Mr. Mellor.]
Mr. Deputy Speaker : With this it will be convenient to take Lords amendments Nos. 345, 346 and amendment (a) thereto, 347 to 359, 512 to 515, 521 to 542, 543 and amendment (a) thereto, 544 to 554, 555 and amendment (a) thereto, and 556 to 574.
Mr. Maclennan : I should like to speak to Lords amendment No. 347. We strongly welcome the Government's decision to allow for a continued pooling of transmission expenses. However, once again, the Bill provides only for an interim period. Despite the Minister's reassurances, there is no protection in the Bill for the sparsely populated areas and areas of difficult terrain on a continuing basis. This gives rise to concern in companies such as Grampian Television that they may be forced out of business and be taken over by geographically more fortunate franchise holders.
I had understood that the Minister's commitment was to provide for a system that would not be brought to a conclusion at the end of the interim period. I am therefore surprised to see the provision in this form. I know that the Minister will be prepared at least to repeat his earlier assurances.
Mr. Mellor : I repeat those assurances. This is not an easy issue. The previous Home Secretary announced in July last year that there would be a uniform tariff for Channel 3 companies. The announcement also made it clear that those cross-subsidy arrangements would be reviewed. Of course, one stands by that.
As for radio, there is a transitional period. Because of the nature of the radio system, it was decided that the kind of elaborate arrangements that might have been appropriate for television were not appropriate for perpetuation in the radio system. Some radio companies are dismayed about that and a long and honourable battle has been waged by Mr. Prag of the Moray Firth radio station. I made it clear to him throughout that I did not think that I could improve on the position that I had inherited and that I was under great pressure from the Association of Independent Radio Contractors not to do so.
We have not moved any goalposts in the amendments, but I understand that we have not gone as far as some other interests would have wished us to do. I can only regret that, but say that I have done so on the best advice from others within the industry.
Mr. Maclennan : I cannot say that I am surprised by the Minister's remarks about radio because they conform to what he has said throughout. I may have misread Lords amendment No. 347, but I thought that it referred to television and I wanted to draw attention to it for that reason. I have been advised that some of the companies are concerned about the provisions. It is, of course, for the smaller companies, such as Grampian Television, which serve areas of sparse population, that the arrangements are to be made only for an interim period. There will not be a continuing guarantee of
cross-subsidisation.
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Mr. Mellor : I am grateful to the hon. Gentleman. At the end of a long evening, I see the point. The break in the mid-1990s was raised on Report. It is necessary to review these matters from time to time, but I cannot conceive that anything is likely to change as the case for these measures will be as compelling then as it is now. It is simply that, following consultations with other Departments, it has not been open to us to put in place a perpetuity arrangement. We are concerned about transmission systems being far more complex in some areas than in others.
On Report, there was petitioning from the west country. My hon. Friend the Member for South Hams (Mr. Steen) said that there were 30-odd booster stations in his constituency alone. The best that I could do then--it was quite considerable--was to say that, while there has to be a review period, I personally doubted whether the basis of the argument would have changed materially to allow any different result from that which we already considered to be conceivable. Mr. Alistair Darling (Edinburgh, Central) rose--
Mr. Mellor : I believe that I am technically intervening in the speech of the hon. Member for Caithness and Sutherland, so I had better sit down and allow him to finish so that the hon. Member for Edinburgh, Central (Mr. Darling) can say his piece.
Mr. Maclennan : I am only too happy to rise to my feet again to allow the hon. Gentleman to intervene.
Mr. Darling : I wanted an undertaking from the Minister rather than an undertaking from the hon. Member for Caithness and Sutherland (Mr. Maclennan) who, I suspect, is not in a position now--nor, with due respect, is likely to be--to give me such an undertaking.
I understand what the Minister is saying. However, it might be helpful--and would be appreciated by those who live in areas that are served by many transmitters--to obtain an undertaking from the Government to keep the situation under review. There may be an opportunity to look at the position again in the mid-1990s, but the worry is that something might happen fairly quickly in the interim which meant that Parliament was unable to respond to developments. If the hon. Member for Caithness and Sutherland could continue his speech to allow the Minister to intervene to give that undertaking, I should be happy.
Sir Giles Shaw (Pudsey) : I rise in support of the points made by the hon. Members for Caithness and Sutherland (Mr. Maclennan) and for Edinburgh, Central (Mr. Darling). Of all the complexities that are described in the Bill, that of the transmission system--its maintenance, its ownership and its effectiveness--is the area of greatest weakness, in my humble estimation. It is at its greatest weakness in the provisions for outlying areas that require many subsidiary transmitters, which add substantially to capital and to operating costs.
My right hon. and learned Friend would be unwise to assume that it was purely a matter of rural areas. It is at its most obvious in rural areas and in the Celtic fringes. However, even in some more populated parts, there is considerable difficulty in obtaining adequate transmitters to fit the existing regional contractors' marketing purposes. My right hon. and learned Friend knows perfectly well that large portions of Yorkshire, for
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example, are omitted from receiving signals from Yorkshire Television and are included in the north-eastern regional station. Those are obvious quirks of geography.The review of the transmission system under the new regime will require even greater resources than do the reviews under the current system. I beg my right hon. and learned Friend to agree that there will be frequent reviews of the transmission system in the early stages of the ITC Channel 3 operation with a view not only to dealing with the problems raised by those in Scotland and in Wales, but to reviewing the system in the rest of the country.
Mr. Mellor : I appreciate the argument advanced by my hon. Friend the Member for Pudsey (Sir G. Shaw). The present cross-subsidy arrangements subsist until 1992 and the new cross-subsidy arrangements will operate from 1993 to 1996.
My hon. Friend asked about the technical capabilities of the system. We discussed that exhaustively in Committee when I was happy to state that we were committed not only to maintaining the existing system, but to improving it for the benefit of those in the so-called black holes of the transmission system. At present, 99.4 per cent. of the population is covered by the system, but we aim to improve on that. In the course of a privatisation there would be no question about that. Obligations would be set to ensure that there was no deviation from the perpetuation of an efficient and effective system covering existing transmission areas. We hope that that would be accompanied not only by further improvements in transmission to areas already covered by the system, but by an extension of the system into some of those black holes. Such improvements are firmly in our sights.
Question put and agreed to.
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