Memorandum submitted by SMG plc (continued)
Universality of Accessit is imperative
that all areas of the country currently receiving an analogue
signal are able to receive digital terrestrial television prior
to analogue switch-off. It will be impossible for any commercial
organisation to fund the cost of the necessary transmitter conversion.
We therefore urge the Government to devise a funding mechanism
to ensure this takes place.
Regionalitywe support the retention and
protection of regional programmes. It is important that viewers
of Scottish Television and Grampian Television have access to
programmes that reflect regional and national identities. Regional
programmes are an integral part of a diverse, high quality schedule:
it is equally important that programmes from the regions form
part of Network schedules.
Public Service Broadcastingwe endorse
the Government's support for public service broadcasting in general,
and ITV's role in particular. The BBC and Channel 4's public service
remits should be better defined and more closely scrutinised,
as should both channels' commercial initiatives.
RegulationOFCOM should report to a single
Department of Communications. We believe that the BBC should be
included within the regulatory framework to ensure a more coherent
and equitable system of regulation.
Gaelic Broadcastingwe support Gaelic
Taskforce's recommendations that Gaelic programmes should be transmitted
on a separate digital channel but question the level of funding
required. Any levy from ITV must come from the existing levies
paid to the Treasury. We will continue to transmit Gaelic programmes
until analogue switchover. Thereafter obligations on commercial
organisations should be removed.
Digital Licencesas analogue licences
transfer into the digital spectrum, given the level of investment
in digital infrastructure and the significant commitment to public
service broadcasting by the ITV companies, subsequent digital
licences should be automatically renewed, subject to meeting licence
1.0.1 Scottish Television and Grampian Television
are SMG's two ITV franchises. ITV Network Centre is submitting
a comprehensive response on behalf of all the ITV companies, dealing
with the issues that affect the network as a whole. We fully support
and endorse that submission and therefore have confined our response
to issues that are of importance and relevance to Scotland and
to SMG Television in particular.
1.0.2 Grampian and Scottish Television cover
a hugely diverse area, with two thousand miles of coastline, hundreds
of islands, several dialects and two languages. The stations have
production centres in Aberdeen, Glasgow, Edinburgh, Dundee and
Inverness. We broadcast to an audience of nearly five million
people which constitutes 10 per cent of the UK television audience.
Unlike any of the other ITV broadcasters and even allowing for
the additional commitments of HTV and Ulster, Scottish and Grampian
require to be national broadcasters, as well as regional broadcasters,
reflecting Scotland's different political, legal, educational
and religious institutions. In addition, we have to take account
of cultural differences and a national sports infrastructure and
1.0.3 Scottish and Grampian support the
objective to ensure that a range of high quality programming is
universally available and that the English regions, Scotland,
Wales and Northern Ireland are properly reflected on our television
1.0.4 This is particularly important in
a devolved United Kingdom: the differing cultures of all the disparate
parts of the country should be represented in the national schedules
of the traditional public service broadcasters (1.0 The Government's
1.0.5 The level of ITV programming produced
in the regions ie outside London, exceeds that of any other UK
broadcaster including the BBC: regional programming is the unique
quality that only ITV can bring to UK broadcasting and this vital
aspect of Britain's most popular broadcaster must be preserved.
No other commercial broadcaster in the UK provides such a service.
1.0.6 Although we do not believe that quotas
should be set for regional production we would like the network
to aspire to proportional representation for the regions and nations
on UK screens.
1.0.7 It is vitally important that the regional
companies make a contribution to ITV network production, not least
to portray their regions andas far as Grampian and Scottish
are concernedthe nation, to the rest of the country, to
avoid a purely metro-centric portrayal of contemporary Britain.
1.0.8 In Scotland, we provide approximately
10 per cent of the ITV audience and it is important that the network
audience has a sense of Scotland, be that in drama or other genres.
1.0.9 We also believe that Scottish and
Grampian Television "meet the needs of different communities
and cultural interests". Like all of the ITV companies, Scottish
and Grampian are a key part of the fabric of the communities they
serve and it is vital that they continue to demonstrate a deep
understanding of the concerns and interests of their regions.
1.0.10 For some 40 years, both stations
have been broadcasting to their respective regions and have built
up a strong relationship with their viewers. All of our research
shows that there is a demand and appetite for a regional television
service. Viewers in Scotland are loyal to their regional companies
and, by providing a regional service, Scottish and Grampian have
become part of the culture of their viewers. Indeed the ITV brand
is not commonly referred to by viewers in Scotland, who relate
more closely to their regional station brands.
2.0.1 The issue of universality of access
is particularly important to Scotland, given the nature of its
geography and topography. 81 transmitters in the UKgiving
78 per cent of the population access to digital televisionhave
been converted to digital. Of these, 13 are in Scotland, leaving
a further 190 requiring conversion. To undertake conversion of
all current analogue transmitters to digital, thereby ensuring
universality of access, will be prohibitively expensive and consequently
impossible for any commercial organisation, such as Scottish Television
and Grampian Television. Therefore there will be large areas,
both rural communities and sizeable towns, that simply will not
receive digital terrestrial television. We agree with the Government
assertion that it is essential that people living in all parts
of Britain, however remote, should have access to television,
radio, telephone and Internet services. If they do not, we will
see the creation of a division in society between the information
"haves" and "have nots"; in essence a communications
ghetto. (3.0 Ensuring Universal Access)
2.0.2 We therefore urge the Government to
devise a funding mechanism to ensure that digital television is
available to all. This would fulfil the objective to:
"make additional services universally available
while also safeguarding commercial interests."
PRODUCTION (4.0 MAINTAINING
3.0.1 We support the retention of independent
television production quotas at the level of the 1990 Broadcasting
Act. Both Scottish and Grampian have good relationships with local
independents and we are happy to continue to commission them.
3.0.2 However, we would like to point out
that the recent acquisitions of leading independent production
companies by broadcasters and overseas companies, indicate that
it will become increasingly difficult to meet that quota without
redefining what constitutes an independent producer. This is particularly
true in Scotland because of the relatively small size of the independent
production sector and the lack of an infrastructure for the companies
to operate within. We therefore welcome the Government's intention
to consider adjustments to help ensure that broadcasters' ability
to meet their obligations is not jeopardised by events outside
3.0.3 As previously stated, Scottish Television
and Grampian Television are part of the ITV Network. With control
of ITV now vested in its two main shareholders, Granada and Carlton,
our share of the Network is currently around 6 per cent. SMG Network
productions is a small supplier of Network programmes, competing
with production giants such as Granada and larger independent
productions companies such as Zenith. However, our share of Network
programmes production does not equate to our Network share of
six per cent, and we believe our position will become increasingly
marginalised as ITV consolidates further and broadcasters continue
to acquire independent production businesses. We would therefore
ask that the definition of Independent Producers be redefined
to include those who have minority stakes in broadcasters. This
redefinition would benefit production in the regions, given that
the quota systems that operate across the BBC and Channel 4, and
help the Government to realise its objectives in UK original production.
3.0.4 In respect of independent production,
Scotland is a microcosm of the UK-wide industry; if it proves
difficult for the ITV network to reach the quota then this will
be exacerbated in Scotland because of the lack of experienced
personnel referred to above. However, we would aspire to the 25
per cent quota and would wish to see it retained.
4.0.1 Both Scottish and Grampian Television
are committed to the retention of their regional dimension as
public service broadcasters.
4.0.2 Regionality is very important to ITV
viewers, and, we would argue, particularly so for Scottish and
Grampian. Scotland is not a region, it is a separate nation within
the UK, with its own political, educational, religious, sporting
and cultural agendas and a regional television service is required
to reflect this. Despite increasing globalisation, regional and
national identities remain strong and our viewers relate to, and
identify with, aspects of life in their local area: there is an
appetite and demand for local/regional information and entertainment.
We believe that Scottish and Grampian meet that demand through
their respective regional programme production. Furthermore, both
companies contribute greatly to the creative economy in Scotland.
4.0.3 Regionality is an integral part of
ITV's publicly stated commitment to a diverse, high quality schedule.
However, regionality cannot, and should not, be measured only
by the number of regional hours that are produced in the region
for broadcast and viewing only in that region. In the diverse
culture of the modern devolved UK, it is important that network
audiences are given access to programmes from the regions. Therefore
regionality, and indeed public service broadcasting, should be
measured by our ability to sustain original production in the
regions for broadcast across the whole of the UK.
5.0 PUBLIC SERVICE
5.0.1 As the leading Public Service Broadcaster,
it is fitting that the BBC should have more demanding targets
for regional production. Similarly Channel 4's public service
remit should include more of a measurable commitment to promoting
regional production. As stated with reference to the regional
production of programmes for transmission on the ITV network,
there should be an obligation to reflect the entire UK on network
screens to ensure diversity of content, both geographical and
5.0.2 The role of the BBC must be discussed,
defined and tightly monitored. It is imperative that the BBC's
activities are closely scrutinised, both in terms of its commitment
to public service broadcasting on its main service, BBC 1 and
its commercial activities. Recent initiatives, such as the removal
of arts and current affairs programming from the peak hours, disturb
the broadcasting ecology within the UK (to which all commercial
broadcasters must react) to the detriment of the viewer. Similarly,
initiatives such as News 24, given free to many multi-channel
operators interferes with the proper operation of the market.
The BBC should, and must, provide services that are only available
because they have access to public funding.
5.1 Gaelic Broadcasting
5.1.1 We will shortly be submitting a detailed
response to the findings of the Gaelic Broadcasting Task Force.
Whilst we support the setting up of a separate channel for Gaelic
language programmes, we would ask the Government to take into
account our concerns as to the level of funding proposed within
the Milne Report. The suggestion that the ITV companies should
pay a new levy to support the channel is not, in our view realistic.
Any levy must come from that already paid to the Treasury by the
companies, as part of their franchise agreement.
5.1.2 We would also hope that the commercial
broadcasters would be released from their Gaelic broadcasting
obligations in their terrestrial licences, but until analogue
switch-off we will continue to produce programmes at the existing
level for transmission on the new channel.
5.1.3 In a totally digital environment,
we envisage a stand-alone Gaelic channel but we would question
the financial viability of setting up a separate broadcaster to
deliver the new Gaelic service. A more economical approach may
be for an existing broadcaster to set up and run the service on
behalf of the Gaelic Broadcasting Authority.
6.0.1 Our view on the three tier regulatory
system proposed within the White Paper (5.0 Securing Quality)
concurs with that expressed in the ITV Network's submission. In
addition we would stipulate the following:
6.0.2 We agree that any new services developed
by Channel 4 should not be "unfairly subsidised". We
would ask that this criterion also applies to the BBC. It is clearly
iniquitous that public funding is used to purchase expensive rights
to programmes that are then only available to those who pay a
subscription to view the channel on which these programmes are
transmitted, as is the case with E4.
6.0.3 It is fitting that Channel 5's public
service obligations are relaxed; this should be reflected in the
level of its tender payments.
6.0.4 With reference to the public service
remit of the BBC (5.7.1), we agree strongly that there should
be a requirement upon the BBC to provide news and current affairs
in peak. We believe this should be extended to include other genres
such as the Arts, and in Scotland, Gaelic. It is anomalous that
in Scotland there is a requirement on the ITV stations to carry
Gaelic programmes in peak, but there is no similar obligation
on the BBC. Currently, there are no Gaelic programmes in peak
6.0.5 Furthermore, it is important that
the BBC should deliver range and diversity on its main service,
BBC1. The BBC is the benchmark against which all other UK public
service broadcasters are measured and to which they react. Recent
scheduling changes indicate that the BBC is diluting the public
service remit of BBC1 and BBC2, disturbing the broadcasting ecology
in the UK, and causing a reaction amongst the commercial broadcasters
that could cause irreparable damage to public service broadcasting
in the long run.
6.0.6 There needs to be discussion of, and
agreement on "the level of requirements regulated at this
level". We endorse and support that there should be no intervention
in scheduling decisions. SMG Television acknowledges and recognises
the need to satisfy viewers by providing a broad range of diverse
programmes but we must also safeguard the interests of shareholders.
These are not incompatible aims. High quality programmes will
attract viewers and consequently increase advertising revenue
thereby contributing to the profitability of the company and satisfying
shareholders. This completes the virtuous circle required to re-invest
money in programme making. (5.0 Securing Quality; 5.7 Second Tier).
6.0.7 The proposal outlining the function
of Regional Boards mirrors the current procedures within both
Scottish and Grampian Television. Therefore we are already complying
with the requirement to implement this before legislation reaches
the statute book. We are also complying with the development of
statements of programme policy. However, with reference to the
function of the Regional Boards, we would emphasise that commercial
management of the companies must remain with the respective management
6.0.8 The proposal to "retain the power
to approve new BBC licence fee-funded services and material changes
to existing services" is to be welcomed.
6.1.1 Whilst we endorse the overall aim
of this proposal, we would issue a note of caution. Of course
there must be freedom of choice: we are all consumers and, as
such, the view of the consumer is an important part of regulation
and legislation. But it should be recognised that some lobby groups,
by their very nature, have a vested interest in changing the media.
It must not be the case that a vocal minority affects the viewing
enjoyment of the majority. (7.0 Protecting the interests of consumers).
7.0 DIGITAL SERVICES
7.0.1 In addition to pictures and sound,
digital television is capable of supporting a number of ancillary
services. Currently, service providers on the DTT platform provide
subtitles, audio description and in-vision signing as well as
the SI data that provides information on the service content,
picture aspect ratio etc.
7.0.2 Many broadcasters on the DTT platform
have also launched or are in the process of launching Associated
and Standalone Data services which can be used to enhance their
programmes and/or advertising by providing background or supporting
graphics and text information. With skilful authoring, such data
services can also be used to give the viewer a sense of interactivity
with the programmes or commercials they are watching and are therefore
a potentially important tool in building viewer interest and loyalty
in a programme service.
7.0.3 As the broadcasting ecology develops
it seems likely that programme service and content providers will
wish to use a number of delivery platforms to deliver their services
to the audience. This is very much in evidence now with services
that used to solely rely on terrestrial transmission now also
being carried on the various cable and DSAT platforms. Broadcasters
will also want to take advantage of new delivery platforms such
as XDSL, Internet etc to further extend the reach and available
7.0.4 Interoperability of all of the elements
of these programme services (pictures, sound, subtitles, ancillary
services and data and interactive services) across all of the
available delivery platforms, will be absolutely crucial to the
success of many of these new services.
7.0.5 The development of digital standards
across all the available delivery platforms to ensure the fullest
levels of interoperability is welcomed. (7.8 Digital Standards).
7.0.6 The views of SMG Television are as
set out in the response from the ITV Network to the Government's
proposals. In addition we would add the following comments: (8.0
The new organisational framework).
7.0.7 The suggestion that digital terrestrial
licences could be renewable indefinitely, subject to satisfactory
performance is commercially sensible. However, there is no clear
understanding of how this will be achieved during switchover to
digital. The ITV licensees have invested heavily in a digital
infrastructure and in ancillary services for minority groups such
as the disabled. Having carried these, and other licence-associated
costs for a period of years, following the switchover from analogue
to digital, it would be invidious if these licences were then
opened up to auction. We would argue for an automatic right to
renew, with terms and conditions to be agreed.
7.0.8 We support the proposals that "Ministers
would consult on the future of public service broadcasting, the
process and criteria for selection of licensees, and the required
privileges". (8.8 Licensing).
7.0.9 We support the development of access
television through RSLs, as their current licences permit. However,
we would be concerned if all of these individual licenses were
acquired by a single organisation intent on forming a network
with guaranteed access to the spectrum, effectively creating a
sixth terrestrial network. This would change the ecology of the
broadcasting industry in the UK beyond that on which all of our
recent licence applications were based.