Select Committee on Culture, Media and Sport Third Report


4 ITV Merger

71. On 16 October 2002, Carlton Communications Plc (Carlton) and Granada plc (Granada) announced a merger aimed at further consolidation of ITV. The companies argued that the main objective of the merger was to remove the dysfunctionality within ITV, and allow it to remain an effective player in the competition for viewers and advertisers, in a rapidly changing and competitive multi-channel environment. There were also significant cost savings to be realized by merging the two companies, currently estimated at around £100 million per annum.[66] At that time, the draft Communications Bill had already signalled the Government's intention to remove the automatic statutory bar to such a merger. The subsequent Communications Act 2003 received Royal Assent on 17 July 2003, allowing the merger to go ahead subject only to the approval of the Secretary of State for Trade and Industry, advised by the Competition Commission.

72. On 11 March 2003 the Secretary of State for Trade and Industry referred the proposed merger between Carlton and Granada to the Competition Commission to determine whether the merger could or would operate against the public interest.

73. The Competition Commission looked at a number of areas of concern relating to the proposed merger, identifying two areas where it could potentially operate against the public interest.

74. First, there was the position of the other Channel 3 regional licensees not party to the merger: Grampian TV and Scottish TV (both owned by SMG plc) and Ulster TV and Channel TV. The Commission considered that additional safeguards were needed in relation to the operation of the ITV Network and the arrangements for the sale of the other licensees' airtime, much of which went through the Carlton and Granada (advertising) airtime sales houses.

75. Second, the sale of Carlton's and Granada's airtime within the UK television advertising market as a whole was a major focus on the effect of the proposed merger.[67] The Competition Commission concluded that there would be a detriment to the public interest in the advertising airtime market unless a suitable remedy was found.[68] As a consequence, Carlton and Granada would only be allowed to merge on condition that they agreed to the terms of a new regulatory mechanism called the Contract Rights Renewal (CRR) remedy.

76. In line with the Commission's recommendations and the OFT's advice, the Secretary of State announced on 7 October 2003 that certain undertakings were required before the merger should be allowed to proceed. These involved abiding by the CRR remedy to protect the advertising community from unfair or discriminatory practices in the selling of television airtime. Furthermore, Granada and Carlton would have to abide by a set of rules to protect the other ITV companies—Ulster TV, Scottish, Grampian and the Channel Islands broadcaster, Channel. The ITC and Ofcom, working with the OFT, were charged with putting these rules in place, in discussion with Carlton and Granada.[69]

77. On 14 November the Secretary of State announced that she had accepted undertakings from Carlton Communications Plc and Granada plc in relation to their proposed merger, which could thus proceed. The newly-merged ITV plc began trading on 2 February 2004.

Television advertising

78. Despite a recent decline in ITV market power, the Competition Commission did not believe that other channels were yet sufficiently close substitutes to prevent an increase in the advertising budget commitment that ITV could demand for a given level of discount, following the removal of competition between Carlton and Granada. ITV provided a number of 'must have' features, including the unique ability to attract big audiences for advertisers, a consistently high audience share in the evening peak, a very high proportion of prestigious programmes, and the ability to attract infrequent (or "light") viewers.

79. In short, the rationale behind the introduction of the Contract Rights Renewal remedy was the Competition Commission's belief that buyer power would not prevent a merged Granada-Carlton from raising prices. With more than half of total television advertising revenues, the newly-merged ITV could have significant influence over the ability of advertisers or their agents (media buyers) to negotiate contracts fairly and effectively. The Contract Rights Renewal remedy addresses that risk by imposing three main conditions:

80. In its report of 7 October 2003, the Commission explained: "The CRR remedy is designed to give all existing customers the fallback option of renewing the terms of their 2003 contracts without change for the duration of the remedy, with the exception that where a contract specified a share of broadcast, this share would vary in direct proportion to ITV's share of commercial impacts, subject to a cap at the initial share. The protection could be rolled forward such that a subsequent year's contract became the base set of contractual terms, subject to mutual agreement. Customers would not be precluded from negotiating different deals if they wished."[70]

81. Mr Mick Desmond, Joint Managing Director of ITV (Granada plc), told us: "Our audience share, within the commercial television sector, is exceedingly important. It has been even more emphasised now with the recent regulatory conclusion from the OFT with the new mechanism we have called CRR."[71]

82. That a conclusion was reached in relation to the complex airtime sales market, and an adjudicator appointed, is a tribute to the effectiveness with which Ofcom has worked with the ITC and the OFT during the regulatory transition period. As Lord Currie observed, "the timing of the Competition Commission Report and the subsequent approval by the Secretary of the State did create a very tight timetable".[72]

83. Ofcom should monitor closely the effect a merged ITV has on the wider broadcast advertising market, ensuring smaller commercial TV companies, including but not restricted to other Channel 3 licensees, are not disadvantaged.

Regional programme production

Regionally-originated programming

84. Channel 3 licensees are obliged to conclude networking arrangements in order to broadcast a common schedule of programmes (with regional opt-outs). The networking arrangements are operated by ITV Network Centre (a division of ITV Network Ltd), which commissions and schedules programmes shown across the network. The Broadcast Board of the Network Centre is a sub-committee of the ITV Council, which is the governing body of the ITV Association. The Board works with the Network Centre to agree the overall nature of the network schedule and its cost for approval by the Council. Once this has been agreed, the Network Centre acts independently to commission, acquire and schedule network programmes.

85. Following a successful reference of the networking arrangements by OFT to the Monopolies and Mergers Commission (now the Competition Commission) in 1992, the arrangements were altered to allow independent producers to submit a programme proposal direct to ITV Network Centre and to prevent programme rights from being acquired (normally) for more than 5 years.

86. As a result of the Competition Commission report, measures have been introduced to protect the position on the ITV Network of the four Channel 3 licensees not part of ITV plc. The pre-conditions attached to the merger were designed to secure for SMG, Ulster and Channel an adequate say in the overall strategy of the ITV Network. Furthermore, their contributions to ITV Network costs are to be capped, increasing by no more than the rate of inflation. Of the other protections, a key one relates to the extent of original programming commissioned from these other ITV companies for transmission on the network. This will be monitored and reported annually to Ofcom.

87. In written evidence to us, Grampian TV and Scottish TV underlined the importance they attach to the independence of both the Network Centre and its Director, believing that only network commissions would further the creation of creative clusters in the regions. They went on: "Commissions should be awarded on merit, but a meritocracy needs transparency, not conflicts of interest. Ofcom has a statutory duty to promote competition and encourage investment and innovation in the regions. Competition and investment will be undermined if the independence of the Network Centre is undermined."[73]

88. Mr John McVay, Chief Executive of PACT, also supported a strong and independent Network Centre; one that commissions on merit.[74] PACT believed the latter could be better secured if disputes involving the Network Centre could be resolved by Ofcom holding hearings in public.[75]

89. A thriving regional production ecology may also have consequences for the long term ownership of ITV plc. Mr Andy Egan, Research Officer, BECTU observed: "Unless there are strong regional commitments with meaningful facilities, staff and freelancers visibly there and visibly required to be there, it will be much easier for a foreign broadcaster who will come in and be able to replicate what is there, because it will be just a shell. If there is a very strong vibrant regional culture within ITV foreign broadcasters will not be able to meet it and will not want to meet it and, therefore, will be much less likely to come to the UK."[76]

90. According to PACT, closer attention must be paid to the definition of a regional production, be it aimed at national or local audiences.[77] A key component of any definition is the percentage of employment of regional talent, which PACT would like set at 70%. Ofcom is proposing an initial figure of 50%, in recognition of the fact that a significant proportion of experienced production talent is currently based within the M25.[78]

91. Andy Egan added: "We think that one thing Ofcom could do within the spirit of the Communications Act sections 286 and 287, which talk about regional programme production, is to require that each ITV region produces a certain amount of production for the network."[79] For Carlton, Clive Jones countered: "There must be a meritocracy, we cannot live by quotas."[80] Section 286 of the Communications Act relates to regional programme making, imposing requirements on Channel 3 and Channel 5 to finance a suitable range of production centres outside the M25. We believe that quotas for regional production for the network are essential to conform with the spirit of the legislation, that there should be sufficient investment in regional production centres of excellence, and that Ofcom should be alert to this need.

Regionally-oriented programming

92. Section 287 of the Act provides for regional programming, which in relation to a regional Channel 3 service is defined as being of particular interest to persons within the area covered. The section includes provision for sub-regional, or local, programming. Ofcom has considerable flexibility over the means of securing a sufficient amount of time given over to a suitable range of high quality regional and local programming, which must include peak time news.

93. Falling advertising revenue has put pressure on ITV licensees to reduce the number of hours dedicated to regional programmes. The NUJ pointed out the "fundamental tension … in terms of seeking to maximise revenue through scheduling programmes which are attractive to advertisers, and what again can be considered a public service obligation, namely to reflect on and report local news and activities."[81] One result has been the Charter for the Nations and Regions, agreed by the ITC and ITV companies in May 2002.

94. A key feature of the charter is a switch in focus from hours of regional output to levels of investment. However, there will, on average, be an additional 30 minutes per week of peak-time regional news. An ITC note comments on the associated standardisation of hours: "regional programming obligations were rationalised in 2002, to facilitate better scheduling. In Northern Ireland and English regions, there are now 8 ½ hours of regional programming, including 5 ½ hours of news. Elsewhere, the amounts vary from 12 hours in Scotland, 10 hours in Wales to just under 6 hours in Borders and the Channel Isles."[82]

95. According to BECTU, the ITC's standardisation of regional hours agreement with Carlton and Granada has neither improved the quality of regional programming nor provided better programme slots.[83] We share the concern of some witnesses over the restricted range of programming genres made in the regions, be they intended for local or national audiences.[84] A wide range of genres aimed at audiences both within and outwith the regions is important to maintain thriving centres of creative talent throughout the United Kingdom. Andy Egan added an historical perspective: "if you ran the film back over the past 20 years it has been death by a thousand cuts in many ways; it has been redundancies here, reduction in facilities there, narrowing of the number of programme genres made in the regions, centralisation of decision-making in London."[85]

96. Regional programming, that is programming within and for the region, fulfils an important role in cementing community identity. In border areas, this identity can be fluid and there are public service merits in allowing viewers to choose between neighbouring Channel 3 franchises. Clive Jones indicated that giving people this kind of choice was unattractive to advertisers. Too bad![86]

Production facilities

97. As the NUJ points out, mergers involving ITV companies have been accompanied by job losses, and the closure of studios and other facilities.[87] While we appreciate that Ofcom should not interfere with legitimate managerial, operational and investment decisions,[88] it has a clear duty to intervene where public service broadcasting obligations are being compromised.

98. As BECTU note in a submitted memorandum: "For PSB regional broadcasting to remain a meaningful concept we believe it entails the following requirements:

  • a broad range of regionally-originated programming of high quality
  • the use of the full range of regionally-based staff, freelances and production facilities
  • the maintenance of a wide spread of regional studio facilities and the avoidance of any further studio closures".[89]

99. PACT viewed the loss of studio facilities with, in our view, surprising equanimity: "Any newly-integrated commercial company will rightly seek economies of scale following consolidation. It is therefore easily conceivable that a single ITV would put some strain on the survival of some of the existing dated regional studio facilities. Production in general has already begun to veer away from studios - the issue is becoming one that is less to do with bricks and mortar than it is to do with the protection of regional production - in essence we must ensure that if a regional studio closes, the status of that region must be maintained and this does not reduce its ability as a regional production centre."[90]

100. Both Mr Donald Emslie, Chief Executive, SMG,[91] and Mr Clive Jones[92] of Carlton referred to "bricks and mortar" as being less important than what goes on the screen. We do not believe the latter can be as readily, not to say facilely, divorced from the existence of studio and production facilities as these remarks suggest.

101. The Committee fully acknowledges and welcomes the possibilities that new digital technologies offer broadcasters. At the same time, broadcasting is about people communicating with people. This communication should be facilitated throughout the regions and reflect cultural diversity at both a regional and national level. It needs broadcasters and their supporting facilities to be in situ. Section 286 of the Communications Act refers to a suitable range of Channel 3 programme production centres; we look to Ofcom to ensure these powers are used appropriately to provide for a thriving regional programme production sector.

ITV regional news

102. The Committee was concerned at evidence it has received, which is accumulating, that the quality of local news coverage on Channel 3 will be corroded by financially-motivated consolidation which will leave fewer journalists and facilities based throughout the communities in question. During this inquiry we studied in detail the predicament which had been put to us in Granada's Meridian franchise, serving the South and South East of England. We have also received representations from the East Midlands,[93] which provide a further illustration of the present threat to regional ITV programming.[94] These issues provide a relevant backdrop to the Granada-Carlton merger and the effects this could have on national and regional programming (including news).

103. In 1982, TVS won the franchise to broadcast in the South and South East and built studios in Kent in order to provide separate news coverage for the South and the South East. In 1991, Meridian was awarded the franchise by the ITC. Under the terms of the licence, Meridian is obliged to provide sub-regional news programmes (South, South East and West). The South East news is currently produced at the New Hythe, Maidstone studios.

104. In July 2000 Granada took over Meridian and in October 2003 proposed the movement of reporting and technical staff to Southampton and the outsourcing of website management, with accompanying job losses.

105. Staff at Meridian Broadcasting, Members of Parliament and others have made us aware of their concerns over developing proposals to close studios based in New Hythe, Maidstone. BECTU were particularly concerned about the proposal to cut 175 jobs, representing approximately half the current staff of Meridian Broadcasting.[95]

106. The production of sub-regional news programmes from the studios at New Hythe would be stopped under the proposals, and there would be a movement of the staff and facilities to Fareham near Southampton (outside the region reported on) together with redundancies related to this move. The present staff believe that the production of the sub-regional news for Kent, Sussex and South Essex, outside the region by non-resident reporters, will affect the quality of news produced. The programme at present is watched by 40% of viewers in the area and with this is the most watched regional news magazine in mainland Britain.[96]

107. In relation to the Meridian presence in Kent, Clive Jones told us: "All we are talking about is moving a presenter and, maybe, a technical director; the journalists will stay there, the reporters will stay there."[97] This assertion has been disputed by the unions,[98] who have provided us with a breakdown of the proposals for staffing levels.[99] We believe that uncertainty over the consequences of the proposals reflects a lamentable lack of meaningful and open consultation with the workforce.[100] The outcome of negotiations, due to take place over the coming year,[101] in relation to the final staffing levels that emerge will, in our view, provide an important indicator of ITV plc's commitment or otherwise to regional television.

108. Plans to downgrade production facilities, for example in the Meridian franchise, have proceeded apace with, to say the least, scant consultation with the trade unions. This situation must be rectified over the coming year, and Ofcom must ensure that any negotiations with ITV are conducted in an open and transparent manner.

109. Clive Jones told us he did not see the plans for Meridian as amounting to a diminution within the region, but that they were rather a consequence of modernisation and the wish to embrace new technology.[102] We are concerned that both the ITC and Ofcom appear to have accepted this glib attempted justification.[103],[104] We are far from reassured in respect of programming both for the Meridian region and for the ITV Network, and believe that Ofcom should be much more vigilant on this issue.

110. With regard to the East Midlands, Clive Jones claimed there was an on-going commitment to the programme-making tradition. However, he said that: "In Nottingham, as part of the process that we go through in any merger, we are going to have to review all our studios. We have an over-provision of studios in the country".[105] The Committee has been made aware that there are growing concerns among journalists in the East Midlands that, as a result of this review, ITV was considering the closure of its site in Nottingham, "consolidating" at Birmingham.[106] This would be worrying in any circumstances, but in this particular case we know that the proportion of the total audience in the region for ITV local news coverage is substantial, and therefore any such moves would be all the more damaging.

111. The production of television programmes for ITV Network distribution requires a critical mass of high level broadcasting skills and funding and facilities to give expression to these. It is important that these skills be present, and fully exploited, in appropriate regional and sub-regional centres throughout the nations and regions. We agree with BECTU that regional centres must remain capable of producing regional news, features and network production.[107] To this end the Committee is concerned that if the centre in Nottingham is closed the only realistic studio production facility for the East Midlands will be lost. The Birmingham site does not appear to provide for both studio production and news broadcast to take place simultaneously.

112. We believe that the situation we have described in detail with regard to Meridian, and the concerns raised relating to the East Midlands, may be part of a trend developing in ITV local and regional news coverage throughout the country. We note that almost two thirds of people claim that their local ITV company is their main source of local news and that ITV's own Charter for the Nations and the Regions asserts: "Regional news is one of the defining features and most popular aspects of ITV's output. ITV is committed to extensive regional and sub-regional news coverage in excess of that offered by the BBC."[108] We agree with the NUJ that this will prove a hollow boast if the relevant programmes are produced by people who do not live in the communities they are serving and have no affinities with them.[109]

113. The Committee looks to Ofcom to monitor the situation closely, and to take steps to safeguard the present high quality of programming in all sub-regions across the whole country. The potential threat posed by over-consolidation of regional and sub-regional news production centres will provide an early, major and crucial test for the credibility of Ofcom.

ITV as a public service broadcaster

114. Commercial broadcasters already have an important role in delivering public service television. The Communications Act requires Ofcom to carry out a review of the extent to which the BBC, Channels 3, 4 and 5, and S4C have provided programmes and services which, taken together, fulfil the purposes of public service television broadcasting in the UK. The review will not extend to radio, but will cover new media services to the extent that they are linked to television, such as interactivity and television-related online content. This is as close as Ofcom can get to influencing some internet content, it having no statutory, not to mention practical,[110] powers in this area.[111] As broadband develops, this black hole in policy will have to be tackled.

115. The review is also required to provide recommendations on maintaining and strengthening the quality of PSB television in the future, taking into account the costs of provision and the sources of income available to the public service broadcasters. As well as providing input into the Government's review of the BBC Royal Charter, Ofcom's review will also inform the eventual re-licensing of Channel 3 franchises. We note with raised eyebrows Lord Currie's reluctance to identify elements of ITV's current schedule which qualify as public service broadcasting.[112] In this regard, we await with great interest the outcome of the Ofcom review.

116. National news bulletins, with scheduling maintained at what Lord Currie called a "sensible" time, (whatever that may mean), fulfil a vital role in informing a democratic society.[113] Our predecessor Committee was sufficiently concerned to recommend that the ITC reject an application by ITV to abolish its News at Ten bulletin.[114] Unfortunately, the ITC acceded to ITV's request, with the result that the late evening bulletin was moved to 11pm, outside the longstanding definition of peak time, 6pm to 10.30pm. It was scant consolation, although meeting the letter of the statutory requirement to provide a bulletin in peak time, that ITV scheduled its main bulletin for 6.30pm. Our predecessor Committee subsequently called on the ITC to require ITV to reinstate News at Ten.[115]

117. Now, following years of chaotic scheduling, a fixed slot for the late evening ITV news been determined at ITV's initiative[116] - but outside peak time, at 10.30pm. This decision was reached in the closing moments of the ITC and with Ofcom's collusion.[117] Section 279 of the Communications Act 2003 provides that the regulatory regime for every licensed public service channel (including Channel 3) includes conditions that Ofcom considers appropriate for securing, among other things, news in peak viewing times. We deplore Ofcom's endorsement of the ITC decision to allow a down-grading of the news service offered by ITV during peak time, and urge them to reconsider their position on this issue during the forthcoming re-licensing of Channel 3 services.

118. Mr Jeremy Dear, General Secretary of the NUJ, pointed to advertiser influence on ITV to reduce regional and political programmes as well as news during peak time: "Only 2.6% of peak time viewing in the ITV network is now on news and current affairs."[118]

119. A merged and thus more powerful ITV shows little interest in maintaining news coverage beyond the bare minimum imposed by legislation and laxly interpreted by the ITC and Ofcom. The Communications Act 2003 provides some flexibility in the regulatory regime for news provision on public service television and we recognise that the news environment has evolved considerably, including 24-hour provision on digital platforms. However, with half the population still relying on analogue services, Ofcom should seek to reinstate on Channel 3 two substantial news bulletins within peak time — 6pm to 10.30pm.

120. The first Ofcom review of PSB comes at a critical time. Historically, commercial broadcasters have contributed to the provision of public service programming on UK television in return for privileged access to scarce spectrum. In future, the end of spectrum scarcity and the proliferation of channels mean that competitive pressures might affect the extent to which the commercial public service broadcasters can continue to sustain, and be required to sustain, PSB content. There may well be a move to reduce the specific PSB burden on ITV and Five and a commensurate increase in the burdens on the BBC and Channel 4.

121. Andy Egan of BECTU made the point that public service obligations may be less of a burden than is sometimes supposed: "I think you would be wrong to conclude that PSB programming is a loser in the marketplace; it is not a loser. Audience research shows that, by and large, given the choice between original programming and bought-in commercial programming from abroad, people prefer the former. There is also research to show that the UK viewing public does strongly value programming made in the regions."[119] Both UK production and regional programming have been traditional strengths of ITV - rightly acknowledged by Granada's Mick Desmond as unique selling points.[120] They must so remain.

122. In evidence to the Committee, Clive Jones of Carlton referred to the costs associated with the privilege of public service broadcaster status: "At the time where we face an enormous increase in competition and our revenue over the last ten years has dropped by £400 million per annum, we maintain our regional commitments and we want to continue to maintain our regional commitments, but I think we would like relief from the massive super taxes that we pay in terms of cash bids and PQR.[121] We are paying £250 million a year, at a time when Channel 4 pays nothing and Channel 5 pays a small amount of special tax and all the BBC seems to get is an ever-increasing source of revenue."[122]

123. Interestingly, the figure of £250 million broadly coincides with some estimates of the economic value of ITV's public service broadcasting, taking into account production budgets and advertising revenue forgone due to the low appeal of certain genres.[123] The Ofcom PSB review may well produce some robust quantitative measures, in so far as it is both possible and appropriate.

124. ITV plc and ITV Network have reportedly been seeking to negotiate reductions in public service commitments, a debate that was alluded to in our evidence session with Granada and Carlton.[124] Some trading of public service commitments has been mooted,[125] for example abjuring a simplistic box-ticking approach to certain genres, in favour of firmer commitments to other aspects of PSB. If this is indeed ITV's intention, they should not be allowed to get away with it.

125. A memorandum from the Campaign for Press and Broadcasting Freedom urged the Committee "to reinstate public service ideals at the heart of television in the UK, not because we wish to return to some mythical 'golden age' of British broadcasting, but because we believe that this is the only hope for a better, more diverse broadcasting system in an increasingly competitive environment. Outside the pages of the Murdoch and Black press, there is a great deal of reliable evidence that the vast majority of British people value tremendously the kind of broadcasting which public service values have helped to create, and they and their descendants will judge harshly those who, whether by accident or design, destroyed it for ever."[126] We agree.


66   Ev 11 Back

67   Carlton Communications Plc and Granada plc: A report on the proposed merger, Cm 5952, 7 October 2003 Back

68   Carlton Communications Plc and Granada plc: A report on the proposed merger, Competition Commission, Cm 5952, Octboer 2003  Back

69   ITC / Ofcom joint briefing in response to the Secretary of State's decision on the ITV merger, 7 October 2003, http://www.ofcom.org.uk/media_office/latest_news/nr_20031007 Back

70   Carlton Communications Plc and Granada plc: A report on the proposed merger, Cm 5952, October 2003  Back

71   Ev 21, Q 53 Back

72   Ev 42, Q 84 Back

73   Ev 1 Back

74   Ev 5, Q 2 Back

75   Ev 7, Q 9 Back

76   Ev 16, Q 36 Back

77   Ev 4 Back

78   Ofcom's proposed guidance on regional production and regional programming, consultation document, consultation closed on 30 January 2004  Back

79   Ev 17, Q 37 Back

80   Ev 22, Q 54 Back

81   Ev 12 Back

82   ITC Note, Channel 3, http://www.ofcom.org.uk/static/archive/itc/itc_publications/itc_notes/view_note70.html Back

83   Ev 14 Back

84   Ev 10, Q 22 Back

85   Ev 19, Q 48 Back

86   Ev 25, Q 74 Back

87   Ev 11 Back

88   Ev 58-59, Letter from Ofcom to Dr Julian Lewis MP Back

89   Ev 14 Back

90   Ev3 Back

91   Ev 9, Q 19 Back

92   Ev 27, Q 88 Back

93   Ev 60 Back

94   Ev 12 Back

95   Ev 14 Back

96   Ev 56-8, Memorandum from Mr Nick Myers and Mr Alan Rook to employees at Meridian Back

97   Ev 23, Q 64 Back

98   Ev 52-3, Memorandum submitted by Meridian Maidstone NUJ / BECTU Back

99   Ev 53-5, Letter from the National Union of Journalists to Meridian Television Back

100   Ev 15, Q 31 Back

101   Ev 23, Q 63 Back

102   Ev 23, Q 64 Back

103   Ev 45, Letter from the Chairman of the ITC to Mr Julian Brazier MP; Ev 59-60, Letter from ITC to Mr Norman Baker MP Back

104   Ev 51-2, Letter from Ofcom to Mr Iain McBride on behalf of the joint unions at Meridian TV in Maidstone; Ev 58-9, Letter from Ofcom to Dr Julian Lewis MP Back

105   Ev 26, Q 79 Back

106   Ev 60, Letter from Pat West, NUJ, ITV studios, Nottingham. Back

107   Ev 14 Back

108   Cambridge Econometrics, 2002 Back

109   Ev 60 Back

110   Ev 33, Q 16 Back

111   Ev 33, Q 14 Back

112   Ev 33, QQ 17-18; Ev 41-2, Q 80 Back

113   Ev 33, Q 13 Back

114   Ninth Report, 1997-98, HC 1110 paragraphs 33-4 Back

115   Fifth Report, 1999-2000, HC 289 paragraph 56 Back

116   Ev 27, Q 94 Back

117   Ev 37, QQ 37-40 Back

118   Ev 16, Q36 Back

119   Ev 20, Q 49 Back

120   Ev 23, Q 58; Ev 25, Q 71 Back

121   percentage of qualifying revenue Back

122   Ev 24, Q 66 Back

123   "Watchdog eases burden on ITV licence", Guardian, 27 January 2004 Back

124   Ev 26, Q 77 Back

125   Ev 17, Q 37 Back

126   Ev 49-51 Back


 
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