Select Committee on Culture, Media and Sport First Report

4  General prospects for future delivery

43. While there is currently an abundant supply of public service content and a plurality of providers of this type of content, there are concerns that this situation is threatened by digital switchover. This chapter assesses the prospects for the general provision of public service content and for provision in specific areas including children's programming; news and current affairs programming; and regional and local content. We also discuss the likely future provision of public service content on new media.

44. Until comparatively recently, public service content has been provided by a small number of large­scale institutions, such as the BBC, ITV or Channel 4. One approach to considering the likely future provision of public service content, therefore, would be to look at inputs—that is, the existing public service broadcasting institutions, and the overall amount of public subsidy they receive. Jeremy Mayhew, a Partner at Spectrum Strategy Consultants, told us that an approach that focuses on institutions is appropriate as the key features of public service broadcasting are quality, innovation, experimentation and "pushing the boundaries" and that, as these things are "inherently subjective" and "nebulous" they cannot be specified precisely and delivered in a contractual relationship. He believed that we needed to consider the importance of institutions in the delivery of public service content because an "ethos inside institutions which have distinctive purposes and remits is not some sideshow to the delivery of the proposition, it is absolutely fundamental to the characteristic of the proposition".[79]

45. Other stakeholders argued that we could best assess the prospects for the future of public service content by looking at the likely provision of outputs—that is, the amount of different types of programming available to consumers. Lord Burns, former adviser on BBC Charter review to the Secretary of State for Culture, Media and Sport, told the Committee that "although it is attractive to think of this in terms of institutions, that is not the way the world is going".[80] The Broadcasting Policy Group argued that until "all participants in the debate recognise […] that there are market and non­market products and that institutional delivery should not determine either how we define nor fund public service content, we will all remain stuck firmly on first base, contemplating a progressively worsening situation".[81] The RadioCentre told us that "any new public service broadcasting strategy will fail if it is fashioned with the tools of a bygone era".[82] BSkyB said that Ofcom has tended to focus on inputs and this "leads them to fret that the amount of public subsidy is in decline and to contrive solutions […] to problems that do not exist".[83] BSkyB added that Ofcom gives "little or no space or analysis to the increasing output of content which meets public service broadcasting criteria but which has no direct or indirect state support".[84]

46. Some stakeholders considered that both inputs and outputs needed to be taken into account. For example, Ofcom argued that it is "really rather dangerous simply to look at output" and that "you must also look at the input side of something as complicated and subtle and nuanced as broadcasting".[85] The Rt Hon Shaun Woodward MP, then Minister for Creative Industries and Tourism, agreed that output indicators are "useful and they provide part of the picture, but the picture also needs to look at the institutions as well and I think those institutions are in good shape".[86]

47. We believe that the primary and most important factor for policy­makers and regulators to assess when looking at the provision of public service content is the amount of content exhibiting public service purposes and characteristics, as defined by Ofcom, available to consumers. However, we recognise that an assessment of the number of public service content providers and their levels of public subsidy can be a useful, but firmly secondary, way of looking at the issue.

Designated public service broadcasters

ITV, CHANNEL 4 AND FIVE

48. The commercially funded broadcasters—ITV, Channel 4, Five—rely on advertising revenue as their main source of income. Under a system termed the "PSB compact" by Ofcom, ITV and Five receive access to a strictly limited number of analogue terrestrial television broadcast licences (together with the associated scarce spectrum to allow terrestrial broadcast delivery) in return for accepting obligations to provide public service content.[87] Channel 4 was also given a licence and the spectrum necessary to allow the terrestrial broadcast delivery of its analogue television services, in return for accepting a more substantial set of public service content obligations. ITV and Five pay for their licences; Channel 4 does not. In addition, ITV, Channel 4 and Five enjoy further indirect subsidies including: appropriate prominence on the electronic programme guide;[88] reserved capacity on the digital terrestrial television platform; and must­carry status on the cable platform.[89]

49. Ofcom said that the "PSB compact" will erode as the UK approaches digital switchover. As audiences fragment as the result of gaining access to more digital multi­channels, the value of the public service broadcasters' exclusive access to analogue spectrum falls. In addition, commercial broadcasters now have alternative routes to audiences—such as digital terrestrial television, cable or satellite—which means it is possible for them to withdraw from the "PSB compact". Forecast falls in television advertising revenue will put commercially funded broadcasters under further pressure. Ofcom told the Committee that "the PSB compact as presently configured will not be sustained in the digital age" and that "while there remains scope in the run­up to digital switchover to hold commercial broadcasters […] to a number of existing obligations, this will not continue once digital switchover is complete".[90] In 2004, Ofcom estimated that the total value of the indirect subsidies for ITV, Channel 4 and Five was around £430 million per year and forecast that this would fall to around £25 million per year after digital switchover.[91]

50. Some stakeholders agreed that the commercial broadcasters will come under pressure as the UK approaches digital switchover and that their provision of public service content would wane as a consequence. For example, Channel 4 argued that it will not be enough to will the "ends" of public service content without putting in place new "means" to support its delivery.[92] Tim Gardam, previously Director of Television and Director of Programmes at Channel 4, said that "the migration of advertising from television towards the Internet is going to put considerable pressure on traditional commercial broadcasters" and added that he was also pessimistic about "the ease with which public service material will be provided by shareholder maximising, profit maximising companies".[93] Pact agreed that the terrestrial broadcasters may come under pressure but said that these concerns may have been exaggerated by the broadcasters in order to create the appearance that they are no longer the dominant party in their relationships with independent producers. [94] SMG, owner of the two Channel 3 licences for central and north Scotland, argued that the prospects for maintaining public service content in the digital age are "extremely challenging" and added that intervention and funding will be "required if the BBC is not to become a sole provider of key public service broadcasting genres".[95]

51. ITV and Five were more optimistic than Channel 4 and SMG about the commercial public service broadcasters' ability to provide public service content. ITV considered that "core network public service broadcasting genres may be sustainable" in future.[96] Five stated that after digital switchover "the market will provide a lot of the programming currently recognised as public service broadcasting" because "the growth of digital will create further opportunities for channel and programme offerings that would traditionally be defined as public service broadcasting".[97] Lord Burns, former adviser on BBC Charter review to the Secretary of State for Culture, Media and Sport, expressed doubts that commercial broadcasters would withdraw completely from providing public service content as he believed that it was good for their branding and image, and could be a money­making proposition.[98] Scottish Screen was also more positive about the prospects for commercially funded public service broadcasters, stating that the "comparative resilience of public service broadcasting […] and the established power of public service broadcasting brands should not be underestimated". It added that the "continuing unique selling point of the commercial public service broadcasters […] to provide advertisers with the ability to reach mass audiences quickly and effectively" should not be undervalued.[99] David Elstein, Chairman of the Broadcasting Policy Group, told us that even after digital switchover, ITV, Channel 4, and Five will have total revenues "north of £2 billion a year and by far the biggest item of expenditure for them will be new, original UK­commissioned content because that is what works for them commercially".[100]

52. In any case, ITV, Channel 4 and Five will still receive indirect subsidies after digital switchover, which Ofcom forecast to be worth around £25 million per annum. The International Broadcasting Trust[101] argued that there should be an obligation on commercial broadcasters to provide public service content—domestic and international news in peak time in particular—in return for the value of this, albeit reduced, subsidy.[102]

53. We recognise that the value of the indirect subsidy of analogue spectrum for ITV, Channel 4 and Five, which granted exclusive access to mass audiences, will diminish as the UK approaches digital switchover and we note the concerns that ITV, Channel 4 and Five might therefore reduce their current provision of public service content. On the other hand, we note that there will still be an (albeit smaller) subsidy for the commercial public service broadcasters after digital switchover and we believe that this, and broadcasters' commercial interests, will sustain public service content. We do, however, believe that it will be increasingly difficult to continue to impose public service obligations on commercial broadcasters beyond the value of this ongoing subsidy. The question, increasingly, will be what level of obligation is sustainable.

THE ROLE OF THE BBC

54. UK consumers have guaranteed provision of public service content, free from commercial pressures, from at least one public service broadcaster: the BBC. In 2007, the BBC received a new Royal Charter, which guaranteed its existence for the next ten years.[103] The Government also stated that the television licence fee—currently reserved exclusively for the BBC—will remain in place for the same period,[104] and set the level of the licence fee for the next six years giving the BBC certainty over its income. [105]

55. The BBC's remit is set out in its Royal Charter and Agreement. The BBC has to fulfil certain public purposes and each of the BBC's UK public services is expected to comply with a published service licence, issued by the BBC's new governing body, the BBC Trust. Each licence sets out the service's remit, scope and distribution, aims and objectives, and budget. These service licences will cover the BBC's media portfolio on all platforms, including eight television channels, ten national radio services, a large number of local radio stations and an online service.

56. The BBC also plays an important role in setting high standards for the rest of the broadcasting market to follow. DCMS, for example, said that the BBC is "unique, adds value in its own right and has undoubtedly helped to set the high standards of quality for which UK broadcasting is rightly renowned."[106] Ed Richards, Chief Executive of Ofcom, told us that "the BBC in a sense sets the standard, and that is a good thing" and recognised that it does so "because it has a unique position with the greatest privileges". He added that the BBC, together with the commercial public service broadcasters, set a standard which other providers without public service broadcaster status have to match and occasionally exceed.[107] Michael Grade, Executive Chairman of ITV, said that "a successful BBC is good news for viewers and good news for advertisers in the end because it keeps our standards up and stops us becoming commodity programme suppliers."[108]

57. The BBC currently provides a wide range of public service content across many genres and plays an important role in setting quality standards for the rest of the broadcasting market. We expect the BBC to continue to provide quality programming and to set standards for other broadcasters in future given its guaranteed income of over £3.2 billion per annum.

58. Many stakeholders, however, expressed the view that the BBC had a negative impact on the provision of public service content by the rest of the market. We also heard that the BBC should therefore be focusing its attention on areas the market genuinely would not provide. For example, Channel 4 argued that "clearly everything the BBC does as a publicly funded organisation distorts the market" and that the BBC's licence fee bid represented a "significant incremental public intervention in the broadcasting market, with the potential to adversely affect the competitiveness of other players".[109] SMG said that the BBC's market dominance over commercial competitors is a problem and that there is a "need for regulatory intervention […] to redress the balance".[110]

59. We also heard concerns about the BBC's involvement in radio and new media. The RadioCentre argued that the BBC is "using its might to threaten a pluralistic public service broadcasting ecology" in radio and that the best option for securing plurality in the provision of public service content on radio is to maintain "reasonable restraints" on the BBC.[111] The RadioCentre also told us that it was not unreasonable to suggest that, if the market is getting bigger and more diverse, providing consumers with more of what they want, then the level of provision by the BBC "need not grow and indeed could diminish".[112] ITN said that the "expansion of BBC News online, and the resources required to invest in these areas, will make it difficult for ITV News and Channel 4 News to develop their online propositions to compete as successfully as they do on television".[113] SMG argued that the BBC's online offering, including publicly funded content free from any commercial activity, is a "real barrier to entry for the development of alternative services".[114]

60. Greg Dyke, former Director­General of the BBC, told us that the BBC should focus on the services that matter the most to the public interest, "which is not necessarily the same thing as [the services that] matter most to the public".[115] When asked in oral evidence from which areas the BBC planned to withdraw, Mark Thompson, Director­General of the BBC, indicated that the BBC would reduce spending on acquisitions and imported programming and stated that "you do not need the BBC generally to show you American programming".[116] In July 2007, in a speech on the future of the BBC, Mark Thompson said that "the BBC needs to become smaller […] in terms of its scale as an organisation and in its operations". He also believed that the BBC "should make less" and "concentrate its finite resources on fewer, better hours of television and radio and fewer, better web pages".[117] More recently, Mark Thompson set out his strategy for the BBC for the next six years. He confirmed that the BBC would be "smaller than it is today" and that the BBC will "make less but make it to a higher standard". He announced, for example, that the BBC plans to commission 10% fewer hours of television than it does today by 2012, which he hoped would allow the BBC to make more landmark programmes such as Planet Earth.[118]

61. Some stakeholders considered that the BBC needed to be involved in a wide range of areas, including more commercial programming, in order to maintain its relevance to the widest possible section of licence fee payers. In the Charter review process, the Government said that "the BBC should provide a wide range of content, across every genre, trying to reach the greatest possible range of audiences"[119] and that in most cases "the BBC's output will achieve its maximum impact only by entertaining its viewers and listeners."[120] The Government further argued that "it is wholly legitimate—and in view of the way it is funded, necessary—for the BBC to provide programmes aimed at a wide audience".[121] The Satellite and Cable Broadcasters' Group told us that "the careful balance of popular entertainment and public service broadcasting is the defining condition of the BBC" [122] and that "the BBC's ability to retain an adequate level of support for public funding will […] remain down to its ability to present a value mix that generates enough public support".[123] Lord Burns, former adviser on BBC Charter review to the Secretary of State for Culture, Media and Sport, noted that people wanted to see variety of programmes on the BBC, but that "it is patently obvious that the programmes which are most watched are the ones that are most similar to the programmes that you do see on the other channels". He believed that it was important that the BBC provided a "good offering which has a big reach that attracts quite a substantial range of people to watch it on a systematic basis".[124]

62. Mark Thompson, Director­General of the BBC, claimed that the BBC has increasingly focused on areas that that the market does not provide, and said that the "BBC has reacted to the arrival of new channels and new competitors by drawing back from those kinds of programmes that can be broadcast by others."[125] He also indicated that, at the same time the BBC sets out its future plans, it would also be clear about the services it is not going to provide, in order to "help the rest of the industry [and] make sure that we do concentrate the licence fee in a way which delivers really outstanding content to the public."[126] In October 2007, while setting out his strategy for the BBC for the next six years, Mark Thompson went some way towards doing this by announcing that the BBC would "make sure what [it does] is really distinctive—different from what commercial broadcasters can provide—and really original".[127]

63. We note that some argue that the BBC should provide more commercially­orientated programming in order to reach a wide range of audiences. However, we do not share this view and instead believe that the BBC should place a high priority on areas that other broadcasters will not provide, while continuing to offer high quality programming which attracts diverse audiences. Given the substantial provision of public service content by other broadcasters, we believe that the BBC could deliver its public service remit without providing all of its current range of services and we note and welcome the BBC's commitment to become smaller in terms of its scale as an organisation and in its operations. We do not believe, however, it is in the public interest for the BBC to be allowed to wither, as some would like, for example, to become akin to the Public Broadcasting Service (PBS) in the US.

64. The BBC's public service content provision is funded by the television licence fee. In 2005, the BBC set out its bid for a new licence fee settlement for 2007-08 onwards. It set out plans to build digital infrastructure, deliver digital services, provide quality content, and increase local relevance, and argued that this would require an increase in the licence fee of RPI plus 1.8% per annum. In January 2007, the then Secretary of State for Culture, Media and Sport announced the licence fee settlement for the next six years: the settlement broke the link between the licence fee and inflation but, based on projections, equates to an increase of approximately RPI minus 0.45% per annum. Michael Grade, Executive Chairman of ITV, stated that the licence fee "fell some way short of what the BBC needed in order to meet the programme that the Government had set for it in the Green and White Papers".[128] Mark Thompson, Director­General of the BBC, told us that the level of the licence fee is a "matter of judgement for government" and that it was now up to the BBC to "deliver the best possible range of services and programmes we can within the funding that we have got."[129]

65. Other parties also considered that the licence fee settlement, while lower than the BBC's bid, would still enable the BBC to provide a substantial amount of public service content. The Government said that the licence fee settlement "will enable the BBC to deliver its new public purposes" as set out in its Royal Charter. BSkyB argued that the licence fee settlement "is more than sufficiently generous" for the BBC to "prioritise its activities so that it delivers more public service broadcasting in areas which might not be served in the future"[130] and Andy Duncan, Chief Executive of Channel 4, considered that although the BBC received "less of a licence fee than they wanted […] they have done very well" especially considering forecast future falls in the advertising market.[131]

66. There were concerns, however, that the BBC would not be able to provide quality programming if it received less resources. Mark Thompson, Director­General of the BBC, recognised that this was a risk and said that "a change which leads to a reduction in quality isn't an 'efficiency', it's a straightforward cut and a diminution in service". However, Mr Thompson argued that although there was "widespread anxiety inside and outside the BBC" about the impact on quality of the BBC's recent three­year efficiency drive, most of the quality indicators at the BBC have gone up, not down, over the past three years.[132]

67. The Government gave the BBC Trust an overriding duty of effective stewardship of the licence fee. In the event that the BBC Trust decides that the BBC can fulfil its public purposes using less resources than afforded by the licence fee, it has the option of "not drawing down the full amount of the licence fee where the Trust considers this is in the public interest".[133]

68. While we recognise the concerns that the BBC received a lower licence fee settlement than desired, we believe that the BBC can continue its role in providing high quality programming within the resources available to it and we welcome the BBC's plans to become a smaller but more distinctive organisation. However, the increase in market provision of public service content suggests to us that further analysis needs to be undertaken to assess the level of public funding that needs to be made available for public service content. On current trends, we would expect that the case for current levels of public funding will diminish. The BBC has rightly reacted to the arrival of new channels by drawing back from programming that can be broadcast by others. We welcome the BBC's approach, and encourage the BBC Trust to limit the BBC's activities in areas where there is already alternative provision. The BBC Trust should not treat licence fee income as a sum that must necessarily be spent in its entirety, irrespective of others' provision of public service content, and we encourage it to bear in mind its option of not drawing down the full amount of the licence fee in future.

THE ROLE OF S4C

69. S4C was optimistic about the prospects for public service content in Wales. S4C told us it could succeed in the digital age and that its 2004 Creative Excellence Strategy would answer the "challenges of the new multi­platform, multi­media environment".[134] S4C was also optimistic about programming genres that other public service broadcasters believe will come under threat as the UK approaches digital switchover. It said that over the past two years it had doubled its financial commitment to its provision for pre­school children. S4C told us that it also planned to launch cross­platform Welsh­language services for children and young people and added that it will not be seeking additional funds for this launch.[135]

70. S4C's comparative optimism may be due to its unique funding arrangements. S4C is relatively insulated from fluctuations in the advertising market as around 95% of its income is received in direct funding from DCMS (under statute, this funding increases by RPI each calendar year).[136] S4C receives only around £8 million from other sources including advertising. DCMS, however, argued that S4C will face challenges in the multi­channel world. It considered that S4C will "not be immune to the competition for audiences facing other public service broadcasters" and noted that digital switchover will mean that S4C loses the advertising revenue it currently receives from broadcasting Channel 4 programmes in Wales.[137]

71. Although S4C benefits from direct public funding, this form of support for public service content has been discounted by the Government as a wider policy option. The main concern about direct funding is the risk that it would compromise the independence of the recipient broadcaster. Despite the fact that the BBC technically receives its licence fee income in direct funding from DCMS, the BBC opposes direct funding in principle, stating that the licence fee "ensures that the BBC remains independent from political […] influences".[138] In relation to news, for example, Channel 4 stated that direct funding needed to be handled carefully "given the absolutely critical requirement for any news provider to maintain independence from the Government and the wider political ecology".[139] On the other hand, S4C told us that it is happy with its direct funding position: it did not believe it was subject to inappropriate scrutiny as its funding formula is set out in legislation.[140] The Canadian Broadcasting Corporation, Canada's national public broadcaster, told us that the direct funding which it receives from the Canadian Government did not compromise its independence.

72. We are encouraged by S4C's optimism about its ability to provide public service content in the future. S4C demonstrates that a broadcaster with direct public funding and a tightly defined remit can deliver public service content without having its editorial independence compromised.

Digital multi­channels

73. The Committee heard that the provision of public service content by the digital multi­channel sector would increase in the future. The Satellite and Cable Broadcasters' Group predicted that it is "inevitable" that public service broadcasting in the digital age will consist of a wide plurality of providers as technological development and the end of spectrum scarcity will allow new channels and platforms to develop.[141] Five echoed this view, stating that "the growth of digital will create further opportunities for channel and programme offerings that would traditionally be defined as public service broadcasting".[142] BSkyB argued that the level of public service content from the multi­channel sector would increase in the future as the rising uptake of digital television will allow multi­channel broadcasters to reach larger audiences and therefore generate greater revenues to invest in content.[143] However, the Satellite and Cable Broadcasters' Group expressed a concern that commercial multi­channel broadcasters would find it difficult to invest in programming and platforms without appropriate oversight of the incumbent terrestrial operators as they believed that subsidised public service broadcasters crowd out the multi­channel sector's investment in content. [144]

74. We outlined earlier the arguments concerning the digital multi­channel sector's investment in UK programming. Some stakeholders argued that investment in UK­originated content by digital multi­channels would grow in the future. David Elstein, Chairman of the Broadcasting Policy Group, pointed out that in the United States, even faster fragmentation of audiences than that experienced in the UK has led to a significant increase in the volume of investment and production of high­quality content.[145] BSkyB stated that the economics for multi­channel investment in UK content were very challenging at the moment but were improving, and that this would mean that more UK content would be commissioned by the multi­channel sector. In addition, UK­originated public service content can be profitable for commercial broadcasters, via sales of rights and formats for example. The Voice of the Listener and Viewer pointed out that the UK is second only to the United States in the economic value of its media exports.[146] In relation to children's programming, Pact noted that some programming is lucrative as it is able to generate substantial revenues from secondary and ancillary sales such as merchandising.[147] On the whole, however, Pact was more sceptical about the digital multi­channel sector's future investment in public service content stating that they "cannot be regarded as a replacement for terrestrial public service programming in the foreseeable future" unless they significantly raise their investment in new UK programming.[148]

75. The provision of public service content by the digital multi­channel sector has increased plurality in UK broadcasting. The sector provides a range and diversity of content that exhibits public service purposes and characteristics as defined by Ofcom and this provision may very well increase after digital switchover as its channels gain access to larger audiences and revenues.

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79   Q 1 Back

80   Q 2 Back

81   Ev 1 Back

82   Ev 37 Back

83   Q 448 Back

84   Ev 179 Back

85   Q 528 Back

86   Q 659 Back

87   Ev 203 Back

88   An on­screen guide to scheduled television programmes. Back

89   Ofcom, Review of public service television broadcasting: Phase 2-Meeting the digital challenge, September 2004, p 21 Back

90   Ev 206 Back

91   Ofcom, Review of public service television broadcasting: Phase 2-Meeting the digital challenge, September 2004, pp 24, 34 Back

92   Ev 88 Back

93   Q 7 Back

94   Ev 67 Back

95   Ev 387 Back

96   Ev 113 Back

97   Ev 128 Back

98   Q 6 Back

99   Ev 289 Back

100   Q 5 Back

101   An educational charity which seeks to promote high quality television and new media coverage of matters of international significance. Back

102   Ev 320 Back

103   DCMS, Copy of Royal Charter for the continuance of the British Broadcasting Corporation, Cm 6924, October 2006 Back

104   DCMS, A public service for all: the BBC in the digital age, Cm 6763, March 2006, p 8 Back

105   HC Deb, 18 January 2007, col 933 Back

106   DCMS, A public service for all: the BBC in the digital age, Cm 6763, March 2006, p 34 Back

107   Q 527 Back

108   Q 251 Back

109   Channel 4, Submission for the licence fee seminar, May 2006, p 2, http://www.bbccharterreview.org.uk Back

110   Written evidence from SMG [not printed] Back

111   Ev 41 Back

112   Q 105 Back

113   Ev 189 Back

114   Ev 387 Back

115   Q 394 Back

116   Q 320 Back

117   Mark Thompson, Delivering creative future: The BBC in 2012, 10 July 2007 Back

118   Mark Thompson, Speech to BBC staff on delivering Creative Future, 18 October 2007 Back

119   DCMS, A strong BBC, independent of government, March 2005, p 8 Back

120   DCMS, A public service for all: the BBC in the digital age, Cm 6763, March 2006, p 10 Back

121   DCMS, A public service for all: the BBC in the digital age, Cm 6763, March 2006, p 10 Back

122   Ev 236 Back

123   Ev 239 Back

124   Q 12 Back

125   Mark Thompson, Delivering creative future: The BBC in 2012, 10 July 2007 Back

126   Uncorrected transcript of oral evidence taken before the Culture, Media and Sport Committee on 3 July 2007, HC (2006-07) 820, Q 26 Back

127   Mark Thompson, Speech to BBC staff on delivering Creative Future, 18 October 2007 Back

128   Q 251 Back

129   Uncorrected transcript of oral evidence taken before the Culture, Media and Sport Committee on 3 July 2007, HC (2006-07) 820, Q 12 Back

130   Ev 180 Back

131   Q 196 Back

132   Mark Thompson, Delivering creative future: The BBC in 2012, 10 July 2007 Back

133   DCMS, A public service for all: the BBC in the digital age, Cm 6763, March 2006, p 61 Back

134   Ev 149 Back

135   Ev 152 Back

136   Ev 154 Back

137   Ev 258 Back

138   BBC, Response to A strong BBC, independent of government, May 2005, p 38, http://www.bbc.co.uk Back

139   Ev 92 Back

140   Q 368 Back

141   Ev 239 Back

142   Ev 128 Back

143   Ev 180 Back

144   Ev 234 Back

145   Q 5 Back

146   Ev 16 Back

147   Ev 72 Back

148   Ev 61 Back

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Prepared 15 November 2007