House of Commons - Culture, Media and Sport

Select Committee on Culture, Media and Sport Written Evidence

APPENDIX

RESPONSE OF SCOTLAND'S SCREEN INDUSTRIES SUMMIT GROUP (SISG) TO PHASE THREE OF OFCOM'S REVIEW OF PUBLIC SERVICE TELEVISION BROADCASTING

First of all, SISG welcomes Ofcom's announcement of a period for further consultation on the provision of PSB for Scotland, in view of the importance of some of the issues regarding the future of PSB in the Nations which were left open at the end of Phase Two of Ofcom's review.

We believe that the key recommendations we made in response to Phases One and Two of Ofcom's Review of Public Service Television Broadcasting continue to be relevant. These are attached (restated where appropriate) as Annex 1. Additionally, we have a number of specific proposals in response to Phase Three of the review, which are highlighted below.

PRODUCTION

Given SISG's core objective of increasing network and international presence and growth in production (see Annex 2 attached), it should be no surprise that Ofcom's proposals regarding PSB production feature prominently in our consultation response.

SISG has no objection to Ofcom's proposal that "the BBC should be asked, as part of Charter Review, to develop new proposals for local and regional programming, which go beyond those set out in its Building Public Value document, and help provide more well-funded television programming for the English Regions to complement its ambitious plans for the Nations." [7]However, we would not wish to see this result in any dilution of the BBC's welcome commitment that "besides Manchester, network commissions from the Nations will increase by 50% to 17% of overall network commissions." [8]The current level of metropolitan commissioning bias is more than sufficient to provide scope for significant increases in the levels of PSB network commissioning both for the devolved Nations and the English regions. We trust Ofcom will ensure that no dilution of the BBC's stated objective of 17% network production from the Nations results from its consultations with the BBC on increasing its out-of-London network production.

Although we are pleased to note Ofcom's statement that it "... will increase ITV1's quotas for out-of-London production for the network to 50% (by value and volume)," [9]we also continue to share Ofcom's concern that "The level of ITV1 network production in the devolved Nations has declined every year since 2000" and that "By 2003, just 2% of total network programme spend went to the three Nations combined." [10]We therefore agree with Ofcom's statement that the first priority should be to tackle network production in the Nations, but believe that Ofcom's suggestion of a voluntary target for the three Nations combined of around 8% of total ITV1 network spend and hours of output[11] should rather be aligned with the BBC's 17% objective. SISG believes that:

1. ITV1 should be charged with matching the BBC's stated objective of 17% of network production from the devolved Nations;

2. as PSB providers, Channels 4 and 5 should also be charged with sourcing at least 17% of their programme production from the three devolved Nations; and

3. 17% should be established as a quota, not as a voluntary target.

SISG has referred in our earlier response to Phase One of Ofcom's PSB review to the provisions made in the Communications Act 2003 that a suitable proportion of Channels 3, 4 and 5 programme production expenditure is spent at production centres outside the M25 area and, further, that "the different programme production centres to which that expenditure is referable constitute what appears to OFCOM to be a suitable range of such production centres." [12]We registered our interest in how Ofcom intends to address the "suitable range" issue moving forward, as we believe that the current benchmarks, which we understand are based on the 2002 actual geographical expenditure profile are unsatisfactory, based as they are on one particular snapshot in time and reflecting existing metropolitan-biased market distortions. The use of these benchmarks sells Scotland short.

We understand that Ofcom will be addressing this issue further in its forthcoming strategic review of broadcasting content production and we look forward to a clarification of Ofcom's definitions and methodology in addressing the dispersal of production across a "suitable range" of centres. [13]

The important contribution of content production matters to PSB, particularly on the location of production, is especially relevant to Scotland. As we have noted in our earlier responses, Scotland's contribution to UK PSB would be compromised if there was a failure to develop sufficient critical mass to sustain production for the UK networks. We continue to believe that Scotland possesses the attributes necessary for a thriving television production centre, but that it needs to be allowed to develop a critical mass of creative talent to realise its full potential. This will require regulatory support from Ofcom.

COMPETITION

SISG also welcomes Ofcom's clear support for plurality in the provision of PSB, exemplified by its statement that "The BBC is at the heart of the UK PSB system, but PSB overall is likely to be most successfully provided if there is a range of different suppliers, with access to different sources of funding, and with different institutional models." [14]We also agree with Ofcom that plurality is needed at three key levels:

— "plurality of outlets: so that viewers do not have to be reliant on a single provider in order to receive PSB;

— plurality of commissioning: so that a range of commissioners working for different organisations can bring their different perspectives to bear on the system; and

However, consistent with our view that the preservation and promotion of Scotland's distinctive national identity is a core objective of PSB, we would also stress the importance of ensuring plurality in a Scottish as well as a UK context. Thus, while SISG continues to believe that the terms of the Scottish and Grampian Television licences with respect to its PSB obligations are matters for SMG to pursue, we would not wish to see a scenario in which the BBC was the only platform for PSB to the Scottish nation.

PUBLIC SERVICE PUBLISHER

We also note and await with interest further developments on Ofcom's Public Service Publisher (PSP) proposal. Based on Ofcom's further statements regarding the probable scope and remit of the PSP, [16]SISG maintains its confidence that a PSP located in Scotland, drawing upon content generated across the breadth of the UK, would bring the necessary qualities to strengthen public service provision not just in Scotland but across the whole of the UK. SISG looks forward to supporting a Scottish based PSP if the Government decides to proceed with the PSP proposal.

OBJECTIVES OF PSB

We welcome the reinforcement of the role of the Nations which is contained in two of the four PSB purposes which Ofcom have included in its new definition of PSB, namely:

— "To reflect and strengthen our cultural identity through original programming at UK, national and regional level, on occasion bringing audiences together for shared experiences.

We also welcome Ofcom's stated aim to ensure that mainstream commercial television fully reflects the lives of people from around the UK[18] and the further recognition that the devolved Nations have distinctive circumstances which require both more, and a greater range of programming specifically for each nation than in the English Regions. [19]We also agree with Ofcom's observation that the television regions in the Nations more closely map onto real cultural identities than in the English Regions. [20]While SISG does not wish to enter the realm of commercial and regulatory negotiations between Ofcom and its individual licensees, we would support measures to facilitate improved news coverage of issues which are now devolved to the Scottish Parliament, for example health and education matters. [21]We also support the propositions that the ITV Networking Arrangements should be amended in order to:

— enable national licensees to opt out of the network schedule in order to meet their regional programming requirements without having to pay for the network programme that they have opted out of; and

GAELIC DEVELOPMENT

SISG welcomes Ofcom's support for the prospect of a dedicated Gaelic service for Gaelic speakers and others interested in Gaelic programmes. [23]As ever, though, the devil will lie in the detail and we would wish to see clarification and resolution of permanent funding arrangements for the proposed Gaelic service.

We are disappointed with the apparently limited scope of Ofcom's review of Gaelic broadcasting, in particular the lack of reference to BBC Scotland's significant past contribution and their potential future contribution.

OFCOM'S ROLE

SISG believes that Ofcom's current review of PSB provision is a valuable and necessary exercise. We believe the importance of the key issues which have been raised are likely to intensify rather than diminish moving forward, particularly as digital switchover approaches. We would urge Ofcom to ensure PSB provision is reviewed on a timely basis and in the light of major developments, which may well be more frequently than the statute requires.

We have been pleased to note the devolutionary tone and recognition of the benefits of this stance which permeate many of Ofcom's statements regarding PSB. We would therefore urge Ofcom to consider a greater devolution of its own activities outside London.

Annex 1

SISG'S KEY RECOMMENDATIONS IN RESPONSE TO PHASES ONE AND TWO OF OFCOM'S REVIEW OF PUBLIC SERVICE TELEVISION BROADCASTING (RESTATED)

PRODUCTION

It is essential that Scotland develops sufficient critical mass to sustain production for the UK networks. Without this, Scotland's contribution to UK PSB will be compromised with a detrimental impact on the objectives of PSB at an UK level.

COMPETITION

While SISG believes that the terms of Scottish and Grampian Television licences with respect to its PSB obligations are matters for SMG to pursue, we would not wish to see a scenario in which the BBC was the only platform for PSB to the Scottish nation. Such an outcome would be to the detriment of consumers and would not deliver PSB objectives in Scotland and beyond. Ofcom must ensure that competition is maintained to ensure that the needs of the consumer/citizen are met effectively.

PUBLIC SERVICE PUBLISHER

SISG also recommends that, in the event that Ofcom and the Government decide to create a new public service publisher (PSP), then the PSP should be located in Scotland.

We are confident that a Scottish located PSP would strengthen public service provision not just in Scotland but across the whole of the UK. SISG itself, with its representation across broadcasters, independent producers and others, demonstrates the collaborative approach which will be necessary for a successful PSP. The range of industries covered by SISG, including television, feature film, animation, advertising and interactive leisure software/computer games, with an accompanying range of associated digital delivery platforms, including broadband and mobile telephony, is also indicative of the diversity and creativity which Scotland would bring to a PSP solution.

Most importantly, Scotland has the capability and the capacity to deliver a PSP of international calibre. Scotland has shown that it is an attractive location for creative talent across the screen industries and is more than capable of commissioning and delivering high quality, successful programming across the UK and internationally. Our capability will be further enhanced by significant infrastructure developments such as Pacific Quay in Glasgow and the Digital Media Park at Seabraes Yard, Dundee, which is gearing to house multi platform content development, production and distribution.

OBJECTIVES OF PSB

To preserve and promote the national aspect of the Scottish screen industries, it is essential that PSB regulation does not disadvantage the Scottish industry compared with the English regions. Scotland has a distinctive national identity. The preservation and promotion of this identity is a core objective of PSB.

GAELIC PROGRAMMES

SISG supports a developing role for Gaelic—with appropriate funding for a rich range of programmes—as part of PSB in Scotland. A robust solution is required, which takes account of the potential impact on language and culture of the developing multichannel environment. The goal should be to give the Gaelic community its own flexible creative space on its own digital channel while maximising the audience by continuing to broadcast Gaelic programmes on PSB analogue outlets during the transition period to digital switchover.

FUNDING

PSB funding models should ensure that Scotland receives a proportionate share of public funding, most notably the licence fee, but there is a need to determine the most appropriate method for identifying that "proportionate share" eg population, viewing.

Annex 2

SISG—BACKGROUND

SISG is a cross-industry group which seeks to increase network and international presence and growth in production across all areas of the screen industries in Scotland. In keeping with this outward looking orientation, SISG is particularly keen to see an expansion of Scotland's share of television production across the UK networks and is lobbying for the following targets, amongst others:

— Scotland's share of television network production should increase; SISG supports an increase in the share of network production from the three nations of Scotland, Wales and Northern Ireland to 17%, broadly in line with population;

— Scotland's network commissioning power should be increased significantly; and

— significant strengthening of the presence of Channels 4 and 5 in Scotland should take place.

The composition of SISG, which encompasses the broadcasters, the independent production sector and other public organisations and private companies, means that it represents the screen industries at the very highest level in Scotland. Current members are:

— BBC Scotland.

— BT Scotland.

— Channel 4.

— Dave Wightman, Edgies.

— Gaelic Media Service.

— Glasgow Film Office.

— Highlands & Islands Enterprise.

— Bob Last, Holdings Ecosse.

— Alan Clements, IWC Media.

— Allan MacDonald, MnE Television.

— Pact.

— Scottish Enterprise.