Memorandum from the Scottish Newspaper Publishers Association

 

1. Background

This paper has been prepared in response to an invitation by the Select Committee for views on the future for local and regional media, ahead of its new inquiry.

 

It is submitted on behalf of the local newspaper publishing industry in Scotland, represented by the Scottish Newspaper Publishers Association (SNPA).

 

2. SNPA - the organisation

The Scottish Newspaper Publishers Association (SNPA) represents Scotland's local press. SNPA has 13 member organisations, between them publishing more than 90 paid-for weekly newspapers and around 30 free papers.

 

SNPA's current role extends principally to:

 

- promote, further and safeguard the interests of its members;

- maintain press freedom;

- advise members on advertising matters;

- advise members on current codes of advertising practice.

 

3. Critical issues facing Scotland's weekly press

The Scottish local newspaper publishing industry is facing the worst media crisis in living memory. Compounding threats include:

 

- the economic down-turn and drastically reduced advertising revenues.

- declining circulation revenues.

- migration of advertising revenues to the internet.

- government encouragement and sponsorship of websites geared to divert public sector recruitment advertising away from the local press to a public sector sponsored website. Scotland's publishers believe that the COSLA portal will fail to live up to expectations; it will close off from application tens of thousands of potential candidates, prove economically wasteful, as well as undermining the private sector medium which already delivers the acknowledged route to recruitment. Moreover, it is suggested that far from attracting candidates from the private sector, the portal will lead to greater churn and consequential salary creep within the public sector.

- the diversion of licensing advertising away from the local press to local authority websites.

- public sector initiatives to pass off in-house newsletters and/or other communications as editorially independent publishing ventures. Some of these are part-funded through advertising sales, encroaching into market space occupied by the commercial publishing sector.

- the threat that statutory obligations relating to the requirement for local government to publish Public Notices might be met in future by a centralised Public Information Notices website. Scotland's publishers believe that public information advertising is crucial to local democracy and is a fundamental duty owed by local government to the communities being served. Moreover, they believe that the local press already represents the best means to live up to such a duty - in terms of both reach (effectiveness) and value-for-money.

- undermining of the industry's core business through the encroachment by the BBC or any other broadcaster through public subsidy, into the provision of local news (diverting audience and, therefore, advertising revenue away from local newspapers).

 

The impact of these combined threats will inevitably encompass:

 

- titles being closed

- job losses : editorial, advertising, production and management

- a democratic deficit arising from the disenfranchisement of local communities.

 

4. Scotland's local press - key features

Scotland's local press is trusted, inclusive and effective:

4.1 Trust and credibility

Local newspapers are at the heart of the communities they serve; local people turn to their paper for information they can trust. UK-wide research bears out the claim that the regional press is the most trusted media channel.

 

Research (TNS) revealed that advertising in local newspapers and their websites is nearly 50% more trusted and reliable than the nearest everyday medium (58% of sample compared with commercial television's 39%, national newspapers' 35%, commercial radio's 31%, and other websites' 30%).

 

The same research confirmed that advertising in local newspaper websites is nearly twice as trustworthy and reliable as national websites (63% of sample for local newspapers and 53% of sample for local newspaper websites compared with other websites' 30%).

 

4.2 Inclusivity

Local newspapers serve the communities in which they're based, regardless of internet take-up or local broadband availability. In Argyll & Bute, for instance, NRS data show that during the year to 30 September 2008, just 36.7% of the population had accessed the internet, while JICREG data for October 2008 show that 91.8% had read a Scottish title.

 

Across Scotland, the overall internet access penetration for the same period was 55.8% (UK - 68.7%) and the local newspaper readership penetration was 85.6%.

 

For a government wishing to communicate with all socio-economic groups, local newspapers deliver the most inclusivity.

 

4.3 Effectiveness

People live their lives locally. Independent research in 2005 (GFKNOP) revealed:

 

- 82% of people spend half or more of their time within 5 miles of home.

- This rises to 89% for a distance of less than 10 miles.

 

And local newspapers play a central role in helping them to feel part of their community. Independent research in 2008 suggests that, in Scotland, local media (local newspapers and their websites) have an important role to help people get to know others in their area:

 

- 32% chose the local newspaper or local newspaper website as their preferred media choice to acquire such information.

- Only 1% chose a national newspaper.

 

Local newspapers are well read, relied on for news not available elsewhere and help readers make the best of their local area (GFKNOP 2005):

 

- 90% read half or more of their local paper.

- 58% rely on their local paper for news they can't see elsewhere.

- 52% say their paper helps them make the best of their own area.

 

Because people live their lives locally, it's no surprise that some 71% (GFKNOP) of those looking for a job want to stay in their own area. Which helps to explain why:

 

- 51% turn first to their local paper to find out about job vacancies.

 

4.4 Debate, democracy and public information

The local press is the only mass medium which informs and stimulates debate about issues affecting people and organisations in the locality. Scotland's weekly newspapers, therefore, are crucial to the democratic process.

 

Because the local press is trusted and reaches the overwhelming majority of the community, it represents a vital platform from which to disseminate public information messages and campaigns.

 

4.5 Economic prosperity

In addition to its collective contribution to the economic health of the nation, Scotland's weekly press serves as an effective catalyst in promoting entrepreneurship and trade in general, at the local level. It shines a spotlight on those organisations which are succeeding as well as warning of those which are failing. Its pre-eminence as a recruitment advertising medium, for instance, also bears witness to this claim.

 

4.6 Investment and innovation

Investment by publishers into digital media development has yielded real dividends for all. These initiatives benefit from the trust and credibility inherent in the printed versions. Publishers are investing to develop the complimentary features of online and offline news ventures.

 

4.7 Press standards and self-regulation

Scotland's local press acknowledges a duty of care to safeguard the trust in which local papers are held and contributes to the costs of self-regulation. Many publishers, for example, have provided access to the Press Complaints Commission (PCC) via their own websites as well as carrying directional advertising for the PCC in the printed titles. The Scottish local press also helps to fund the Advertising Standards Authority (ASA), and the Committee of Advertising Practice which publishes the CAP Codes.

 

5. Industry views on the Committee's identified issues

In its announcement relating to the inquiry, 11 issues were identified, for which views were sought by the Committee:

 

5.1 The impact on local media of recent and future development in digital convergence, media technology and changing consumer behaviour.

The ways in which consumers access news content have been evolving for decades. The long-run decline in circulations of national daily, regional and weekly newspaper titles is evidence of such change. The process has its roots in the advent of commercial television and, later, community radio. These initiatives helped to deliver content directly into people's homes. More recently, over the past 10 years, the internet has ensured that the pace of change accelerated greatly, with investment in broadband penetration across the UK significantly reducing download times, thereby improving the customer's experience.

 

At the core of the newspaper business has always been the commercial imperative to offer advertisers access to audience. Given the plethora of emerging new media opportunities, it is unsurprising that newspapers' audience share has been placed under threat of dilution. While these new media channels have been developing, newspaper publishers have been investing in, and adapting their own products in order to retain their audience by harnessing the benefits which online content delivery can offer.

 

The shift in delivery mechanism from offline to digital has seismic implications for media owners, journalists, advertisers and, ultimately, readers. Websites and RSS feeds abound and offer free content, yet much of this is sourced from offline publications or is aggregated from other online resources. What's more, user-generated and blog content has exploded from their genesis in the readers' letters pages of newspapers. The true costs of formal newsgathering and content creation, therefore, remain largely borne in the traditional way by existing players.

 

One significant way in which newspaper publishers have been rising to the challenge to the prevailing business model has been the training of journalists to work across offline and online platforms. Delivery of high quality content by trained journalists, irrespective of delivery channel, must be paid for, yet there are very few examples around the world of newspaper websites being able to operate on a commercial basis. The industry is in transition, as new solutions are being explored. The current economic crisis, with falling advertising budgets, is exacerbating the problem for publishers.

 

In summary, advertising and circulation revenues pay for newsgathering and content delivery. Digital convergence, the development of media technology, changing consumer behaviour and the economic downturn are compounding to place those revenues - and, therefore, local media such as Scotland's weekly newspapers - under unparalleled threat.

5.2 The impact of newspaper closures on independent local journalism and access to local information.

Scotland is home to around 120 local newspapers; around 90 paid-for weekly and bi-weekly and 30 free distribution titles. These papers serve local communities the length and breadth of the nation, enjoying extremely high penetration across the socio-economic spectrum.

 

It does not necessarily follow that a modest reduction in the number of titles will deleteriously affect local journalism and access to local information. Efficiencies introduced through consolidation of some titles, for instance, can enable newsgathering as well as journalistic standards to be maintained.

 

The market space occupied by local papers, on the other hand, is reliant on those papers' relevance to the communities served. If publishers are forced to close significant numbers of titles, local journalism will suffer and access to local information will be reduced, leading to a genuine reduction in democratic accountability.

 

5.3 How to fund quality local journalism.

Local weekly newspapers represent the training grounds for many UK journalists. Local papers, in their turn, are funded by circulation and advertising revenues, principally the latter. The business model for local newspaper publishing is entirely transparent and it is self-evident that anything which damages a publisher's ability to sell papers or space within its titles or which pushes up its cost base, will limit the availability of funding for journalism.

 

If follows that the industry is urging Government at all levels not to encourage or foster initiatives which seek to migrate advertising revenues away from their titles. Such migration cuts at the heart of publishers' ability to deliver trusted content to local communities.

 

5.4 The appropriateness and effectiveness of print and electronic publishing initiatives undertaken directly by public sector bodies at the local level.

The Scottish weekly newspaper industry applauds efforts by local authorities and other local public sector bodies to communicate with their stakeholders. Moreover, the industry is confident that it can deliver unbeatable local household penetration and excellent value-for-money to assist those organisations in reaching those target audiences.

 

It is not appropriate, however, for local authorities to apply public funds to pass themselves off as independent publishers nor to encroach into market space occupied by the commercial publishing sector by selling space in their own offline or online publications.

 

Local people expect their local papers to hold public sector bodies such as councils to account. Information received by the public through a council-owned publication, therefore, will not be perceived as credible as information read in the local newspaper. It follows that public sector publishing initiatives will pass neither the test of appropriateness or effectiveness.

 

5.5 The role and effects of search engines and online content aggregators on local media.

Local newspapers cover local stories by deploying trained journalists at the community level. No other medium employs anywhere near the number of journalists to gather local news and write local content.

 

Search engines and websites which aggregate news content poach the material gathered by newspaper journalists whose activity, in turn, is funded by publishers. While intellectual property rights might not being breached, it is clear that such activity threatens to undermine newspapers' fundamental proposition.

 

In tackling this issue, publishers are committed to continuing to invest in their own online initiatives.

 

5.6 The future of local radio and television news.

Primary newsgathering is expensive and, as argued elsewhere in this submission, is paid for in terms of local newspaper publishing through advertising and circulation revenues.

 

For local radio and television news, the position is similar. The severe difficulties confronting STV, for example, are testament to the experience shared in common with publishers of news organisations having to come to terms with increasing costs and the rapidly expanding digital provision.

 

That said, Scotland's newspaper publishers would be strongly averse to any initiatives which threatened to distort the market. Specifically, publishers would oppose any further escalation of the BBC's local news ambitions, funded through the public purse. Similarly, publishers would oppose any publicly funded cash injection to support STV/Channel 3 local news output. SNPA members are particularly concerned that, in a converging market, Ofcom may back efforts to apply public funds to support STV, permitting it to gain unfair competitive advantage in the digital space.

 

5.7 The desirability of changes to the regulatory framework for print and electronic local media, including cross-media ownership and merger regulations.

Until regulations on cross-media ownership and newspaper mergers are relaxed, media owners are denied the opportunity to identify and reap the rewards of efficiency savings engineered through appropriate consolidation. Given that such opportunities are open to other industries, Scotland's publishers are hopeful that the current review will conclude that the existing regulations are unjust as well as hugely unhelpful in these exceptionally difficult times.

 

5.8 The opportunities and implications of BBC partnerships with local media.

Partnership implies mutual benefit. The publishers of Scotland's local newspapers, which operate at the community level, would be pleased to explore the opportunity to work with the BBC to develop such mutually beneficial partnerships.

 

There are significant challenges which would require to be overcome. In objecting to proposals developed for the BBC Local initiative last year, for instance, SNPA warned against any licence fee-funded move by the broadcaster to rob local papers of their audience.

 

5.9 The extent of plurality required in local media markets.

With digital media, user-generated content, blogs, RSS feeds and news-based websites, plurality would seem to be safe and certain. Yet, as argued elsewhere in this submission, so much of this online content has been assembled from offline sources or aggregated from other (newspapers and others') websites.

 

It is, therefore, vital that local newspapers remain a key news component within the communities they serve. This is the only medium which trains and employs journalists to cover stories at the local level. Any damage inflicted on the local newspaper publishing business would seriously undermine local media plurality, thereby jeopardising local democratic accountability.

 

5.10 Incentives for investment in local content.

Scotland's publishers employ thousands of journalists at the local level to gather news and write content for around 120 newspapers and associated websites. They do this without any public sector financial intervention.

 

Any intervention, made on behalf of another media sector such as a public service broadcaster or a public sector body such as a council would cause publishers serious concern, as it would be viewed as a deliberate move to create an unlevel playing field.

 

Conversely, publishers regard the public sector-sponsored migration of recruitment advertising away from their titles as a disincentive for investment in local content.

 

5.11 Opportunities for "ultra-local" media services.

The authors of the BBC Local proposals defined the parameters for its "ultra-local" approach to Scotland in terms of six regional websites. The local newspaper business in Scotland, on the other hand, publishes some 120 local titles.

 

The journalists employed by these papers cover local council and committee meetings, the courts, schools, businesses, housing and a myriad of truly "ultra-local" stories.

 

The stories are researched, written, published (offline and online) and read within the communities being served. The medium delivers excellent value to the advertisers who ultimately fund the majority of the costs associated with newsgathering. The industry believes that any new entrant to newsgathering at such a local level should compete on equal terms with existing providers and should not expect to receive any financial or other subsidy.

 

6. What is being asked of Government

The Scottish local newspaper industry is not seeking direct financial assistance from the Government.

 

It is convinced, however, that irreversible damage will be the consequence of allowing or, worse, facilitating revenues to be diverted away from what should be acknowledged as a valuable component of the Scottish economy and democratic process.

 

Publishers would ask members of the Select Committee:

 

- to acknowledge the many contributions made to Scottish life by its local newspaper publishers.

- to recognise the severity of the challenges facing Scotland's publishing industry.

- to do what it can to discourage the UK or Scottish Governments from legislating to allow local authorities to divert public information notice advertising away from local newspapers.

- to help safeguard the level playing field for media in Scotland, opposing any steps to provide subsidy to broadcasters for the provision of local news.

- to condemn public sector publishing initiatives which seek to pass themselves off as independent and/or encroach into the commercial sector.

 

May 2009