Written evidence submitted by Scottish
Screen
EXECUTIVE SUMMARY
Scottish Screen is the national government-backed
agency responsible for developing all aspects of screen industry
and culture across Scotland, focusing on the following five priority
objectives:
1. Educationto ensure that
people of all ages and backgrounds are inspired and equipped to
analyse, appreciate, explore, create and share screen media;
2. Enterprise and Skillsto
ensure that there are appropriate levels of skilled individuals
and viable companies to sustain all aspects of the screen industries
across Scotland;
3. Inward Investmentto promote
Scotland as a dynamic, competitive and successful screen production
hub;
4. Market Developmentto ensure
that the widest range of screen product reaches and is appreciated
by a diversity of audiences;
5. Talent and Creativityto
identify nurture, develop, support and progress Scotland's screen
talent and screen production companies.
Scottish Screen welcomes this opportunity to
respond to the House of Commons Culture, Media and Sport Select
Committee Inquiry into the Future for Local and Regional Media.
Understandably, in view of our remit, we have a particular interest
in Scottish local and regional media.
From a Scottish perspective, it is also important
to note that there are four main geographical categories to consider
in terms of target audiences and readership: UK-wide, national
(ie Scotland-wide, such as The Herald and The Scotsman
newspapers), regional (such as The Press and Journal
and The Courier newspapers) and local-sub-regional. In
a post-devolutionary UK, where so many of the important issues
affecting people's lives are devolved matters, Scotland's national
media has an important democratic role which is distinct from
the role played by the UK's (including Scotland's) regional media.
We trust that an assessment of the future of Scotland's national
media lies within the scope of the Committee's inquiry.
The main points we wish to raise are that:
Although the declining circulation figures
of the Scottish press may be viewedat least in partas
evidence of the damaging effects of changes in technology and
consumer behaviour, it would be a very unbalanced view which fails
to recognise the potential to enhance both consumer choice and
informed citizenship offered by the very same changes. The changing
media landscape also offers an unprecedented opportunity for a
radical democratisation of the media, for instance through the
advent of User Generated Content (UGC). It will be vital to ensure
that all citizens have equal access to this new technology in
order to maintain and nourish a thriving and participative democracy.
Scottish Screen has welcomed the support for an updated Universal
Service Commitment which has been outlined in the UK Government's
Digital Britain interim report,[2]
but is concerned that it has set the aspirational bar too low
for such an important part of the UK's competitive infrastructure,
specifically in relation to its proposed standard-minimum speed.
Scottish Screen supports the recommendations
of the Scottish Broadcasting Commission (SBC),[3]
including its proposal for a new Scottish digital network, as
a means of addressing the inadequacies of current television network
news coverage in Scotland. News and current affairs coverage in
Scotland remains unsatisfactory[4]
and the "Scottish Six" issue, while only part of the
problem, has yet to be resolved.
While Scottish Screen has absolutely
no objection to public investment or other support for quality
local journalism, this should not be confused with support for
local press as an alternative to or variant of support for Out
of London (OOL) PSB.
Within Scotland, the current Borders
situation is clearly unsatisfactory. We wish the local TV initiative
in the Borders every success, butassuming it proceedsthis
needs to be seen as complementary to, rather than a substitute
for an alternative PSB to BBC Scotland for viewers in the Scottish
part of the current ITV Border region.
We would stress the need to assess the
impact of cross-media ownership and mergers on the public interest
at the Scottish as well as the UK level.
Scottish Screen is keen to see a significant
expansion of the BBC's role as a catalyst within the broader creative
industries in Scotland, including local media,
Given the weakness of its indigenous
press and the commercial pressures upon stv, Scotland faces the
real threat of an extremely dangerous loss of essential plurality
of supply across both broadcast and printed media. This is one
of the main reasons why we support the SBC's recommendation for
a new digital network.
Scottish Screen believes there is a strong
case for additional support for local media content, not just
news.
Scottish Screen recognises the potential
for "ultra-local" media opportunities and supports their
assessment as part of the so-called "Scottish 7th MUX",
but would also sound a note of caution regarding the viability
of funding models and quality of content.
1. THE IMPACT
ON LOCAL
MEDIA OF
RECENT AND
FUTURE DEVELOPMENTS
IN DIGITAL
CONVERGENCE, MEDIA
TECHNOLOGY AND
CHANGING CONSUMER
BEHAVIOUR
The most significant current drivers of change
in local media are the accelerating pace of digitisation and the
convergence of media delivery platforms, accompanied by the rapidly
growing user acceptance of the internet. Large sections of the
population now regard the internet as the preferred source not
only for newswhich has dented the circulation of national
as well as local newspapersbut also for consumer information,
for example when purchasing a house or car or finding a job. This
latter trend has proved particularly damaging to the regional
press, which has traditionally relied on classified advertising
revenues.
The situation is undoubtedly also affected by
the (hopefully) cyclical effects of the current deep recession,
exacerbated by the fact that property, cars and jobs are particularly
exposed to this economic downturn. Thus it is reported that UK-wide
advertising revenues fell 37% in the first quarter of 2009, while
the impact on employmenttypically regarded as a lagging
indicator of economic healthis reflected in a 10% decline
in the regional press workforce in the past six months.[5]
The press in Scotland is of course subject to
these same changesstructural and cyclicalwhich are
affecting the UK titles.
However, there are also a number of additional,
distinctive factors which need to be addressed in considering
the position in Scotland. In a post-devolutionary UK, where so
many of the important issues affecting people's lives are devolved
matters, Scotland's national media has an important democratic
role which is distinct from the role played by the UK's (including
Scotland's) regional media. But the historical strength of the
indigenous Scottish press, and its ability to fulfil this role,
is under severe threat. We note, for example, the evidence to
the Commons Scottish Affairs Select Committee given by Paul Holleran,
Scottish Organiser for the National Union of Journalists,[6]
who states that the Scottish-based newspapers are at relative
disadvantage in comparison with the Scottish editions of English-based
titles:
"One of the discussions I have with the
managing directors in Scotland is that they believe that the English-based
titles that have Scottish editions are in a stronger position.
With The Express, for example, they would have substantially
fewer journalists than the Scottish office. The Sunday Times
would be the same or The Times would be the same. The Daily
Mail would have much more staff. They have an English base
of a newspaper with Scottish pages, so there is a competition
element. The cut-price sale of the Daily Star and The
Sun has obviously added to some of the difficulties. There
is a problem across the whole industry, there is no doubt about
that, but at the moment the Scottish titles seem to be trying
to use the same template to find a solution." [7]
Mr Holleran also indicates that the declining
circulation figures have not been helped by a number of editorial
appointments where editors originating from "south of the
Watford gap" were given responsibility for national newspapers
in Scotland "without knowing their new patch."
While the relative weighting of the contributory
factors may be open to debate, the March 2009 Audit Bureau
of Circulations (ABC) figures certainly confirm the significant
decline in year on year circulation for Scotland's nationally-audited
papers:[8]
Daily Record (owned by Trinity
Mirror)329,067 (down 9.87%);
The Herald (Newsquest)59,329 (down
10.5%);
The Scotsman (Johnston Press)48,011 (down
7.4%);
Sunday Mail (Trinity Mirror)408,753 (down
9.31%);
Sunday Post (DC Thomson)248,062 (down
8.9%);
Scotland on Sunday (Johnston Press)60,031 (down
11.3%); and
Sunday Herald (Newsquest)40,870 (down
17.5%).[9]
Although these declining circulation figures
may be viewedat least in partas evidence of the
damaging effects of changes in technology and consumer behaviour,
it would be a very unbalanced view which fails to recognise the
potential to enhance both consumer choice and informed citizenship
offered by the very same changes. For example, the reality of
convergence of media delivery platforms is illustrated by the
growing interest of regional press groups in the potential opportunities
for local television which digital switchover (DSO) will bring.
Guardian Media Group (via Channel M in Manchester) is already
an active broadcaster, while other press organisations are taking
a very keen interest in Ofcom's recent proposals for independently
funded news consortia (IFNC) as a possible element in the new
Public Service Broadcasting (PSB) ecology.
The changing media landscape also offers an
unprecedented opportunity for a radical democratisation of the
media, for instance through the advent of User Generated Content
(UGC). The power of UGC was seen in two of the recent leading
news stories in the UKthe policing of the G20 protests
in London and the Downing Street adviser Damian McBride's emailswhich
were broken through amateur video footage and a non-mainstream
political blogger. It will be vital to ensure that all citizens
have equal access to this new technology in order to maintain
and nourish a thriving and participative democracy. This is why
Scottish Screen has consistently supported the principle of establishing
high speed broadband as a truly Universal Service Obligation.[10]
We believe that the starting point for any policy
framework needs to be that access to super-fast broadband will
be an essential utility for every UK citizen, just as we ensure
access to high quality water supplies to all UK homes or medical
treatment which is freely available to all citizens at the point
of delivery. Super-fast broadband can and should become an essential
tool for all citizens to participate fully in the democratic process
and in social and cultural life, as well as engaging in economic
activity as informed and empowered consumers. As Scotland's national
screen agency, we also wish to ensure that the Scotland's screen
industries are not competitively disadvantaged in the increasingly
competitive UK and international markets in which they operate.
Scottish Screen has welcomed the support for
an updated Universal Service Commitment which has been outlined
in the UK Government's Digital Britain interim report,[11]
but is concerned that it has set the aspirational bar too low
for such an important part of the UK's competitive infrastructure,
specifically in relation to its proposed standard-minimum speed.
2. THE IMPACT
OF NEWSPAPER
CLOSURES ON
INDEPENDENT LOCAL
JOURNALISM AND
ACCESS TO
LOCAL INFORMATION
The declining circulation figures (see above)
emphasise the struggle for survival of much of Scotland's indigenous
press. This is especially concerning against the background of
a decade of Scottish devolution and the woefully inadequate coverage
of Scottish news in the allegedly "UK wide" press. The
comments on this subject by Professor Anthony King of the University
of Essex (from his report for the BBC Trust on BBC network news
and current affairs coverage of the four UK nations) are pertinent:
"The major London-based newspapersThe
Times, the Daily Mail, the Sun and so forthare
still customarily referred to as constituting the UK's "national"
press. But it is at least open to argument that the UK no longer
possesses a truly nationalie UK-widepress. Few London-based
newspapers now have full-time correspondents based in Northern
Ireland and fewer, if any, have full-time correspondents in Wales.
The London-based daily papers do have full-time staffs in Scotland,
but the members of those staffs are, in most cases, principally
concerned with producing the Scottish edition of the paper they
work for; they find it increasingly difficult to place stories
about Scotland in the south-of-the-border editions of their own
paper. The effect is that news of Wales, Northern Ireland and
Scotland has become increasingly ghettoised in the print media.
It is largely confined to newspapers published in those nations
(the Glasgow-based Herald, the South Wales Echo,
the Belfast Telegraph and so forth) and to the editions
of the London-based newspapers that are distributed there. In
particular, Scottish newspapers and the Scottish editions of London-based
papers continue to report news of events and developments taking
place in England, but it is becoming harder and harder for newspaper
readers outside Scotland, including in England, to follow what
is going on elsewhere in the UK."[12]
These deficiencies are not confined to print
media, however. Research conducted by a team from Cardiff University
for the King Report also highlighted the full scale of the inadequacy
of coverage of the devolved Nations on the BBC's supposedly UK
wide television network news bulletins:
"During the four weeks that were monitored
during October and November, the Cardiff team identified 136 stories
on the BBC network that dealt with education and health: that
is, with arguably the two most important policy fields that are
largely devolved to Scotland, Wales and Northern Ireland. Of the
136 stories, all 136 dealt with England alone. None
dealt with education or health in one of the devolved nations."[13]
Nor was the BBC unique among broadcasters; in
fact:
"Although the BBC network's performance
in reporting the whole UK was less than wholly satisfactory, the
BBC's performance was nevertheless consistently superior to that
of other broadcast outlets when relevant comparisons were made.
In other words, the BBC needs to be judged by its own high standards,
not by comparison with other broadcasters."[14]
To their credit, the BBC Trust have stressed
their commitment to address these glaring inadequacies. However,
it is important to recognise that the key differences between
the English regions and the Nationscertainly for Scotlandare
qualitative rather than quantitative. Many of the important issues
which affect people's liveshealth, education, justiceare
devolved matters which, despite welcome improvements, will never
be adequately covered on the UK-wide news. The vast population
imbalance between England and the other component nations of the
UK means that this would be an unrealistic expectation.
Scottish Screen supports the recommendations
of the Scottish Broadcasting Commission (SBC),[15]
including its proposal for a new Scottish digital network, as
a means of addressing this particular democratic deficit, as well
as the vital economic and cultural benefits the new network would
bring.
The SBC's work has moved the debate about the
future of PSB in Scotland on to a much broader discussion than
the much debated "Scottish Six" issue:
"For more than 10 years now there has been
a significant level of debate about the advantages and disadvantages
of providing audiences in Scotland with integrated television
news programmes blending international, UK and Scottish news.
Because of a particular BBC proposal much debated inside and outside
the corporation, this is often referred to for convenience as
the "Scottish Six" debate. Although that proposal was
discussed only in relation to the news hour between 6pm and 7pm
on BBC1, it has become the shorthand description for the general
principle of combined or integrated television news programmes
aimed at audiences in Scotland."[16]
Former BBC Director General Lord Birt makes
it clear in his autobiography that he regarded the "Scottish
Six" as an extremely importantand dangerousissue:
"I wrote to, and then went to see, the
new Prime Minister Tony Blair. I expounded not just from the BBC's
perspective but from the nation's
..Opting out of the Six
would be a powerful symbol of Scotland moving away from UK-wide
institutions
.The end of a single, common experience of UK
news would, moreover, encourage separatist tendencies
Blair
was quick, as ever, to grasp the case. "Let's fight,"
he said.
This painful episode had an ultimately
benign outcome. In 1999, when devolution finally became a reality
in Scotland and Wales, no organisation was better prepared to
serve both the nations and the UK as a whole than the BBC. Meanwhile,
the British Broadcasting Corporation lived to fight another
day"[17]
Scottish Screen welcomes the expansion of the
Scottish PSB debate. However, our view is that Lord Birt's optimism
over the BBC's capacity to serve both the nations and the UK as
a whole was unfounded. News and current affairs coverage in Scotland
remains unsatisfactory[18]
and the "Scottish Six" issue has yet to be resolved.
3. HOW TO
FUND QUALITY
LOCAL JOURNALISM
There are several parallels between the broadcast
and print media in Scotland, for example:
digitisation and technological convergence
are undermining historical funding models;
London-centricity is prevalent and the
regional players are struggling to survive; and
genuinely local and regional content
is in danger of being squeezed out by non-indigenous content.
However, it would be wrong to jump to the conclusion
that local press and the internet are viable substitutes for broadcast
news. Technological convergence should not lead to the incorrect
conclusion that these are substitutable products serving the same
market. Moreover, as we stated in our response to Ofcom's Second
Public Service Broadcasting (PSB) Review, concerning the way that
other (non-PSB) digital channels and interactive media contribute
towards the public purposes:[19]
"We agree with Ofcom that the contribution
of non-PSB channels to public purposes remains very limited, particularly
with respect to UK origination and genre diversity.
The growth of the internet and interactive media
in providing content which delivers public purposes is a significant
development, but is primarily complementary to PSB television
and unlikely to provide a feasible substitute for PSB in the foreseeable
future."
One of the key differences between press and
broadcast news is that the press is not impartialor at
the very least it is not regulated to ensure impartiality, unlike
PSB broadcast news. The impartiality of news broadcast on the
PSB channels is widely acknowledged, in contrast to press news,
including Scotland's national press. This is not to deny the institutional
London-centricity of the PSBs, including the BBC, but this needs
to be distinguished from partiality of editorial content.
So while Scottish Screen has absolutely no objection
to public investment or other support for quality local journalism,
this should not be confused with support for local press as an
alternative to or variant of support for Out of London (OOL) PSB.
4. THE APPROPRIATENESS
AND EFFECTIVENESS
OF PRINT
AND ELECTRONIC
PUBLISHING INITIATIVES
UNDERTAKEN DIRECTLY
BY PUBLIC
SECTOR BODIES
AT THE
LOCAL LEVEL
No comment.
5. THE ROLE
AND EFFECTS
OF SEARCH
ENGINES AND
ONLINE CONTENT
AGGREGATORS ON
LOCAL MEDIA
No comment.
6. THE FUTURE
OF LOCAL
RADIO AND
TELEVISION NEWS
Note our comments in sections 2 and 3 above
regarding television news.
We would also add that in Scotland the current
Borders situation is clearly unsatisfactory. We wish the local
TV initiative in the Borders every success, butassuming
it proceedsthis needs to be seen as complementary to, rather
than a substitute for an alternative PSB to BBC Scotland for viewers
in the Scottish part of the current ITV Border region.
7. THE DESIRABILITY
OF CHANGES
TO THE
REGULATORY FRAMEWORK
FOR PRINT
AND ELECTRONIC
LOCAL MEDIA,
INCLUDING CROSS-MEDIA
OWNERSHIP AND
MERGER REGULATIONS
We would stress the need to assess the impact
of cross-media ownership and mergers on the public interest at
the Scottish as well as the UK level.
8. THE OPPORTUNITIES
AND IMPLICATIONS
OF BBC PARTNERSHIPS
WITH LOCAL
MEDIA
Scottish Screen is keen to see a significant
expansion of the BBC's role as a catalyst within the broader creative
industries in Scotland, including local media,
9. THE EXTENT
OF PLURALITY
REQUIRED IN
LOCAL MEDIA
MARKETS
As with our comments on cross-media ownership
and mergers (7 above), we would stress the importance of addressing
Scottishnot just UKplurality requirements. Given
the weakness of its indigenous press and the commercial pressures
upon stv, Scotland faces the real threat of an extremely dangerous
loss of essential plurality of supply across both broadcast and
printed media.
This is one of the main reasons why we support
the SBC's recommendation for a new digital network.
10. INCENTIVES
FOR INVESTMENT
IN LOCAL
CONTENT
News appears to be viewed by some, including
Ofcom, as the last remaining plank of PSB provision. But this
viewpoint is wrong and largely stems from the common, but misguided
view of PSB as a mechanism to address genre-based market failure.
It is this perspective which has resulted in the self-fulfilling
prophecy of inadequate resources leading in turn to a perception
of inferior quality and declining viewing figures for regional
programmes on ITV. (The same has also been true of stv in Scotlandat
least until the Scottish broadcaster's relatively recent change
of senior management and strategy.)
News provision is important, and is vital to
the effective functioning of our democracy, but broadcast news
is only one piece in the larger PSB jigsaw. It is no accident
that PSB is commonly described as an ecology. As we stated in
commenting upon the Digital Britain interim report:
"Television also lies at the heart of the
UK's successful creative industries, is by far the most pervasive
medium in people's lives and plays a huge role in our cultural,
civic and democratic lives. PSB, in particular, needs to be celebrated
as a successful, abiding and essential component of our democracy,
not as an obsolescing mechanism to address market failure in the
communications market."[20]
Scottish Screen believes there is a strong case
for additional support for local media content, not just news.
11. OPPORTUNITIES
FOR "ULTRA-LOCAL"
MEDIA SERVICES
Technological change now means that local television
has the potential to deliver real benefits, but it will also need
to overcome the long-standing concerns over the viability of funding
models and quality of content which have undermined most previous
attempts to establish local television services.
In a world of finite resources, it is also important
to recognise that local TV is unlikely to make a significant contribution
in the short term to the urgent matter of establishing a critical
mass of production activity in Scotland.
In short, Scottish Screen recognises the potential
for "ultra-local" media opportunities and supports their
assessment as part of the so-called "Scottish 7th MUX",
but would also sound a note of caution regarding the viability
of funding models and quality of content.
May 2009
http://www.scottishbroadcastingcommission.gov.uk/Resource/Doc/4/0000481.pdf
http://www.publications.parliament.uk/pa/cm200809/cmselect/cmscotaf/uc401-i/uc40102.htm.
http://www.allmediascotland.com/articles/3891/15042009/double-digit_sales_drops_for_sunday_herald_and_sos.
http://www.bbc.co.uk/bbctrust/assets/files/pdf/review_report_research/impartiality/uk_nations_impartiality.pdf.
http://www.bbc.co.uk/bbctrust/assets/files/pdf/review_report_research/impartiality/uk_nations_impartiality.pdf
http://www.scottishbroadcastingcommission.gov.uk/Resource/Doc/4/0000481.pdf
http://www.scottishbroadcastingcommission.gov.uk/Resource/Doc/4/0000481.pdf
http://www.culture.gov.uk/images/publications/ScottishScreen_DBIRResponse.pdf.
2 Department for Business, Enterprise & Regulatory
Reform and Department for Culture, Media & Sport, Digital
Britain-The Interim Report, January 2009, at http://www.culture.gov.uk/images/publications/digital_britain_interimreportjan09.pdf Back
3
Scottish Broadcasting Commission, 2008, Platform for Success at Back
4
For example, the inadequacy of the clumsy opt-out on the BBC from
Newsnight to Newsnight Scotland. Back
5
Financial Times, Lifeblood drains from local press, 30 March
2009, at FT.com/UK-Lifeblood drains from local press . Back
6
This evidence was as yet uncorrected at the time of writing. Back
7
House of Commons Scottish Affairs Committee, Crisis in the
Scottish press industry, 31 March 2009, Uncorrected Transcript
of Oral Evidence to be published as HC 401-I, at Back
8
Figures taken from allmediaSCOTLAND.com, Double-Digit Sales Drops
for Sunday Herald and SoS, at Back
9
For comparison, the English-based titles' sales in Scotland over
the same period were as follows: Daily Mirror-28,181 (down
14.1%); Daily Star-88,572 (up 3.3%); Sun-372,439 (down
6.4%); Daily Express-72,097 (down 5%); Daily Mail-117,833 (down
6.4 %); Daily Telegraph-23,159 (down 2.1%); Financial
Times-5004 (down 7.9%); The Guardian-15,627 (down
3.15%); The Independent-8905 (down 9.9%); The Times-27,009 (down
3.4%); Daily Star Sunday-28,172 (down 3.45%); News
of the World-268,321 (down 7.77%); Sunday Mirror-24,450 (down
18.4%); The People-18,088 (down 13.35%); Sunday
Express-41,434 (down 4.8%); Mail on Sunday-100,303 (down
10.1%); Independent on Sunday-7088 (down 27.3%); The
Observer-22,198 (down 3.9%); Sunday Telegraph-20,517 (down
0.6%); and Sunday Times-71,719 (up 6.4%). Back
10
For example, see Scottish Screen's Response to Ofcom's Consultation
on Delivering super-fast broadband in the UK: Setting the right
policy framework, December 2008, at http://www.ofcom.org.uk/consult/condocs/nga_future_broadband/responses/scottishscreen.pdf. Back
11
Department for Business, Enterprise & Regulatory Reform and
Department for Culture, Media & Sport, Digital Britain-The
Interim Report, January 2009, at http://www.culture.gov.uk/images/publications/digital_britain_interimreportjan09.pdf Back
12
BBC Trust, The BBC Trust Impartiality Report: BBC NETWORK NEWS
AND CURRENT AFFAIRS COVERAGE OF THE FOUR UK NATIONS, June 2008,
p.25, at Back
13
BBC Trust, The BBC Trust Impartiality Report: BBC NETWORK NEWS
AND CURRENT AFFAIRS COVERAGE OF THE FOUR UK NATIONS, June 2008,
p.30, at http://www.bbc.co.uk/bbctrust/assets/files/pdf/review_report_research/impartiality/uk_nations_impartiality.pdf. Back
14
BBC Trust, The BBC Trust Impartiality Report: BBC NETWORK NEWS
AND CURRENT AFFAIRS COVERAGE OF THE FOUR UK NATIONS, June 2008,
p 30, at Back
15
Scottish Broadcasting Commission, 2008, Platform for Success at Back
16
Scottish Broadcasting Commission, 2008, Platform for Success,
p 26, par 3.39,at Back
17
Birt, John, The Harder Path: The Autobiography, Time Warner,
2002, pp 483-487. Back
18
For example, the inadequacy of the clumsy opt-out on the BBC from
Newsnight to Newsnight Scotland. Back
19
Scottish Screen's Response to Ofcom's Second Public Service Broadcasting
Review-Phase One: The Digital Opportunity, p 4, June 2008,
on the Ofcom website at http://www.ofcom.org.uk/consult/condocs/psb2_1/responses/ss.pdf. Back
20
Scottish Screen Comments on the Digital Britain Interim Report,
p 7, on the Digital Britain website at Back
|