Memorandum from 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. Education - to ensure that people of all ages and backgrounds are inspired and equipped to analyse, appreciate, explore, create and share screen media;

2. Enterprise and Skills - to ensure that there are appropriate levels of skilled individuals and viable companies to sustain all aspects of the screen industries across Scotland;

3. Inward Investment - to promote Scotland as a dynamic, competitive and successful screen production hub;

4. Market Development - to ensure that the widest range of screen product reaches and is appreciated by a diversity of audiences;

5. Talent and Creativity - to 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 (i.e. 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 viewed - at least in part - as 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[1], 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)[2], 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[3] 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, but - assuming it proceeds - this 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 news - which has dented the circulation of national as well as local newspapers - but 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 employment - typically regarded as a lagging indicator of economic health - is reflected in a 10% decline in the regional press workforce in the past six months.[4]

 

The press in Scotland is of course subject to these same changes - structural and cyclical - which 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[5], 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." [6]

 

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[7]:

 

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%).[8]

 

Although these declining circulation figures may be viewed - at least in part - as 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 UK - the policing of the G20 protests in London and the Downing Street adviser Damian McBride's emails - which 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[9].

 

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[10], 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 newspapers - The Times, the Daily Mail, the Sun and so forth - are 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 national - i.e. UK-wide - press. 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."[11]

 

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."[12]

 

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."[13]

 

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 Nations - certainly for Scotland - are qualitative rather than quantitative. Many of the important issues which affect people's lives - health, education, justice - are 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)[14], 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 ten 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."[15]

 

Former BBC Director General Lord Birt makes it clear in his autobiography that he regarded the 'Scottish Six' as an extremely important - and dangerous - issue:

 

"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"[16]

 

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[17] 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[18]:

 

"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 impartial - or 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, but - assuming it proceeds - this 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 Scottish - not just UK - plurality 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 Scotland - at 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."[19]

 

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



[1] 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

[2] Scottish Broadcasting Commission, 2008, Platform for Success at http://www.scottishbroadcastingcommission.gov.uk/Resource/Doc/4/0000481.pdf

[3] For example, the inadequacy of the clumsy opt-out on the BBC from Newsnight to Newsnight Scotland.

[4] Financial Times, Lifeblood drains from local press, 30 March 2009, at FT.com / UK - Lifeblood drains from local press .

[5] This evidence was as yet uncorrected at the time of writing.

[6] 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 http://www.publications.parliament.uk/pa/cm200809/cmselect/cmscotaf/uc401-i/uc40102.htm.

[7] Figures taken from allmediaSCOTLAND.com, Double-Digit Sales Drops for Sunday Herald and SoS, at http://www.allmediascotland.com/articles/3891/15042009/double-digit_sales_drops_for_sunday_herald_and_sos.

[8] 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 per cent); 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%).

[9] 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.

[10] 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

[11] BBC Trust, The BBC Trust Impartiality Report: BBC NETWORK NEWS AND CURRENT AFFAIRS COVERAGE OF THE FOUR UK NATIONS, June 2008, p.25, at http://www.bbc.co.uk/bbctrust/assets/files/pdf/review_report_research/impartiality/uk_nations_impartiality.pdf.

[12] 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.

[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

[14] Scottish Broadcasting Commission, 2008, Platform for Success at http://www.scottishbroadcastingcommission.gov.uk/Resource/Doc/4/0000481.pdf

[15] Scottish Broadcasting Commission, 2008, Platform for Success , p.26,par. 3.39,at http://www.scottishbroadcastingcommission.gov.uk/Resource/Doc/4/0000481.pdf

[16] Birt, John, The Harder Path: The Autobiography, Time Warner, 2002, pp. 483-487.

[17] For example, the inadequacy of the clumsy opt-out on the BBC from Newsnight to Newsnight Scotland.

[18] 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.

[19] Scottish Screen Comments on the Digital Britain Interim Report, p. 7, on the Digital Britain website at http://www.culture.gov.uk/images/publications/ScottishScreen_DBIRResponse.pdf.