Chapter 2: scope |
14. In this chapter, we consider the major questions
which arose during the inquiry relating to the scope or target
of a plurality policy.
15. We address the following aspects of the scope
of a plurality policy:
lifecycle of news; and
SHOULD GENRES BEYOND NEWS AND CURRENT AFFAIRS BE
INCLUDED IN THE SCOPE OF A PLURALITY POLICY?
16. One of the questions we posed in our call
for evidence was, "Should [the scope of media plurality policy]
encompass news and current affairs or wider cultural diversity
in content provision as well?" Voice of the Listener and
Viewer made the case for a wider variety of content being included
in any plurality policy:
"The availability of a range of genres,
including drama, comedy and even, in some instances, light entertainment,
especially where these involve content produced within the national
culture, is important; these can be a powerful force in influencing
the agenda or debate. They can also engage a different audience
from that for news and current affairs programmes and should be
included in the scope of media plurality policy."
17. Lord Puttnam agreed that the scope of plurality
policy should be wider than only news and current affairs,
"By way of an obvious example, one of the
reasons we fund and support public-service broadcasters is to
secure plurality beyond simply news and current affairs. We rightly
concern ourselves at the possibility of a narrowing taste of the
the clear solution, surely, is to achieve a plurality
of offering, so that audiences have an optimal opportunity to
access the widest possible range of works."
18. Whilst not dismissing these views, others
have pointed out that reforming plurality policy is a difficult
task and that getting it right with regard to news and current
affairs is the priority. Accordingly, Suzanne Rab and Dr Alison
Sprague acknowledged that some genres such as soaps might influence
one's viewpoint but, nonetheless, recommended that the scope of
media plurality should encompass news and current affairs only.
Lord Fowler was emphatic on this point:
"I think you do what it is possible to do
and you also do what is most important. I think what is most important
is news and current affairs
it is going to be difficult
enough to do that without getting into new areas, like drama with
My own feeling would be to concentrate on what
we can achieve
and what has the most impact,
and current affairs. That has the most direct effect on the proper
functioning of a democracy. If we can achieve that, we will be
achieving a vast amount."
19. The BBC concurred that news and current affairs
are the most important genres in terms of driving the news agenda
and developing public debate, and so therefore should be the primary
genres to be considered in any plurality policy.
20. There are also practical difficulties associated
with a wider scope of genre for a plurality policy. Ed Vaizey MP,
Minister for Culture, Communications and Creative Industries explained
"Unless one is prepared to not let the best
be the enemy of the good, you could have this debate almost endlessly.
Should films form part of the debateindividual films can
be extraordinarily influential, wildlife documentaries, for examplevideo
games, books being published, clearly polemical books on particular
issues? You would be hard pressed to come to any kind of manageable
system that incorporated that wide a scope."
21. Conversely there are good practical reasons
for limiting the scope of a plurality policy to news and current
affairs. Ofcom gave two examplesthe genre "news and
current affairs" is already used in television and online
measurement systems and it is also easily understood by respondents
in consumer research.
As a category, news and current affairs can be identified for
the purposes of assessment.
DOES LIMITING THE SCOPE OF PLURALITY POLICY TO NEWS
AND CURRENT AFFAIRS IGNORE IMPORTANT ASPECTS OF MEDIA POWER?
22. Other witnesses have argued that plurality
policy should include genres outside news and current affairs
because plurality policy should be concerned with the ability
of media organisations to merge and concentrate power, and the
implications which this has for agenda diversity in and beyond
the genre of news and current affairs.
23. Mr Goodall explained that, "Our
belief is that most of the malign influence of extremely high
market shares in media arises not necessarily from the ability
to influence the political process, but to influence the economics
of the industry in this large company's favour."
Professor Barnett gave some practical examples of this,
"there are two
aspects to it. One
is pure commercial self-promotion. If you are an organisation
that holds sports rights
you are much more likely to play
news about those sports in your bulletins
Also, by virtue
of your commercial power, you will have influence over the regulator
It is important to remember that there are other aspects
to plurality beyond the influence on citizens and the public,
which are all about the nature of exercising power in a democracy."
24. Following this argument through leads its
principal proponent, Enders Analysis, to recommend a cap of 15%
on each player's revenue share of the overall media market. Mr Goodall
admitted that this cap was arbitrary,
"We have gone for a relatively simple, extremely
arbitrary ruleI use that word carefully because to me that
is a good thingbecause it is then very much easier for
regulators to maintain control and to make sure that the rules
are well understood by every participant."
The merits and demerits of a "revenue cap approach"
are discussed in the following chapter.
25. Some witnesses however claimed that the 15%
cap on revenues is more deliberate with respect to the scope of
plurality policy than its proponents claim. Professor Collins
told us that whatever measurement instrument is taken by regulators
and policymakers, "it is not an innocent choice. We know
that your Committee has received evidence suggesting that a revenue
measure should be taken
the choice of the measuring instrument
takes the regulator in very different directions."
26. Mr Elstein was rather more specific
in explaining his objection to the 15% revenue cap proposal,
"It is just another way of dealing with
Murdoch. I said to [Enders Analysis]: Be open about it. Ask the
House of Lords to put forward a Bill banning Murdoch.
you want to do, just do it, but do not muck up our media plurality
regime for the sake of a personal campaign against a particular
proprietor. However well intentioned you are and however well
merited that campaign might be, that is not the point of this."
27. We recognise that all genres and channels
of information used by UK citizens play a role in the ideas and
perspectives available to them. Accordingly, there is some justification
for including within plurality policy any channel or genre through
which those ideas and perspectives are spread. But, for the practical
and pragmatic reasons outlined above, we recommend that a plurality
policy should be limited to the activities of media enterprises
engaged in news and current affairs content. Content diversity
in other genres is not unimportant but is a matter of independent
commissioning or the stipulations set out in licence and Charter
renewal agreement which create the context in which commissioning
decisions are made.
28. Citizens of the United Kingdom can receive
news and current affairs content from suppliers based all over
the world and this is especially true of internet-based content.
This raises the question of whether and how the United Kingdom's
plurality policy, which is by definition embedded in the national
jurisdiction, should take account of this international dimension.
Suzanne Rab and Dr Alison Sprague pointed out that whilst
there was a broad international consensus supporting pluralism,
"there is no internationally recognised regulatory model
as to how this goal is best served."
Certainly, a broad-based international approach to plurality does
not appear to be in prospect. However, we did hear evidence on
the possibility of greater European involvement in this area.
THE EUROPEAN DIMENSION
29. The European Commission is involved, to a
limited extent, in UK media plurality policy through the EC Merger
which competition aspects of large international mergers which
satisfy certain jurisdictional criteria fall to be considered
by the European Commission's Competition Directorate. Only the
competition aspects of the merger are considered by the Commission
leaving Member States free to take appropriate measures to protect
their 'legitimate interests,' including plurality of the media.
As such the media public interest considerations raised by these
mergers remain to be considered by UK authorities.
Put simply, "Only when media mergers pose issues of market
dominance across the EU does the EU Competition Commission intervene."
30. There is a debate about whether European
Union competence in this area should be extended. The European
Initiative for Media Pluralism (EIMP) claimed that, "An EU-wide
standard framework of rules on media ownership would provide a
clear and important foundation for free and independent media."
This statement followed to some extent from the High Level Working
Group on Media Freedom and Pluralism set up by the EU Commissioner
for Digital Agenda, Neelie Kroes, which recommended that "The
EU should be considered competent to act to protect media freedom
and pluralism at State level."
31. There was, however, considerable scepticism
in the evidence we received about the idea of a pan-European policy
on media plurality per se. Professor Collins explained
that "We think that the media markets of European Union member
states are so diverse that it is very, very hard to imagine a
coherent and meaningful pan-European policy coming into existence
and we think continued effort is not really worthwhileto
formulate a coherent and effective European policy on this."
Similarly Dr Craufurd Smith said that "the EU has tried
to intervene in this field before and was unsuccessful
because a number of member states feel quite strongly that these
issues are better dealt with, and
can be better contextualised
and developed at the national level."
Dr Tambini developed this point further: "News markets
are still very national
given that polities remain national
and so, in many cases, do language groups."
32. Despite the general scepticism amongst our
witnesses about a European media plurality policy per se,
two areas were identified where a pan-European (or wider than
UK-only) approach could be of potential merit:
address digital intermediaries; and
· to remove
state aid constraints which might block Member States' endeavours
to use targeted and proportionate public funding to stimulate
and support greater agenda diversity in their national media.
33. In relation to the first Mr Foster told us
"The EU already has well developed competence
in telecommunications access regulation, and these are big pan-global
companies that operate at European scale. There may be some scope
for encouraging thinking at the European level about how access
regulation could be developed to apply to these digital gateways."
With regard to the second area he said that,
"there is a more important role for public
funding of high-quality journalism in future, which does raise
issues of state aid
We need to make sure, working at the
EU level, that proposals that seem to make sense here and no doubt
in other member states do not fall foul of those sorts of constraints."
34. There appears to be a strong consensus
that UK media markets should be the focus of UK media plurality
policy; we agree. We recognise that plurality policy remains broadly
a matter for the UK and this report relates to a UK plurality
35. However, that is not to say that it may not
be appropriate and necessary for any assessment of plurality in
the UK to take into account the presence of internationally-sourced
content in UK citizens' news diets. Indeed it would be important
that any plurality policy approach may take into account media
enterprises based in the UK as well as those outside UK jurisdiction
to the extent that they are consumed by UK audiences if this is
considered relevant to the overall assessment.
NATIONAL V LOCAL MEDIA PLURALITY POLICY
36. There is some agreement around the idea that
plurality concerns are finely balanced against the issue of financial
sustainability, particularly at the regional/local level. RadioCentre
told us that "local media companies
are already under
considerable financial strain to survive."
The Media Standards Trust pointed to the decline in plurality
of provision of regular and sustainable sources of news and current
affairs content at the local and regional level in the United
Kingdom. Professor Barnett
described this dramatically in his written evidence:
"the decline of the local press and inadequacy
of other local media
is producing a severe democratic deficit
within local communities."
37. Against this background, we were interested
to hear from Ashley Highfield, Chief Executive Officer of the
Johnston Press that whilst, "The last seven years has been
extremely brutal for the regional press industry
now at a level, provided that we can cut our cloth accordingly,
that is sustainable for the long term as we move to the predominantly
38. Whether or not the commercial prospects of
the local and regional media may improve, there were clearly grounds
in Ofcom's advice to the Secretary of State to acknowledge that
plurality may be under greater pressure in relation to local media
than at the national level.
Indeed, for this reason we expressed hope in a previous Report,
The Future of Investigative Journalism,
that the Government's removal of rules relating to local cross-media
ownership would provide an opportunity for local media organisations
to develop a sustainable business model through consolidation
in future if they wish to do so, although we do note that the
effectiveness of consolidation as a route to improving the commercial
prospects of local and regional media is contested. On the one
hand, the Media Reform Coalition claimed that, "there is
simply no evidence that consolidation of ownership improves the
prospects for sustainability and some evidence to the contrary."
On the other, the Newspaper Society warmly welcomed the abolition
of local cross-media ownership restrictions in 2012.
39. In any case, the understandable concerns
about the commercial health of local and regional media suggest
that these considerations should form an integral part of any
media plurality policy. As Professor Barnett explained, "At
the local level, [the pertinent questions may] be different [to
those at the national level]
"How do we shore up the
kinds of media enterprises that we want and need?" Not necessarily
just for plurality, but just so that there are some local news
information sources that exist."
We leave consideration of the exact approach a policy might take
to the next chapter on Approach. The important point is the following:
40. The scope of any plurality policy should
encompass both local and regional media as well as national media
in the devolved nations and UK-wide media enterprises. In dealing
with local or regional media, those tasked with making decisions
should in reaching their conclusions pay particular attention
to the question of financial sustainability.
SHOULD THE BBC BE INCLUDED IN A PLURALITY ASSESSMENT?
41. The evidence we received was unanimous that
the BBC should be included in any assessment of media plurality.
The consensus appears to be that not including the BBC in a media
plurality assessment would be difficult to justify. News Corporation
told us that,
difficult to conceive of any
sensible regulatory regime which would ignore the role and position
of the BBC"
and Ms Rab and Dr Sprague told us that the "BBC's position
in news provision means that it would be incongruous not to consider
it in any measure of viewpoint diversity."
The Government appear to agree. Mr Vaizey told
us that "The BBC, clearly because it has got its huge share
of voice, has to be taken into account when you are considering
42. Whilst there was consensus that the BBC should
be included in any assessment of media plurality, we heard that
it should not nececssarily be subject to any control measures
as a result of that assessment, at least from outwith its own
regulatory framework. For some, this was because this framework
imposes requirements on the BBC which are themeslves a sufficient
safeguard to ensure that its conduct in relation to plurality
is addressed satisfactorily. This echoes a view put in the Leveson
"governance controls in place to ensure
internal plurality within the BBC, and the effect of the impartiality
requirements meant that its size gave rise to no plurality concerns"
43. A similar view was expressed by Avaaz:
"the BBC is subject to a substantial range
of public interest regulation that make it exceedingly difficult
for it to threaten democracy in the ways privately-owned entities
do, to whom these regulations do not apply. Aside from requirements
to maintain balance, impartiality and offer the right of reply
in all its news programmes, the BBC is also subject to a range
of quotas and governance requirements designed to ensure its accountability,
internal plurality and diversity of output."
44. Whether or not the existing requirements
on the BBC are sufficient in addressing the organisation's role
in respect of plurality, there is a more straightforward case
to make that control measures should not be imposed from outwith
its own regulatory framework. The current BBC governance structure
places a responsibility on the body which oversees the organisation
to monitor and intervene in the BBC's direction if necessary.
Under the existing governance rules this is the BBC Trust. To
argue that control measures should be imposed on the BBC from
outwith this governance structure is to open up a debate about
these arrangements which would be a matter for an entirely separate
inquiry. Quite straightforwardly, therefore, as long as these
arrangements remain as they are, it is appropriate that control
measures are a matter for the body which oversees the BBC at present.
45. As such, we agree with the overwhelming balance
of the evidence we have received. The BBC should be included
in any assessment of media plurality but it should not be subject
to any control measures imposed from outwith its own regulatory
framework as a result of that assessment. It is for the body which
oversees the BBC, under the existing governance rules this is
the BBC Trust, to ensure that the BBC's conduct in relation to
plurality is addressed satisfactorily.
SHOULD ONLINE MEDIA BE INCLUDED IN THE SCOPE OF MEDIA
46. Ofcom's plurality report observed that "newspapers,
online and radio are perceived by consumers to be broadly similar
in terms of importance," with use of online news steadily
growing from 15% who "ever used" it in 2002, to 27%
in 2007, to 41% of UK adults who use the internet for news in
2012. The growing
importance of the online delivery of news and current affairs
was also described by Mr Foster:
"for the under-45s
the internet is
now a more important source of news than television or newspapers,
probably for the first time. There is a real split in the market
between the over-45s, who still like print and television, and
the under-45s, who rely much more on digital media. That just
shows it has to be included in any assessment."
47. This highlights an issue with the current
plurality arrangements which were designed with newspapers and
broadcasters in mindnot online providers. Indeed, for the
purposes of plurality, the Communications Act 2003 does not recognise
online-only enterprises as "media enterprises" at all,
leading Lord Puttnam to stress that the "challenge that confronts
us as legislators
is to get from where we are now, based
on legislation framed principally in an analogue age, to where
we ought to be in a digital age."
The consensus across the evidence was very clear: that this issue
should be resolved and online media should be in scope for the
assessment of media plurality.
SHOULD DIGITAL INTERMEDIARIES BE INCLUDED IN THE
SCOPE OF MEDIA PLURALITY POLICY?
48. We heard oral evidence from two digital intermediariesFacebook
and Google. Mr Simon Milner, Policy Director, UK and Ireland,
Facebook, told us that Facebook was open to the "Government
wanting to include all the different ways in which people find
out about what is going on in the world via digital and traditional
analogue media within that [media plurality policy] framework"
but was keen to stress that Facebook was not a media platform
or a news organisation.
Similarly Mr Peter Barron, Director of Communications
and Public Affairs for Europe, Middle East and Africa, Google
stressed that Google was not a publisher. It did not create content
but helped people to access content.
While no witnesses made a specific claim that digital intermediaries
are a present threat to UK media plurality, we received some evidence
that they could represent a potential threat if not properly monitored.
49. Mr Foster explained that "The public
interest concern is whether they have an incentive and an ability
to decide what sources of news we can get to through their platforms.
At the moment, I suspect it is not a major concern, but you can
see that in the future, the way in which [digital intermediaries]
operate could start to determine which news sources get priority
treatment and which get pushed down the list; which news sources
they willing to carry and which they are not."
50. Dr Schlosberg made a similar point that
digital intermediaries had a kind of "gate-keeping"
power which was potentially open to abuse.
While the influence of these enterprises may not represent a present
threat to media plurality, there was a clear consensus around
the view that the impact on plurality of digital intermediaries
must be kept under review and taken into account as part of any
51. We recommend that media plurality policy
should not be limited by the media channel through which content
is primarily delivered: print, broadcast and content delivered
over the internet may all be relevant, as could be the influence
of digital intermediaries on the consumption of this content.
It should, therefore, be open to an assessment of plurality to
determine which media channels should be in scope based on whether
they are relevant to the overall assessment of plurality at the
52. There is a separate question about whether
some of the major digital intermediaries can be brought within
the jurisdictional reach of any plurality remedies or interventions.
We leave this matter to Chapter 5 where we describe our proposal
for a media plurality policy.
The Lifecycle of News
SHOULD PLURALITY POLICY FOCUS ON THE SUPPLY OR CONSUMPTION
OF MEDIA, OR BOTH?
53. To recap, in Ofcom's advice to the Secretary
of State, media plurality is described as a means to an end which
should have two desired outcomes, the first of which is:
"Ensuring there is a diversity of viewpoints
available and consumed across and within media enterprises."
54. For some, the inclusion of the word "consumed"
was conspicuous and raised a question about whether Ofcom's intention
had been to suggest that media plurality policy should actively
seek to stimulate the demand for and consumption of diverse viewpoints.
As a result, Professor Picard was keen to stress that "There
is no way you can force consumption, but you want to make it readily
available to everybody, make it readily available to people at
a price that is acceptable for them, and make sure that you are
not excluding them in some way along the way."
Similarly Mr Foster told us that one could not require the public
to consume different viewpoints "The first priority should
be to focus on ensuring the public has at least the option of
finding a diversity of viewpoints, even if in the end it chooses
not to take advantage of them."
55. Robert Kenny explained that the inclusion
of the word "consumed" was important. It did not necessarily
suggest that media plurality policy should seek to intervene in
consumer behaviour, but rather to capture the importance of making
an assessment of consumption of diverse viewpoints across and
within media enterprises. He told us that assessing "availability
by itself is insufficient, and it is appropriate therefore to
In oral evidence, Steve Gettings of Ofcom explained its inclusion
in a similar way, noting that an assessment of plurality should
take into account certain characteristics of the way in which
consumers behave, for example, that,
is high among all sections of society
and that there is
good evidence of multi-sourcing,
For us that was quite
an important metric [because it would help reveal whether any]
content has what policymakers might regard
as an unreasonably high level of consumption, in other words dominates
the news media market."
56. We recognise the importance of ensuring
that no content provider has an unreasonably high level of consumption
and recommend that a media plurality policy should take into account
both the supply and consumption of content, albeit that any interventions
available will have to be limited in application to the supply
The value chain
57. The value chain for the supply of news is
complex. Ofcom explain this in their advice to the Secretary of
"Content might be originated by one company
(e.g. a newswire such as Reuters), aggregated by another (e.g.
a wholesale news provider such as ITN), and made available to
citizens by yet another (e.g. a broadcaster such as Sky)."
58. Ofcom's document refers to content produced
in-house as retail content and content sourced from third parties
as wholesale content. We note that the use of these labels attracts
a mixed reception from the media enterprises involved. For example,
Mr Clive Marshall, CEO of the Press Association told us that
he is "very happy with the description of wholesaler. Our
role is to provide the building blocks of the news for our news
By contrast, Mr John Hardie, CEO of ITN, told us that he
is "rather unhappy with the expression "wholesalers"
being used about us
A wholesaler to me implies the middle
man in the distribution chain
That is nothing like what
we do. ITN is an originator of television news."
However, these labels have been useful to us in discussing the
role played by different media enterprises in the value chain
of news and current affairs, and so we have continued to use them
in this Report.
SHOULD 'WHOLESALERS' OF NEWS BE TAKEN INTO ACCOUNT
IN A REVIEW OF MEDIA PLURALITY?
59. We considered whether wholesalers of news
should be taken into account in any media plurality policy or
assessment. The evidence we received was that a judgment needed
to be made about where in the value chain editorial control was
exercised: if editorial control was exercised by wholesalers,
they should be included in the assessment. Professor Collins
acknowledged that it was not always easy in practice to work out
where editorial control was exercised:
"Editorial control is the key issue, and
that that may be at the wholesale or retail level
out those chains [however] would be a nightmare task for any regulator
[influence may be exercised] at many places along the chain."
60. The commercially-funded PSBs
however, were all firm in their view that the editorial control
lay with them rather than their "wholesaler," ITN. Mr Magnus
Brooke of ITV explained "We are the customer so we set the
overall strategy and editorial objectives for our news programmes
and we are in charge. We are paying for them, which is not to
say we are in day-to-day editorial charge
we are not consulted
on a daily basis about what stories to run but we certainly have
Mr Dan Brooke of Channel 4 told us that "From our point
of view we hold the whip hand. We have a commercial contract with
ITN, which is very detailed"
and Mr Marcus Lee of Channel 5 told us "It is not so
much a concern that ITN
has too much of a powerful voice
our news output is
Channel 5's voice and it just
so happens that ITN create that for us."
61. We heard evidence from ITN and the Press
Association, two news wholesalers. Mr Marshall was clear
that "At the Press Association, the editorial control rests
with our customers, so at the retail part of the process
We do not editorialise. We would not produce opinion columns."
But whether ITN exercises editorial control seems less clear-cut
than this, "Day-by-day we are making the editorial choices,
consulting with them. They get to see what our running order may
be and so forth, but we are not debating on a day-by-day basis:
what is first up tonight?"
62. Ofcom's advice to the Secretary of State
allows for the possibility that a degree of editorial control
may be exercised by the wholesaler and recommends that a new media
plurality regime should not rule out the possibility of influence
being attributed to "wholesale" providers of news:
"The value chain is likely to continue to
evolve; as, for example, new types of online aggregators become
[and therefore] we recommend that flexibility
is required to consider at which points in the value chain editorial
control is most likely to be exercised, and therefore how best
to measure diversity and influence."
63. We recommend that a media plurality policy
should be flexible enough to take into account both the wholesale
and retail provision of news and current affairs content. It should
establish an approach to determining how to attribute content
to media enterprises operating at different points in the value
chain. This determination will require the location of editorial
control in the value chain to be identified in each case.
12 In other industries, this might be termed the "supply
chain;" we explain further what is meant by "value chain"
later in this chapter. Back
Voice of the Listener and Viewer. Back
Q 149. Back
Suzanne Rab and Dr Alison Sprague. Back
Q 149. Back
Q 426. Back
Q 108. Back
Q 81. Back
Q 114. Back
Q 30. Back
Q 253. Back
Suzanne Rab and Dr Alison Sprague. Back
Council Regulation (EC) No 139/2004 of 20 January 2004 on the
control of concentrations between undertakings (the EC Merger
Regulation). Available online:
Competition Commission. Back
A free and pluralistic media to sustain European democracy
The Report of the High Level Group on Media Freedom and Pluralism.
Jan 2013. Available online:
Q 57. Back
Q 10. Back
Q 12. Back
Q 27. Back
Q 27. Back
Media Standards Trust. Back
Professor Barnett. Back
Q 340. Back
Ofcom 5 October 2012. Measuring media plurality: Supplementary
advice to the Secretary of State for Culture, Media and Sport
and the Leveson Inquiry. Available online: http://stakeholders.ofcom.org.uk/binaries/consultations/measuring-plurality/letters/advice.pdf Back
Select Committee on Communications, The Future of Investigative
Journalism (3rd Report, Session 2010-12, HL Paper 256). Back
Media Reform Coalition. Back
Newspaper Society. Back
Q 71. Back
News Corporation. Back
Suzanne Rab and Dr Alison Sprague. Back
Q 422. Back
An inquiry into the culture, practices and ethics of the press:
report [Leveson] Volume 3. Available online:
Ofcom, 6 June 2012, Op. Cit. Back
Q 18. Back
Q 141. Back
Q 387. Back
Q 387. Back
Q 22. Back
Q 334. Back
Ofcom, 6 June 2012, Op. Cit. Back
Robin Foster. Back
Robert Kenny. Back
Q 407. Back
Ofcom, 6 June 2012, Op. Cit. Back
Q 276. Back
Q 276. Back
Q 61. Back
ITV, Channel 4, Channel 5. Back
Q 239. Back
Q 239. Back
Q 240. Back
Q 279 and Q 280. Back
Q 279 (Mr Hardie). Back
Ofcom, 6 June 2012, Op. Cit. Back