Response of the Newspaper Society to the BBC Strategy Review Consultation

1. The Newspaper Society represents the regional media industry. Its print, online and broadcast platforms now deliver trusted local and regional news, views, information and entertainment to 40 million print readers a week and 37 million web users a month through 1200 newspapers, 1500 websites, 600 niche and very local titles, 43 radio stations and 2 TV channels.

2. The BBC Trust and BBC Executive need to ‘set new boundaries’ which will immediately and truly reduce and restrict the BBC’s local role and local ambitions across all media platforms including print, online, radio and television and which will really curtail the BBC’s activities which have potential adverse impact upon its commercial competitors. These need to be backed by strong oversight and enforcement measures.

3. This really requires fundamental reform of the BBC Charter, Agreement and BBC Governance arrangements and funding, which ultimately may require government intervention. In the meantime, the BBC Trust and BBC Executive have ample powers to set and enforce clear and effective restrictions which would reduce the BBC’s existing activities and future ambitions in the nations, regions and localities. The NS suggests some simple and pragmatic ways below to implement the necessary reduction and restriction by way of interim measures.

4. The issue is whether the BBC Trust and BBC Executive wish to exercise self- control or whether the strategy review may become the latest in a long line of BBC acknowledgment of criticism of its ever growing activities, without any effective action to curb and reduce them. The Newspaper Society will continue its dialogue with the BBC Trust and BBC Executive in the hope that the current review achieves simple and verifiable controls on the BBC’s local activities and ambitions.

5. The industry’s fundamental concern is that the BBC Strategy Review‘s proposals will not result in reduction and restrictions upon BBC local activities. The BBC Executive does acknowledge that ‘local services are an area where the BBC’s proposals have been criticized for their possible impact on commercial providers’ and that ‘the BBC needs to respond to the changes affecting other local news providers’. But it fails to leave ‘a clear space for commercial providers’ or suggest the ‘right proposals for new boundaries and new BBC behaviours’ for BBC Trust consideration.

6. The BBC Executive suggests that it could develop a ‘new contract for local’ that sets out the BBC’s role as well as the limits to its ambitions. Far from responding to the industry’s concerns, this demonstrates the extent to which the BBC intends to compete head on with regional and local media’s core content.

Namely that:

• ‘In local online, the BBC will only produce material in its core editorial areas of news, sport, travel, weather and local knowledge. It will not provide listings, local guides or similar feature material. • The BBC will be no more local in England than it is today on all platforms - that is, it will not increase the BBC’s number of local services on television, radio and online.’

7. The Review thus now confirms the BBC’s continued intentions in local online to focus on core editorial areas of news, sport, weather, travel and local knowledge (i.e. supporting BBC initiatives where there is local relevance, but not general feature content) and improve the quality of its websites.

8. The Review also confirms the BBC’s intention to embark upon reporting of business, of the local democratic process – both staples of local newspaper coverage – via the BBC’s multiplatform coverage of local government and politics through Democracy Live; more prominence for audiovisual content; and its general development of interactive services.

9. The NS has already raised concerns in its continuing discussions with the BBC and BBC Trust about the BBC’s current development of its regional and local services, in direct competition with the regional press throughout the UK. These already include the BBC’s current initiatives under its Nations and Regions news agenda and its implementation of the revised BBC Local proposals, encompassing the development of local radio websites (see below).

10. The regional press has of course always editorially focused upon local and regional news, sport, local knowledge, travel and weather, and has extended its audience beyond its core print titles to online and digital services. The BBC Strategy Review starkly confirms the BBC’s intention to develop local online, in direct competition with the local commercial media, and exploiting fully the freedom of action conferred by its Charter, service licences, licence fee and flexible budgets. It fails to pay any meaningful regard to the adverse impact of such BBC activity upon the independent commercial media. The only restrictions which the BBC is prepared to suggest are confined to the (albeit welcome) repetition of its past public concessions on dropping its production of listings, guides and similar feature material.

11. The BBC says that it will not increase the number of its local television, radio or online services. This is welcome but still offers less comfort than is immediately apparent, since:

• The BBC has no intention even in England of reducing its current local and regional services, nor of drawing back from the expansion of local and regional services already proposed, nor of restricting any development of any existing local and regional service which it deems does not amount to a service licence change requiring BBC Trust approval. It also wants to develop its services in the North of England and elsewhere.

• The BBC wants to be free to increase as well as develop its local television, radio and online services in Wales, Scotland, Northern Ireland, (no doubt with reference to the past BBC Trust statements used to justify its original BBC Local ambitions).

• If IFNCs or other such local partnerships involving the commercial independent media went ahead, successful bidders would face new competition, not a ‘clear space’ or concrete and useful partnership proposals from the BBC.

• The BBC is silent on past pledges against revival of its local and regional print magazines, newspapers and other publications, or their electronic equivalents.

12. Nor is the BBC suggesting that it is about to adopt any new or more rigorous restrictions upon its aspirations for service development in England.

13. The Strategy Review simply appears to be repeating the BBC’s previous assurances as to the reduction of its original ‘ultra local services’ ambitions (which it originally presented as a natural and minor development of its existing services) first as a result of budget revisions and then the refusal of the BBC Trust to approve its original BBC Local Video proposals. The BBC Trust’s online consultation says that the BBC Director-General has suggested that this means ‘not offering any more localised services than the BBC already does - for example new services for individual towns or cities’. Obviously, welcome though this is, it would be helpful to have this assurance translated into a binding restriction, along the lines that are suggested below.

14. Moreover, the BBC Strategy Review is not proposing that the BBC would impose any restrictions on the content of its existing local services, or on any ways of tailoring content to produce localised material in response to individual demand, or on ways to access such material on any media platform.

Necessity for effective restrictions upon the BBC’s regional and local activities and ambitions

15. The BBC’s local and regional activities and ambitions need to be reduced, not entrenched, as a result of the BBC Strategy Review. Comprehensive, consistent and coherent restrictions must be drawn up in consultation with the regional media on the BBC’s public service and commercially funded activities which adversely affect the regional media. Pending radical review of BBC governance arrangements, they then need to be introduced, policed and enforced by the BBC and BBC Trust. Appropriate changes must also be made to Service Licences, protocols, budgets, commercial and public policy strategies.

16. The restrictions must be clear and capable of implementation by staff in a straightforward manner. Any breaches of controls over local services or local content should be capable of being quickly and easily detected and dealt with by BBC local management. The local management must be able to address problems or resolve complaints by the local media quickly. There must also be swift and effective procedures for local review of decisions and appeal, in addition to the established compliance and oversight procedures of the BBC Trust and BBC Executive.

17. Transparency is also necessary for the BBC’s competitors to be convinced that any controls will actually work in practice. A comprehensive and detailed public audit (constantly updated) of the BBC’s local and regional activity is necessary, detailing all the BBC’s actual websites, online content, services, activities and ambitions - existing, planned and proposed (sourced to the relevant policy and strategy documents) - and then explaining the application of controls to them. This includes details of the approval/oversight proposals and all budgets as allocated including specific breakdowns at local level, investment limits, and oversight mechanisms.

18. Indeed it would be helpful if the BBC identified precisely the effects of the BBC Strategy Review’s proposed limits on its local activities and ambitions, with precise illustration of what it intends to retain, expand or develop and what would be dropped, whether in relation to the content itself or the means of accessing and selecting it. The BBC’s competitors would then have a better understanding of what the BBC itself meant by them. After all, the BBC Trust has yet to prove the effectiveness of its retrospective monitoring of the approved BBC Local Video services. The NS is also concerned by the reappearance of the proposals and arguments for expansion advanced by the BBC for developing its local services, without any suggestion of effective controls to avoid detriment to the commercial media.

19. New controls should be placed on any BBC activities which compete for audience or revenue with the regional and local media – such as BBC’s print, online and audiovisual content and services however accessed or received and by whatever technological means.

20. In the short term, these may have to be simple restrictions, some along the general lines previously proposed by the BBC itself but more rigorous, provided they are strictly enforced.

21. Maximum story count: Introduction and enforcement of a specific maximum number of regional and local stories and other material per day (midnight to midnight), published or otherwise available on each BBC local radio website and any other relevant BBC website, which carry local and regional material and which is accessible at any time by any means during the 24 hour period. The restrictions would have to apply to all categories of content, irrespective of the BBC’s definition of its four core editorial content categories, or current categorization used by the BBC, such as ‘news’ or associated headings such as ‘people and places’, ‘religion and ethics’, ‘things to do’, ‘history’, ‘arts and culture’, ‘science’ etc., which resemble local newspaper/media content (print/online) and other services, including user-generated content. Live streaming, user generated content, updates and substitution of material should also be specifically limited and included in maximum daily count (avoiding easy bypass of limits – we refer you to our submission on BBC Local Video, an extract from which is attached, which explained why the BBC’s then proposed story count limit would be ineffective). 22. Links: As Ofcom concluded, links will not remedy the negative market impact upon the commercial media caused by BBC expansion into local media activities. However, it could be helpful to include a specified minimum number of prominent links each day from the home page of any relevant BBC website, such as the BBC local radio/local online websites, to local commercial media websites and to stories originated by local commercial media, with agreed and appropriate description of the local media concerned. The basis for the BBC’s choice must be transparent and agreed with local commercial media. The BBC should not claim that it has thereby become, expressly or impliedly, the local portal for all local content and services. Conversely, the BBC should not link through to websites in ways which would undermine the regional media’s revenue earning commercial and editorial relationships.

23. Monitoring of click-through: The use of the links and traffic engendered needs to be monitored and recorded, in ways verifiable and useful to local commercial media.

24. BBC acknowledgment of its source material: The BBC should be obliged to identify fully and properly acknowledge, in accordance with the manner agreed with the local media, its use of any material produced by a local media source (e.g. title, website) for any of its stories and other material used on air, online etc, by the BBC, whether the BBC picked up and recast the story or incorporated it into its own report, with or without BBC original material, or simply reproduced it in whole or in part.

25. BBC link to local media’s story used as source material: The BBC should be obliged to publish links to the local media’s full story where appropriate, (and with full and proper acknowledgment of this local media source as above), whenever and wherever the story is used by the BBC, whether on international, national or local website, broadcast, or other publications and however accessed.

26. Prohibition of BBC cross-promotion of its local and regional licence fee funded and commercial services should be introduced and enforced.

27. Prohibitions on BBC online content or services: The BBC must be prevented from producing or publishing or facilitating anything similar to local commercial media services, such as listings, directories, classified advertising, public or private sector recruitment, local government and other public sector publicity and information, community information, statutory or other public notices; local guides, ticket sales and from launching or publishing any printed media, including newspapers and magazines, whether or not carrying third party advertising or public notices.

28. Pending radical review, simple agreed procedures should be introduced to maintain the agreed controls over the BBC’s local activities:

• Regular review in conjunction with the local media to ensure that prohibitions are understood, effective, clarified, updated and extended where necessary before adverse impact upon the local commercial media.

• Simple procedures to ensure that any transgression by the BBC is immediately detected and rectified and prevented from re-occurring, with a record of each day made, retained and submitted and verified by local management; reported, monitored and policed by the BBC Executive at national level and by BBC Trust; also made available to the media/public. Simple and expedited complaint processes at every level will be needed. Merely retrospective analysis of compliance needs to be avoided, since harm could be caused to the BBC’s competitors before any breach is even detected, much less put right.

29. Transparency, full disclosure, advance notice and continuing consultation about any activity planned by the BBC. Prior local consultation of the regional and local media must be undertaken at the earliest stage and continue thereafter. Consultation must precede any proposed development or changes to BBC’s local services and then be maintained, if the proposals do proceed, in order to avoid any adverse impact upon the local commercial media. Any proposed partnership arrangements with local public sector and local government of any kind must also be subject to appropriate restrictions, prior notification, detailed consultation and controls.

30. Regular reviews of the operation of the controls, at local level upwards, would be necessary to ensure compliance, detect problems, update and extend restrictions where necessary.

31. Transparent accounting, transparent detailed budgets (local/regional/ national/service) and financial information should also be readily available from the BBC to supplement its own explanation of the true extent of the BBC’s investment in BBC’s local and regional activities in any particular area, whether licence fee funded or otherwise. This includes the precise budgets, specific details of proposed expenditure broken down by service, service content definition and service licence controls.

32. These obligations would exist in addition to any formal existing obligations upon the BBC and BBC Trust in respect of Fair Trading Rules, PVT assessment, review of service licences, budget arrangements.

33. The NS and its members have of course repeatedly put these points to the BBC Executive and the BBC Trust (see attached).We hope that the BBC Trust and BBC Executive will now actually discuss, consult and then implement strong and effective controls over its local and regional activities, as part of its current dialogue with the industry.

34. Fundamental reform of the BBC, BBC governance and BBC funding remains necessary.

The Newspaper Society 24 May 2010 Contact details: Santha Rasaiah, PERA Director, The Newspaper Society, St Andrew’s House, 18-20 St Andrew Street, London EC4A 3AY. E- Mail: [email protected]; direct tel. no: 020 7632 7461 Extract from the Newspaper Society’s submission to the BBC Trust and Ofcom: BBC Local Video, Public Value Test, 12 August 2008

‘55. The NS and its members have also explained why the BBC’s suggestion of upper limits on story counts would not neutralize the impact of the service.

56. The upper limits would be completely ineffective controls. They are retrospective, as compliance will be judged by volume and duration averaged out over a year. They are meaningless and capable of seemingly infinite exceptions, given that none of the following will count towards the upper limit: continual update on any story during any 24-hour period, unaided user-generated content, live streaming, and exceptional circumstances, from flood to election. Services in London and Wales are to enjoy far higher upper limits of story count and duration (with a ‘double’ service in Wales with the English and Welsh services covering different stories or providing different treatments, to their respective upper limits) and budget. The BBC’s application documentation suggests that the BBC does not regard these limits as a restraint upon the service but rather as the optimum for an audience at which it is aimed:

‘‘The range and depth of stories presented as possible with the new video offer, are felt to be ideal’ (Opinion Leader). ‘There is little appetite for an increase in the amount of video content beyond the proposed number of local video stories.’ OLR 2008, BBC Management’s assessment of the public value of the BBC Local Video Proposal.

57. In addition, the BBC intends that content can be accessed and personalized into a truly local news and information service, tailored to any particular individual with the assistance of site navigation including geotagging, interactive maps and information supplied in response to the user typing in a post code (p15, BBC Management’s assessment of the public value of its Local Video proposals). The NS and its members have expressed their deep concern about this aspect of the BBC’s service, how it duplicates regional media and how it will have an adverse effect upon the market for those regional media’s regional and local audiences and services.

58. This is one of a number of areas of overlap with our members’ services, which could have a market impact upon our members’ businesses, but which do not directly fall within the BBC Local Video assessment.

59. The NS has asked for information to be supplied by the BBC for the purpose of the MIA and PVT about the precise budgets, specific details of proposed expenditure broken down by service, service content definition and service licence controls. (See appendix of meetings, etc.) This includes information relating to the related services which the BBC Trust has said are outside the scope of the PVT assessment and are not reliant upon the approval of the local video project, although the project will be assessed in the context of these developments:

• BBC’s proposed development of user generated content; • the bringing of BBC local sites in Scotland and Ireland into line with the current provision in England and Wales; • the improved search, navigation and site architecture, including a greater use of map-based technology, for which new investment above the baseline budget will be available, are outside the scope of the PVT assessment of the Local Video service and are not reliant on the approval of the local video project.

60. These are all aspects of the BBC’s expansion covered by the BBC Trust review of bbc.co.uk statement that ‘BBC management also proposes to enhance the local and nations’ sites in 2009.’

61. Obviously, our members will be affected by the potential impact of the ‘enhancement’ of the sites as a whole, in addition to the broadband services. The NS therefore repeats the points that it has flagged up to you before: that an important area for consideration in the MIA and PVT as a whole will be the interrelation between the proposed BBC Local Video service and the bbc.co.uk service, including implementation of the bbc.co.uk review’s conclusions and other related services and service licences.

62. This includes information about changes to the services; what additional resources will be made available and how they will be allocated between the different services and their respective budgets; what those budgets will be; what and how resources will be apportioned between different radio stations, websites or other services and for what purposes, especially where the BBC intends to ‘bring them into line’ or start from scratch; the cumulative effect of budget allocations between services, activities and geographic area; the precise controls and restrictions placed upon the BBC - and the operational safeguards put in place that would actually ensure their effectiveness in day to day local practice - which ought to be imposed by the service licence and annexes; the annex to which local news will be assigned; the nature and effectiveness of new BBC management controls; and the outcome of the BBC Trust’s request that the BBC responds to the Newspaper Society’s concerns about the lack of distinctiveness of bbc.co.uk in local media, given that it is an area well-served by commercial providers.

63. The NS and members are very concerned by the BBC’s complete disregard of the industry’s identification of its existing and future core editorial activities in its discussions with the BBC. Worse, the BBC then cites these areas in justification of its expansionist proposals.

64. Our members have explained the role of user-generated content in their services and their future development. This includes its importance to local and regional news coverage, debate and analysis of community, local and regional affairs, features and entertainment. The BBC proposal fails to spell out the effect of its proposals for user-generated content and how this will compete with our members’; that this will not be original or distinctive since our members are already using and developing their services; that this will be a source of ultra-local, local and regional news and material capable of being accessed as such by any member of the audience and thereby drawing such audiences to the BBC rather than commercial media; that the BBC have deliberately excluded BBC unaided contributions from their ‘story count’, thereby rendering these meaningless.

65. We suggest that Ofcom and the BBC Trust should also consider the BBC’s ‘digital democracy portal’ since this intended to enrich its coverage of the UK’s political institution, including the Scottish Parliament, Welsh Assembly, Northern Ireland Assembly ‘as well as, over time, local government institutions’(BBC’s response to Network News Report BBC Management Response and Action Plan Trust Impartiality Report: Network News and Current Affairs Coverage of the For UK Nations). This is to offer live, on demand and searchable audiovisual coverage, complemented by other information and analysis.

66. BBC Management’s assessment of the public value of its Local Video proposals states that relevant video stories will link where appropriate to the websites of local government institutions, including to live streaming of key proceedings.

67. This service will not be distinctive. Regional newspapers already investigate, report, analyse, explain and comment upon national, regional and local government and public authorities with particular reference to the relevant regional audience. They employ a number of political correspondents based in Westminster, in addition to specialist correspondents. Tribute to their role as ‘the backbone of local democracy’ has been paid to them inside and outside Parliament. This has always been a key area of the regional media’s work - indeed the NS and regional press led the successful campaign against the government’s proposals to shut out press and public from local government meetings and decision-making.

68. Our members’ political coverage exploits the possibilities of new media: it now includes webcams of local authorities’ meetings, election coverage, online interviews and interactive question and answer sessions with local MPs. The NS and individual companies have emphasised to the BBC that such coverage remains an important part of their work. In meetings with the BBC, regional media companies have also explained that this is not merely undertaken as a public service. They explained that such online coverage and interactive interviews are popular features, attracting audiences to their site and the advertising revenues on which they depend. Indeed, local newspapers and their websites are seen by the public as the best means of obtaining information about local authorities and public services (Local Matters, Millward Brown, June 2008).

69. Nor can the BBC claim that its manner of coverage necessitated by its impartiality obligations will differentiate its service from those of the regional media. The regional media’s coverage tends to reflect the communities that it serves, rather than adopt any party political line. The BBC cannot therefore suggest that its intention to devote a large part of its service to national, regional or local political institutions would result in a distinctive service either in terms of content, depth, manner or technique. Nor will its impartiality obligations mark it out from our industry’s approach.

Civic Information

70. The BBC, apparently with backing from the Government (see Communities in Control) is also planning to expand its civic and community coverage in direct competition with the regional and local press.

71. The BBC’s application documentation suggests that it wants to develop and promote its sites as the portal to all things local. This would obviously divert audience from local media sites, which are already performing a similar service.

72. This also undermines the BBC’s claims that the local service will be kept clear of advertising, local government and other public bodies’ publicity and information, community information, listings and other areas from which the regional media derives advertising revenue.

73. It is important that the matters listed at paragraph of 4.13 of the Ofcom/BBC Trust Local Video Public Value Test Description of Services are comprehensively, clearly and firmly excluded from any area of BBC activity. This must be achieved by specific prohibition in all relevant service licences and firm effective controls, properly enforced. BBC activity has seeped into this area before. The regional media long ago raised the problem of radio stations’ swap shops and BBC free local magazine and newspaper publications carrying classified advertising. After the Government asked local authorities not to expand their website activities into areas which competed with local businesses, such as listing information, as a result of concerns raised by the regional press, the BBC Director-General also undertook that the local BBC sites would also stop carrying listings and ‘click through’ to ticket purchase.

74. However, these prohibitions will not be effective unless the BBC is prevented from developing its services into other related areas as important to regional media revenue.

75. For example, the BBC states that it will not include public notices including planning applications, or compete with recruitment listings, or cinema and commercial listings.

76. Yet the BBC has made clear in meetings and in its submissions that it does not intend to impose any limitations on any local service’s ability to link to whatever sites it considers interesting in any locality. This includes more specific links to particular information, sites or service provided by public and commercial bodies. This would compete with our members’ existing and revenue- earning commercial and editorial relationships.

77. The BBC’s submission to Ofcom’s public service review states that the BBC intends to collaborate with others who provide internet related services such as ‘improving findability for third party content’ on ‘access to local services; job centres; transactions with government; or access to public institutions websites such as those of galleries and museums.’ The BBC also says that it wants to develop its relationship with the Highways Authority. These are examples of collaboration, some in the areas of recruitment, entertainment and public notices, which could undermine the public service coverage provided by local commercial media and the advertising revenue upon which it depends. There is a danger that the public bodies will also claim that a BBC link would satisfy statutory or other publicity requirements. This would encourage public bodies’ preference to rely merely upon their publicity machinery disseminated through their own websites and media channels, instead of the effective independent regional media and its ability to reach the local community as a whole or particular target audience within it, by advertising or editorial, and enable proper public scrutiny.

78. Nor will the BBC’s suggestion that it will not carry commercial listings provide adequate differentiation and demarcation of the BBC’s activities from those of the regional media nor provide sufficient protection for the regional media’s advertising revenues. The BBC does propose full coverage of local and regional entertainment and events. This will be in direct competition with regional media companies’ editorial and commercial activities. Human Capital’s review of bbc.co.uk’s distinctiveness states that ‘the delivery of some content (for example local area listings) is close to that provided by local newspapers, and other sites make better use of video content’.

79. The BBC Local Video proposal is silent on sponsorship agreements. Any BBC sponsorship activity would again directly compete with the regional media’s commercial activities, including sponsorship revenue. In view of the recent statement by the Director-General that commercial sponsorship of programmes will cease once existing contracts expire, we would expect that similar prohibitions should be applied across the BBC’s activities, including all regional and local online services. We also believe that the BBC’s own intentions as to pursuit of regional and local sponsorship and other similar commercial relationships should be examined as part of this assessment. The BBC’s cross-promotion of events which it sponsors is tantamount to direct advertising.

Sport

80. Our members already provide comprehensive regional and local media sports coverage, from the grassroots - junior teams and schools - to Premier League, through their editorial and commercial activities. The BBC’s proposals to concentrate upon sport therefore again duplicate existing services and threaten commercial revenues.

81. There is also a danger that new exclusive arrangements could be negotiated as a result of the new BBC services between the BBC and sporting bodies or regional and local teams. These may be encouraged by the BBC’s existing national sports rights arrangements, combining exclusive coverage and its ability to offer unrivalled cross-promotion of the activities in which it is involved.

82. Indeed, the BBC has already indicated that it intends to develop its relationship with the Football Association. This could result in disruption of editorial and commercial arrangements between the local and regional press and local clubs and sports bodies.

83. It could also encourage more attempts by the football and other sports authorities to fortify their negotiations and exclusivity of deals on broadcast or online rights concluded with broadcasters, to the detriment of the independent press which are not party to such arrangements. For example, these bodies and venues already attempt to impose tight controls upon non-broadcast national media’s reporters and photographers’ access to matches, press conferences, interview opportunities, to curtail the non-broadcast national media’s editorial and commercial use of its reporters’ material, across its print and online activities - and have even attempted to regulate its actual control.

84. We note that the BBC specifically excludes sports material from its offer to make its audiovisual content freely available to all third parties.

Partnership

85. The NS and the industry do not accept the BBC’s suggestions that its offer of partnership either make its BBC Local Video service distinctive or could counterbalance the negative market impact of the proposal. 86. The BBC said that it could not replicate the depth of local news generated by the local press and so it originally pitched ‘partnerships’ as a way that its proposed services could benefit from the local newspapers’ journalism. When questioned as to whether the local newspaper could expect to be paid for its provision of copy, the response varied between statements that this would be forbidden to speculation that the usual ‘stringers’ rates might apply’.

87. One or two of the BBC’s past and future so-called ‘partnership’ proposals simply boil down to propositions that the BBC should actually acknowledge the newspaper titles as the source of stories which the BBC discuss or otherwise use on air or online.

88. The BBC cites a few examples of what it considers to have been ‘partnership arrangements’ with local and regional newspaper companies during the Midlands Project. We suggest that Ofcom and the BBC Trust should approach the newspaper companies concerned for their views on both the substance and outcome of the claimed initiatives. We are unaware of any support from the industry for the BBC’s Local Video Service based upon the prospect of partnership opportunities with the BBC.

89. Our members have commented individually upon the BBC’s offer of its material to third parties. There are concerns that the BBC could simply exploit this as yet another way to promote its own service. The BBC’s offer of free material might undercut the commercial sector. The BBC might be merely helping content aggregators and others establish regional and local commercial services, including advertising services, in direct competition with the regional industry, but free of any of the costs of journalism and content origination borne by the industry.

90. The proposal for a very modest community fund is also unlikely to benefit the industry. It could develop into yet another example of rival media subsidised from public funds. In this case, it would be the combined force of a publicly-funded BBC subsidising our industry’s regional, local and community competitors.’

[Extract from the Newspaper Society’s submission to the BBC Trust and Ofcom on the BBC Local Video Public Value Test, 12 August 2008]

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