Ofcom Advisory Committee for Scotland Response to BBC Trust consultation on BBC nations' radio, BBC Alba and news and current affairs on TV and online in the devolved nations ‘The Advisory Committee for Scotland advises Ofcom about the interests and opinions, in relation to communications matters, of persons living in Scotland.’1 This response to the BBC Trust Consultation is from the Advisory Committee for Scotland (ACS). In no sense does it represent the views of Ofcom. However, it draws on the collective knowledge and expertise of the Advisory Committee for Scotland, informed by discussion at our meetings, the agendas and minutes of which are available on the Ofcom website. Summary The Ofcom Advisory Committee for Scotland considers that:- BBC TV and radio news and current affairs struggles to provide sufficient Scottish content, localness, depth, analysis and originality to meet PSB aims in Scotland. The ability of the current PSB system to meet the needs of Nations’ audiences with increasing devolution was highlighted as an area of concern in Ofcom’s 2015 PSB review 2. Funding is certainly part of the problem, dedicated services such as Radio Scotland receive significantly lower levels of funding than their counterparts in other nations3. The increasingly distinctive public policy agenda in Scotland is not adequately addressed by either BBC Scotland or Network output, where the recommendations in the King Review have yet to be fully implemented. It is hard to see how changes to BBC Scotland alone can solve this problem. There is a persistent measurable public purpose gap, with research from the BBC showing that only 48% of Scots think the BBC is good at representing their life in news and current affairs content, the lowest in the UK. The BBC continues to fail to adequately reflect and represent Scots both to themselves and to the rest of the UK.4 This is a reflection of the points made above and needs to be addressed, whether that be through the Charter Renewal process or another mechanism. 1 http://www.ofcom.org.uk/about/how-ofcom-is-run/committees/scotland/ 2 Page 15 http://stakeholders.ofcom.org.uk/binaries/consultations/psb-review- 3/statement/PSB_Review_3_Statement.pdf 3 http://stakeholders.ofcom.org.uk/binaries/research/cmr/cmr15/Scotland_3.pdf 4 Page 33, http://downloads.bbc.co.uk/annualreport/pdf/2014-15/bbc-annualreport-201415.pdf Introduction and striking a balance of BBC services Q2. The BBC tries to strike a balance between providing services at a local, national and UK-wide level. For example, some channels, such as Radio One, have a UK- wide reach, whereas others, such as BBC Radio Scotland, are only available in Scotland. How successful or unsuccessful do you think the BBC is at striking this balance? Very successful Quite successful Quite unsuccessful Very unsuccessful Don’t know Q3. Please explain why you think the BBC is successful or unsuccessful at striking this balance. While it is recognised that the BBC endeavours to deliver services at a UK wide, national and local level, the provision of services in Scotland appear to sit uneasily in this mix. BBC Scotland (TV and radio) tends to provide Scotland wide services (national) with very limited output at a local level (some limited radio local news opts). This is in stark contrast with the English regional output and local radio which reflect geographical diversity within the English regions. Scottish viewers/ listeners do not consume solely Scottish originated news and current affairs and there continue to be problems in ensuring that UK wide news and current affairs programmes (both on TV and radio) do not present an England only or England and Wales bias. There is not always adequate recognition of differences in devolved areas such as health, education, policing etc in ‘network news’. At times issues are still reported without reference to where they apply, which can cause confusion to audiences in Scotland. The lack of coverage of Scottish issues as part of UK wide news was particularly marked in the reporting of the Independence Referendum in Scotland in 2014, where BBC network news was perceived by many Scots to have engaged with the debate and the issues very late in the process. Even when it did so, it took a very different editorial view to that of BBC Scotland. This difference was clear to audiences in Scotland who consume both offerings on a daily basis, which may have contributed to the continuing belief by some that the BBC was at times biased in relation to its reporting on the Referendum. The BBC should consider how consumers of BBC output in different parts of the country experience the BBC as a whole when analysing its offer. The review of different parts of the output as separate issues (based around current Service Licences) does not adequately address the overall question of the Scottish audience’s needs, particularly in light of the increasingly distinctive public policy agenda. This is reflected in the persistent public purpose gaps that exist in Scotland, specifically in relation to the BBC reflecting or representing Scottish audiences both to themselves and to the wider UK. Consideration should therefore be given to the development of a cross-cutting ‘Service Licence for Scotland’ which would set out clear outcomes for Scottish audiences, to be tested across all services to ensure that this public purpose gap is addressed. BBC services for audiences in Scotland Q11. Which BBC services for Scotland do you use? Please tick all that apply. Radio Scotland Radio nan Gàidheal BBC Alba Scottish news and current affairs on television e.g. Reporting Scotland, Scotland 2015, BBC Scotland Investigates, Politics Scotland/Sunday Politics Scotland BBC Scotland online (www.bbc.co.uk/Scotland) BBC Scotland social media e.g. Twitter, Facebook I don’t use these BBC services for Scotland Q12. In a paragraph, please provide a summary of what you think about these BBC services for Scotland. BBC services in Scotland provide a range of output, variable both in terms of quality and public appreciation. Commercial radio in Scotland has a significant market share (48% in terms of listening hours, compared to 43% for England and 39% for Wales5)and Radio Scotland struggles both within that market and the wider BBC portfolio, see below. Gaelic output has a small but very loyal audience which relies on these services. Scottish news and current affairs programming is more mixed; Reporting Scotland continues to be the most watched news programme in Scotland. BBC Scotland Investigates produces high quality investigative journalism, however output here is very small in terms of broadcast hours and there is a lack of comparable radio based investigative journalism, perhaps due to budget constraints. Further detail on each of these points is given below. 5 Page 56, http://stakeholders.ofcom.org.uk/binaries/research/cmr/cmr15/Scotland_3.pdf Q13. BBC Radio Scotland’s remit is to: provide accurate, impartial and independent news; report and scrutinise national political life carry extensive sports coverage support Scottish music, culture and arts fully reflect the diverse faiths, cultures and communities of Scotland provide opportunities for informal learning across a wide range of subjects encourage participation. How well do you think BBC Radio Scotland does this? Radio Scotland’s remit (as outlined above) is extremely broad given it has a limited budget of just £21.9m in 2015/16. The amount spent by the BBC on local/nations content radio in Wales in 2014-15 was £14.7 per head of population while in Scotland it was just £4.776. This difference is sometimes attributed to the larger population in Scotland diluting the spend further, but it should be noted that Scotland has under twice the population of Wales, but nearly four times the area, with very diverse communities across that area, ranging from urban Glasgow or Aberdeen to very remote island communities. Scotland has a single national station (with minimal regional opts) to serve the whole of that audience’s needs. Within these budget constraints, Radio Scotland achieves reasonable coverage of news, current affairs and sport, subject to the points made above. There is currently a tendency to rely on repetitive programming – speech based during the day and music based in the evening. The ACS considers that it is not possible to produce a high quality speech based radio station without more resources. Radio Scotland appears to lack an identity - falling between speech and music, national and local and does not serve any audience particularly well. This may contribute to the fact that local/nations commercial radio in Scotland accounts for 34% of all listening, 4% higher than the UK average, while BBC local/nations listening in Scotland is the same as the UK average, and BBC network listening is 6% below the UK average7. Within this, Radio 2 also does well in Scotland (increasing share year on year). The ACS considers Radio Scotland would benefit from more features and reports, more investigative journalism and documentary style programmes, greater local opts and/or features and an improved mix of speech and music. It may be that the Radio Scotland model has had its time and that a more radical rethink of how the BBC addresses Scottish radio audiences might be undertaken. Q14. BBC Radio nan Gàidheal’s remit is to: 6 Page 59 http://stakeholders.ofcom.org.uk/binaries/research/cmr/cmr15/Scotland_3.pdf 7 Page 56 http://stakeholders.ofcom.org.uk/binaries/research/cmr/cmr15/Scotland_3.pdf provide accurate, impartial and independent news report and scrutinise national political life provide coverage of sport in Scotland support Scottish and Gaelic music and arts and broadcast occasional drama fully reflect the diverse faiths, cultures and communities of Scotland offer formal and informal education and support Gaelic learners offer a platform for the Gaelic-speaking communities of Scotland and encourage participation from listeners.