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/-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. , 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 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.

How well do you think BBC Radio nan Gàidheal does this?

In the 2011 census 58,000 Gaelic speakers were identified in Scotland (just over 1% of the population), the majority being in the Western Isles and in the North and West Highlands. RnG has a dedicated audience within this part of the Scottish population. News and current affairs is a particularly important aspect of RnG output and it is noted that the station is able to draw on Gaelic speakers from across the globe very effectively.The station does however draw largely an older audience and much more will need to be done to ensure that it remains relevant in engaging with younger Gaelic speakers.

The ACS notes that 1.5m people in Scotland regularly speak Scots, and the census identified a wide range of other languages spoken (e.g. Urdu, Punjabi and Polish), and yet there are no specialist programmes for them. This should be a consideration when planning future radio programming.

Q15. BBC Alba’s remit is to:

 provide output for speakers and learners of Gaelic  reflect, strengthen and promote Gaelic cultural heritage  offer programming for pre-school and older children  provide opportunities for informal learning  provide accurate, impartial and independent news and current affairs  support Scottish music and arts

How well do you think BBC Alba does this?

The ACS recognises the role that Gaelic as a minority language plays in terms of the consciousness of Scotland as a nation. BBC Alba has an important role in contributing to national awareness of the language and aiding the growth in Gaelic learners, essential to maintaining the language.

BBC Alba currently attracts between 70-80% of the intended audience. It is noted that the Gaelic community audience is split evenly between the Highlands and Islands, and the rest of Scotland. However, it is also noted that recent changes to iPlayer (listings moved from channel to genre making programmes harder to find), as well as poorer broadband access and speeds in the core audience’s geographic areas are providing a challenge for the channel.

Learning, soft learning and news are the programme types most appreciated by the core Gaelic audience. However, appreciation and viewing by this core audience is anticipated to fall as the level of repeats, which is already high, continues to increase. There also remain challenges in engaging with younger audiences. This latter point is not helped by constrained budgets meaning limited ability to produce short form content for online. Broadband limitations also particularly affect accessibility for younger audiences who more likely to access content via iPlayer.

From a cultural policy perspective, in terms of transitioning from viewing to learning, the ACS would support the embedding of the channel within the next Charter for the BBC and would support recent calls for an increase in originations. These currently sit at 479 hours per year8 as compared to S4C in Wales (1929 hours of originations per year)9 or TG4 in Ireland (1821 hours per year)10.

Q16. Which, if any, of BBC Scotland’s television news or current affairs coverage do you watch? Reporting Scotland Scotland 2015 BBC Scotland Investigates Politics Scotland/Sunday Politics Scotland I don’t watch BBC Scotland’s news or current affairs programmes UK wide news e.g. BBC News at Six; BBC News at Ten Other (please specify below)

Q17. What do you think about BBC news and current affairs on television in Scotland?

Scottish audiences consume news and current affairs which originate from both London and Scotland and they do not necessarily differentiate between the two. The terms of reference of a review such as this (or indeed the previous reviews of network news or speech radio) require a division to be made which does not necessarily reflect the audience’s needs or experiences.

Network news by default tends to treat English news as UK news, and is weighted towards London and the south-east within England itself. It frequently fails to recognise public policy variations in Scotland. Many of the recommendations of the 2008 King report11 are still relevant today. In addition, topics such as the Scottish Independence Referendum in 2014, immigration, or the forthcoming EU Referendum are often viewed by Scottish audiences as being reported on in a ‘Londoncentric’ way by network news. Reporting Scotland, as already noted, continues to be the most viewed television news programme in Scotland and the ACS considers it provides generally good quality coverage of Scottish news. It fails however to deliver

8 http://www.mgalba.com/downloads/reports/annual-report-14-15.pdf 9 http://www.s4c.cymru/abouts4c/annualreport/acrobats/s4c-annual-report-2015.pdf 10 http://s3.amazonaws.com/tg4-docs/tg4-redesign-2015/wp-content/uploads/2015/07/TB2014-B.pdf 11 http://www.bbc.co.uk/bbctrust/our_work/editorial_standards/impartiality/network_news.html#heading- bbc-trust-impartiality-report the level of ‘local’ news demanded by audiences, particularly outwith the Central Belt. The success of the move from Scotland, which had underperformed for some time, to Scotland 2015, now has been mixed. The ACS considers there remains a demand for analytical and investigative journalism in relation to Scottish issues that has yet to be addressed by the current news and current affairs offer in Scotland.

As stated above, the balance between UK wide, national and local news on television which meets the needs of the Scottish audience in terms of both geographical coverage and depth of analysis remains a challenge which has yet to be properly addressed by the BBC as a whole. Changes to BBC Scotland alone cannot solve this problem.

Q18. What do you think about the BBC’s online site for Scotland or the Scottish news you can choose to get through the BBC’s News app?

BBC online in Scotland continues to expand, with considerable growth in use attributed to coverage of the Scottish Independence Referendum, where a greater quantity of content and analysis was available online than through traditional news sources. This particularly addressed the needs of younger audience members, with anecdotally considerable uptake via mobile news apps. The ACS however suggests that there is scope to continue to improve the offer in Scotland, with a higher level of explanation of complex issues (e.g. local government spending and the relative impacts of Council Tax freezes in different areas) and greater investigation and scrutiny of issues (eg Curriculum for Excellence) and institutions (eg Police Scotland) as they impact on Scotland. This is needed to match the increasing levels of devolution and the recent passage of the new Scotland Act. It is likely to be particularly important as Scottish print journalism is in a period of decline.

The ability within the BBC News App to personalise content and to select ‘Scotland’ as an interest means that Scottish news is easily accessible in this format. In growing this area further however there does however need to be recognition of the continuing problems of broadband and mobile coverage in rural, urban and peri- urban Scotland. Access and affordability also remain key issues for many in more deprived areas.

Q19. What do you think about the news and information available from BBC Scotland through social media sites, such as Twitter or Facebook?

Social media can provide a useful tool for accessing news stories. However, the fact that BBC Scotland alone has 10 separate Twitter handles depending on users interests (e.g. 4 covering news/ current affairs, 1 each for weather, travel, sport, Radio Scotland, SSO etc.) is likely to mean that infrequent or casual Twitter Users are missing out, due to lack of knowledge. The ACS suggest that this be reviewed to see if it is possible to make it more transparent and easily accessible.

Ofcom Advisory Committee for Scotland, January 2016