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.