BECTU response to ITC consultation on regional programming in ITV

14 June 2000

1. As with the ITC consultation on Public Service Broadcasting, BECTU is happy to submit some general views on this issue. However, we do not propose at this stage, to provide a full response to all the specific questions raised by the ITC, preferring to await the imminent debate on the Communications Reform White Paper and subsequent Bill.

2. We do, however, take the issue of regional programming in ITV very seriously and take the very choice of this issue for consultation as a sign of its significance in our broadcasting system.

   The regional identity of ITV

3. From its inception, the underlying rationale for ITV has been its regional character - in an otherwise seemingly unwieldy structure of 14 franchise regions, with additional sub-regions and opt-outs. Despite decades of development in broadcasting, ITV's distinctive feature remains its regional structure, regional franchise commitments and regional programme origination - unmatched in this respect by any new cable, satellite or digital channels.

4. We note that this regional structure rests on a regulatory base requiring sufficient regional programming (including news) and regionally-based proposals for network programming.

5. We also note that ITV regional output continues to be popular with viewers, performing strongly in the ratings on a like-with-like basis.

6. Finally, we observe that the facility for regional television production provides a strong base for the broader cultural sector in each of the franchise production centres. These regional economies benefit not just directly from the contribution of the ITV companies to their area but more broadly from the attendant focus of skills, creativity and talent from a skilled labour force and ancillary independent companies - bringing economic and cultural benefits over and above ITV's regional output itself. The estimate, quoted in the ITC paper, of 56,000 creative industries jobs based around Yorkshire TV, is one example of this.

   Regionalism under threat

7. We are concerned, however, at recent trends which have served to dilute the regional character of ITV. This has been demonstrated in a number of ways.

8. Firstly, we are concerned about ITV companies' failure to invest adequately in regional programming. In a number of areas there have been cutbacks in budgets and staffing to the detriment of regional output. BECTU's Report into ITV licence compliance (focussing on Granada TV, Ulster, Scottish and Grampian) sets out in some detail how such cutbacks have undermined regional licence commitments. This has already been presented to and discussed with the ITC.

9. The tendency, as noted in the ITC paper, has regrettably been towards cheaper programme formats, co-productions, common formats and using regional programmes as network pilots. In our view this was not helped by the recent Schedule Review and resulting decision to scrap News at Ten (with the consequent effects on regional programming adjacent to national news output).

10. Secondly, there has been a distinct and increasing focus of decision-making at the level of the Network Centre. This has had harmful scheduling effects on some regional output. More worryingly, increasing Network Centre autonomy has been accompanied by an increasing failure on the part of some ITV franchise holders to maintain network production levels (or to even attempt to bid for network output). On the ITC's own figures, 9 companies decreased their supply of programming for the network between 1993 and 1999, with 4 companies (Border, Channel, Grampian and Ulster) supplying no network output at all in 1999.

11. Thirdly, it is simply impossible to ignore the increasing concentration of ownership in ITV, with all the worrying implications this has for regional diversity. Granada, Carlton and United, together with Scottish, already dominate the network. On all current forecasts, concentration is likely to increase further to the point of perhaps two major players in the near future. This trend is already undermining the regional nature of ITV by concentrating decision-making at group level and eroding genuine regional autonomy on programming issues.

    How to protect regionalism

12. We currently operate in anticipation of new broadcasting legislation which - if most commentators are to be believed - is likely to lead to a relaxation of media ownership regulations. While reserving our position on ownership issues as such, we believe that any further such relaxation can only be contemplated if accompanied not by a weakening but a strengthening of regulatory requirements on regionalism.

13. We note but are not at this point convinced by ITC's suggestions on redefining licence commitments to allow more flexibility and a standardising minimum time allocation in the fewer mandated categories.

14. We are supportive of the ITV suggestions on:
    • requiring regional programme budgets to be held (at least) in real terms to the amounts agreed at licence renewal
    • requiring a minimum number of regional programme slots in and around peak-time
    • improving the reliability of relevant financial data supplied by licencees.

15. Our own priority, however, is different. Particularly in the event of any relaxation on ownership, we believe that stronger regulatory requirements on regional programme origination should be written into primary legislation rather than left to secondary regulation and discretionary commitments. In our view, given that regionalism is a key characteristic of ITV, a strong commitment in primary legislation would be the necessary quid pro quo for any further concentration of ownership. Without such unequivocal and visible legislative requirements, we believe that the current dilution of ITV regionalism will continue to the point when the channel's regional character is completely undermined. This should not be allowed to happen.

16. Any such commitment to regional programme origination should include:
    • A requirement for a full range of programming including regional news output but also many other programme strands.
    • A strong commitment to the full range of regionally-based staff and freelance labour and regional production facilities, to the exclusion of any notionally-regional productions made largely with London-based facilities and labour.
    • A requirement for a minimum level of contribution to network production from each franchise holder in proportion to their size.
    • A requirement for regionally based management with sufficient delegated powers and autonomy over regional programme production.

    Conclusion

17. We believe that a strong commitment to ITV regionalism is now necessary in primary legislation. Given other likely changes in our regulatory system - including the possible relaxation of ownership rules - this is the minimum necessary step for preserving the regional character of our major commercial channel.