Response by MG ALBA – 6th October 2015


1. Introduction

MG ALBA is short for Meadhanan Gàidhlig Alba (Gaelic Media Scotland) and is the operating name of Seirbheis nam Meadhanan Gàidhlig or Gaelic Media Service.

MG ALBA delivers BBC ALBA (the Gaelic language television channel) in partnership with the BBC. BBC ALBA is the first partnership television service to operate under a BBC licence.

BBC ALBA is a success. Audience figures are strong, with over 700,000 average weekly reach (MG ALBA, 2015). BBC iPlayer augments viewing – 7.43m views in 2014 (MG ALBA, 2015).

BBC ALBA is an important part of the Scottish broadcast ecology. PACT (the Producers’ Alliance for Cinema and Television) has estimated that BBC ALBA accounts for over 50% of all Scottish commissions by hour (PACT, 2010). The channel commissions 78% of its content from Scotland’s independent production sector (MG ALBA, 2014).

This submission first sets out MG ALBA’s proposal of increased BBC investment in BBC ALBA under the next charter. It then goes on to answer the specific questions raised in the Department of Culture, Media and Sport’s (DCMS) consultation document on BBC Charter Renewal.

2. General

Two principles inform MG ALBA’s response to the consultation on BBC Charter Renewal:

(i) the BBC is deficient in the way it is currently serving Scotland, and the BBC is deficient in the way it is currently serving Gaelic broadcasting. These are two separate issues; they should not be in competition in Scotland.

(ii) in order to address the current under-funding of BBC ALBA, and the audience deficiencies that arise as a consequence, the BBC must articulate a consistent philosophy on supporting its autochthonous language services across the UK as a whole.

2.1 BBC ALBA – Audience Deficit

The current funding of BBC ALBA creates significant audience deficits.

MG ALBA’s statutory remit includes the provision of a wide and diverse range of high quality Gaelic programmes. Since the channel’s inception, it has been the ambition for BBC ALBA to deliver at least 3 hours of original programming per day, in order to provide a full public service through the medium of Gaelic.

On current funding, only 1.7 hours of originations per day, including News, are possible. This compares to other autochthonous language services in the UK and Ireland as follows: almost 8 hours of originations per day on the Welsh channel, S4C (S4C, 2014/15), and 5 hours of originations on the Irish language channel, TG4 (TG4, 2014).

The lack of originations results in a high repeat rate. BBC ALBA’s current repeat rate is 73%.

In addition to an unsustainable repeat rate, this funding gap creates significant deficiencies for BBC ALBA audiences:

  • • there is no weekend news available in Gaelic;

  • • there is a significant lack of original programming for children and young people;

  • • there are gaps in comedy, entertainment and programming for learners.

A full, comprehensive service for the BBC ALBA audience is therefore not possible under the current funding settlement.

This deficit not only directly affects audiences, but also undermines the broader citizenship outcomes of Gaelic broadcasting, such as the channel’s contribution to the normalisation of Gaelic and Gaelic culture in Scottish society, related uptake of Gaelic language learning, and the stimulation of digital engagement through the medium of Gaelic, particularly relevant to Gaelic speaking young people.

It is MG ALBA’s view that continued under-investment in BBC ALBA will put at risk the enormous achievements of the channel so far: audience fatigue is a significant risk. This has repercussions not only for the channel, but also for the BBC and the status of the Gaelic language in Scotland.

The current funding model, whereby the BBC supplies 4.4 hours of originations per week, including News, served to establish the feasibility of the channel in its early stages. It is not however, a sustainable model. Nor is it a model which is capable of delivering the standards of quality and distinctiveness required of a channel which seeks to inform, educate and entertain Gaelic users in their own language.

2.2 BBC ALBA – Parity of BBC In-House Contribution Sought

MG ALBA asks that the BBC in-house programming contribution to BBC ALBA’s output should be increased to match that made by the BBC to S4C, on the basis of a consistent BBC philosophy on supporting its autochthonous language services across the UK.

In order to address the audience deficits set out above, MG ALBA proposes increased BBC investment.

Specifically, we ask that the BBC increase its programme contribution to BBC ALBA from the current 230 hours per annum to 520 hours p.a., or 10 hours of high quality programmes per week, to match that made by the BBC to S4C, i.e. 520 hours p.a.

2.3 BBC - Consistency of Approach to Autochthonous Languages

Decisions about the funding of BBC ALBA should be based on principles articulated by the BBC about its support of autochthonous language broadcasting.

It is MG ALBA’s view that the time is right for the BBC to articulate a consistent philosophy on supporting investment in autochthonous language programming.

A set of guiding principles in relation to BBC autochthonous language services is necessary in order to provide a coherent framework for consideration of the questions arising in relation to these languages and their respective services.

Such coherence is particularly relevant as these services, such as BBC ALBA, mature, and as the diversity of the UK, and its constituent nations, continues to evolve.

Such principles would be cognisant of:

  • • the distinct circumstances of each language; and

  • • the distinct funding mix of each service.

Equally, however, MG ALBA believes that such principles should include:
  • • an articulation of a ‘BBC autochthonous language service minimum standard’, including the minimum number of originations per day such a BBC service will provide for audiences;

  • • an articulation of the objectives of such services, including cognisance of the impact such services have beyond linguistic function, as demonstrated in Scotland by BBC ALBA’s significant success with the non-Gaelic audience;

  • • an articulation of the principle that the funding of BBC in-house programming for such services is separate to, and distinct from, the BBC’s commitment to English-language programming in Nations and Regions. Clarity on this point is required to make clear that funding for BBC ALBA is separate from the allocation of funding to address the deficit in English language programming in Scotland, and that the allocation of resource to BBC ALBA is in no way detrimental to BBC Scotland’s English language output; and

  • • a statement in relation to the PSB status of BBC ALBA in particular. Currently BBC ALBA is deemed to be a PSB by virtue of being a BBC channel, and not because it has PSB status conferred expressly by statute or by Royal Charter. This is inconsistent with other UK autochthonous language channels, such as S4C, which has PSB status conferred by statute. With that status comes the expectation of a comprehensive public service, including the full range of programme genres. BBC ALBA has no such status. The UK Government has adopted Article 11 of the European Charter for Regional or Minority Languages, including the obligation to provide a Gaelic language television channel. The constitutional requirement for the channel is therefore clear. The UK Government, Scottish Government and the BBC together fulfil this obligation through the BBC ALBA partnership. MG ALBA asks that the new Royal Charter be explicit about BBC ALBA’s PSB status, and therefore the resources which underpin its delivery.

3. Response to Green Paper

MG ALBA now considers the specific questions asked in the DCMS Charter Review consultation.

Why the BBC? Mission, purpose and values

Q1. How can the BBC’s public purposes be improved so there is more clarity about what the BBC should achieve?

MG ALBA agrees that the public purposes should have sharper focus. We specifically comment on the tightening of focus required around two of the Public Purposes: commitments to autochthonous languages, under Public Purpose 4; and on the BBC’s role regarding the stimulation of creative capital, under Public Purpose 3.

(i) Public Purpose 4. Representing the UK, its Nations, Regions and Communities.

MG ALBA believes this public purpose should be tightened, as indicated above, to provide consistency and clarity on (i) the specific objectives sought by the BBC’s autochthonous language services, and (ii) the minimum standard such services will provide.

MG ALBA has stated above its recommendation that the BBC establish guiding principles in order to ensure consistency in relation to its autochthonous language services.

Such guiding principles would underpin the increased investment sought by MG ALBA for BBC ALBA, and MG ALBA suggests these should be articulated in the context of Public Purpose 4.

There are specific metrics which MG ALBA suggests could underpin such principles, and enable the sharpening of focus required of Public Purpose 4.

These metrics would ensure that the direct objectives of such channels, as well as the broader citizenship functions services are properly captured – i.e. the extent to which they contribute to language revival, including through normalisation, as well as the initiation and maintenance of language learning:

  • • metrics such as a minimum number of hours of origination per day for BBC autochthonous language services;

  • • metrics which capture the recruitment of new learners to the language;

  • • other measures such as hours spent viewing, audience appreciation ratings and programme quality (as evidenced in nominations and awards);

  • • other non-broadcast impacts such as contribution to a more vibrant creative economy (see below).

(ii) Public Purpose 3: Stimulating Creativity and Cultural Excellence

The BBC’s role in relation to stimulating the creative economy has historically been framed in the context of Public Purpose 3.

MG ALBA believes that sharper focus on the BBC’s role as a facilitator for economic growth is required. MG ALBA believes this is particularly important in the context of Scotland, given the current weakness of its domestic content market.

BBC ALBA commissions 81% of its content from the independent production sector and is closely involved in the development of its supply sector (MG ALBA, 2014/15). MG ALBA is ambitious for the growth of its supply sector and its development strategy is focused on internationalisation – through co-production/co-commissioning and secondary sales.

MG ALBA’s most recent economic impact assessment found that the total impact of MG ALBA was 290 FTE jobs, and GVA of £12.5m (Matthew, 2015). Of this, around 100 jobs are based in the Outer Hebrides and Skye, with wages above average for the area.

In this context, it is important to note that this has been achieved by the MG ALBA/BBC partnership. The DCMS consultation paper on charter review refers to opportunities for partnership working. The partnership by which BBC ALBA operates is unique, and exemplifies what can be achieved through a BBC partnership - not only from the perspective of audience, editorial and operational track record, but also from the perspective of the stimulus delivered by the publisher-broadcaster model, including the very wide reach of the supplier footprint.

A clear statement about the BBC’s role in stimulating the creative industries in the Nations is required, and MG ALBA would urge that in this context, DCMS and the BBC are cognisant of the effect of a publisher-broadcaster partnership such as that of BBC ALBA.

The consultation paper also refers to wider sector support through training and skills. Again, this is something MG ALBA would welcome, not only as a direct partner, but also for the benefit of the wider Scottish broadcast ecology.

Q2. Which elements of universality are most important for the BBC?

Universality has the same meaning for the purposes of Gaelic broadcasting as it does for broadcasting in any medium: ‘sustained quality of programming, in a broad range of genres’ to paraphrase the Future of the BBC document published in September 2015.

In this context, BBC ALBA’s PSB status, or lack of it, is important. MG ALBA aspires to provide a full PSB service for Gaelic users. As noted above, the current framework does not expressly confer that PSB status, and the current funding settlement does not enable the provision of such. MG ALBA urges that both issues should be addressed as part of Charter Review: that PSB status be expressly included in the new Royal Charter, and that the BBC increase its contribution of in-house programming in order to provide such a PSB service for Gaelic users.

Q3. Should Charter Review formally establish a set of values for the BBC?

MG ALBA agrees that establishing a set of values would be useful, and would complement clarity on the BBC’s public purposes. The set of values set out at p19, Table 2 of the DCMS consultation document are acceptable: MG ALBA would also suggest adding the value consistency. The rationale behind including consistency as a value is that it relates to the parity point noted above: there should be consistency in the BBC’s approach to its autochthonous language services in different parts of the UK.

MG ALBA particularly welcomes the emphasis on diversity as a value. In addition to the urgent issues regarding the representation (on and off screen) of BAME, disabled people and women, MG ALBA would further emphasise the importance of the representation of the cultural diversity of the UK, including within each of the Nations themselves, to each Nation.

What the BBC does: scale and scope

Q4. Is the expansion of the BBC’s services justified in the context of increased choice for audiences? Is the BBC crowding out commercial competition and if, so, is this justified?

It is MG ALBA’s view that the BBC could serve its audiences better still with enrichment of existing services. Local reach could be better leveraged to reflect the diversity referred to above.

However, where commercial competition is highly active, the BBC should be less active.

Q5. Where does the evidence suggest the BBC has a positive or negative wider impact on the market?

Through the BBC ALBA partnership, and its predominantly publisher-broadcaster model, the BBC has a positive effect on the supply sector in Scotland.

As noted above, 81% of the channel’s content is sourced from independent production companies (MG ALBA, 2014/15), and PACT has estimated that the channel commissions 50% of commissions by hour in Scotland (PACT, 2010).

MG ALBA is ambitious for its supply sector and its development strategy has two principal objectives: (i) increasing the capacity of suppliers to co-produce/co-fund Gaelic originations (including other language versions for UK or international markets), thereby extending the impact of the existing public monies going into Gaelic broadcasting and drawing new investment into the sector in Scotland; and (ii) increasing the capacity of the sector to leverage its assets, including intellectual property rights. Internationalisation informs both these objectives. This will strengthen the sustainability of the sector. In doing so, MG ALBA is facilitating a culture of entrepreneurship and creative business leadership.

In addition to this, MG ALBA promotes sector sustainability through its long-term supply arrangements: it commits almost two-thirds of its commissioning budget to 3-year contracts. This allows companies to plan their finances, their staffing and their creative talent to greater effect, thereby also allowing the company to create a repertoire and collaborations with longer time horizons.

This positive effect on the content market in Scotland is further evidence of the value of BBC ALBA: it is more than a linguistic tick-box, it is a valuable tool which can reflect, and strengthen, cultural diversity, while at the same time delivering public policy objectives such as creative industries’ growth.

Q6. What role should the BBC have in influencing future technological landscape including in future radio switchover?

Q7. How well is the BBC serving its national and international audiences?

MG ALBA notes Scotland’s relatively low performance scores in ‘representing my nation/region in news/drama’.

In this context MG ALBA would like to emphasise the role played by BBC ALBA in Scotland. BBC ALBA enjoys consistently high appreciation levels, both within the Gaelic community, and with the channel’s national audience:

Scotland, Age 16+ Scotland, Age 16+ Positive General Impression (mean score out of 10)
BBC ALBA (Scotland wide) Jan – Aug 2015 7.1
BBC ALBA (Gaelic community 8.1

Source: BBC ALBA (Scotland-wide): TNS Scottish Opinion Survey for the BBC, 16+ adults living in Scotland, 2015. Monthly omnibus c. 1,000 respondents per wave. BBC ALBA (Gaelic community) by TRP panel of c. 350 16+, 2015.

As noted above however, without further investment, it will be increasingly challenging to sustain BBC ALBA’s appreciation ratings, and audience fatigue is a significant risk.

In the context of serving national audiences, we note the recent debate about English language provision in Scotland, and specifically the call for a separate, English language Scottish channel as proposed by Scotland’s First Minister in the Alternative MacTaggart lecture at the Edinburgh international Television Festival in August 2015. We note too the BBC’s proposal for the creation of an interactive digital service for each of the Nations of the UK (BBC, 2015).

MG ALBA recommends that discussions in relation to English language content in Scotland recognise:

  • (i) the existing value and success of BBC ALBA, for audiences and for the development of Scotland’s creative capital;

  • (ii) the opportunity for BBC ALBA to collaborate, as well as compete, according to genre; and

  • (iii) that MG ALBA has tested, and proved, the partnership model. This partnership model has proved good for Gaelic, good for audiences, and good for the production sector. Further partnership working has the potential to deliver more of these dividends.

A partnership strategic approach could also ensure that the structural barriers within Scottish broadcasting were addressed. This could include focus on content which (i) addresses public service content requirements; (ii) has the potential to be commercially successful on global markets – including through co-financing and co-production; and (iii) catalyses the development of the critical mass of skills and talent required for Scotland’s creative industries’ growth.

MG ALBA would like to address three points made on Box 6 on page 30:

BBC ALBA’s audience figures demonstrate significant success with the non-Gaelic audience. This is a notable achievement.

The metric ‘cost per listener hour’, suggests autochthonous language channels such as BBC Radio nan Gàidheal are disproportionately expensive. In fact, MG ALBA understands that BBC Radio nan Gàidheal, with a content budget of £3.7m (BBC Annual Accounts) has one of the lowest production costs per hour of any of the BBC’s National radio stations at less than £1000 per hour. Further, as noted above, the public value of such services can be measured by metrics in addition to those relating to cost: services such as BBC ALBA and BBC Radio nan Gàidheal add to the UK’s cultural diversity, a value that should be measured. MG ALBA suggests that the BBC consider measurement using UNESCO’s cultural diversity frameworks.

BBC One Scotland and BBC TWO Scotland are services which opt out of network provision, rather than channels per se.

In relation to international audiences, MG ALBA seeks international distribution for content to those outwith the UK with an interest in Gaelic programming. This is currently possible for BBC Radio nan Gàidheal but not for BBC ALBA. MG ALBA urges that the BBC be an ‘enabler’ of Gaelic heritage internationally as well as within the UK. Thus the public purpose of ‘Bring the UK to the World and the World to the UK’ should include the UK in the sense of all of its rich diversity, including its autochthonous languages. We believe that the combination of the “BBC” and the “Scotland” brand assets in an international context has not been tested and its development would represent a significant opportunity to bring “Scotland to the World”, to the benefit of audiences and citizens.

Q8. Does the BBC have the right genre mix across its services?

No. As noted above, BBC ALBA should be designated a PSB, with the expectation of the full range of programming a PSB would enjoy. Specifically MG ALBA notes the particular deficits created by the current funding settlement.

  • • Repeat rate of 73%;

  • • no weekend news available in Gaelic;

  • • a significant lack of original programming for children and young people; and

  • • gaps in comedy, entertainment and programming for learners.

Q9. Is the BBC’s content sufficiently high quality and distinctive from that of other broadcasters? What reforms could improve it?

As stated above, it is MG ALBA’s view that increased investment in BBC ALBA would significantly improve the quality and distinctiveness of its programming, and enable it to provide a PSB service for Gaelic users. In this regard, MG ALBA believes that the establishment of a minimum UK-wide standard for the BBC’s autochthonous language services, as part of the articulation of consistent principles on such services, would be helpful.

Q10. How should the system of content production be improved through reform of quotas or more radical options?

We wish to make four points:

  • • local markets

  • • quotas for network supply

  • • producer-based incentives

  • • international market mechanisms

The domestic production market in Scotland is significantly smaller than in many other countries of a similar size. Further, the work, such as it is, is in great measure short-term work. MG ALBA applies 2/3ds of its content budget to multi-annual production deals with independent producers. This gives stability to the sector, allows for planning, for investment, for the development of skills and talents in a planned way. This “sow to reap” approach involves a great deal of mutual trust between commissioner (MG ALBA) and producer, and by guaranteeing a certain volume of work, creates the conditions for the producers to develop their businesses, grow, and diversify their revenues. This cannot happen if the ecology is wholly “kill to eat”. A mixed ecology is required.

The current system of quotas for network supply does not foster the organic growth of the indigenous independent sector in Scotland, and arguably exacerbates the Nations/Regions portrayal performance gap that has been identified. It is essential for Scotland-based producers to make content for network, and therefore the current system must be made to work better or must be significantly improved by, for example, requiring the spend to be associated with or originated by indigenous producers. If the “lift and shift” system must be used, it should require the non-Scottish producer to partner with a Scottish production company before accessing Scottish quota funds.

Scotland’s television production sector is dominated by microbusinesses. While these survive because of PSB, they do not grow, because of issues of scale, of scope, of the cost-plus funding model, a lack of networks, a lack of market intelligence, the inherently insecure nature of the commissioning model, and the absence of effective fiscal stimulus. The countries with growing media production businesses have co-production funds (generally for cultural product or for international co-productions) and/or a tax relief or tax credit scheme. Many countries have both. While the Communications Act 2003 opened the door to allow independent producers to exploit programme IP, the fact is that – apart from the High End TV Tax Relief scheme and its extensions for animation and children’s – there is no producer incentive available for most players in our sector in Scotland. Without these incentives they stand at a considerable disadvantage in international markets, as they do not have the essential calling cards.

As such, the independent sector in Scotland, which generally faces to the BBC in Scotland for “opt-out” commissions in Scotland, or faces to the BBC in London or Salford (albeit often mediated by a local champion) for network commissions, needs a third way to face: directly towards the international markets, and without mediation other than the support and investment that a BBC Scotland Worldwide might provide.

MG ALBA therefore suggests that a different system be introduced to address both stimulation of the Scottish domestic market and representation issues. This could be addressed for example through a federalised BBC.

BBC Funding

Q11. How should we pay for the BBC and how should the licence fee be modernised?

MG ALBA is clear that it does not support subscription as an option for PSB delivery. Subscription will not enable the BBC to deliver content that provides social benefit as opposed to commercial return.

MG ALBA wish to play a role in discussions on the available options for funding PSB, including Gaelic broadcasting, in Scotland. MG ALBA has a particular interest in models that devolve the fiscal responsibility and parliamentary accountability to Scotland. We have an initial preference for a progressive form of licence fee paid by households, perhaps linked to Council Tax.

Q12. Should the level of funding for certain services or programmes be protected? Should some funding be made available to other providers to deliver public service content?

Funding for public service autochthonous languages such as BBC ALBA should be protected, not least because the UK would otherwise risk being in contravention of its treaty obligations under the European Charter for Regional or Minority Languages (ECRML).

As noted, BBC ALBA is the mechanism by which the UK Government implements its international obligations under Article 11 of the ECRML.

As stated above, through Charter review MG ALBA seeks clarity on both the channel’s status as a PSB channel, and increased BBC resourcing in order to deliver a comprehensive PSB service to Gaelic users. Again, we note that in contrast to Welsh language broadcasting, BBC ALBA has neither PSB status conferred by statute, nor does it have a statutory guarantee that the Secretary of State must ensure sufficient funding for the channel to accomplish its remit.

MG ALBA asks that the articulation by the BBC of consistent guidelines for its autochthonous services establish parity between the services.

Q13. Has the BBC been doing enough to deliver value for money? How could it go further?

MG ALBA notes the cuts that have been implemented by the BBC over recent years in order to achieve the savings the organisation was required to make. These included cuts in Scotland. MG ALBA notes the tension between such cuts, and the requirement of the BBC to reflect the cultural diversity of all of the UK, including but not limited to its autochthonous languages.

MG ALBA warns against cuts which so weaken the BBC infrastructure, including its critical mass of skills, that the very cultural diversity which the BBC should represent is unable to be reflected. This risks the creation in turn of a homogeneous version of UK cultural life, rather than communicating and celebrating the richness of the UK’s diversity, including within its Nations and Regions. Where cultural diversity is, by default, inhibited, there are risks of inhibiting in turn the very citizenship outcomes sought by public service broadcasting.

On a separate point, the MG ALBA and BBC partnership has created a highly efficient operating model which has delivered value for money. The current funding model, however, is unsustainable, as indicated above: not only will the high repeat rates (73%) increase audience fatigue, but major demographic segments remain significantly underserved.

Q14. How should the BBC’s commercial operations, including BBC Worldwide, be reformed?

BBC Worldwide takes negligible Gaelic programming, and little Scottish programming. This raises two questions:

  • (i) whether there is sufficient volume of Scottish programming; and

  • (ii) whether or not the remit of BBC Worldwide should be framed in the context of the BBC’s public purposes, specifically its obligations to stimulate creative industries’ growth across all of the UK, including supporting the growth of the Gaelic supply sector through internationalisation.

In terms of (i), MG ALBA’s internationalisation strategy includes the identification of content that could work on both the domestic channel and for the international market; and an increase in Scottish English-language programming would also increase the total volume of Scottish content.

It is MG ALBA’s view that the remit of BBC Worldwide should be framed as in (ii) above – a BBC Scotland Worldwide with its locus in the BBC’s public purposes and that works to stimulate creative industries’ growth across the whole of the UK, including explicitly supporting the growth and diversification of the creative supply sector in Scotland and investing in the internationalisation of Gaelic media content. Without that, an enterprise like RTÉ’s RTÉ Global or a body like ZDF Enterprises needs to be established in order to work the market for Scottish producers.

This reframing of BBC Worldwide and its role in relation to internationalisation could take place in the context of a more federal BBC structure.

As regards the proposals for BBC Studios, MG ALBA makes the following points:

  • (i) The Scottish domestic content market is weak. The rapid consolidation in the global content market which has seen UK independent companies as key acquisition targets and the emergence of mega-indies - which informs the BBC Studios proposal - does not represent the reality of the Scottish broadcast sector, including the Gaelic supply sector. On the contrary, and as noted above, the Scottish broadcast sector is dominated by micro-businesses, which survive because of Public Service Broadcasting (PSB), but do not grow for the reasons cited earlier. The BBC Studios proposal has been framed in the ‘UK as creative capital of the world’ narrative. This does not apply to Scotland. It is MG ALBA’s view that the BBC Studios proposal will create a two-tier production system, will exacerbate the gap between the Scottish production sector and the rest of the UK, and will hasten the decline of the Scottish production sector.

  • (ii) It is MG ALBA’s view that the BBC Studios proposal seriously risks undermining the BBC’s public purposes in relation to the Nations and Regions, both in terms of representation and in terms of its effect on creative industries’ growth.

  • (iii) In particular, MG ALBA notes that content development, and specifically content development in the Nations, can have a profound effect on growth within that domestic production sector. For example, the BBC’s decisions on where to locate particular genres have the potential to shape the growth of a region/Nation’s creative industries. It is MG ALBA’s view that the BBC Studios proposal pays insufficient regard to this point.

BBC Governance and regulation

Q15. How should the current model of governance and regulation for the BBC be reformed?

A federal structure

MG ALBA supports a federated BBC structure, at the level both of governance and of management.

This would enable the following issues to be addressed:

(i) representation of the unique diversity of each Nation, including the role of Gaelic broadcasting - thereby addressing concerns over the perceived Scottish representation gap;

(ii) the concern over the relative weakness of the Scottish supply sector.

Ofcom as regulator

The BBC Trust’s double role of ‘cheer-leader’ and 'editorial regulator' of the BBC is difficult to sustain. MG ALBA believes that an extension of Ofcom’s role as umbrella regulator of all UK broadcasting could be achieved without too much difficulty. As umbrella regulator it could interface more effectively with the impact of European broadcasting legislation on the broadcasting environment in the UK.

Also, due to the importance of the BBC in the PSB sector, especially in the UK nations, a federal BBC would necessitate a federal Ofcom. An Ofcom Scotland would be a very welcome development, allowing a better development of PSB and commercial services in Scotland in the context of Scotland’s audiences and Scotland’s creative sector.

Q16. How should the Public Value Tests and Service Licenses be reformed and who should have responsibility for making those decisions?

Q17. How could the BBC improve engagement with licence fee payers and the industry, including through research, transparency and complaints handling?

Q18. How should the relationship between Parliament, Government, Ofcom, the National Audit Office and the BBC work? What accountability structures and expectations, including financial transparency and spending controls, should apply?

The Scottish Parliament and the other devolved institutions should be included in this relationship matrix. The BBC should be accountable to each in the respective Nation.

The governance, management and editorial control of the BBC should continue to be exercised independently and by reference to the principles laid down in the Royal Charter. Those principles should, implicitly or explicitly, be consistent with targeted outcomes agreed with the UK and Scottish Governments and the other devolved administrations.

The UK does not in any way benefit from the somewhat fractious relationship that governments and political parties sometimes enjoy with the BBC. The BBC has a journalistic obligation to “hold power to account” and, with Ofcom as the only regulator, the management of complaints, for example of misreporting or bias, would be subject to more straightforward, transparent procedures.

The same accountability expectations should apply to the BBC as apply to other publicly funded bodies, allowing for commercial sensitivities.

Q19. Should the existing approach of a 10 Year Royal Charter and Framework Agreement continue?

MG ALBA supports the existing ten-year approach. A shorter timeframe - e.g. 5 years – jeapordises the stability possible through a ten year review period, and MG ALBA cautions against this. Similarly, some broader citizenship outcomes of Gaelic broadcasting, such as the channel’s contribution to the normalisation of Gaelic and Gaelic culture in Scottish society; related uptake of Gaelic language learning; and the stimulation of digital engagement through the medium of Gaelic, are more likely to be achieved across a longer period, and should be assessed across a longer time frame.




MG ALBA, 2014/15, MG ALBA Annual Report 2014/15

BBC, 2014/15, BBC Annual Report 2014/15

S4C, 2014/15, S4C Annual Report 2014/15

TG4, 2014, TG4 Annual Report 2014

PACT, 2010, February 2010, Response to DCMS Consultation on Reclassification of Production companies, https://www.pact.co.uk/support/document-library/documents/pact-reclasses-indies

Matthew, 2015, Economic Impact of MG ALBA, Reference Economic Consultants, 2015

BBC, 2015, BBC Charter Review, “British, Bold, Creative”, 7 September 2015 retrieved 27th September 2015 from http://downloads.bbc.co.uk/aboutthebbc/reports/pdf/futureofthebbc2015.pdf

HIE, 2014, Highlands and Islands’ Enterprise, Ar Stòras Gàidhlig, published November 2014, retrieved 15 December 2014 from http://www.hie.co.uk/community-support/support-for-gaelic-development/gaelic-research.html

Inside the BBC, 2014, Public Purposes: Reflecting UK Audiences, retrieved 11 September 2015 from http://www.bbc.co.uk/aboutthebbc/insidethebbc/whoweare/publicpurposes/communities.html

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