THE SNP submitted their views to Ofcom's consultation on the licensing of a new BBC Scotland channel which is due to launch next February.

Below is the SNP's full submission.


BBC Scotland channel consultation response

The SNP is cautiously optimistic about the creation of the new BBC Scotland channel.

We welcome the creation of new media jobs in Scotland and encouraged that the new channel will give a boost to the wider creative industries in Scotland. We are also hopeful that the new channel helps tackle the issues regarding BBC Scotland TV news output, as detailed in this submission report.

It is vital that Scottish audiences are well served, both by the BBC and the broadcasting sector in general. We support the BBC’s view that the new channel “should give audiences the choice of something entirely Scottish – that reflects all aspects of life in Scotland” and we acknowledge that this is presently missing.

The new channel's success should be judged against the public purpose set out in the BBC's Royal Charter which states the BBC must provide: "Impartial news and information to help people understand and engage with the world around them."

The BBC's own audience council surveys demonstrate that trust in the BBC is lowest in Scotland. The BBC itself has admitted that its coverage on the 2014 referendum lead to a loss of trust among a significant number of Scots. In effect many people in Scotland do not feel the public purpose to deliver impartial news and information is always being met in Scotland.

Since the referendum nearly four years ago we have seen no evidence of BBC Scotland delivering on its promise to increase the “trust” that it lost. Its own audience surveys two years after the referendum reflect this failure.

The new channel’s hour-long news output must show new thinking that positively changes people’s perception of the BBC in Scotland. It must deliver a product which helps to regain “trust” to the public service broadcaster.

We have set out five key points, including wider points and factors specific to the competition assessment, covering existing issues that should be at the forefront of considerations as BBC Scotland prepare to launch the new channel.


The creation of the new channel presents an opportunity to fill the current gap in Scottish coverage.

The news gap exists in the BBC’s coverage in three main forms:

a) Context: There is a lack of context in existing BBC Scotland TV news output. Scotland’s performance in areas of social policy are too often reported in isolation without detailed comparison to results across the regions and nations of UK, or other nations and regions. That is before any insight or investigation about the UK economy being one of the most unequal developed countries in the world. This gap reflects what many people believe to be the parochial nature of Reporting Scotland’s news output.

b) Disparity of focus: The SNP firmly support the role of Scotland’s media in scrutinising government and the political process and organisations. We recognise this as a necessary and important part of our democracy. The people of Scotland were told, repeatedly during the referendum campaign, that Scotland has two governments and two parliaments. And yet BBC Scotland’s news focus – particularly so with Reporting Scotland – is predominantly focused on negative aspects of matters concerning devolved powers. Conversely, the coverage of reserved matters including the impact of UK government decisions on the people of Scotland is given far less space and coverage. We have raised this matter about the two governments not being treated with the same scrutiny – with a number of specific examples – but have not yet received any sort of satisfactory explanation or response. Despite significant BBC Scotland resource at Westminster, not enough effort is made to scrutinize the UK government, its policies and their impact on the people of Scotland.

c) Network input: BBC Scotland is supposed to have a strong ongoing input for what the network covers, but there is little evidence of this in action. Often we have to nudge, sometimes persistently and often unsuccessfully, for devolved parts of UK-wide policy matters to be given due prominence on network news. In November 2015 the BBC appointed its first Scotland Editor. The BBC claimed the role would provide enhanced coverage and analysis of significant Scottish stories for a UK audience through the Six and Ten o'clock News, the Today programme, radio bulletins and the BBC News website. However, we doubt the UK audience would notice any difference in network coverage of Scotland two and a half years later.

An outward looking, high quality and properly funded Scottish news channel has the opportunity to remedy these issues.


A key public purpose in the BBC Charter states that the corporation must “...reflect, represent and serve the diverse communities of all of the United Kingdom’s nations and regions and, in doing so, support the creative economy across the United Kingdom”. We believe the BBC currently fails to deliver on this public purpose in Scotland, and the new channel must address and reverse this shortcoming. This has also been noted by industry professionals.

There has been a historical underspend on programming by the BBC in Scotland. In 2015/16 the BBC raised over £320 million from the licence fee in Scotland but only spent 54.6% of this revenue on programming in Scotland.

In 2017, the Screen Sector Leadership Report (SSLG), prepared by industry professionals and lead by former BBC Scotland controller John McCormick, stated: “A stronger commitment and greater investment from the BBC is essential to drive the development of television production in Scotland. 55% of the licence fee revenue raised in Scotland is spent in Scotland compared with 95% in Wales (not including licence fee investment in S4C) and 75% in Northern Ireland. The industry would be transformed if this deficit, equal to some £140m, were invested in work in Scotland.”

The budget for the new BBC Scotland channel, of £32 million per year, has raised public concerns about the quality and quantity of the output. Questions have been raised by production companies, media commentators and by the First Minister. Industry experts have raised concerns that the channel is ‘born to fail’. The Scottish Broadcasting Commission (2008) estimated the cost for such a project would be between £50-75 million. On these calculations there is a shortfall of tens of millions of pounds.

Greater control of broadcasting budgets in Scotland should transfer from Westminster to the Scottish Parliament. The creation of a new BBC Scotland TV channel in itself reopens the debate about the transfer of powers to Scotland. The new channel presents a unique opportunity for greater responsibility and budgetary control to be moved from BBC network to BBC Scotland. The new channel should be a test for this autonomy, while understood that the slim budget for year one is a decision from the BBC in London.

Beyond news, the increase in Scottish content has been driven by reports by Scottish Parliament committees. Various cross-party committee enquiries have shone a light on poor practise such as Lift and Shift – where programmes traditionally produced elsewhere are moved to Scotland in order to meet quotas – and the London centric nature of commissioning. We are encouraged that the BBC Charter addresses representation of the nations and the support for their creative industries, these principles should be at the forefront of the new channel’s direction and the budget it requires to succeed.

Confidence would be gained by proposed budget growth for year two and year three. This should be provisionally openly requested by the BBC in Glasgow and must adequately reflect an ambition of growth for Scotland. The BBC in London should meet this request and commit long term to this channel. It must not be allowed to fail due to a lack of investment.


In any democracy, the general public must have a choice of key broadcasting news options – and it is widely accepted that any kind of move towards a news monopoly would be retrograde. The impact of the BBC’s plans on their market share in Scotland should be independently reviewed on an ongoing basis.

The public value offered by a BBC Scotland channel should be balanced and justified by any potential adverse effects on competition.

STV have made public their concerns at the BBC’s dominance and pointed towards BBC Scotland’s expansion as part of the reason for the closure of STV2 and the loss of other jobs in the newsroom.

The BBC’s market share is lower in Scotland than in the rUK. So while there is no immediate threat of a monopoly, reassurances should be given to show that moves to extend their market share are sought through relevant high-value content and not at the expense of any potential reduction of alternative broadcasters or other traditional news sources within the wider market.


We understand BBC Scotland’s 9pm flagship news programme will be aimed at a broad audience and look to attract a greater share of the younger audience. Achieving this is vital. With the average age of Reporting Scotland’s audience understood to be 61, this highlights just how different the style, tone and content the new channel’s news output needs to be compared to existing BBC Scotland TV news.

The new programme must invest money and resource into unique high-quality content; it also must seek to be relevant to the political, cultural and social aspirations of Scotland’s younger and digitally engaged audience.

It has been suggested that the channel will be closely tied to BBC Scotland’s website and BBC Scotland’s digital output in order to engage and attract that younger audience. The web news output from BBC Scotland is often just a reflection of Reporting Scotland. It is vital that the new channel commands its own agenda and generates strong multi-platform content for the main BBC website and social media channels.


The much-vaunted 80 new jobs that the channel will create is of course welcomed but should not be at the expense of other media outlets.

The gender pay issue within the BBC is well documented. Within BBC Scotland the issue is even more prominent, with the gender bonus gap far bigger. The new channel must set out to ensure no gender pay gap exists in its staff from the outset.

There is an ongoing problem with BBC network resources, most notably a lack of working cameras located in and getting cameras to rural Scotland. A member of the senior management of the BBC in London recently told us it "wasn’t a good use of public money" getting a working camera to Skye. This is deeply concerning.

If, as has been suggested, the new channel will feed into the network and improve coverage so Scotland gains due prominence then we welcome this too. And comprehensive details showing how resources will be improved for the wider network to ensure fair and appropriate news coverage from all areas across Scotland would be welcome too.