Consultation 
on 
draft 
Party 
Political 
Broadcasts 
policy 


December 
2011 


Getting 
the 
best 
out 
of 
the 
BBC 
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bbc.co.uk/bbctrust 



CONSULTATION: 
Draft 
Party 
Political 
Broadcasts 
policy 


Background 


The 
BBC 
is 
required 
to 
broadcast 
party 
political 
broadcasts 
(referred 
to 
as 
PPBs 
in 
this 
document) 
on 
some, 
or 
all 
of 
its, 
UK 
Public 
Broadcasting 
Services.1 


The 
BBC 
Trust 
(which 
is 
the 
governing 
body 
of 
the 
BBC 
and 
is 
separate 
and 
independent 
from 
the 
day-to-day 
management 
of 
the 
BBC) 
must 
determine 
which 
UK 
Public 
Broadcasting 
Services 
should 
transmit 
PPBs 
and 
the 
basis 
on 
which, 
and 
the 
terms 
and 
conditions 
subject 
to 
which, 
they 
should 
be 
included 
(the 
latter 
being 
referred 
to 
as 
PPB 
allocation 
criteria).2 


The 
BBC 
Executive 
Board 
(the 
Executive)3 
is 
responsible 
for 
determining 
PPB 
allocations 
in 
accordance 
with 
the 
PPB 
allocation 
criteria 
approved 
by 
the 
Trust. 


The 
BBC 
Trust 
proposes 
putting 
in 
place 
a 
new 
policy 
detailing 
the 
criteria 
for 
the 
allocation 
and 
timing 
for 
party 
political 
broadcasts 
to 
registered 
political 
parties.4 
This 
public 
consultation 
seeks 
views 
on 
this 
new 
proposed 
policy. 


The 
Trust’s 
role 
is 
to 
approve 
the 
criteria 
by 
which 
parties 
are 
allocated 
a 
PPB 
and 
the 
basis 
on 
which 
they 
should 
be 
broadcast. 
It 
is 
the 
role 
of 
the 
BBC 
Executive 
to 
apply 
the 
criteria 
approved 
by 
the 
Trust 
as 
to 
which 
political 
parties 
qualify 
for 
a 
PPB 
and 
then 
liaise 
with 
the 
political 
parties 
around 
the 
specific 
scheduling 
of 
their 
broadcast. 
Any 
complaints 
regarding 
allocation 
are 
directed 
to 
the 
Executive 
in 
the 
first 
instance. 
If 
the 
complainant 
remains 
dissatisfied, 
the 
Executive's 
decision 
may 
be 
subject 
to 
appeal 
to 
the 
Trust. 
Details 
of 
the 
complaints 
procedure 
can 
be 
found 
here: 


http://www.bbc.co.uk/bbctrust/assets/files/pdf/our_work/rcb/complaints_proce 
ss.pdf 


1 
UK 
Public 
Broadcasting 
Services 
is 
defined 
in 
clause 
104 
of 
the 
Agreement 
to 
be 
‘those 
UK 
public 
services 
which 
consist 
of 
television 
programme 
services 
and 
radio 
programme 
services’. 
2 
see 
Clause 
48 
of 
the 
Agreement. 
3 
The 
BBC 
Executive 
Board 
is 
responsible 
for 
the 
day-to-day 
operation 
of 
the 
BBC. 
4 
PPBs 
are 
one 
type 
of 
party 
political 
broadcast. 
Party 
election 
broadcasts 
and 
referendum 
campaign 
broadcasts 
are 
not 
included 
in 
this 
policy. 



Legislative 
Framework 


Section 
48 
of 
the 
Agreement 
between 
the 
Government 
and 
the 
BBC 
details 
that: 


“(1) 
The 
BBC 
must 
include, 
in 
some 
or 
all 
of 
the 
UK 
Public 
Broadcasting 
Services, 
party 
political 
broadcasts 
[and 
referendum 
campaign 
broadcasts.] 


(2) 
The 
Trust 
must 
determine— 
(a) 
which 
of 
the 
UK 
Public 
Broadcasting 
Services 
are 
in 
principle 
to 
include 
party 
political 
broadcasts 
[and 
referendum 
campaign 
broadcasts]; 
and 
(b) 
the 
basis 
on 
which, 
and 
the 
terms 
and 
conditions 
subject 
to 
which, 
such 
broadcasts 
are 
to 
be 
included 
in 
them. 
(3) 
In 
particular, 
the 
Trust 
may 
determine, 
so 
far 
as 
they 
are 
permitted 
so 
to 
do 
by 
sections 
37 
and 
127 
of 
the 
Political 
Parties, 
Elections 
and 
Referendums 
Act 
2000 
(only 
registered 
parties 
and 
designated 
organisations 
to 
be 
entitled 
to 
party 
political 
broadcasts 
[or 
referendum 
campaign 
broadcasts])— 
(a) 
the 
political 
parties 
on 
whose 
behalf 
party 
political 
broadcasts 
may 
be 
made; 
and 
(b) 
the 
length 
and 
frequency 
of 
party 
political 
broadcasts 
[and 
referendum 
campaign 
broadcasts].” 
Party 
Political 
Broadcasts 
– 
current 
position 


In 
England, 
Scotland 
and 
Wales, 
PPBs 
are 
currently 
offered 
to 
qualifying 
political 
parties 
and 
the 
timing 
of 
broadcasts 
is 
linked 
to 
specific 
political 
events, 
such 
as 
the 
party 
conferences 
and 
the 
Queen’s 
Speech. 


In 
addition, 
there 
has 
been 
a 
broadcast 
from 
the 
Chancellor 
of 
the 
Exchequer 
on 
Budget 
day, 
followed 
by 
a 
response 
from 
Opposition 
parties. 


In 
Northern 
Ireland 
qualifying 
parties 
are 
offered 
one 
PPB 
in 
the 
period 
of 
September 
to 
March. 


Our 
proposal 


Allocation 


We 
propose 
that 
the 
existing 
criteria 
for 
the 
allocation 
of 
PPBs 
do 
not 
change. 


Full 
details 
of 
these 
criteria 
are 
detailed 
in 
the 
proposed 
criteria 
document 
but, 
in 
summary, 
these 
state 
that 
registered 
political 
parties 
will 
qualify 
for 
a 
PPB 
if 
they: 


1. 
have 
a 
minimum 
level 
of 
representation 
at 
a 
national 
level; 
and 
2. 
can 
demonstrate 
substantial 
levels 
of 
electoral 
support 
across 
a 
series 
of 
elections 
(in 
the 
relevant 
nation) 
BBC 
Trust 
Party 
Political 
Broadcasts 
Consultation 
page 
2 


It 
is 
the 
role 
of 
the 
BBC 
Executive 
to 
apply 
the 
criteria 
approved 
by 
the 
Trust 
as 
to 
which 
political 
parties 
qualify 
for 
a 
PPB 
and 
then 
liaise 
with 
the 
political 
parties 
around 
the 
specific 
scheduling 
of 
their 
broadcast. 


In 
determining 
substantial 
electoral 
support 
across 
a 
series 
of 
elections 
for 
the 
allocation 
of 
PPBs, 
examples 
of 
the 
evidence 
that 
will 
be 
taken 
into 
account 
by 
the 
Executive 
are: 


• 
Performance 
in 
different 
types 
of 
elections 
in 
terms 
of 
number 
of 
seats 
held 
and 
share 
of 
the 
vote; 
• 
Levels 
of 
support 
in 
recent 
elections; 
• 
Changed 
circumstances 
(for 
example, 
the 
formation 
of 
new 
parties 
or 
party 
splits). 
This 
is 
not, 
however, 
an 
exhaustive 
list. 


The 
BBC 
has 
used 
the 
term 
'substantial 
electoral 
support' 
as 
a 
criterion 
for 
determining 
the 
allocation 
of 
PPBs 
for 
the 
last 
18 
months, 
as 
well 
as 
for 
Party 
Election 
Broadcasts 
(PEBs) 
for 
a 
number 
of 
years, 
and 
for 
ensuring 
fairness 
in 
the 
allocation 
process. 
Evidence 
taken 
into 
account 
in 
allocating 
PPBs 
and 
PEBs 
is 
similar, 
however, 
the 
due 
weight 
given 
to 
that 
evidence 
differs 
because 
PEBs 
are 
tied 
to 
a 
particular 
election. 
The 
Trust 
considers 
that 
‘substantial 
electoral 
support’ 
is 
well-established 
and 
understood 
by 
those 
eligible 
for 
a 
PEB 
and 
a 
PPB. 
This 
has 
in 
the 
past, 
for 
example, 
provided 
PEBs 
for 
what 
are 
considered 
to 
be 
the 
main 
political 
parties, 
as 
well 
as 
other 
political 
parties. 
However, 
it 
also 
allows 
sufficient 
flexibility 
in 
the 
system 
to 
appropriately 
take 
into 
account 
changing 
circumstances 
as 
the 
political 
environment 
develops. 


It 
is 
important 
that 
an 
appropriate 
benchmark 
is 
set 
for 
the 
allocation 
of 
PPBs 
to 
political 
parties. 
The 
combination 
of 
actual 
representation 
in 
a 
legislative 
chamber 
and 
sustained 
electoral 
support 
seems 
proportionate. 


Seasonal 
broadcasts 


We 
propose 
removing 
the 
connection 
between 
the 
time 
of 
broadcast 
of 
PPBs 
and 
specific 
political 
events 
and 
instead 
offering 
qualifying 
parties 
in 
England, 
Scotland 
and 
Wales 
PPBs 
on 
a 
‘seasonal’ 
basis 
in 
autumn, 
winter 
and 
spring. 


Acknowledging 
the 
different 
context 
in 
Northern 
Ireland, 
we 
are 
proposing 
either 
(i) 
retaining 
the 
current 
policy, 
whereby 
qualifying 
parties 
in 
Northern 
Ireland 
are 
allocated 
one 
PPB 
in 
the 
period 
of 
September 
to 
March 
or 
(ii) 
offering 
qualifying 
parties 
two 
PPBs 
in 
that 
period. 


This 
proposal 
includes 
the 
removal 
of 
Budget 
broadcasts, 
although 
qualifying 
parties 
may 
choose, 
if 
they 
wish, 
to 
schedule 
their 
seasonal 
broadcast 
around 
the 
Budget, 
subject 
to 
scheduling 
considerations 
(see 
below). 


BBC 
Trust 
Party 
Political 
Broadcasts 
Consultation 
page 
3 


Why 
are 
we 
proposing 
this 
change? 


The 
existing 
system 
for 
scheduling 
PPBs 
follows 
historic 
practice 
and 
does 
not 
take 
into 
account 
changes 
to 
the 
political 
environment 
over 
the 
years, 
such 
as 
the 
televising 
of 
parliament 
and 
progress 
of 
devolution. 


Now 
the 
Welsh 
Assembly 
and 
Scottish 
Parliament 
are 
established, 
it 
is 
not 
obvious 
why 
there 
should 
be 
a 
different 
number 
of 
PPBs 
throughout 
the 
year 
in 
different 
parts 
of 
the 
UK. 


We 
recognise 
that 
there 
is 
a 
different 
context 
in 
Northern 
Ireland 
that 
justifies 
differential 
treatment. 
This 
lies 
in 
the 
fact 
that 
the 
political 
structure 
in 
Northern 
Ireland 
is 
different 
from 
the 
rest 
of 
the 
UK 
(which 
could 
give 
rise 
to 
some 
impartiality 
issues) 
and 
that 
the 
different 
timing 
of 
devolution 
in 
Northern 
Ireland 
has 
meant 
the 
practice 
of 
PPBs 
only 
began 
relatively 
recently. 


We 
also 
recognise 
that 
for 
some 
political 
parties, 
especially 
in 
Northern 
Ireland, 
PPBs 
may 
present 
a 
financial 
difficulty 
and 
that 
too 
could 
give 
rise 
to 
impartiality 
issues. 


We 
are 
therefore 
consulting 
on 
whether 
qualifying 
parties 
in 
Northern 
Ireland 
should 
be 
offered 
an 
additional 
PPB 
or 
whether 
the 
current 
allocation 
of 
one 
PPB 
should 
remain. 


Linking 
PPBs 
with 
events 
has 
meant 
parties 
being 
offered 
fewer 
PPBs 
in 
years 
(such 
as 
2011) 
when 
there 
was 
no 
Queen’s 
Speech, 
as 
well 
as 
uncertainty 
over 
timing. 
The 
government’s 
decision 
to 
move 
the 
Queen’s 
Speech 
to 
“Spring” 
means 
this 
is 
no 
longer 
appropriate, 
as 
it 
is 
likely, 
most 
years, 
to 
fall 
either 
just 
before 
or 
just 
after 
the 
beginning 
of 
an 
election 
period, 
when 
PPBs 
cannot 
be 
broadcast 
(because 
that 
is 
when 
Party 
Election 
Broadcasts 
are 
scheduled). 


The 
Trust 
is 
of 
the 
provisional 
view 
that 
current 
practice 
behind 
Budget 
broadcasts 
is 
also 
outdated. 
The 
BBC 
has 
no 
obligation 
under 
its 
Charter 
or 
Agreement 
to 
offer 
a 
Budget 
broadcast 
and 
believes 
it 
no 
longer 
serves 
the 
audience 
for 
the 
intended 
purpose. 
The 
broadcasts 
originated 
when 
there 
was 
neither 
TV 
nor 
radio 
available 
from 
the 
chamber 
of 
the 
House 
of 
Commons 
and 
the 
Budget 
broadcast 
was 
the 
only 
way 
in 
which 
the 
Chancellor 
could 
be 
seen 
and 
heard 
communicating 
directly 
to 
the 
public 
the 
content 
of 
the 
budget. 
Now 
the 
audience 
has 
the 
opportunity 
to 
watch 
and 
listen 
to 
the 
Chancellor 
live 
in 
the 
House 
of 
Commons, 
or 
to 
catch 
up 
on 
iPlayer, 
or 
to 
see 
and 
hear 
the 
key 
points 
across 
many 
different 
outlets. 
It 
is 
the 
Trust’s 
provisional 
view 
that 
in 
a 
devolved 
UK, 
allocating 
separate 
PPBs 
which 
are 
broadcast 
by 
nation 
is 
fairer 
and 
more 
consistent 
than 
the 
current 
system 
for 
the 
Budget 
broadcast 
(in 
which 
the 
UK 
government 
and 
Official 
Opposition 
transmit 
UK-wide 
broadcasts, 
the 
SNP 
and 
Plaid 
Cymru 
have 
broadcasts 
which 
are 
specific 
to 
Scotland 
and 
Wales 
respectively). 


BBC 
Trust 
Party 
Political 
Broadcasts 
Consultation 
page 
4 


We 
provisionally 
consider 
that 
the 
BBC 
should 
have 
in 
place 
a 
policy 
that 
accommodates 
such 
changes 
and 
creates 
a 
consistent 
approach 
to 
allocation 
and 
scheduling 
across 
England, 
Scotland 
and 
Wales, 
as 
well 
as 
a 
fair 
approach 
for 
Northern 
Ireland. 


What 
would 
the 
proposed 
changes 
mean 
in 
practice? 


Since 
devolution 
began, 
Scotland 
and 
Wales 
have 
had 
an 
extra 
PPB 
in 
the 
spring. 
The 
BBC 
proposes 
to 
bring 
England 
in 
line 
with 
the 
rest 
of 
Great 
Britain 
and 
offer 
a 
PPB 
in 
spring. 
In 
practice 
this 
would 
mean 
qualifying 
parties 
in 
England, 
Scotland 
and 
Wales 
would 
each 
receive 
three 
PPBs 
per 
year. 
One 
in 
spring, 
one 
in 
autumn 
and 
one 
in 
winter.5 


Since 
PPBs 
were 
introduced 
in 
Northern 
Ireland, 
qualifying 
parties 
have 
received 
one 
PPB 
per 
year. 
We 
are 
consulting 
on 
whether 
that 
allocation 
should 
be 
increased 
to 
two 
PPBs 
in 
the 
period 
of 
September 
to 
March 
(excluding 
December). 


As 
previously, 
PPBs 
would 
be 
broadcast 
in 
the 
relevant 
nation 
on 
BBC 
One 
and 
BBC 
Two. 


PPBs 
would 
no 
longer 
be 
necessarily 
tied 
to 
the 
party 
conferences 
or 
the 
Queen’s 
Speech, 
nor 
would 
there 
be 
a 
series 
of 
Budget 
broadcasts 
tied 
to 
the 
Budget 
statement 
in 
the 
House 
of 
Commons. 
However, 
qualifying 
parties 
may 
choose, 
if 
they 
wish, 
to 
schedule 
their 
seasonal 
broadcast 
around 
such 
events, 
subject 
to 
scheduling 
considerations 
(see 
below). 


It 
is 
proposed 
that 
the 
duration 
of 
PPBs 
and 
the 
precise 
scheduling 
will 
remain 
an 
operational 
matter 
for 
the 
BBC 
Executive 
and 
not 
the 
Trust. 
The 
Executive 
works 
with 
the 
Broadcasters’ 
Liaison 
Group6 
on 
the 
detailed 
arrangements 
of 
scheduling, 
duration 
and 
Production 
Guidelines 
and 
the 
Trust 
expects 
that 
any 
such 
guidance 
will 
be 
consistent 
with 
the 
requirements 
of 
any 
final 
Trust 
policy 
on 
PPB 
allocation. 
For 
instance, 
application 
of 
BLG 
Production 
Guidelines 
has 
in 
previous 
years 
meant 
that 
PPBs 
can 
be 
either, 
2’40’’, 
3’40’’ 
or 
4’40’’ 
in 
duration 
(with 
duration 
a 
matter 
of 
choice 
for 
the 
parties). 


5 PPBs would not be scheduled during election periods and may be cancelled or postponed if elections or 
by-elections are called. 

6 The Broadcasters' Liaison Group was formed in 1997 and is comprised of representatives of each of the 
broadcasters who make airtime available to registered political parties. The Electoral Commission also 
sits on the BLG as an observer. 

BBC 
Trust 
Party 
Political 
Broadcasts 
Consultation 
page 
5 


About 
this 
consultation 


This 
consultation 
will 
allow 
the 
Trust 
to 
take 
into 
consideration 
the 
views 
of 
registered 
political 
parties, 
relevant 
organisations 
such 
as 
the 
Electoral 
Commission, 
together 
with 
other 
regulatory 
bodies, 
broadcasters 
and 
members 
of 
the 
public 
in 
determining 
whether 
the 
proposed 
PPB 
policy 
should 
be 
approved. 


PPBs 
are 
also 
provided 
by 
ITV 
and 
S4C, 
who 
are 
members 
of 
the 
Broadcasters’ 
Liaison 
Group. 
ITV 
is 
regulated 
by 
Ofcom. 


The 
consultation 
period 
will 
be 
from 
6 
December 
2011 
until 
20 
January 
2012. 


Questions 
on 
which 
we 
are 
seeking 
a 
response 


We 
are 
interested 
in 
receiving 
any 
comments 
which 
are 
related 
to 
the 
proposed 
policy. 


In 
particular, 
it 
would 
be 
helpful 
to 
receive 
responses 
to 
the 
following 
questions 


Scheduling 


1. 
Is 
the 
proposed 
switch 
to 
‘seasonal’ 
broadcasts 
for 
PPBs 
in 
England, 
Scotland 
and 
Wales 
relevant 
and 
appropriate? 
If 
not, 
explain 
why? 
2. 
Do 
you 
have 
any 
other 
comments 
on 
the 
proposed 
‘seasonal’ 
approach 
to 
PPBs 
in 
England, 
Scotland 
and 
Wales? 
3. 
Do 
you 
think 
the 
current 
allocation 
of 
one 
PPB 
to 
qualifying 
parties 
in 
Northern 
Ireland 
is 
appropriate? 
Also, 
do 
you 
consider 
that 
qualifying 
parties 
should 
continue 
to 
be 
offered 
one 
PPB 
per 
year 
or 
two? 
Allocation 
Criteria 


1. 
Are 
the 
criteria 
by 
which 
the 
Executive 
will 
decide 
which 
parties 
will 
be 
allocated 
PPBs 
clear 
and 
appropriate? 
2. 
Do 
you 
have 
any 
other 
comments 
on 
the 
proposed 
Criteria? 
Budget 
broadcasts 


1. 
Do 
you 
have 
any 
comments 
about 
the 
proposal 
to 
end 
Budget 
broadcasts? 
BBC 
Trust 
Party 
Political 
Broadcasts 
Consultation 
page 
6 


How 
to 
make 
a 
submission 


This 
consultation 
is 
being 
run 
over 
a 
six 
week 
period 
(excluding 
Christmas 
week). 


The 
closing 
date 
is: 


20 
January 
2012 


Please 
send 
your 
submission 
to: 
ppb.consultation@bbc.co.uk 
or 
by 
mail 
to: 


Party 
Political 
Broadcasts 
Consultation 
BBC 
Trust 
180 
Great 
Portland 
St 
London 
W1W 
5QZ 


Next 
steps 


The 
BBC 
Trust 
will 
take 
the 
consultation 
responses 
into 
account 
and 
publish 
the 
results 
of 
this 
consultation 
on 
the 
Trust 
website 
together 
with 
the 
final 
policy, 
once 
approved 
by 
the 
Trust. 


BBC 
Trust 
Party 
Political 
Broadcasts 
Consultation 
page 
7