Our Ref: SR/BB13a

22nd March 2007

Ann Bastow
Purpose Remits Public Consultation
BBC Trust Unit
Room 211
35 Marylebone High Street
London
W1U 4AA

Dear Ms Bastow,

Purpose Remits Consultations

The Newspaper Society represents the regional newspaper industry.

The Public Purpose Remits are very broad and our members are concerned that they will continue to give the BBC wide latitude to pursue and develop a very wide range of activities, irrespective of the BBC Trust's ability to approve, monitor and review the BBC's services.

The regional newspaper industry considers that it is important that the purpose remits do explicitly oblige the BBC to avoid adversely affecting its commercial competitors, where relevant, in addition to the BBC/Ofcom market impact assessments and public values test that the BBC Trust will apply in reviewing and granting service licences, since these will of course have reference to the public purpose remits. We note that this has been acknowledged in some of the draft purpose remits, although we feel that some changes could be made to improve the control and monitoring of the BBC. 

The regional newspaper industry has a particular concern relating to the draft 'BBC Public Purpose Remit: Representing the UK, its nations, regions and communities, Annex 11 Explanatory Note Section 2: Market Context and the BBC Role'.

The annex first suggests that the traditional local and regional commercial media has been under increasing financial pressure as competition mounts for audiences and advertising expenditure, that this pressure has been greatly increased by the new entrants to the market that digital technology enables and that the result may be a further reduction in investment in local and regional content by commercial media. It then presents this as the market context which justifies the public service imperative for the BBC's role. 

The draft does not fully reflect the market that it purports to describe nor the impact of the BBC. The draft does not acknowledge that traditional regional media such as regional newspaper companies are investing in and diversifying their regional and local media portfolios using traditional new media to provide the regional and local content that they originate to their growing audiences and readers when, where and how they want. The draft market context does not acknowledge that the BBC's activities might disrupt nascent markets and deter the local commercial media, thereby bringing about the decreased investment which it then suggests justifies its expansion into that area. We therefore suggest that the final paragraph is tightened to impose greater controls over the BBC. 'Taking care not to undermine a continuing plurality of local and regional media', might suggest that the BBC should merely avoid closing down its commercial competitors. Perhaps this paragraph could be amended to expressly address 'In delivering this Remit, the BBC should take care to avoid a negative market impact and take care not to undermine a continuing plurality of local and regional media . Wherever possibly it should work in partnership with appropriate local and regional providers and always seek to complement rather than replicate their provision.'

I enclose the Declaration.

Yours sincerely


Santha Rasaiah
Political Editorial and Regulatory Affairs Director