Gaelic Digital Service Public Value Assessment Organisation Responses

September 2007

Introduction

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The BBC Trust is currently conducting a Public Value Test (PVT) into the proposal for a Gaelic Digital Service. As part of the PVT process the BBC Trust must examine the public value of the proposal. As part of the Public Value Assessment (PVA) the Trust consulted publicly for 3 weeks. This document contains the full responses from organisations to the consultation.

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Organisation responses in full

The BBC Trust received representations during the public consultation from the following organisations: An Lochran Audience Council England Audience Council Northern Ireland Audience Council Scotland Audience Council Wales Bord na Gaidhlig Comhairle nan Eilean Siar Gaelic Advisory Committee Gaelic Education Trust Glasgow Lewis and Harris Association Highlands and Islands Enterprise MacTV MnE PACT Sabhal Mòr Ostaig Scottish Screen TeleG Tobar an Dualchais Three organisations also responded requesting that their submissions remain confidential.

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An Lòchran Question 1 What role should the BBC play in the provision of content and services in Gaelic in Scotland? The BBC exists to serve the public interest, and one of the BBC’s public purposes is to represent the UK, its nations, regions and communities; It is An Lòchran’s view that the BBC has a crucial role to play in the provision of Gaelic content and services, and it has a history of commitment to Gaelic across a number of platforms. The growth of digital technology has visibly changed the face of traditional broadcasting, enhancing consumer choice and introducing interactive services, and the BBC should deliver public value in this context. The BBC should deliver a co-ordinated, multiplatform approach to the commissioning and delivery of Gaelic media content and build on its current provision of Gaelic TV and radio output. Question 2 To what extent does the service as outlined represent a desirable use of the licence fee, both generally and compared to alternative uses? A dedicated digital service will more effectively meet the needs of the Gaelic community than the current provision, and in delivering greater public value to the Gaelic audience, we believe that the new service will improve licence fee payer perceptions of the BBC in Scotland. Question 3 What contribution would the service make in helping to drive or maintain usage of BBC services? The proposed service will enable the BBC to deliver new content to a previously underserved audience across three platforms. We believe this will encourage users to experience Gaelic content how and when they want, and offer users a richer experience which in turn will drive usage of BBC Services Question 4 To whom do you think the service would appeal? The service will appeal to Gaelic speakers, learners and those with an interest in the language and culture. However, we feel that he audience for Gaelic programmes far exceeds the number of Gaelic speakers and a substantial number of overseas residents access programmes on the existing website.

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Question 5 How relevant would the service be to the BBC maintaining high standards of quality? The new service will allow the delivery of a wider and more diverse range of high quality programmes than is available at present through developing new talent, sharing of ideas and artistic expression, stimulating creativity and cultural excellence and the creation of new Gaelic material. Question 6 How distinctive is the proposal from other services in the market? An Lòchran believes that this proposal will be unique in Scotland, as it is the only multi-platform dedicated service for the Gaelic community, and as such has no direct competitors. Question 7 Does the proposal offer value for money? In our view, the proposed new service will deliver greater public value to its audience, and by pulling together all the different strands of Gaelic broadcasting into a dedicated service, it will ultimately increase investment that would not otherwise have been possible. Question 8 What benefits does the proposal offer to, one, consumers and, two, society as a whole? The proposal offers many benefits to the individual such as increased choice and accessibility of programmes, filling gaps in provision for children, young people and learners, and the ability for the individual to be involved through interactive services. Society will benefit from increased access and availability to our historical and cultural heritage and from the contribution the service will make to sustaining the language, an avowed aim of the Scottish Government and an explicit objective of the Gaelic Language Act 2005. It will also have social and economic benefits in strengthening sparsely populated communities by providing significant and diverse employment opportunities. Question 9 How does the proposal fit with the BBC's role as defined by its public purposes (which are: sustaining citizenship and civil society; promoting education and learning; stimulating creativity and cultural excellence, representing the UK's nations, regions and communities, bringing the UK to the world and the world to the UK, helping to deliver digital Britain)? The proposal fits well with the BBC’s public purposes, as the service will reflect and support a specific linguistic community therefore meeting the BBC’s purpose to ‘represent the UK’s nations, regions and communities’ Gaelic programming is also a resource used in Gaelic medium education, and developing learning resources online for children and learners meets the purpose of ‘promoting education and learning’.

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The new service will also nurture new talent and create opportunities for artists, writers and performers towards ‘stimulating creativity and cultural excellence.’ The proposal accords with recent Government initiatives to support and promote Gaelic language and culture eg the establishment in 2002 of a national agency (NDPB) for the language, Bòrd na Gàidhlig, the Gaelic Language Act 2005 and the publication of a National Plan for Gaelic earlier this year. It will also help the UK Government meet some of its obligations under the Council of Europe Charter on Regional and Minority Languages. Question 10 Are there any other issues regarding the public value assessment you would like the Trust to consider? An Lòchran would like the Trust to consider the importance of maintaining Gaelic on whatever the most prominent channels are in a post-digital world. In our view there is a danger that Gaelic could become marginalised if confined to a channel, and we feel that Gaelic should be part of the constant diet of popular channels.

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Audience Council England Question 1 What role should the BBC play in the provision of content and services in Gaelic in Scotland? The provision by the BBC of Gaelic services as one of the UK’s minority indigenous languages is a given under the terms of the Charter & Agreement; the question to be resolved is the level of that provision. Whatever the level of provision, the BBC should always exert management and editorial control. Question 2 To what extent does the service as outlined represent a desirable use of the licence fee, both generally and compared to alternative uses? This is a relatively large budget for a very limited minority audience and on the face of it, does not appear to be a desirable use of resources. Whilst recognising that the Charter & Agreement states the requirement for ‘appropriate provision of services for indigenous minority languages’, the potential audience (86,000) is a small percentage of the UK’s 60 million population, an important consideration particularly at a time of wide-ranging budget cuts. Is there a significant demand for an enhanced provision from the Gaelic speaking community or is this proposal driven by other considerations? And how does it fit with the recent call for a Scottish Six? Provision should not be made at the cost of more mainstream services that appeal to the majority. The principle of best serving all audiences must remain paramount. Online provision only could be considered in order to reduce costs to a more reasonable level. Cost effectiveness and the ability to ensure a quality product are key. The proposal raises questions around the BBC’s responsibility to other much larger minority groups for whom English is their second language. As the BBC already offers the Asian Network as a digital service, with a number of Asian languages non-indigenous to the UK and therefore not a Charter obligation, could a decision to fund the enhancement of Gaelic services digitally for such a small group be seen as discriminatory to those other minorities? It is unclear from the consultation papers whether the timing of the Public Value Test means that if given the go-ahead, the service, requiring more than £5m of additional funding, would be secure and not subject as other BBC services are to review against an under-inflation licence fee settlement. Question 3 What contribution would the service make in helping to drive or maintain usage of BBC services?

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Very little; the actual and potential audience is too small to have an impact on overall use of services. Question 4 To whom do you think the service would appeal? Existing Gaelic speakers and learners, any potential future additions to those groups and a small number of non-speakers who are interested from a cross-cultural perspective including linguists and historians. Question 5 How relevant would the service be to the BBC maintaining high standards of quality? Of little relevance. Question 6 How distinctive is the proposal from other services in the market? It would be entirely distinctive as there are no commercial alternatives and the non-commercial ones are very localised and mainly voluntary. Question 7 Does the proposal offer value for money? On a financial basis, not at all. An annual budget of £7.8m of licence fee money (and considerable but unquantified distribution costs) is disproportionate for such a small audience. The estimate of a potential future audience of 9.7% of the Scottish population seems rather optimistic. This proposal can be justified only if there are important public service broadcasting grounds which override the financial aspects. The requested additional £5m plus from the BBC alongside the GMS contribution in order to create a minority station appears good value. However, re-allocation of current BBC spend and any subsequent ‘casualties’ could impact negatively on perceptions of value for money. Question 8 What benefits does the proposal offer to, one, consumers and, two, society as a whole? There are benefits of wider and increased choice of programming to Gaelic speaking consumers including the facility to improve and practice the language. There is a very small benefit to society as a whole, in supporting a marginally increased diversity. Question 9 How does the proposal fit with the BBC's role as defined by its public purposes (which are: sustaining citizenship and civil society; promoting education and

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learning; stimulating creativity and cultural excellence, representing the UK's nations, regions and communities, bringing the UK to the world and the world to the UK, helping to deliver digital Britain)? The proposal would appear to fit with the first four public purposes to some extent. As the service would be available only on digital platforms, it might also encourage digital take-up among the Gaelic speaking community. However, a dedicated language channel ‘excludes’, whereas other BBC services targetted at minority audiences, for example Radio Three, does not. Question 10 Are there any other issues regarding the public value assessment you would like the Trust to consider? It is not clear how this proposal compares with provision for other indigenous minority languages in the UK; this factor should be considered as part of the decision-making process. Currently it appears that no commercial broadcaster wishes to provide this service, so any Gaelic provision will have to be provided by the BBC. The BBC has a duty to provide minority programming as part of its core services and output – and quite rightly so – but the key question of this Public Value Test is whether the proposed enhancement to the current provision is justifiable.

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Audience Council Northern Ireland The Audience Council for Northern Ireland warmly welcomes the proposal for a Gaelic Digital Service. It believes that the proposed service reflects the BBC’s Public Purposes and that it would bring value to Gaelic speakers and the wider community in Scotland. Question 1 What role should the BBC play in the provision of content and services in Gaelic in Scotland? Gaelic represents an ancient, unique and fragile thread of the UK's culture. In terms of the linguistic and cultural ecology of both the UK and the world, in an era when minority languages are disappearing at an alarming rate, the maintenance of this culture is entirely the responsibility of the UK (outside Scotland, Gaelic exists as a community language in only one other place, in a small and ageing population in Nova Scotia). A Gaelic broadcasting service is critical to the survival of Gaelic as a living language, and the Gaelic-speaking audience is too small to sustain a commercial service. The BBC, as the only viable non-commercial PSB provider in the UK, is possibly the only institution which has the resources to maintain such a service for Gaelic and the UK's other indigenous minority languages. We welcome the BBC's commitment to playing a significant part in the new service. The BBC’s Purpose Remits outline a key public service role in safeguarding and supporting indigenous minority languages. The “Representing Nations, Regions and Communities” Purpose Remit notes their importance within the UK’s indigenous cultural heritage, as well as the value placed on such a commitment by speakers. The proposed service would also provide wider access to Gaelic language and culture for non-Gaelic speakers. The BBC has a role to play in promoting learning and stimulating creativity and cultural excellence, both of which are supported by this proposal. See also the response to Question 9. Council notes that the wider marketplace is unlikely to provide a service of this range available across multiple platforms. BBC content and services should sit alongside other media outlets, offering the audience a diversity of services. Question 2 To what extent does the service as outlined represent a desirable use of the licence fee, both generally and compared to alternative uses? Council believes that the proposed service is firmly rooted in the BBC’s Public Purposes, an essential criterion for use of the licence fee. The proposed service, drawing on two strands of public funding, provides added value to the BBC's input, which is comparatively small, given the ambitious schedule envisaged in the proposal. The technical and infrastructural support of the BBC, and access to its archive, offers the best possible opportunity for developing a comprehensive and economically viable

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service that could not be replicated under any other model at such a low cost. TG4, the Irish language service in the Republic of Ireland, has demonstrated the potential that a small service has for maximising creative synergies on an extremely cost-effective basis. Council further notes that the level of provision and nature of indigenous minority language services provided in Scotland, Wales and Northern Ireland has, in the past, largely been assessed independently for each Nation. Whilst recognising that history, stage of development, nature of demand and cultural context for each of the indigenous minority languages should play a major part in determining provision, Council suggests that it would be helpful if the BBC Trust developed a consistent approach, taking account of the above and other relevant factors. Such an approach may take the form of a weighted evaluation framework, based on the key drivers of need. Question 3 What contribution would the service make in helping to drive or maintain usage of BBC services? Council believes that the Gaelic Digital Service would offer a significantly enhanced service for Gaelic speakers as well as those learning the language. It would provide extended coverage across multiple platforms, offering a varied schedule including news, entertainment and learning. The proposed service would further drive usage by providing a widely accessible, modern and varied service for those wishing to learn the language. It is possible that demand for learning the language would be stimulated by an increase in content, which illustrates the role of Gaelic within Scotland’s cultural heritage. Council also notes that the proposed service is of interest to some others who are not speakers or learners of Gaelic , offering access through subtitling to programmes which reflect important aspects of cultural heritage and community life in Scotland. The opportunity to mainstream programmes relevant to a wider audience, on BBC Scotland’s non-Gaelic services, offers further value. As an additional digital service it would extend choice for audiences without displacing the English language services already available. Council believes that a commitment to indigenous minority languages can reflect the BBC’s public value to an audience beyond those who speak the language. Council notes that the digital multi-platform service extends access within and beyond Scotland, and enhances the opportunity for innovative and appealing content to meet the diverse needs of the audience. In an increasingly fragmented market-place, this service, dedicated to a distinct audience not otherwise catered for, can attract and maintain a loyal audience. Question 4 To whom do you think the service would appeal?

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The primary appeal of the service will be to the 3% of the audience in Scotland who have knowledge of Gaelic, including those who are learning it. However, Council also notes with interest, research carried out by the BBC Executive that indicates that a further 19% of the Scotland population believes that they may find some personal value in the service, in spite of not having knowledge of Gaelic. In addition to native speakers of Gaelic in Scotland, this would include native speakers throughout the rest of the UK, fluent learners of Gaelic, those who are learning Gaelic, speakers of Irish throughout the UK (and in the Republic of Ireland), non-Gaelic speakers interested in Gaelic, those interested in traditional music and song, others interested in minority cultures. From the experience of TG4 in Ireland, many non-Gaelic speakers will watch sub-titled programmes of general interest if they are of a high quality. Council endorses the decision to subtitle the television service as this would extend the potential reach of the service. Question 5 How relevant would the service be to the BBC maintaining high standards of quality? Council believes that a new Gaelic digital service must be of the highest editorial quality, exemplifying the characteristics of public service broadcasting as defined in the Agreement. The service offers an opportunity to deliver innovative content through the use of digital technology across different platforms. It also has particular scope to provide a high quality learning experience for learners of Gaelic at different levels, and to promote cultural excellence and diversity. Council notes the importance of the BBC retaining clear editorial responsibility for the service. Question 6 How distinctive is the proposal from other services in the market? A dedicated Gaelic television service will be not only distinctive, but unique, in that it will provide the only comprehensive Gaelic television service in the world. The needs of this service's particular audience will, quite aside from the question of the linguistic medium, make for distinctive programming. Again, the Irish experience has shown, particularly through its music, documentary programming and news service, and to some extent through its drama, that a small, modestly funded minority language service can develop a unique broadcasting ethos that reflects, and is remarkably close to, its core audience. As a digital multiplatform service, it extends choice for the audience in terms of how and when they consume output, as well as the range of services available. Digital technology would also enable audiences outside Scotland to access the service. The proposed service offers not just an increased volume of output but also a wide mix of programme genres, including news and entertainment. Digital technology across multiple platforms provides opportunities for innovative interactive content with appeal to diverse sections of the audience.

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The innovative partnership between the BBC and the Gaelic Media Service also makes the proposal distinctive in terms of how it is funded and managed. The distinctiveness of the service is underlined by the fact that it is unlikely to be provided through the wider market. Question 7 Does the proposal offer value for money? Council believes that a number of factors contribute to value for money objectives. Firstly, the partnership with the Gaelic Media Service would ensure that the service to the audience would be greater than the service that could be provided through the BBC licence fee contribution alone. The use of archive programmes and narrative repeats within the schedule, would further contribute to value for money objectives, if well balanced with programme originations. Council particularly commends the inclusion of subtitles which would help to extend the reach of the service, and ensure that people with little or no knowledge of the language might benefit from the programmes. It is especially useful that subtitling would be optional. The mutliplatform approach provides significant opportunity to provide value for money for audiences, with the use of Radio nan Gaidhael as a sustaining service, and the opportunity to share staff and resources across platforms. The projected broadcasting schedule will involve 2,555 hours of television per annum, of which 548 hours will be originated content. This is for a projected budget of £17.9 million. The value of the service in underpinning a rich but fragile culture is incalculable and provides clear value for money. Question 8 What benefits does the proposal offer to, (i) consumers and (ii) society as a whole? Consumers would benefit from an enhanced range of programmes, accessible through a wider variety of platforms. The Gaelic-speaking audience and learners of Gaelic will benefit from a comprehensive service in their language of choice. Non-Gaelic speakers will be given a unique insight into that society and culture. Broader society will benefit from a service that supports and reflects a unique, rich and ancient culture. There is benefit to be derived from a service which would help different language communities to understand each other, a key Purpose Priority. The service would also carry benefits for creative and cultural life and promote education and learning. Question 9 How does the proposal fit with the BBC's role as defined by its public purposes (which are: sustaining citizenship and civil society; promoting education and learning; stimulating creativity and cultural excellence; representing the UK's nations, regions and communities; bringing the UK to the world and the world to the UK; helping to deliver digital Britain)?

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The BBC must reach out to serve all of the audience – recognising and celebrating cultural diversity. The proposal clearly aligns with several of the public purposes: Representing Nations, Regions and Communities: The proposed service sits with the BBC’s commitment to safeguard and support indigenous minority language. It notes the value to the Gaelic speaking audience and also the highly important place of Gaelic within Scotland’s cultural heritage, and therefore its relevance to a wider audience. The proposed service also fits with the specific Purpose Priority to “encourage interest in and conversation about local communities” by reflecting life in Gaelic speaking communities. It would support the aim of reflecting and celebrating different cultures and communities across the UK, and promote understanding between the language communities. Sustaining Citizenship and Civil Society: Council notes the commitment to news coverage within the proposed schedule, and believes that this contributes to sustaining citizenship. Promoting Education and Learning: The proposed service would promote education and learning. Its mixed genre approach, complemented by subtitles, would serve the needs of learners of Gaelic, and more fluent speakers as well as those with a wider cultural interest or less formal learning interests. Stimulating Creativity and Cultural Excellence: The proposed service would offer further opportunities to explore and celebrate Gaelic cultural traditions, including its rich contribution to music and literature. The proposed service would play an important role in supporting the local creative economy, by providing opportunities for local talent and the independent sector. The fit with this Purpose would be greater if the ‘aspiration’ to provide some comedy and drama were to be realised, and Council would encourage progress in this area. Emerging Communications: The proposed service offers the potential for digital multiplatform technology to be ultilised, to provide audience benefits of wider access, innovative content and value for money. This service can bring a marginalised and neglected section of society in a neglected and marginalised region, into the mainstream without compromising its integrity and unique qualities, and bring an understanding of the culture of that community to the wider world. It has a significant educational role both for Gaelic speaking and non-Gaelic speaking communities. Question 10 Are there any other issues regarding the public value assessment you would like the Trust to consider? Council notes that, under the proposal, SMG will no longer be required to broadcast programmes in Gaelic. Council believes that, as a general principle, plurality of provision offers audience benefits and that the BBC should not have sole responsibility for public service commitments. Nonetheless, in this particular case, Council accepts that the proposal

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offers greater benefits to the audience through enhanced services. It is reassuring that, despite the downsizing of STV’s Gaelic output, the new Gaelic digital service will operate in a competitive environment with a merit-based commissioning system that should ensure that innovation in programming is not to be stifled. It also particularly endorses the commitments to the independent sector. While there is a danger in any situation where a single provider has a monopoly, the alternative, a fragmented service over a number of platforms, and at the mercy of larger broadcasters with an essentially Anglophile world-view, may be worse. A single station will at least have an opportunity to develop a coherent ethos, create audience loyalty, and avail of economies of scale. Council endorses the distinctive and innovative nature of this proposal. If the proposal is accepted, it will be particularly important for the Trust to ensure that robust risk management is in place, in order to deliver audience benefits against clear measures of success.

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Audience Council Scotland 1. What role should the BBC play in the provision of content and services in Gaelic in Scotland? The BBC has played a pivotal role in sustaining Gaelic, fulfilling its duty as the UK’s leading public service broadcaster to promote and support indigenous languages, and this should continue. BBC Radio nan Gaidheal has done much to instil confidence in the language among members of the Gaelic community. The service should be a complete multimedia service, reflecting the Gaelic community to itself and allowing it to engage with the wider world as the BBC’s English language services do for English speakers. The multimedia vision of the management proposal is a highly creative response to the opportunities of the digital age – allowing the BBC to harness the technology of the future to protect and develop an irreplaceable part of Scotland’s cultural heritage. In the case of a small, indigenous language community it is particularly appropriate for the BBC to work with partners to achieve this, in the interests of strategic co-ordination, to set the highest standards for Gaelic output, and to offer the maximum value for money to the licence payer. Attendees at a Gaelic language consultation on the proposal held in Glasgow emphasised that content on radio, online and television should be of a high standard, and of a quality equivalent to that of the BBC’s English language provision. It was also felt that the Trust should consider the possibility of retaining Gaelic output in English language schedules after the launch of the new service. In the new service, there should be a good balance between programmes on Gaelic history and culture and material in Gaelic which reflects issues in the wider world. At a consultation of Gaelic speakers on the proposal in Glasgow on 3 September 2007, it was stated that the proposed channel would be very important to Gaelic and its survival. 2. To what extent does the service as outlined represent a desirable use of the licence fee, both generally and compared to alternative uses? Surveys suggest a high awareness among Scottish audiences of the value of Gaelic for Scotland. The proposal offers excellent value because of the partnership with the Gaelic Media Service, bringing much of the available funding together to leverage maximum value for the Gaelic language community. Though small in numbers, the Gaelic community is a highly significant component of Scottish life and culture. In the view of the ACS, the increased expenditure represents high public

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value because it is likely to prove highly significant – among a basket of measures - in sustaining Gaelic language and culture for future generations. Unlike many other minority languages in the UK, the long term health of Scottish Gaelic (like Welsh) will depend solely on measures taken within the UK. The Council recognises that there are many priorities for BBC audiences in Scotland, and that not all sections of the audience would prioritise increased expenditure on Gaelic services. Delivering increased benefits for audiences does not always require increased expenditure; the provision of a comprehensive media service for the Gaelic community is one which does. The Council believes that the increased investment represents good value for the benefits which may be expected to accrue for Gaelic and non Gaelic audiences alike, and that investment in this proposal will produce greater benefits than if an equivalent sum were put towards the achievement of any of the Council’s other priorities. 3. What contribution would the service make in helping to drive or maintain usage of BBC services? The Council expects that the proposed GDS service would increase usage of the BBC’s Gaelic services; and has the potential to extend the reach of BBC Scotland’s English language services if GDS material is used creatively to enrich the latter. The digital service plans to offer Gaelic content on all 3 platforms. There is clear potential for the television channel element to drive increased usage of the radio and online elements, above current levels of usage. By extending the range of genres, increasing volume and enhancing creativity, it is likely to drive higher overall consumption of BBC Gaelic content. More innovative use of new technology, such as video games and podcasts, should be used to attract younger audiences, and there should be more coverage of sport and events throughout the Gaelic area. The extension of BBC news coverage in the north of Scotland, the opportunities for co-production/versioning between the English and Gaelic services, and the development of the Gaelic independent sector all have the potential to enrich BBC Scotland’s English language services. 4. To whom do you think the service would appeal? There is every reason to believe that the service as proposed will appeal to all members of the Gaelic community in its widest sense, including learners and non-speakers interested in the language and culture. The Council has frequently noted that there is significant identified usage of current Gaelic programming by non speakers, via subtitles (Eorpa, some factual content and some children’s programming). The provision of material such as this which is highly distinctive in a Scottish

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context significantly increases the public value of the BBC’s Gaelic content. Under the present proposal, there is clearly potential to increase this appeal. Lack of coverage of material from outside the Central belt has been a long running concern for the Council. Although the proposed channel has a universal brief, a special focus on material related to the Gaidhealtachd area may be expected. The Council believes that this could be another source of appeal to non speakers. At the consultation on 3 September, it was stated that all of Scotland should have an interest in the service as well as Gaelic speakers, Gaelic learners throughout Britain and beyond; and that it would appeal to young people in particular. It was stated that, between the proposed service and Radio nan Gaidheal, there would be increased potential for Gaelic speakers to inhabit a Gaelic broadcast environment for sustained periods if they wished, which would be especially valuable for families who were bringing up their children as Gaelic speakers. There was significant feeling at the consultation against a mixed language service; that a service “half in Gaelic and half in English” was not wanted. The Council believes that there are strong cultural and linguistic reasons for providing a service which is almost completely in Gaelic (with subtitling where appropriate), according to the policy successfully followed by Radio nan Gaidheal. 5. How relevant would the service be to the BBC maintaining high standards of quality? The Council believes that, by creating a service under the creative leadership of the BBC at the centre of the Gaelic media sector, the proposal will maintain and enhance the standards of the sector. The Council believes that the BBC provision (from both in-house and independent sources) currently sets the benchmark for standards in Gaelic programming. It is expected that via the BBC commissioners of the new service these standards would apply to all content on the multimedia service. In this way the new service should extend the range and reach of high-quality Gaelic content. Because of the very limited nature of current Gaelic provision on television, some of it at the edge of the schedule, current Gaelic content can be hard to access even for the core audience. The new service would therefore offer an opportunity to make available some of the high-quality material in the Gaelic programme archive for audiences who may have missed it first time round. At the consultation on 3 September, it was stated that the Gaelic community trusted the BBC to provide a service with high standards – as it did in programmes it provided at present.

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6. How distinctive is the proposal from other services in the market? The service would be unique in the Gaelic media market. It is also a highly distinctive proposition in the context of minority language provision. 7. Does the proposal offer value for money? The Council and its predecessor have frequently acknowledged the high quality of output achieved by the BBC Gaelic department (from in-house and independent sources) on relatively low budgets. The Council is confident that the production teams for the new service will make good use of the relatively small increase in funding envisaged in the proposal to deliver greatly enhanced public value for Gaelic audiences. At the consultation on 3 September, it was observed that one and a half hours of original material a day was very little; the service could do with more money. This was felt to be more important because of the track record of BBC Gaelic staff in making good programmes on small budgets. 8. What benefits does the proposal offer to, one, consumers and, two, society as a whole? The proposal is likely to drive expansion and greater diversity in the Gaelic media market and so benefit consumers of all Gaelic media. Because of its multimedia presence, its position in the BBC’s family of channels, the expansion of news coverage in the North and West of Scotland, and the opportunities for co-production and versioning, it is also likely to draw Gaelic broadcasting and culture to the attention of a much wider audience than at present. Sustaining and developing Gaelic, and increasing awareness of its role in Scottish culture, will have benefits for Scottish audiences as a whole. In particular the Council believes that the service should be based as far as is practicable in the Gaidhealtachd area to help develop its economic infrastructure and provide sustainable jobs in the area. This would maximise the benefits for Gaelic culture. The Council has welcomed the investment in the media infrastructure of the West of Scotland represented by the new headquarters building at Pacific Quay. The Council believes that the BBC’s current commitment to spreading licence fee investment outside of London should be mirrored in Scotland, and that BBC investment in Scotland should not be restricted to West Central Scotland. The Council believes that there are strong economic and cultural arguments for directing as much as possible of the proposed GDS investment to the Gaidhealtachd area. 9. How does the proposal fit with the BBC’s role as defined by its public purposes? The BBC’s current provision for the Gaelic community covers off most of the BBC’s purposes and to this extent already ‘fits with’ those purposes. However, its overall impact is

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constrained by the very limited television and interactive offerings, so that the total impact achieved by BBC Gaelic provision for the Gaelic community falls far short of that achieved for English speakers through the BBC’s English language services. For Gaelic speakers, the expansion of the service would greatly enhance the qualitative impact of BBC content in the areas of citizenship, education, creativity and representation of the Gaelic community. In this sense the new service would represent a step change for the BBC in achieving its public purposes within the Gaelic language community. At the consultation on 3 September, it was stated that the proposed channel was a good example of what the BBC should be doing to fulfil its obligations. The Council agrees. 10. Are there any other issues regarding the public value assessment you would like the Trust to consider? A range of survey evidence suggests that Scottish audiences feel that the BBC could do more to reflect and represent Scottish life and experience. This proposal would be a major step forward in addressing this perception for a section of the community, and the Council believes it is likely to improve perceptions even among those audience groups who do not use the service. The provision of a network of BBC news journalists across Scotland, and especially in the Highlands and Islands, would have significant benefits in providing content for BBC English-language news outlets in Scotland and on network. The Council is concerned that as many Gaelic speakers as possible are able to access the service from launch. The Council urges the BBC to explore the possibility of a presence for the service on Freeview, in some shape or form, from as early a date as possible.

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Audience Council Wales General comments The Audience Council for Wales is perhaps uniquely placed to offer comments on the proposals, operating as it does bilingually and from within a bilingual broadcasting context. The ACW warmly welcomes these proposals and commends the BBC Executive and the Gaelic Media Service for their innovative agreement to provide an increased Gaelic Digital Service for Scotland and beyond. News – the ACW welcomes the central place earmarked for news in the proposed schedule. As has been made evident in Wales, the BBC Wales produced Welsh language news programme, Newyddion, has claimed and retained a pivotal place within S4C’s schedule and demonstrated that the BBC can produce a news programme with a world-wide as well as a local agenda in a minority indigenous language. Education – the ACW welcomes the emphasis placed in the proposals as outlined upon education. Audiences in this regard include children of all ages, but also those of all ages learning Gaelic or interested in languages. The ACW is also of the opinion that it would have a wider educational impact not least in providing a bridge between the linguistic communities of Scotland and allow access to Gaelic culture to a wide audience in Scotland and beyond. The ACW also notes that provision for young children (who are the most likely monoglot Gaelic speakers) should be welcomed since it encourages early appreciation of the provision and the language. Emerging Communications – the ACW welcomes the emphasis in the proposals on maximising the opportunities represented by emerging communications, (such as the PSB Freesat service and iPlayer) since these can often be of particular importance to licence fee payers in topographically challenged or geographically remote areas. It also welcomes the proposal that the service should be available on a variety of platforms. Proposal 4.1, “an aspiration to provide some comedy and drama” – the ACW expressed its concern at the use of the vague ‘aspiration’ in this proposal and suggests that the new service should instead put in place structures, training and resources to facilitate the provision of drama and comedy on the Gaelic Digital Service. Wales is home to the BBC’s longest running drama series Pobol y Cwm and the daily weekday episodes and Sunday omnibus edition regularly top S4C’s viewing figures. This evidence suggests that the programme’s audience, which includes both those fluent in Welsh and those with little grasp of the language (who use the subtitling facility), appreciate the inclusion of BBC produced drama within S4C’s schedule. Encouraging creativity and development of the creative industries – the Audience Council for Wales welcomes the emphasis placed in the proposals on the intention “in due course [that] up to 50 per cent of non-news and current affairs programmes on the TV channel would come from independent producers”. The experience of Wales is that the establishment of S4C in 1982 gave a significant boost to the development of an independent Welsh TV production base

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and had a substantial positive impact on the economic and cultural vigour of the creative industries in Wales. Question 1 What role should the BBC play in the provision of content and services in Gaelic in Scotland? The BBC as a Public Service Broadcaster should play a central role in the provision of content and services in Gaelic in Scotland since this appears entirely consistent both with creating public value and the BBC’s six public purposes. The proposals would contribute to ‘Sustaining citizenship and civil society’ through providing a comprehensive news service to an under-served audience; to ‘Promoting education and learning’ in several ways, including provision for Gaelic speaking children, Gaelic language learners, but also by providing an introduction to the wider Scottish and UK population to Gaelic language and culture; to ‘Stimulating creativity and cultural excellence’ by broadening the provision of material broadcast in Gaelic on television and encouraging the growth of the creative industries sector in Scotland; to ‘reflecting the UK’s nations, regions and communities’ and ‘bringing the UK to the world and the world to the UK’ by providing a bridge between the presently under-served Gaelic speaking community and other audiences in the UK and beyond. Reference is made above to the importance attached by the ACW to the availability of the service on a variety of platforms and the use of emerging technologies. Question 2 To what extent does the service as outlined represent a desirable use of the licence fee, both generally and compared to alternative uses? The service as outlined represents, in the view of the ACW, a desirable use of the licence fee in providing for an audience which is at present under-served and doing so in a manner which represents value for money e.g. through the provision of Gaelic material in a way which will make it available to other audiences such as by use of subtitles and production of Gaelic/English programmes concurrently. Question 3 What contribution would the service make in helping to drive or maintain usage of BBC services? The ACW believes the Service would contribute significantly to driving and maintaining usage of BBC services. A concern of ACW is that the BBC does not receive due credit from the audience for its Welsh language television programming broadcast on S4C. It believes that the structures outlined for the Gaelic Digital service will avoid such lack of recognition for the BBC’s contribution in this context. The ACW believes that it is crucial that the BBC receives due credit from the audience for the fulfillment of its public service broadcasting responsibilities and believes that the introduction of a BBC Gaelic Digital service, encompassing TV, radio, iPlayer and the web, would contribute to further boosting such a perception of the BBC’s services in Scotland.

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Question 4 To whom do you think the service would appeal? As outlined in these proposals, the ACW believes the Gaelic Digital TV service will not just be a service for Gaelic speakers but for the Scottish community as a whole as well as appealing to those geographically located beyond the borders of Scotland – students, those of Scottish origins now living elsewhere, language/linguistics students and so on. It would also appeal by means of the provision of sub-titles to the wider non-Gaelic speaking Scottish audience, but in particular perhaps to those who live in the Gaelic speaking areas. The service could provide a valuable point of contact between the two linguistic communities and be a genuine means of bridging both language communities and increasing understanding between them. Question 5 How relevant would the service be to the BBC maintaining high standards of quality? Quality is key. In the bilingual context of Wales the BBC is seen as setting quality standards and is the benchmark for other broadcasters in Wales. The ACW considers it reasonable to anticipate that the BBC’s Gaelic Digital Service will become the quality benchmark for Gaelic TV provision in Scotland. Question 6 How distinctive is the proposal from other services in the market? Very – the ACW welcomes the collaboration between the BBC and the GMS as well as recognizing that this is an area which is unlikely to see spontaneous market-led activity. The content of the service as outlined in section 4.1 of the proposals seem to be placed squarely within the parameters of provision by a Public Service Broadcaster, with some reservations, as outlined above, at the use of the term ‘aspiration’ in the final bullet point of this section. Question 7 Does the proposal offer value for money? As a service for the whole of Scotland and beyond, this would seem to represent good value for money. With the use of sub-titles and opportunities for ‘back to back’ production of English/Gaelic programmes, this could be a real value for money means of access to Gaelic culture for a significant audience as well as providing new original material for an English language audience. Similarly using BBC Radio nan Gàidheal as a sustaining service, close cooperation between staff producing material for radio, TV and the web service and BBC Gaelic Digital Service journalists also providing coverage of news items for inclusion in bulletins on BBC’s English language services would all appear to be sterling examples of ensuring value for money. The use of archive material “drawn from the store of Gaelic programmes already transmitted by the BBC or other broadcasters” also represents good value for money.

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Question 8 What benefits does the proposal offer to, one, consumers and, two, society as a whole? As already outlined, the proposals offer both individual consumers and society as a whole significant benefits. Question 9 How does the proposal fit with the BBC's role as defined by it's public purposes (which are: sustaining citizenship and civil society; promoting education and learning; stimulating creativity and cultural excellence, representing the UK's nations, regions and communities, bringing the UK to the world and the world to the UK, helping to deliver digital Britain)? As outlined in the ACW’s response to Question One above, the Council is of the opinion that the proposals fit squarely within the BBC’s role as defined by its six public purposes, and does so in a manner likely to represent good value for money for those paying the licence fee. Question 10 Are there any other issues regarding the public value assessment you would like the Trust to consider? No. The proposals as outlined represent good value for money and an enhanced PSB offering for an audience which is presently under served and appear entirely consistent with the BBC’s six Public Purposes.

Bord na Gaidhlig

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Introduction and Background to Bòrd na Gàidhlig & The National Plan for Gaelic 1. Gaelic is an integral part of Scotland’s identity and providing a sustainable future for

Gaelic in Scotland is a stated policy aim of the Scottish Ministers. Significant progress has been made in recent years to enhance the status of Gaelic, to expand the provision of Gaelic-medium education and to establish a Gaelic digital television service. Census figures demonstrate very clearly, however, that there is no room for complacency and that the position of Gaelic in Scotland remains fragile.

2. A key milestone in Gaelic development was reached when the Scottish Parliament

passed the Gaelic Language (Scotland) Act 2005. The 2005 Act established Bòrd na Gàidhlig (the “Bòrd”) as a statutory body charged with securing the status of Gaelic as an official language of Scotland commanding equal respect to English. The Bòrd has specific statutory functions to promote, and to provide advice to Ministers and public bodies on matters relating to, the Gaelic language, Gaelic culture and Gaelic education. The Bòrd is required to exercise these functions with a view to increasing the number of users of Gaelic, and with a view to encouraging and enabling increased access to and understanding of Gaelic.

3. The 2005 Act, places a duty on the Bòrd to produce a National Plan for Gaelic, and

this key policy document, approved in March 2007 provides a blueprint for the future development of Gaelic. The National Plan is underpinned by four well-established and interrelated language planning principles, and makes recommendations on how to support Gaelic in the home, community, workplace and place of learning through language acquisition, usage, status, and corpus development.

4. Successful implementation of the priorities identified in the National Plan will require

the proactive engagement of government, public bodies, local authorities and the private and voluntary sectors. The National Plan priorities act as a guide for public bodies to consider what their contribution to Gaelic development should be. The Bòrd notes that the BBC’s six public purposes support and complement our vision and priorities as set out in the National Plan.

5. Gaelic broadcasting has a vital role to play in sustaining and revitalising Gaelic

language and culture. The Gaelic Digital Service will raise the profile of the language and will help unite the scattered Gaelic communities in Scotland, the UK and across the world. It will deliver a service into the homes of those wishing to access it and will promote the positive benefits of Gaelic described in the National Plan. The Gaelic Digital Service is a vital contribution to the delivery of the National Plan and will positively encourage language acquisition and usage.

6. The Gaelic Digital Service will also create significant employment opportunities,

increasing artistic and technical skills, stimulating parents’ interest in Gaelic education, appealing to and serving adult learners, and strengthening Gaelic usage in extremely important media.

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The BBC Public Value Test & the Ofcom Market Impact Assessment Specific Comments from Bòrd na Gàidhlig 7. Bòrd na Gàidhlig warmly welcomes the opportunity to comment on the BBC PVT

and the Ofcom MIA. The Bòrd strongly supports the establishment of a national Gaelic Digital Service and welcomes the proposed partnership between the BBC and the Gaelic Media Service (GMS) to deliver such a service. Effective collaborative working between the BBC and GMS will be vital to the success of the Gaelic Digital Service.

8. The Bòrd recognises that the regulation of the Gaelic Digital Service rests with the

Director General of the BBC. We feel strongly, however, that GMS must play a major role in the strategic development of the digital service and in content planning to ensure that the needs and aspirations of the Gaelic community are met. The proposed management group must take cognizance of the fact that GMS at the outset will provide funding for the majority of programme content and must be recognised as the protagonist for a new Gaelic broadcasting culture. The Bòrd expects the digital service to be radical in its approach and it should stretch boundaries and challenge perceptions. A bi-lingual community expects something different of its Gaelic service to what they would get through the English media, culturally as well as linguistically. Meeting this challenge in respect of the Gaelic community is the raison d’etre of the Gaelic Media Service.

9. GMS was established essentially to correct market failure. Its decision to better

serve its community and fulfil its remit in partnership with the BBC in the Gaelic Digital Service, aggregating resources to create a critical mass of programming and a stronger foundation for service development, is to be welcomed. It remains, nevertheless, accountable to Parliament and in a sense to the Gaelic community.

The Bòrd considered whether the digital service would compete with or complement existing services, and is of the view that there are no associated competition issues. TeleG and BBC will continue to broadcast Gaelic content on analogue until switch-over and the digital service will greatly enhance and complement existing services in Gaelic education, publishing, arts and culture. We anticipate that the Gaelic Digital Service will work in partnership with other agencies to stimulate further developments in these fields as envisaged in the National Plan. Furthermore, we recognise that the Gaelic Digital Service will provide an improved infrastructure and greater opportunities for independent Gaelic producers.

10. The Gaelic Digital Service will provide a dedicated location where Gaelic speakers,

learners and non-Gaelic speakers can access Gaelic programmes. This will be particularly important to the growing youth market. The new service must engage with a young audience and providing a contemporary service for young people (14-

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25yrs) will be a major challenge for GMS and the BBC. Champions will need to be identified to engage with our youth market. New and innovative online challenges / competitions to encourage young Gaelic speakers to produce 5 minute online shorts or radio broadcasts should be investigated and exploited. Young Gaelic speakers require to be convinced of the economic benefits of acquiring and using Gaelic and the digital service will raise the profile of the language and provide increased opportunities for young Gaelic speakers in respect of training and employment. As parents of the future, a quality service that supports and enhances the language will encourage young people to choose Gaelic Medium Education for their children.

11. The Bòrd warmly welcomes the fact that the combined forces of GMS and BBC will

facilitate the delivery of proportionately more hours of output than would be possible individually. In real terms this will represent upwards of 1.5hrs of new, originated programmes every day on the digital service, which should provide a platform for further development and increase in original programme output. The option to broadcast a wealth of quality archive material is also welcomed.

12. The Bòrd suggests that the feasibility of the service being available for broadcasting

on the web should be investigated. However, this option should only be considered as complementary to the dedicated digital service and not as an alternative. Broadband availability is limited in many rural areas and a web only service would result in the exclusion of a significant number of viewers from accessing the service.

13. The Bòrd warmly welcomes the proposal to provide text enhancement for Radio nan

Gàidheal programmes on the digital service. This will provide invaluable support to the great number of Gaelic speakers wishing to develop their literacy skills and the extensive learners market and will support the Bord’s initiatives with other partners in language corpus development. The Bòrd would also support the investigation of the potential for non-commercial advertising on the digital service. A non-Gaelic speaker accessing the digital service would welcome on-screen information on where to find out more about language learning opportunities, Gaelic-medium education or Gaelic issues and events.

14. In conclusion, the Bòrd views the Gaelic Digital Service as a very positive

development that will assist us in implementing many of the National Plan priorities. It will also fulfil the Council of Europe requirement to support ‘the creation of at least one radio station and one television channel in the regional or minority languages’. The strength of the Gaelic Digital Service lies in the partnership model being proposed by GMS and the BBC.

The aggregation of GMS and BBC resources within a cohesive digital service will offer much greater value to the wider Gaelic community for the financial investment being made. As a public service provider, the BBC has a duty to provide regional and minority language support and the Gaelic Digital Service has the potential to place the BBC / GMS partnership in the vanguard of developing an excellent example of how a language and culture can be supported and revitalised. As a UK broadcaster the BBC will now be able to serve the Gaelic audience outside Scotland, at times

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when they are available to view. The effect of this will be that the public will get much better value for money from the aggregated, more cohesive, public investment of BBC and GMS funding. Finally, as a member of the GMS board, Bòrd na Gàidhlig is looking forward to being actively involved in the development of the new Gaelic Digital Service.

Bòrd na Gàidhlig Secretariat 5 September 2007

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BBC Gaelic Advisory Committee At their last meeting on 28th August the Gaelic Advisory Committee agreed to contribute to the public consultation on the Gaelic Digital Service proposal. I am pleased to convey the following points in particular on behalf of the Committee. The BBC have a significant role to play in the provision of Gaelic services in Scotland, having long experience of providing high quality material for Gaelic services. The existing resources available to the BBC in this field places the corporation in primary position with regard to the provision of Gaelic Digital Services. The service would undoubtedly contribute to the BBC maintaining high standards of quality and would help to ensure that the BBC is in the forefront of emerging communication technologies and takes a leading role in the switchover to digital television. The Committee are of the view that it is essential that the service be as dynamic and flexible as possible, with high quality output. Consequently it is crucial that there be adequate funding provided to ensure this. The Committee wholly support the proposal to fund the aspiration to increase originated content in the service from 1.5 to 3 hours. In any assessment of "value for money", as it applies to the proposed service, it is important that this exercise be set in the context of the BBC's public purposes, which include education and learning, stimulation of cultural identities and excellence, and representing the UK's nations, regions and communities. The Committee believe that the proposal represents value for money when these principles are borne in mind and is therefore a desirable and justified use of the licence fee. It is a matter of some concern to the Committee that the Gaelic Digital Service would not be available across the UK on Digital Terrestrial Television and that a proportion of the Gaelic speaking population would not have access to the service. Access to the service across all platforms, and to a maximum audience area, is desirable if not essential, especially in view of the fact that the channel should engage in a constant dialogue with the audience.

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Comhairle nan Eilean Siar Comhairle nan Eilean Siar is an all purpose Authority with the responsibility for the provision of public sector services for the 26,500 residents in the Western Isles. Since the Comhairle was established in 1975/76, it has championed Gaelic on many fronts. The Comhairle recognises that Gaelic has a very special place in the lifestyle of the people of the Western Isles as it permeates every facet of life from culture to crofting and from the croileagan to the church. Since it was established, the Comhairle has attempted to create a strong Gaelic ethos within the community and provide support for initiatives which support eh Gaelic language. For many years now Comhairle nan Eilean Siar, and other Gaelic organisations, have lobbied successive Government’s to provide funding for a dedicated Gaelic Television Service. The Comhairle recognises that Gaelic broadcasting has a vital role to play in sustaining a revitalizing Gaelic. Gaelic broadcasting also has a vital role to play in raising the profile of the language and complementing initiatives to secure its future in the fields of education, the arts, social and economic development. Quality public service broadcasting provision is considered essential to the wellbeing of the citizen/consumer in wider society in the United Kingdom; quality Gaelic public service broadcasting provision is an even more crucial factor in ensuring a sustainable future for the Gaelic speaking community. Gaelic is one of the key indigenous languages of the United Kingdom. It is desirable and in the national interest, on grounds of social justice and cultural diversity, that the Gaelic speaking audience should be served by a broadcasting system appropriate to the 21st century. The future wellbeing of the Gaelic language is partly dependent on the expansion of Gaelic Medium Education. Independent research has shown that Gaelic television is the single most significant aspect in positively influencing parent’s choice of Gaelic Medium Education for their children. This inextricable link between Gaelic television and Gaelic Medium Education must be strengthened with the delivery of high quality Gaelic television programmes. This should be a key target for all those with an input from the Gaelic broadcasting sector. When the Gaelic Digital Service commences, the audience will be expecting and anticipating television programmes of a high quality. Gaelic Media Service has had to trim its broadcasting aspirations during the last few years due to the reduction in revenue, in real terms, as the Gaelic Broadcasting Fund was not index linked. In order to deliver high quality Gaelic programmes in future, it is imperative that the Broadcasting Fund is index linked using a statutory funding formula, similar to S4C in Wale2s, which will be index linked in order to ensure continuity of quality output to consolidate the place of Gaelic broadcasting within the Scottish broadcasting sector. Comhairle nan Eilean Siar recognises that establishing a Gaelic Digital Service will also create additional broadcasting employment opportunities in Gaelic heartlands such as the Western Isles. There is already a “media village” in Stornoway and the new Digital Service would enhance the opportunities for Gaelic speakers with appropriate skills to enter this sector and this in turn would generate economic benefits for the Western Isles economy.

Gaelic Education Trust

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On behalf of Urras Foghiam na Gàidhlig I would like to highlight the need for a Gaelic digital T.V. service. We also believe that the service should be of high quality, be adequately funded and meet the viewing needs of all age groups with particular emphasis on the educational aspect of the programmes.

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Glasgow Lewis and Harris Association As President of The Glasgow Lewis and Harris Association I would like to urge you to press ahead with this service as soon as humanly possible. This is a watershed decision as regards the future of our beloved language and it will be nothing short of criminal for you to delay the inception of this service for whatever reason. The Gaelic language has suffered enough over the centuries and what we are demanding is merely our just and long overdue rights. I sincerely trust that this is not the usual consultation where the decision has already been made.

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Highlands and Islands Enterprise Highlands and Islands Enterprise has always been strongly supportive of the development of a Gaelic Digital TV Channel, as we recognise that this will have a significant range of benefits for the Highlands and Islands in terms of new high quality jobs, population retention and impact on Gaelic language and culture. HIE is currently in process of drafting a Gaelic Plan for Highlands and Islands, for implementation from 2008 onwards. The primary aims of the Plan are to better deliver services to the Gaelic-speaking community in the Highlands and Islands (on the basis of equal respect for Gaelic and English); to fully normalise the language as an element of contemporary Scottish life, and to capitalise on the development opportunities arising from investment in the re-growth of the language. The Gaelic Plan for HIE should help deliver on the long-term goals of the National Plan for Gaelic which targets 100,000 speakers by the time of the 2041 census (there were just over 58,000 speakers recorded at the 2001 UK census), providing a solid basis for the language's natural growth and future intergenerational transmission. The proposed Gaelic digital service can play an important role in delivering a broadcasting service to the Gaelic community, reaffirming the worth and validating the importance of an indigenous Gaelic perspective on life. A growing broadcasting sector will offer Gaelic careers options thus expanding the Gaelic labour market and the contribution of the Gaelic economy to the wider economy regionally, nationally and internationally. In addition to other benefits, the proposed digital service can help stimulate the further growth of Gaelic education - the primary key tool for achieving the targeted growth in numbers of speakers. HIE considers these to be key elements in the continued growth of the language. The development of Gaelic forms an intrinsic part of HIE's strategy for strengthening communities, and increasingly as a vehicle for economic and business growth. The HIE Network and its predecessor organisation HIDB have played a major role in orchestrating the revival of Scotland's Gaelic language and culture. It was HIDB which in 1983 created Comunn na Gaidhlig (CNAG) whose task was to fill a developmental vacuum and turn round the catastrophic downward spiral in which Gaelic found itself at the late nineteen seventies. The HIE Network since its creation became involved partly because Gaelic is an important and distinctive aspect of the heritage of the Highlands and Islands, but also because Gaelic based development yields significant economic benefits. Investment in Gaelic is also important for social justice and inclusion as it helps to create employment and income in some of the most fragile parts of the Highlands and Islands. The concept of using Gaelic as a motor for development is the basis of HIE's strategy for promoting the language at all levels, through education, heritage, communities and business development. To that end we welcome the opportunity to contribute towards the BBC Trusts Public Value Test on the proposed BBC/GMS Gaelic Digital Service. Your consultation process asks a specific series of questions for Stakeholders. We will consider each in turn:-

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What role should the BBC play in the provision of content and services in Gaelic in Scotland Currently the BBC is by the far the major provider of Gaelic language news, current affairs and contemporary programming, delivered through TV, Radio and on-line. The Gaelic Media Service funds elements of this, predominantly broadcast TV. The BBC has considerable expertise and competence in delivering Gaelic language programming in these areas, and HIE considers that this is where the BBC should focus its efforts and activities. HIE also believes that a thriving private sector, producing content and programmes for the new channel is crucial to both its success and impact. At the same time, however we are particularly aware that the physical location of the core functions of any digital channel (its decision making capacity, its administrative, commissioning and significant programme making) is crucial when looking at the economic, social and language impact of the channel. That is why HIE believes that real benefits to the Highlands and Islands will flow from the new Channel having significant presence in the region, and from Stornoway being a key centre for management, commissioning and programme making. A policy of focussing efforts on the impressive new resources of BBC Scotland's Pacific Quay HQ for the delivery of content and services for the new channel could carry the real risk of minimising the wider impact of the channel on its heartland, the Highlands and Islands. Does the service represents a desirable use of the licence-fee, both generally and compared to alternative uses. The 2005 Ofcom review of Public Sector Broadcasting notes that:- .. "if as a society we value the maintenance and growth of indigenous languages, we must start thinking now about how to ensure that Digital Media and New-Media Services can service these aims. " Currently the Gaelic is the only indigenous language in the UK that does not have a dedicated TV channel, and current provision is patchy at best. For a language to be relevant to the people who speak and use it, it must both reflect the culture, life and aspirations of those who speak it, and how they interface with the wider world. For a living Northern European language in the 21st century not to have a series of specific media outlets which includes a dedicated TV Channel is almost inconceivable. The BBC has a unique role in Scottish and Gaelic broadcasting, and a long history in the delivery of both, and it is crucial that it continues to allocate resources to support the development of a new Gaelic Digital Channel, and other media outlets. The question of alternative uses is interesting, as the only logical alternatives are either less Gaelic programming or none at all. Neither is a serious option. What contribution would the service make in helping to drive or maintain usage of BBC Services? The rapidly developing world of modern multi-media and multi-channel communications, pose interesting challenges for large public broadcasting organisations such as the BBC.

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Fragmenting audiences and the growth of commercial niche broadcasters limit growth opportunities for the BBC. However, the development of a Gaelic Digital channel, whose resources clearly have to be provided by the public sector and public broadcasters, provides the BBC with a significant opportunity to be an important provider of services to a niche but crucial market. To whom do you think the service would appeal? HIE notes the research on channel "reach" within the BBC/Ofcom Description of service. This quotes research undertaken by the BBC executives that predicts that the service might be used by around 10% of the Scottish Population. HIE would concur with that, but would suggest that the usage within the Highlands and Islands would be higher, not least because the bulk of Gaelic speakers live here. However a Digital Channel that reflects the issues of living and working in the Highlands and Islands, as well as interpreting the rest of the world from a Gaelic and Highlands and Islands viewpoint would, in our opinion, attract reasonable audiences from within the region, albeit many consuming the service through sub-titles. The popularity of the BBC produced and GMS funded current affair programme "Eorpa" is a case in point here. How relevant would the service be to the BBC maintaining high standards of quality? As noted earlier the BBC is by the far the major provider of Gaelic language news, current affairs and contemporary programming, delivered through TV, Radio and on-line. This is widely considered to be a quality service, valued by its target audience. The proposed new Channel would see the BBC continuing to deliver these elements, both through the new Channel, and through existing BBC outlets. We would assume that there would be no dilution of the BBC's production values for content for the new channel, so it would benefit the BBC in providing additional audience opportunities. How distinctive is the proposal from other services in the market? The only existing dedicated Gaelic TV service is Tele-G, which provides one hour of previously Broadcast programmes daily. A service which provides at 7 hours programming a day, of which 1.5 hours will be new is a significant addition. However the BBC and GMS have stated that they will continue to provide programming for Tele-G for the duration of its licence. However it’s important to recognise that the terrestrial TV free to air channels (BBC, ITV) provide a service that raises the public profile of Gaelic, with Gaelic programmes such as Eorpa broadcast at peak times on mainstream channels. Loss of this platform carries the danger of significantly reducing the public profile of Gaelic in mainstream media. To that end HIE would support the proposed "dual" broadcasting of BBC Gaelic programmes on BBC2 Scotland and the proposed Digital Channel.

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Does the proposal offer value for money? In HIE's opinion the development of the proposed Gaelic Digital service offers the licence fee payer both excellent value, as for a relatively modest increase in investment the BBC will both strengthen its own offering on-line and through the radio, as well as delivering new Broadcast material through a dedicated channel. What benefits does the proposal offer to consumers and society as a whole? As has been noted the HIE Network is involved in supporting the development of Gaelic in large measure not just because of its heritage value but because Gaelic based development yields significant economic benefits. Broadcasting plays a vital role in the promotion of the language and it's associated culture. Since the development of a new Gaelic Broadcasting industry during the 1990s, a new high quality media industry has been enabled to grow in the Highlands and Islands including the acquisition of high grade skills by local people. This new industry is all the more important in that it has had a significant impact in the Western Isles - a location of high development priority for HIE and the Scottish Government. HIE undertook an economic impact assessment of the proposed Gaelic Digital Channel in January 2006, which found that it would create 90 direct FTE's and 60 indirect FTE's in the Western Isles, with salary levels above the average for the Western Isles. In this light HIE regards the proposal for a Gaelic Digital Channel as an extremely important opportunity to develop an expanded and more fully integrated Gaelic based multi-media industry in the Highlands and Islands. To that end HIE has been financially supporting the investment programme of GMS, in the Stornoway Studio Complex, to ensure that its meets the technical needs of the BBC, as well as supporting the development of the Fas creative industries incubator at Sabhal Mor Ostaig. HIE have also been working to ensure that the industry itself has the capacity to support the programming needs of the proposed channel, both through our normal business development programmes, and through the secondment of a senior member of BBC staff to HIE since January 2007. In conclusion, HIE is strongly supportive of the Gaelic Digital service, and has been working with a wide range of stakeholders and businesses to ensure that it will have the appropriate impact on the language, culture, heritage and business life of the Highlands and Islands.

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MacTV Mactv welcomes the proposal by BBC Management for a GDS. The idea of a dedicated channel for Gaelic Broadcasting has been a long time in the air and even the gestation period for a joint venture between the BBC and GMS has itself been somewhat extended and much still remains to be decided as is indicated in the management documents. It is to be hoped that the final birth will be relatively painless and the progeny will develop and mature to be beneficial to all the stakeholders in Gaelic Broadcasting. Whilst overall the proposal is a major step forward mactv does have reservations about some of the detail provided in these documents. Section 2.4 Joint BBC Trust / Ofcom Description of Service This section appears to reserve news and current affairs programming for in-house BBC production. The actual BBC Management Application document doesn’t appear to mention current affairs as being “reserved”. The independent sector can contribute current affairs programming. For example, mactv has experience of producing three series of a weekly current affairs series (Ceann-La) on Scottish and Grampian TV. Mactv has further experience of producing two episodes for the GMS funded current affairs programme Eorpa on BBC. There is no justification for reserving current affairs for in-house production. Section 2.4 Joint BBC Trust / Ofcom Description of Service “at least half of the programme fund contributed by GMS will be spent in the independent sector” This statement appears to be attempting to reserve a greater proportion of the GMS fund for BBC in-house production than the BBC has previously been able to achieve. Over the past six years the proportion of the GMS spend in the independent sector has averaged over 50% and last year was actually 63%. The spend in the last year in the BBC was 32%. The intention of the 2003 Communications Act was to counter the dominant effect of the BBC in the content supply market and to encourage a competitive market. The GMS fund has over the years managed to go much further towards achieving the aims of the 2003 Act than the BBC itself has nationally. To allow this statement to be included would counteract the aims of the 2003 Act and potentially permit the BBC to gain a greater share of a market than it has previously be able to achieve. Section 2.4 Joint BBC Trust / Ofcom Description of Service

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“in due course up to 50% of non news and current affairs …….. would come from independent producers, subject to a sufficiently developed independent Gaelic production base” According to these documents the BBC currently spends £2.1 on Gaelic Broadcasting. It has not been known to spend any of this amount with the independent sector and there is nothing in these documents to indicate that it would in the future. The BBC Management Application document indicates that the additional £2.5m BBC spend will be split as follows - £2.0m for News, £0.2m to RnG leaving a balance of £0.3m for other television content. That balance combined with the GMS contribution of £10.1m provides a maximum total of £10.4m for television content production. The document further states that the GMS additional spend will be £3.0m which indicates that its current spend is £7.1m. £10.4m compared to £7.1m represents a 46% increase in available funding. Mactv has recently, in anticipation of GDS, increased its core team by 50% bringing in directing, editing and research skills in addition to the production, directing and research skills already in-house. The BBC lists 19 independent suppliers in its Preliminary Market Assessment. Should the additional spend of £3.3m be allocated in equal shares across these independents it would amount to c£175,000 each per annum. Even those which are independent producers rather than functioning businesses would be able to handle an increase in production of that magnitude. For the BBC to state, repeatedly throughout these documents, that the independent sector is not capable of delivering the additional output is not sustained by the facts and any statements relating to “GDS ultimately spending up to 50% with the sector when it is sufficiently developed” would appear to be at best erroneous and at worst an attempt to preserve unjustifiable amounts of content production for BBC in-house. The independent sector can supply the additional content and caveats need not be put in place. If, however, there are to be limits then maybe the figure should be that the BBC is capped at 32% of the overall amount available for all content production. Section 6.6 Joint BBC Trust / Ofcom Description of Service One of the current difficulties for independent producers with producing Gaelic programmes is that there exists a dual responsibility – to the BBC (mostly editorial and production) and to GMS (mostly financial). At times tensions have been generated, usually when GMS extends its remit into editorial and production. Outwith these documents it has been suggested previously that when GDS is launched GMS funding may still be delivered to the independent producer directly by GMS rather than

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through GDS. This would perpetuate a problematic system of dual responsibility. Mactv would like to see it clearly stated that there is a single route for commissioning and funding. Furthermore any audit processes put in place by GDS must apply to ALL content producers not simply the independent sector. Section 7.1.5 and 7.1.6 of Application Document No mention is made in any of the documents as to how the BBC will ensure that there is a clear separation between BBC employees involved with commissioning in GDS and the BBC in-house production element of BBC Scotland Gaelic department. Without some defined measures it will be difficult to ensure that the BBC is not unduly favouring its in-house production arm at the expense of providing best value for money through the provision of a level playing field for all producers. In the BBC’s Preliminary Market Assessment it highlights the potential risk of the BBC becoming the sole purchaser of Gaelic talent. Without clear separation between commissioning and in-house production this risk will inevitably be increased. A significant / majority proportion of the funding for GDS is coming from GMS. A significant market distortion would occur if the GDS proposal permitted the BBC to gain a greater share of the Gaelic Broadcasting content supply market than it currently has. Measures must be put in place to ensure transparency in the commissioning process and a level playing field for all producers. General Throughout all the documents all references to online seem to suggest development of the BBC alba web site. There appears to be no scope for the independent sector in this area. General The financial figures given in various parts of the BBC Managements Application document are inconsistent and somewhat difficult to reconcile. However, this is not necessarily an issue for the independent sector.

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MnE MNE Media very much welcomes the proposal by BBC management to launch a new BBC licensed public service, the Gaelic Digital Service (GDS). The Gaelic speaking community, those interested in the language and the Diaspora will all welcome the opportunity to have Gaelic language content available in a clearly defined locus on television and the internet, and at times when UK viewers generally access their media content. Furthermore, it will benefit the co-ordination of commissioning from the Production sector. 1) We further welcome the proposal that the service is delivered in a co-funding arrangement with the Gaelic Media Service, as a way of maximizing the output of scarce resources in manpower, engineering, distribution and creative capacity. 2) Whilst welcoming effective co-ordination, we would nevertheless wish to ensure that material in the Gaelic language funded by GMS, will not be exclusive to the new GDS, and that, subject to the approval of GMS, it may be made additionally available to as many outlets as are approved by GMS and as widely as possible (e.g.) on commercial internet sites willing to carry the material. 3) We find the proposal for a new joint BBC/GMS Board to which the Management will report, to be unnecessarily cumbersome and duplicating of existing resources and structures. For such a modestly funded channel, the GDS executives would need to make reference to the views of OFCOM, The BBC Trust, BBC Executive Management, the BBC Gaelic Advisory Committee, the Broadcasting Council for Scotland, the Gaelic Media Service full Board, and the Development Committee of the Gaelic Media Service. We would recommend rather that an Executive Chairman be appointed to Gaelic Media Service, and that the GMS Board should include the Chief Executive of GMS and the Head of Service appointed by the BBC (in addition to the BBC seat on GMS already enshrined in legislation). 4) The structure we have recommended at (4) above would have the effect of creating real options for the future, after the 5-year period of the original co-funding agreement comes to an end. 5) BBC Management clearly has a duty in making application to launch a new BBC licensed service, to have some certainty that such a channel has the potential for putting adequate content supply arrangements in place. We are of the view that the proposal, however, over-represents the level of contribution required from the BBC in Gaelic content production, at the expense of under- representing the capacity and capability of the Independent sector and other contributors. The new Channel allows an opportunity for growth and sustainability across a number of production partners in a diverse sector, and given the BBC’s current dominant position within both the broadcasting and production elements of this proposal, it seems essential

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that in moving forward, any modelling should make provision for a clear separation between commissioning and the BBC’s own production department. 6) The BBC has made it clear to the independent trade association PACT that it does not feel the effectiveness of its own in-house Gaelic production department can withstand the introduction of the WOCC financial model of production in respect of the BBC’s own funded programmes. Given that the BBC is currently accessing around a third of GMS programme grants, and that it plans to substantially increase its own programme funding contribution to the GDS project, we would urge further consideration of the following to ensure maximum diversity and range of supply and content in the partnership approach, and avoid dominance by any one supplier: a. The BBC’s position on the WOCC b. The proportion of GMS grant-aid allocated to the independent sector and

other contributors, being reviewed upwards from its present 63%. One possible model which may in practical terms be worthy of consideration, might be that a proportion of GMS funds be ring-fenced annually for the BBC (subject to outcomes agreed with GMS), which the BBC can commission from its own Gaelic production department along with projects funded by its own committed licence fee funding. The balance of funds available at GMS could then be made available to the independent and others sector, with GMS having its own dedicated Independent Commissioner working in partnership with the Head of Service appointed by the BBC. 7) In the building of this new Channel, we welcome the BBC’s commitment to considering personnel attachments from the Corporation to energise the independent industry. MNE Media has already made use of the BBC Gaelic Department’s flexibility and progressive thinking in sharing a limited talent market, and welcomes the opportunity to build on this in the future. We do not however, agree that this is a measure that the Scottish independent industry is in need of to have ‘a kick start’. The sector is already well capable of dealing with a total available funding which equates to half the turnover of medium sized independent companies across the country. 8) Finally, the co-ordinated approach to delivery across platforms which this proposal outlines (and which we welcome) is an opportunity for the BBC to engage effectively with the potential of new media initiatives within the Independent sector which look to future methods of distribution, and we would seek further clarification on the approaches in this direction which are envisaged by the BBC. We are concerned and cannot understand the logic of excluding independent companies from contributing to the Current Affairs programming, and whilst News programming should indeed only be funded by the BBC, we are not of the view that this equates to an

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argument that News programming should only be produced by the BBC. In a particularly challenged country geographically, it seems to us that imaginative use of production companies and indeed nowadays, the public, can make an enormous contribution to the production of News. We very much welcome the BBC offer to contribute Radio nan Gaidheal as a sustaining output for the new GDS television service. It will be warmly welcomed by the audience for the many good programmes it produces, and will better enable independent producers to synchronise their thinking across both radio and television. However, we think that concurrent with this development, there should be a Business plan published by the BBC outlining its plans for growth for the RNG service during the five year period of the joint agreement with GMS.

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PACT Pact is the trade association representing the commercial interests of independent content creation and distribution companies in television, film and interactive media. We have a membership of more than 700 companies across the entire UK. Executive summary 1) A dedicated Gaelic service can in Pact’s view most clearly contribute to two of the

purposes enshrined in the BBC Charter:

• “representing the UK, its nations and regions;”

• and “stimulating creativity and cultural excellence.” 2) While Pact therefore strongly supports the principle of creating a dedicated Gaelic

channel, in our view the model outlined for a Gaelic Digital Service (GDS) fails to fully capitalize on this opportunity. The channel creates a monopoly or near monopoly in the provision and commissioning of Gaelic content. It represents a consolidation of the three major investors in or providers of Gaelic content – the BBC, Gaelic Media Service (GMS) and SMG.

3) Without adequate safeguards, this dominance risks restricting the range of

programmes on offer to audiences, as well as stunting the growth of the external production sector. BBC management’s market impact assessment states:

“There will be fewer players in the Gaelic television broadcasting market (and hence less competition and fewer routes to market for Gaelic television content).”

4) It adds:

“The monopsonistic relationship the BBC/GMS will have with the suppliers of its programmes does bring downsides (such as dependencies and difficulties in providing a platform for new ideas).”

5) Exacerbating this contraction in commissioning gatekeepers for Gaelic content is the

fact that ITV’s investment in the non-news Scottish regional programming is drying up, having dropped by 65% since 2002. Many companies making Gaelic programmes might otherwise have supplemented their Gaelic work with English-language commissions from ITV services.

6) The independent sector can act as a safeguard against this dominance, providing an

alternative creative voice to in-house production so that audiences are offered a wider range of programming. To do this, however, the independent sector requires a level of investment that will allow it to compete effectively with in-house production at the BBC, and encourage it to take risks by investing in development and backing talent.

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7) As proposed, however, the service does not in Pact’s opinion create the conditions

to establish the necessary critical mass in the independent sector, as it fails to guarantee a significantly enhanced level of investment for independents. The GMS commitment to commission at least 50% from independents guarantees only a modest increase of approximately 10% (£500,000) over and above the volume of commissions that independents currently win from the GMS (and this is assuming that GMS’ entire contribution to the service goes directly into production and development).

8) In comparison, BBC in-house is expected to benefit by at least four times that much.

The BBC management’s proposal states that the majority of the BBC’s additional £2.5m investment in the service is “ear-marked for the Gaelic news service.” This means independent companies will be excluded from competing, and BBC in-house is the expected beneficiary. It is also worth noting that little if any of the BBC’s current television production budget of £2.1m is spent on independent commissions. Additionally, the BBC benefits from around 30% of GMS funds, which go to in-house production. Independents are sometimes used in a relatively minor capacity to re-voice third-party programmes.

9) The current proposal also falls short of making any concrete commitment to start

working straight away towards the stated goal of commissioning up to 50% of output excluding news and current affairs from independents, saying only that this will occur “in due course…subject to a sufficiently developed independent Gaelic production base.”

10) On top of the lack of significantly enhanced commissioning funds for which

independents can compete, there is no indication in the proposal of how commissioning and in-house production at the channel will be separated. This is vital in ensuring a meritocratic approach to commissioning, and has been embraced by other parts of the BBC.

11) Pact rejects suggestions that the independent production base in Scotland will

struggle to deliver any increase in demand. The Gaelic production sector boasts a wide range of companies of different scale, with a strong track record of successful programme-making. The BBC’s list of Gaelic companies also fails to take into account non-specialist companies that are involved in Gaelic programming.

12) Moreover, given the sharp decline in ITV’s investment in Scottish regional

programme-making and the fact that the new service represents a consolidation of existing buyers, competition for commissions from the new service is likely to be strong.

13) Pact therefore suggests that 90% of GMS funds should be earmarked for

independents, with the remaining 10% being contestable between BBC in-house and all external suppliers.

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14) Ring-fencing 90% of the service’s GMS funds for independent commissions will act as a valuable counterbalance to the strength of the BBC’s in-house production departments. Given that the new service will be the only significant Gaelic commissioner and provider, this proposal will fit firmly with the GMS’ primary remit under the 2003 Communications Act to secure “a wide and diverse range of high quality programmes in Gaelic.”

15) A 10% contestable window will allow the new service flexibility should BBC in-house

require additional funding above and beyond the £4.6m that the BBC is effectively guaranteed.

16) In summary, our suggestions for strengthening and clarifying the service’s remit

include:

• 90% of all GMS programme funding should be earmarked for independents, with the remaining 10% contestable for all;

• A commitment to begin commissioning for the new service as soon as possible after

it is granted permission to go ahead;

• Clear separation between in-house production and commissioning;

• The service should apply range and diversity tests as per the independent production quota;

• Clarity that independents are allowed to compete for current affairs commissions;

• Clarity over independents’ proposed role regarding the development of online Gaelic

services;

• Crucial to encouraging the growth in the independent sector will be an appropriate IP framework whereby programme-makers are able to benefit from the exploitation of the content they create and to build sustainable businesses. We expect to negotiate Terms of Trade for the new channel with the BBC, and we expect those terms to be largely similar to the UK Network BBC Terms of Trade, including agreements regarding online services. These would, however, be subject to appropriate changes to reflect the particular nature of the channel. In the interim we are in discussions with the GMS over the rights framework that will be applied to GMS commissions made before the creation of the channel.

17) As the BBC’s impact assessment highlights, the experience of S4C in Wales shows

the positive impact that the GDS could have. However, the assessment fails to point out that S4C is a “publisher broadcaster,” commissioning the majority of its programmes from the independent sector. This strong commitment to independents has been a significant factor in S4C’s success in developing a Welsh broadcast-related sector.

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18) As we have argued, a dedicated Gaelic channel offers a significant opportunity to stimulate the independent Scottish production sector, providing the commitment in the current proposals to commissioning from external sources is strengthened. Appropriate changes would in Pact’s view create a virtuous circle, encouraging innovation and creative competition in the programme supply sector and providing audiences with the best, most diverse range of content.

The potential benefits of a Gaelic service

1) A dedicated Gaelic service has the potential to enrich the cultural lives of the Gaelic

community. We see the creation of a dedicated service as a logical response to the opportunities provided by the multi-channel environment.

2) Such a service can in Pact’s view most clearly contribute to two of the purposes laid

out in the Government’s White Paper on the BBC Charter: “representing the UK, its nations and regions” and “stimulating creativity and cultural excellence by using the licence fee as venture capital for creativity.”

3) To fully achieve both purposes, the channel must allow a wide range of voices to be

represented in its programming, drawing on ideas from external sources as well as BBC in-house. In so doing, the channel will create a virtuous circle. It will enhance its representation of Gaelic culture by encouraging creative competition and reflecting its diversity, and stimulate the external production sector, which will in turn generate further creative competition and growth.

4) The BBC management’s proposals for the Gaelic Digital Service (GDS) rightly return

to the issue of range and diversity of programming again and again. The three key reasons for creating the service include delivering Gaelic programming: “in larger volumes and greater variety.” Management argues that the service will “enable the delivery of a wider and more diverse range of high quality programmes.” Most importantly, the BBC’s consumer research indicates that Gaelic speakers want “more choice within the volume of output.”

5) Diversity is also key to the primary remit of the Gaelic Media Service (GMS) under

the 2003 Communications Act, which mandates it to secure “a wide and diverse range of high quality programmes in Gaelic.”

6) Additionally, the service can trigger growth in the Scottish production sector. BBC

management rightly points out that “the nearest comparable service” is S4C, as a Welsh-language service. The BBC’s market impact assessment highlights S4C as “an indication of the potential positive impacts that the GDS could have on expansion in the production sector in Scotland.” This is supported by a University of Cardiff report for S4C that concluded that: “For every direct job at S4C and its supplying independents, a further 2.1 jobs are generated in Wales.”

7) The experience of television broadcasting in Wales shows that talent and experience

won on Welsh-language programming soon percolates through into English language

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content – and often UK Network – production. There is valuable cross-fertilisation between Welsh and English-language production in Wales.

8) However, unlike the proposed Gaelic service, S4C is a “publisher broadcaster” and

the majority of its programmes are sourced from independents. This commitment to commissioning from independent companies has been a vital factor in S4C’s significant role in stimulating the Welsh broadcast-related sector. An S4C report found that this commitment to external suppliers was crucial in developing a Welsh production sector, stating that:

“There is no doubt that S4C has been responsible for providing the vital underpinning of broadcast-related sector in Wales.”

9) The report went on to highlight how investing in programming from external

suppliers had in turn benefited S4C by providing a stream of cost-efficient and suitable content: “S4C has created and shaped a sector, which serves it well.”

The danger of a BBC monopoly

10) As proposed, there is a danger that the GDS could damage the diversity of

programming on offer to audiences, and fail to effectively spark growth in the production sector. The new service would be by far the dominant provider of and investor in Gaelic content, effectively subsuming previously independent funding from the GMS and combining it with that of the BBC.

11) The channel will also largely take over from SMG as a source of Gaelic programming.

SMG is to scale back its provision dramatically and is expected to shed its requirement to produce and broadcast its own Gaelic content and programming funded by the GMS in peak time. In return, it will contribute programming for the new channel.

12) In other words, the three key gatekeepers for investment in and the provision of

Gaelic content will have largely consolidated. And after switchover, Gaelic provision will no longer be part of the BBC2 offering, but rather entirely the remit of the new channel.

13) The sole alternative for Gaelic-speaking audiences is currently Tele-G, from ITV-

owned SDN, which provides only a limited service of up to one hour daily that is reliant on content funded by the BBC and GMS, plus simulcasts from ITV’s Scottish franchisees. The BBC management’s market impact assessment goes further, predicting that: “Tele-G will cease to have a role in digital Gaelic programme provision given that all Gaelic language television content will be available on GDS.”

14) Further limiting available routes to market, ITV’s non-network output in Scotland has

dropped by nearly 40%, from 1,250 hours per year in 2002 to 752 in 2006. This drop was particularly pronounced in non-news genres, ie the programmes most likely to be made by independents, which fell by almost 65%, from 479 hours in 2003 to

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just 172 in 2006. This has obviously hit independent companies that might have supplemented Gaelic commissions from the new service with English-language commissions.

15) The resulting monopoly or near monopoly could potentially dampen creative

competition and stunt growth in the supply market. As the BBC management’s market impact assessment states:

“There will be fewer players in the Gaelic television broadcasting market (and hence less competition and fewer routes to market for Gaelic television content).”

16) It adds:

“The monopsonistic relationship the BBC/GMS will have with the suppliers of its programmes does bring downsides (such as dependencies and difficulties in providing a platform for new ideas).”

17) The BBC’s market impact assessment goes on to argue that consolidation will

generate economies of scale, leading to lower hourly costs per programme. We have not been provided with figures for these savings, but remain unconvinced that there will be an overall saving, particularly during the initial period when the start-up costs of £2m cited in the BBC’s proposal are factored in.

18) Any cost efficiency savings from consolidation must be weighed against the impact of

a near monopoly, which Ofcom has warned can lead to inefficient production practices, along with limiting the range of programmes on offer to audiences. In its last public service broadcasting review, the regulator warned that lack of competition:

“Risks leading to complacency, inefficient production, lack of innovation, lower quality programming, a narrowing of perspectives and the loss of PSB programming for certain groups.”

The flawed proposal for a Gaelic Digital Service

19) Given that the new service would have a near monopoly on Gaelic commissioning

and provision, the need to ensure creative competition is all the more important. This is the role of the independent sector. Independent production businesses represent an alternative production centre to in-house production at the BBC. The BBC’s market impact assessment acknowledges this, stating for example:

“Although there is a risk that the BBC could become the sole purchaser of Gaelic talent (leading to a sub-optimal level of demand for labour), this risk will be small as long as there is a thriving independent sector who will also need Gaelic speaking actors and presenters to feature in their programmes.”

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20) In Pact’s view, however, the proposal fails to ensure the conditions for the independent sector to thrive. To flourish, the independent sector requires a level of investment that will allow it to compete effectively with in-house production at the BBC, and encourage it to take risks by investing in development and backing talent. This is doubly important given the increased level of consolidation in commissioning represented by the new channel.

21) The GMS commitment of at least 50% of its funds going to independents guarantees

only a modest increase of 10% (£500,000) over and above the volume of commissions that independents currently win from the GMS.

22) In comparison, BBC in-house is expected to benefit by an increase in programme

funding of at least four times that much. The BBC management’s proposal states that the majority of the BBC’s additional £2.5m investment in the service is “earmarked for the Gaelic news service.” This means independent companies will be excluded from competing, and BBC in-house is the expected beneficiary – the BBC proposes that “the BBC provides television and online news.”

23) It is also worth noting that little if any of the BBC’s current Gaelic television

production budget of £2.1m is spent on independent commissions. The BBC also benefits from around 30% of GMS funds, which go to in-house production. Independents are sometimes used in a relatively minor capacity to re-voice third-party programmes.

24) Additionally, the current proposal falls short of making any concrete commitment to

start working straight away towards the stated goal of commissioning up to 50% of non-news and current affairs output from independents. It says only that this will occur “in due course…subject to a sufficiently developed independent Gaelic production base.”

25) It must be noted that the BBC does not have a strong track record historically in

commissioning from the independent sector and has for years failed to achieve far clearer goals than those proposed for the new Gaelic service. The BBC as a whole has until recently treated the independent quota of 25% as a ceiling rather than the floor that it is intended to be under statute. Indeed, for many years it even failed to reach the 25% mark, and we welcome recent moves seeking to change this culture such as the Window of Creative Competition.

26) The creation of the joint board of the new service is welcome, but in itself does not

in our view go far enough to ensure a culture change throughout a service that will be run predominantly by the BBC on a day-to-day basis.

27) Pact rejects suggestions that the independent production base will struggle to deliver

any increase in demand. The Gaelic production sector boasts a wide range of companies of different scales, with a strong track record of successful programme-making. It is a sector that the BBC acknowledges is “relatively competitive” in its

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market impact assessment for the service, which also states that entry for newcomers is “fairly easy.”

28) The BBC’s list of independent production companies in its market impact assessment

focuses on those businesses seen as specialising in Gaelic programming. This under-represents the scale and potential of the sector. Companies, some of considerable scale, working in English-language content also produce Gaelic programming. For example, The Comedy Unit, a well-known English-language producer owned by RDF, makes the hit Gaelic comedy series Comadaidh Oir as a co-production with MNE. This trend would seem likely to increase with increased commissioning opportunities from a new service.

29) Companies in the independent sector have been scaling up in anticipation of the new

service. Mactv has, for example, recently increased its core team by 50%, bringing in directing, editing and research skills in addition to the production, directing and research talent already in-house.

30) Moreover, given the sharp decline in ITV’s investment in Scottish regional

programme-making and the fact that the new service represents a consolidation of existing buyers, competition for commissions from the new service is likely to be strong.

31) We also see no reason why independents should be excluded from competing for

current affairs commissions from the new service, as the BBC’s current proposal that up to 50% of output excluding current affairs and news seems to suggest. Independents already successfully produce current affairs shows for a range of network and regional services, ranging from Question Time (Mentorn) for the BBC and Dispatches for Channel 4. For Gaelic services, Mactv has produced three series of a weekly current affairs series (Ceann-La) on Scottish and Grampian TV, as well as two episodes for the GMS-funded current affairs programme Eorpa on BBC.

Proposals for stimulating Scotland’s production sector

32) Pact therefore suggests that 90% of all GMS funds should be earmarked for

independents, with the remaining 10% contestable between BBC in-house and all external suppliers. This will help ensure the independent sector has the critical mass to act as a counterbalance to the strength of the BBC’s in-house production departments.

33) Given that the new service will be the only significant Gaelic commissioner and

provider, this proposal will fit firmly with the GMS’ primary remit under the 2003 Communications Act to secure “a wide and diverse range of high quality programmes in Gaelic.”

34) In summary, our suggestions for strengthening and clarifying the service’s role

include:

• 90% of all GMS programme funding should be earmarked for independents, with 10%

contestable for all;

• A commitment to begin commissioning for the new service as soon as possible after it is granted permission to go ahead; otherwise, a hiatus in commissioning from the main source of funding for independents, the GMS, will create uncertainty in the market;

• Clear separation between in-house production and commissioning; the current

proposal does not make any mention of how this will be achieved;

• The service should apply the range and diversity tests as per the independent production quota;

• Clarity that independents are allowed to compete for current affairs commissions;

• Clarity over independents’ proposed role regarding the development of online Gaelic

services;

• Crucial to encouraging the growth in the independent sector will be an appropriate IP framework whereby programme-makers are able to benefit from the exploitation of the content they create and to build sustainable businesses. We expect to negotiate Terms of Trade for the new channel with the BBC, and we expect those terms to be largely similar to the UK Network BBC Terms of Trade, including agreements regarding online services. These would, however, be subject to appropriate changes to reflect the unusual nature of the channel. In the interim we are in discussions with the GMS over the rights framework that will be applied to GMS commissions made before the creation of the channel.

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Sabhal Mòr Ostaig

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Sabhal Mòr Ostaig is pleased that a Gaelic Digital Service is forthcoming and as you have invited views, we would like to raise a few points on aspects which we feel need further clarification. Sabhal Mòr Ostaig has been involved with Gaelic broadcasting for many years and we have had a particularly strong relationship with the Gaelic Media Service (GMS). We also recognise the support which the BBC has given our efforts over the years in terms of the planning and delivery of training courses and providing job opportunities for our students. We welcome the news that the new service will be run jointly by the BBC and GMS, but we have questions about the nature of this partnership. Without an answer to these questions, it is difficult for us to form a complete view of the BBC Executive’s proposals. Our questions are as follows: 1. Are GMS and the BBC entirely at one regarding the proposals outlined, or are there outstanding issues which have yet to be resolved? 2. Could you provide further details regarding the joint management arrangements? What exactly is meant by joint funding? Will leadership of the initiative at every stage in the cycle from strategy to evaluation be subject to joint control, or will the BBC and GMS retain separate areas of responsibility? If subject to joint control, what sort of management team is envisaged? What, in layman’s terms, does ‘editorial control’ mean? 3. We would like further details regarding your statement that the BBC will contribute the same level of funding to the service as GMS. 4. The BBC’s work on behalf of Gaelic is commendable. However, we feel that the independent sector has also made a great contribution to Gaelic broadcasting overall, and particularly regarding the generation of income and employment in the Highlands. It is not clear to us what the precise role of this sector will be in the new service. 5. We are aware that the BBC and GMS are subject to different legislation. Does this have any negative implications for joint working? Until these matters are clarified it is difficult for us to provide you with informed opinions. There is, however, one point on which we are agreed: there is a need for a Gaelic Digital Service. And the sooner the better.

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Scottish Screen Scottish Screen is the national government-backed agency responsible for developing all aspects of screen industry and culture across Scotland, focusing on the following five priority objectives: 1. Education – to ensure that people of all ages and backgrounds are inspired and

equipped to analyse, appreciate, explore, create and share screen media; 2. Enterprise and Skills - to ensure that there are appropriate levels of skilled individuals

and viable companies to sustain all aspects of the screen industries across Scotland; 3. Inward Investment and Communications - to promote Scotland as a dynamic,

competitive and successful screen production hub; 4. Market Development - to ensure that the widest range of screen product reaches

and is appreciated by a diversity of audiences; 5. Talent and Creativity - to identify nurture, develop, support and progress Scotland’s

screen talent and screen production companies. Scottish Screen welcomes the opportunity to comment on the proposals for a BBC/GMS Gaelic Digital Service, as part of the BBC Trust’s Public Value Test. We have sent a similar response to Ofcom’s Consultation on a Simplified Approach to Ofcom’s Market Impact Assessment of the BBC’s Proposed Gaelic Digital Service. Scottish Screen has consistently advocated the case for increased support for Gaelic programming and the BBC’s role in facilitating this, for example in our response to the last BBC Charter Review White Paper: “We welcome the clarity of the Government’s support for the BBC to continue to play a crucial role in safeguarding Gaelic cultural heritage and share the desire to see the current discussions being brought to a rapid conclusion and the launch of enhanced services from 2007. ” We also endorsed the response of Scotland’s Screen Industries Summit Group (SISG) to Phase 1 of Ofcom’s Review of Public Service Broadcasting in stating that: “SISG supports a developing role for Gaelic – with adequate funding - as part of PSB in Scotland. A robust solution is required, which takes account of the potential impact on language and culture of the developing multichannel environment as well as issues of ghettoisation. The goal should be to give the Gaelic community its own flexible creative space on its own channel whilst continuing to afford it another PSB outlet for some of its output to reach a wider audience.” Scottish Screen therefore supports the establishment of the proposed BBC/GMS Gaelic Digital Service and does not wish to see any further delay to the revised launch date in 2008. (We understand that further delay would be likely in the event of the requirement of a full market impact assessment by Ofcom. )

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However, we do wish to raise a number of concerns which we hope will be considered by the BBC Trust and Ofcom in refining their proposals for the BBC/GMS Gaelic Digital Service: Balance of BBC in-house and independent sector programme-makers Scottish Screen endorses the view that the BBC has a key part to play in acting as a pump-primer for the UK’s creative industries. We believe that this essential role is best achieved via the BBC’s support for a strong independent sector, one which is not totally dependent on the broadcaster for Gaelic programme commissions. Writing some five years ago, when the Welsh production ecology was markedly different from today, the former Controller of BBC Wales, Geraint Talfan Davies, spelled out the potential dangers of an independent sector which remains dependent on a single, domestic source of commissions: “This step change in Welsh television broadcasting [the launch of S4C] saw an increase in weekly Welsh language production from 10 to 22 hours, later rising to more than 30 hours a week. In addition, the shift of the Welsh language output from BBC1 and ITV to S4C generated commitments from the broadcasters to fill the available space with increased opt-outs in English. The net result was a very sharp increase in television output for Wales and the creation of an independent sector (I would say dependent sector) that had no economic need to look beyond Wales for its market.” Scottish Screen believes that the establishment of the ‘sufficiently developed independent Gaelic production base’ which is referred to in the joint BBC Trust/Ofcom description of the service should be set as a priority, with clearly defined benchmarks to measure progress. The BBC itself has a major role to play in this. Such an approach would also strengthen the case made in the BBC Trust’s own preliminary market impact assessment in favour of a thriving independent sector: “Although there is a risk that the BBC could become the sole purchaser of Gaelic talent (leading to a sub-optimal level of demand for labour5), this risk will be small as long as there is a thriving independent sector who will also need Gaelic speaking actors and presenters to feature in their programmes.” Looking outwards as well as inwards We believe it is also important that the new service looks outwards as well as inwards, particularly in the context of its role in promoting the long-term health of the Gaelic language. It should look to avoid the danger of ‘ghettoisation’ which was noted in the SISG response to Phase 1 of Ofcom’s Review of Public Service Broadcasting (see above). While we accept that the service can be expected to appeal mainly to the two per cent or so of the Scottish population who understand Gaelic, it should actively seek to exploit the opportunities to engage non-speakers noted in the BBC’s Summary of PVA Research. This will be particularly important on completion of digital switchover when the regular Gaelic

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zones on BBC Two terrestrial will cease and when it is anticipated that SMG will seek release from all its Gaelic obligations. The statement in the BBC Management’s preliminary market impact assessment that fewer than one in ten of the Scottish population will be likely to ever use the GDS should be regarded as a challenge, not a given. Importance of drama Drama programming is hugely important both culturally and in sustaining and developing talent. In the words of Geraint Talfan Davies: “Such is the predominance of television drama as an ingredient in our cultural environment that Raymond Williams described our society as a dramatised society…If that is the case and if, additionally, television drama can be such a powerful tool to legitimise minority cultures, then places like Wales cannot afford to opt out. At the risk of overstatement, in television it is a case of no drama no nation.” We therefore welcome the aspiration to provide some comedy and drama as part of the proposed new service, but would wish to see the inclusion of drama in the schedule as more than an undefined aspiration.

TeleG

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TeleG welcomes this first opportunity to comment on the proposed BBC/GMS Gaelic Digital Service (GDS). In principle, the proposal is to be supported, although there are several aspects about the operation of the new service that are not sufficiently clear at this stage, including the future role of TeleG and its involvement during the transition phase towards digital switchover. This response is being submitted to both the BBC Trust and Ofcom since the issues we wish to highlight are relevant as part of the Public Value Test and Market Impact Assessment process. We favour the simplified approach for the Market Impact Assessment since it would not be in the best interests of the Gaelic community to further delay this first significant development of Gaelic broadcasting since the launch of the daily Gaelic TV service, TeleG, in October 1999. The proposed multiplatform model for the new service is to be endorsed as the only sustainable way forward for a Gaelic service, as opposed to a linear TV channel. This will pave the way for a more cohesive and integrated Gaelic service to be developed for the first time. The Gaelic community has had to contend with a fragmented Gaelic media provision over the years, being without structure or any real sense of community. Although the current response refers to the proposal from the BBC within a BBC/GMS partnership, we also note that GMS have been granted an additional TV license for a Gaelic channel (Sia) which would further segment the Gaelic service provision. There is no reference to this channel license in the present proposal, nor how it will affect or interact with the GDS service. Without any detailed knowledge at this stage, we make the assumption that the GDS and GMS services are mutually exclusive. Whilst the GDS proposal is to be welcomed, we must highlight our concerns regarding the impact this will inevitably have on the current service provided by TeleG in Studio Alba, and SDN, who transmit the service on Multiplex A. It is important and essential to look at how the new service will impact on the overall operation of TeleG, both in terms of staff employment and transmission facilities. Having been established as a result of the ’96 Act, and broadcasting a daily service since 1999, TeleG’s experience and expertise should be built upon and developed in conjunction with the new service. There has been no dialogue with TeleG about the new service structure or proposed delivery plans and we believe that this should be done as a matter of urgency. There is a limit to the degree of integration that can be achieved between TeleG and any new service given by DTT capacity allocated for Gaelic on Multiplex A within the 1996 Broadcasting Act. Assuming that the new service is approved, it is reasonable to make the assumption that a large number of viewers will migrate away from TeleG to the new service. Transmitting two Gaelic services in direct competition with one another does not represent

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good public value. Given that most of the programmes carried by TeleG would be sourced from both BBC and GMS, then a more appropriate way forward may be to provide the simultaneous carriage of the new service on both platforms, but with a modified schedule to accommodate the practical restrictions that are present in Multiplex A. This could be done with careful planning of the schedule to provide a variant of the service on DTT which is a more inclusive service provision, rather than transmitting an alternative channel on another platform. However, this will require further discussions with TeleG and SDN to discuss what may be possible.

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Tobar an Dualchais Tobar an Dualchais is an innovative project which aims to digitise, catalogue and disseminate 12,000 hours of Gaelic and Scots sound recordings online. For further information about the project please go to www.tobarandualchais.co.uk Tobar an Dualchais would very much welcome the introduction of a Gaelic digital service and is delighted that it is proposed that the BBC would have a pivotal role within this, given its record of commitment to Gaelic broadcasting both in terms of output and quality. We would also welcome the Gaelic Media Service’s role in partnership with the BBC. We believe that the Gaelic digital service will be very important to the sustainability of the Gaelic language and culture, and that it will also raise awareness among non-Gaelic speakers, both at home and further afield, of its invaluable contribution to Scotland’s culture and society and to the Gaelic diaspora around the world. Although its primary markets will be Gaelic speakers and learners of all ages, we believe non-Gaelic speakers will also be attracted by the nature and content of the programming. The proposed use of opt-in English subtitling will also offer greater accessibility to viewers, while also giving Gaelic speakers the option not to have them. In addition to the benefits to viewers, Tobar an Dualchais also welcomes the additional employment opportunities that the new service would create. Tobar an Dualchais supports the broadcasting of programmes for up to seven hours per day and the wide range of programmes which have been proposed. We also support the proposal that the service would be available during the late afternoon and early evening as this would make it accessible to the majority of people. We believe that 1.5 hours of original programming per day is a good start for the service but would like to see funding proposals developed to ensure that the provision of additional original programming is achievable within a relatively short timescale. Tobar an Dualchais believes there are considerable benefits in operating the service as a multi-media one as outlined, comprising television, an enhanced radio service and internet delivered programming with related online content. This would allow greater integration and cohesion among the services offered as well as the potential for greater audience engagement. It would also increase availability to local users while taking aspects of the service to a global audience.