III. COMPETITION, ACCESS AND ECONOMIC
19. One of the starting points for the White Paper
is the Government's ambition to make the United Kingdom "home
to the most dynamic and competitive communications and media market
in the world".
We have observed before that the United Kingdom has important
advantages in the new communications and media market, including
the English language and strong creative industries.
The media and communications sectors are of increasing importance
to the British economy. They are growing 11 per cent faster than
the rest of the economy.
They are important components in the knowledge-based sector of
the economy by which increasing store is set.
Judged by criteria such as availability of narrowband Internet
services, particularly in the home, mobile telephone penetration
and take-up of digital television, the United Kingdom appears
well-placed compared with other major European countries as a
consumer market for new technology.
20. The production sector is vital not only as a
source of employment, but also in providing the innovative content
that can drive the spread of new technologies.
The continuing vitality of more established technologies was also
demonstrated in the 1990s by the striking success of commercial
radio, a sector that greatly increased its turnover, its income,
its audience and the range of services it offered.
Broadcast radio employs nearly as many people as broadcast television.
The latter production sector is also strong and growing.
Through investment in production, such as that by Channel 4, television
also contributes to the health of the British film industry, a
vital element of the creative communications industries, even
though the film industry is understandably not central to the
regulatory concerns of the White Paper.
21. It is hard to disagree with the economic ambition
set by the Government to make the United Kingdom "home to
the most dynamic and competitive communications and media market
in the world". It is important, however, that that ambition
does not become a platitude, asserted by the Government in the
face of inconvenient evidence to the contrary. Performance in
relation to that ambition must be subject to proper audit and
It is appropriate for the new regulator to conduct such an audit,
both because its own regulatory activities will affect the development
of a competitive market and because the audit will encourage the
regulator to examine other restrictions upon competition for which
the regulator is not directly responsible. We recommend that
a statutory duty be imposed on the new regulator to conduct and
lay before Parliament an annual audit of performance in relation
to the stated Government objective of making the United Kingdom
"home to the most dynamic and competitive communications
and media market in the world". We envisage that this audit
would look beyond sectors subject to direct oversight by the new
regulator, to the film industry, for example, to broaden understanding
of relations between the sectors.
22. One example of a specific intervention in competitive
markets by means of legislative action is the independent production
quota imposed by the Broadcasting Act 1990 that requires the BBC,
ITV companies, Channel 4 and Channel 5 to devote at least 25 per
cent of the time allocated to qualifying programmes (broadly excluding
news, acquired programmes and repeats) to the broadcasting of
a range and diversity of independent productions.
It is widely accepted that the quota has contributed both to the
health of the thriving independent sector and to the quality of
The White Paper's position that the quota remained desirable for
the moment, but might require adjustments to reflect the changing
nature of the independent sector, was broadly supported in evidence.
23. Many new technologies in communications and the
media are labour intensive and thus create new employment opportunities.
These opportunities are dependent upon a skilled and trained workforce.
Trends in the industry, particularly the television production
sector, have created a workforce with many freelance employees,
making it less possible to rely on in-house training.
The White Paper states that "there is a case for OFCOM to
have a general responsibility to promote support for training
across the wider broadcasting industry", including a power
for the regulator to require broadcasters to set out training
plans as a licensing requirement.
This proposal was welcomed by BECTU and by Skillset, the national
training organisation for broadcast, film, video and interactive
Channel 4 argued that the Government should go further and set
for other broadcasters the statutory targets for training expenditure
that are already in place for Channel 4.
We are not convinced that inflexible legislative provisions
relating to training expenditure by all licensed broadcasters
are desirable, but we support the granting of a power to the new
regulator to promote training activities, where appropriate with
specified universities, that are proportionate to the public service
obligations and privileges of particular licensed broadcasters.
The priority of competition regulation
24. The White Paper proposes that OFCOM's central
regulatory objectives should be:
"· protecting the interests of consumers
in terms of choice, price, quality of service and value for money,
in particular through promoting open and competitive markets;
· maintaining high quality of
content, a wide range of programming, and plurality of public
· protecting the interests of
citizens by maintaining accepted community standards in content,
balancing freedom of speech against the need to protect against
potentially offensive or harmful material, and ensuring appropriate
protection of fairness and privacy".
The White Paper acknowledges that, "in the context
of any particular decision falling to the regulator, these objectives
may pull in different directions, and it will then be for the
regulator to strike the right balance".
The Government envisages the governing body of the regulator resolving
"any conflicts between the regulator's different objectives
in a clear and transparent way".
25. The Green Paper that preceded the firmer proposals
of the new document stated:
"The regulatory process starts with Government.
Regulators must have a clear legislative framework within which
to operate. With greater clarity of duties and objectives comes
improved accountability for their deliveryto Parliament,
to Ministers and to consumers."
Some evidence called into question whether the greater
clarity envisaged by the Green Paper had been provided in the
White Paper. The ITC considered that there was "an inherent
tension in OFCOM's prospective duties" and that it would
be wrong to leave the resolution of such tensions entirely to
OFCOM, suggesting instead that Parliament provide guidance on
A similar point was made by ntl: "There is no indication
of how OFCOM should attempt to balance these objectives, which
risks lack of clarity, inconsistency of rules and compromising
all three objectives".
26. BT suggested that there was a tension within
the first objective, combining as it did the distinct issues of
consumer protection and of the promotion of open and competitive
Consumer protection is a desirable objective, but it is distinct
from the promotion of markets, which is a means to other ends
as well. The favoured solution of both the ITC and ntl was to
establish the promotion of open and competitive markets or competition
as the primary objective of OFCOM.
27. We are not convinced that such an approach is
desirable. Nevertheless, we are concerned at the lack of clarity
both in the phrasing of the objectives and in their intended priority.
At one stage, the White Paper refers to consumer protection as
"a principal duty" of the regulator and the apparent
primacy of this duty is reinforced by its placement as the first
of the three objectives.
We would not wish to see the new regulator perceived simply as
a consumer watchdog. We recommend that the new regulator be
given distinct objectives relating to consumer protection and
to the promotion of open and competitive markets. We further recommend
that the Government prepare policy guidelines for the new regulator
on matters affecting the priority of its different objectives
to be debated as part of the legislation giving effect to the
proposals in the White Paper.
Access and sector-specific regulation
28. In 1998 we considered the impact of growing competition
and of enhanced powers for competition regulators such as the
Office of Fair Trading upon future economic regulation of broadcasting
and communications. We heard suggestions that sector-specific
economic regulation of these sectors was no longer necessary.
We rejected this view. We concluded that there would be a need
for "swift, coherent and effective regulation of infrastructure
and gateways" and that this regulation would "require
sector-specific skills and focus".
29. The White Paper indicates that the Government
is of the same view. The document states that OFCOM will have
concurrent powers with the Office of Fair Trading to exercise
Competition Act powers for the communications sector and that
OFCOM may rely increasingly upon such powers, but that OFCOM will
also have "additional sector-specific powers" to "ensure
that there is fair access to dominant network systems for both
content providers and infrastructure competitors".
The ITC, ntl and Video Networks Limited all indicated that progress
in opening up networks to new services would be a key factor in
determining OFCOM's success.
30. The importance and sensitivity of these regulatory
issues were illustrated by the concerns evinced by witnesses about
the operation of current and future obligations to provide certain
channels on all networks. Doubts were expressed both about the
fairness of charges levied and costs incurred by networks for
carriage of certain free-to-air channels and about the possible
burdens associated with additional channels with "must carry"
BSkyB contended that apparent differentials in charging policies
between satellite and other networks reflected a fundamental difference
that costs were incurred for satellite operations to ensure that
British channels were not available abroad whereas there were
no equivalent costs for terrestrial or cable transmission.
The White Paper proposes that responsibility for the regulation
of such matters be transferred from the Office of Fair Trading
31. We support the proposals in the White Paper
to grant sector-specific powers to the new regulator. The exercise
of these powers will have a vital role to play in the continued
development of accessible networks and fair and competitive markets.
It is appropriate that such powers be exercised by the new regulator.
32. In addition to the economic benefits that flow
from a competitive, regulated market in communications, competition
also produces plurality. However, while the White Paper accepts
that "fostering competition is the first step to promoting
plurality in the media", the Government considers that there
may be a continuing need for "backstop powers to underpin
plurality of ownership and a plurality of views in the media".
The White Paper is not clear about what form such backstop powers
might take. When the Government embarked upon consultation on
communications reform in 1998, no reference was made to possible
changes to the restrictions on media ownership in the Broadcasting
Acts 1990 and 1996. Accordingly, the Government has only recently
embarked upon consultation on media ownership controls.
33. As an exception to the generally tentative approach,
the White Paper makes specific proposals relating to ownership
of certain ITV licences.
Some of these changes were proposed by the ITC and they were supported
by both Granada plc and Carlton Communications plc in evidence.
Mr Stuart Butterfield, Managing Director, Granada Broadcasting,
looked forward to a possible move from "the rather hobbled
federal system which has existed for the past 40 years to a unitary
structure which we believe is the only way to compete both domestically
He thought that such a move would enable there to be "a strong
British player on the worldwide scene, which does not exist at
The White Paper refers to the possible benefits of "streamlining
the strategic decision-making process within ITV, and promoting
the international standing of ITV companies", but Mr Smith
emphasised that further amalgamation of ITV companies would remain
subject to the normal provisions of competition law.
34. The White Paper proposes that the increased possibilities
for the further consolidation of ITV should be balanced by continued
regional obligations in licences for ITV companies, with particular
provisions to review regional obligations when ownership changes.
BECTU emphasised the need to ensure such obligations were maintained
in practice, with particular regard to regional news and the contribution
of regional production to network programming.
ITV and its component companies saw the regional commitment as
crucial to ITV's continuing public service identity in the digital
era and showed no wish to see regional obligations reduced.
The ITC told us that discussions were already taking place about
whether there should be legislative provision for a single ITV
licence with regional requirements or whether separate regional
licences should be retained. The ITC saw merits in the retention
of regional licences.
So do we. We recommend that, notwithstanding the proposed removal
of specific legislative barriers to further ITV consolidation
above and beyond the general provisions of competition law, separate
licences be retained for each ITV region, including provisions
relating to regional production and the contribution of each region
to network programming. We further recommend that there be a legislative
obligation upon the new regulator to maintain a network of offices
in the nations and regions of the United Kingdom to facilitate
effective monitoring of compliance with regional obligations by
35. While the Secretary of State appeared to view
competition law and licensing obligations as providing sufficient
safeguards with regard to ITV, he was not convinced that this
was the case in other sectors. In the White Paper and in his oral
evidence, a distinction was drawn between "diversity"defined
as the range of different programmes and services available to
viewers and listenersand "plurality"viewed
as being about the choices viewers and listeners were able to
make between different providers of such services.
The value of this distinction was noted in evidence,
but it does not, of course, necessarily follow that there is a
clear public interest in specific protection of both in all cases.
It was suggested by SMG plc that the stability available to larger
media owners was crucial to the investment in content and new
products that produced diversity in output.
Lord Gordon of Strathblane made a related point in the context
of radio ownership:
"From the point of view of the listener,
I would suggest that plurality of ownership, far from producing
diversity of output, may in fact reduce it for reasons both of
motivation and availability of resources. It is, perhaps, obvious
that if a single owner has several radio stations in the one marketplace,
it is in his own self-interest that different services will be
provided and listener choice enhanced."
36. Radio ownership is currently controlled by a
points system, whereby licences are awarded points according to
the size of the population covered by the service and no organisation
can control licences accounting for more than 15 per cent of the
total number of points.
We received evidence that these restrictions were limiting investment
in the radio market and providing a perverse incentive to take
such investment overseas.
It was suggested that failure to revoke the rules would jeopardise
the development of this small sector.
The Radio Authority considered that the existing ownership rules
for radio were "becoming anachronistic".
Despite the apparent unanimity in the radio industry that no special
restrictions on radio ownership nationally were required beyond
the provisions of competition law, the White Paper speaks vaguely
of the possibility of replacing "the current system with
one that is simpler and fairer whilst still protecting the objectives
of plurality and diversity".
We do not believe that the case for specific restrictions on
radio ownership at national level has been made and we recommend
accordingly that legislation giving effect to the White Paper
proposals should remove all such restrictions.
37. While there are specific provisions on television
and radio ownership in the Broadcasting Acts 1990 and 1996, the
most complex and contentious rules relate to cross-media ownership.
Even the White Paper's concise summary of the voluminous legislation
lists 13 separate provisions, of which the most significant is
the prohibition on a proprietor of national newspapers with a
national market share of 20 per cent or more having more than
a 20 per cent stake in a regional or national Channel 3 service
or Channel 5 or a national or local radio service.
38. We received some evidence supporting the status
BECTU argued that there would continue to be only a few "big
players" in the marketplace and that this justified continuing
controls on cross-media ownership.
The BBC contended that existing restrictions "are appropriate
and proportionate, have worked well in the public interest, and
should be maintained".
Granada plc was also concerned at the possible extension of "cross-media
consolidation involving newspapers and the broadcast media, where
two very different cultures, of impartiality and partisanship,
39. Others suggested that existing restrictions had
failed to keep pace with a more diverse and internationally competitive
market. The growth in the number of channels and the number of
media outlets was viewed as having changed the market in ways
that existing legislation did not reflect.
This case was made by Mr Charles Sinclair, Chief Executive of
Daily Mail and General Trust plc:
"The historic approach to regulating cross-media
ownership is out-dated and irrelevant, and may even be counter-productive
... Competitive activity in most media markets is a stimulant
to the quality, and that is what attracts people to use media;
and it stimulates the providers of media to be better. We see
that time and time again. Cross-media restrictions help none of
40. Both SMG plc and Daily Mail and General Trust
plc argued that cross-media ownership brought positive advantages
to viewers, listeners and readers and to the creative and journalistic
Accordingly, Mr Don Cruickshank, Chairman of SMG plc, considered
that "the cross-media ownership rules are now more of a cost
to society and economy than they are of benefit".
Both organisations adamantly rejected the notion that involvement
in ownership of newspapers that are not subject to public sector
content regulation somehow reduced an organisation's capacity
or willingness to comply with standards of impartiality imposed
upon the broadcast media.
41. As the White Paper notes, there is support from
some quarters for restrictions based on overall "share of
Controls based on a definition of a single media market and the
differing levels of influence of different media were canvassed
by the last Government, but eventually rejected by it, in part
because of the problem of measuring shares in individual media
and determining how those shares ought to be aggregated across
different media markets.
Regulation by "share of voice" was advocated by GWR
Group plc and the Broadcasting Standards Commission, although
neither explained how such a system might work in practice.
Daily Mail and General Trust plc have argued that subjective judgements
about impact can be avoided if "share of voice" is calculated
according to profitability and turnover.
42. We remain to be convinced that "share of
voice" regulation is practical. Proposals for such an approach
fail to take account of the fundamentally different regulatory
environments of different media.
Such proposals either involve a whole range of unproven assumptions
about the relative impact of different media or rely on economic
indicators that may bear little relation to actual influence.
Even more fundamentally, all arguments for "share of voice"
regulation that we have heard take no account of the impact of
the Internet. The new media have had the effect of ensuring that
newspapers compete in a more diverse market, for example, regardless
of circulation, readership, turnover and profit.
43. News International plc contended that all present
rules relating to cross-media ownership "are discriminatory,
penalise success and are increasingly obsolete".
Dr Irwin Stelzer, a consultant to that organisation, suggested
that normal competition law was sufficient to prevent the danger
of excessive concentration of economic power.
44. Even from those who advocated retention of detailed
sector-specific ownership controls, there was a recognition that
limits set out in primary legislation could rapidly become counter-productive.
For this reason, there was support for the idea that specific
limits should be contained in secondary legislation rather than
on the face of a new bill, or at least amendable by subsequent
The White Paper hints at such an approach, stating that "our
new legislation will ... build in flexibility for further liberalisation
as and when the market permits this without compromising plurality
45. We consider existing rules on cross-media
ownership contained in the Broadcasting Acts 1990 and 1996 to
be increasingly unnecessary in a more diverse and competitive
media market in which general competition law, sector-specific
regulatory powers and content regulation by licensing all apply.
We view restrictions based on "share of voice" as quite
impractical even if they were desirable. We consider that matters
of such parliamentary and public importance as media ownership
and control should not be open to significant amendment by means
of secondary legislation. A certain inflexibility is inherent
in primary legislation, but this is a price worth paying for full
scrutiny. The inflexibility inherent in such controls in primary
legislation is a compelling reason why specific controls should
be maintained in forthcoming legislation only if the case for
such controls is overwhelming and enduring.
The BBC and the competitive market
46. The White Paper aims to consider the main issues
that affect the development of the United Kingdom as the home
of "the most dynamic and competitive communications and media
market in the world".
Yet one matter that fundamentally affects that development is
largely ignoredthe role of the BBC in the competitive market.
47. During our inquiry we heard a number of allegations
that BBC activities acted contrary to the interest of developing
a competitive market.
The British Internet Publishers' Alliance was particularly concerned
that the range of activities of the licence fee-funded BBC Online
went beyond what could be viewed as "the legitimate extension
It was argued that the BBC was providing services that competed
directly with commercial providers. These elements of BBC provision
were said to have no clear public service rationale; they did
not provide services that were not available from the market;
indeed, they actually prevented the growth of commercial competitors.
According to Mr Robert Hersov of Sportal, "it is enough for
the BBC to hint that they may consider extending their activities
into a certain area to deter a start-up company from seeking funding
and a venture capitalist from providing that funding".
48. Similar arguments were advanced about other markets.
The commercial radio sector was said to be particularly vulnerable
to proposed new BBC services.
It was suggested that some new services were not compensating
for market failure, but undermining successful commercial provision:
"What they are doing now is they are watching the market
and seeing where they can attack us"the words of a
commercial radio manager who worked for the Corporation for 25
The Publishers Association argued that the BBC's proposals for
free electronic learning material were stifling the development
of a commercial market, resulting in "less choice and plurality
for teachers and schools in the range of resources that they can
use in the classroom".
Artsworld Channels Limited also argued that the BBC was transferring
its behaviour formed in the era of spectrum scarcity to fields
more akin to publishing where diversity was likely to develop
In consequence, it was considered that the BBC was in danger of
creating rather than remedying market deficiencies "by using
its dominant power to crush new initiatives".
49. Criticism of new BBC services is not confined
to commercial competitors. Sir Michael Checkland, a former Director-General
of the BBC and now a member of the ITC, was concerned that the
BBC commitment to some new ventures might be premature.
He went on to say:
"The consensus, which used to be in support
of the BBC, has slowly been eroded because people have been worried
about the BBC trying to get involved in everything and I think
that has caused concern. When I was Director-General the first
speech I gave to the BBC staff was to say the BBC should stop
its imperial march. I am afraid it is on a bigger march than was
ever done in the 1980s ... The BBC should not be allowed to run
riot in every area because I think it is destroying the consensus
which I think has been very important for British broadcasting."
50. Sir Christopher Bland, the Chairman of the BBC,
denied that the BBC undertook activities that imitated or replicated
what was already provided in the commercial sector.
In defence of its proposed new publicly-funded television and
radio channels, the BBC pointed to their distinctive elements,
including the high level of domestic originated content and the
fact that they would be "without advertising".
Mr Greg Dyke, the Director-General of the BBC, was also comforted
by "overwhelming support" for one of these new services.
The BBC's brand identity may perhaps make proposed new services
popular in principle, even if BBC Choice and BBC Knowledge have,
by the BBC's own admission, hardly enhanced the strength of that
The BBC's reference to the absence of advertising as an argument
in favour of its introduction of new services is a dangerous and
circular argument: there is almost no market in which the BBC
will not be comparing itself with commercial rivals that necessarily
rely on advertising.
51. Our concern in this Report is not with the merits
of particular proposed new BBC services. Rather it is with the
adequacy of regulation relating to such services and their impact
on a dynamic and competitive market. Responsibility for giving
approval to new BBC licence fee-funded services and material changes
to existing services lies with the Secretary of State for Culture,
Media and Sport.
We have previously recommended that this responsibility be transferred
to the independent regulator.
The White Paper rejects this recommendation, proposing that the
power remain with the Secretary of State, while envisaging an
advisory role for OFCOM.
52. Some evidence supported our earlier recommendation,
arguing that OFCOM was far better placed than the Secretary of
State to understand the market as a whole.
The British Internet Publishers' Alliance argued that the Department
for Culture, Media and Sport "seems focused on the narrow
issue of ensuring that licence fee money is not used on clearly
Mr Cruickshank thought that decisions on new BBC services "should
be central to the [work of the] communications regulator".
The Radio Authority also considered that the Secretary of State's
powers of approval and review should pass to OFCOM at the time
of Charter renewal "or ideally earlier".
53. One reason why we have proposed a switch in responsibility
previously is the potential political dimension to the exercise
of the powers of approval and review. We stated in 1999 that "the
proposal to grant to a politician a general power of review of
individual BBC services seems to us to jeopardise the independence
of the BBC and to tend towards direct ministerial control of broadcasting".
This concern was illustrated by Mr Smith's statement that a review
of News 24 would not take place just yet in part because "the
immediate run-up to a General Election ... would not be a right
and appropriate time to review a new service".
It is hard to understand why it will be acceptable for a politician
to conduct a review that might be open to a perception of political
influence after a General Election when it is not acceptable to
do so before a General Election.
54. Mr Smith claimed in oral evidence that "economic
regulation" of the BBC will be the responsibility of OFCOM
and the competition authorities.
This statement appears to equate economic regulation with oversight
of the commercially-funded activities of the BBC. In fact, new
BBC services funded from the licence fee have the potential to
make a profound impact on the development of open and competitive
markets. The new regulator is best placed to judge this impact,
and also to weigh that impact in the balance against the regulatory
objective of "maintaining high quality of content, a wide
range of programming, and plurality of public expression".
The new regulator should be able to reach such decisions transparently
and in a manner that is free from any imputation of political
interference. The decisions relate precisely to the type of issues
that the new regulator is being established to regulate.
We recommend that, from the time of its establishment, the
new regulator assume the powers to approve and to review new BBC
licence fee-funded services currently held by the Secretary of
State for Culture, Media and Sport. We expect that the new regulator
would be given powers to ensure that, while the BBC retained the
right and the ability to continue with services and to launch
new services funded from the licence fee, such services would
be conducted on the basis of fair competition.
5010, para 1.2.1. Back
(1997-98) 520-I, paras 65-67. Back
5010, para 1.1.18. Back
for all in a world of change: a white paper on enterprise, skills
and innovation, Cm 5052,
February 2001, para 1.18; Evidence, p 75. Back
Warburg e-index", Connectis, February 2001, pp 6-7. Back
5010, para 1.2.2. Back
256, 337, 483; Evidence, p 171. Back
p 65. Back
of the Box, p 11; Q 167. Back
Evidence, p 221. Back
5010, p 108. Back
(1997-98) 520-I, para 101; Eighth Report from the Culture, Media
and Sport Committee, Report and Accounts of the BBC for 1997-98,
HC (1997-98) 1090, para 25; Cm 5010, para 4.2.3; Q 445. Back
5010, sect 4.3; Out of the Box, pp 14-15; Q 167; Evidence,
pp 119, 120-121, 174; Memorandum from the Producers Alliance for
Cinema and Television, paras 39-48. Back
(1997-98) 520, para 67. Back
151-153, 173, 414. Back
5010, para 5.6.3 Back
74 Q 155;
Memorandum from Skillset, paras 4-5. Back
p 127; QQ 414-415. Back
5010, para 8.5.1. Back
para 8.5.3. Back
para 8.6.1. Back
4022, para 5.5. Back
p 143. Back
p 23. Back
p 9. Back
pp 23, 143. Back
5010, para 7.4. Back
(1997-98) 520-I, paras 77-79. Back
para 81. Back
5010, sects 2.3 and 2.4. Back
p 141; QQ 111, 117, 148. Back
pp 57, 116, 235; QQ 402-405, 469, 644-645. Back
pp 111-113. Back
5010, para 2.3.1. Back
para 4.2.6. Back
93 Q 609. Back
5010, paras 4.6.1-4.6.3. Back
para 4.6.1; Evidence, pp 121, 118. Back
96 Q 409. Back
97 Ibid. Back
5010, para 4.6.2; Q 609. Back
5010, para 4.4.3. Back
p 39; QQ 161, 169, 179. Back
394, 408; Evidence, p 175. Back
5010, para 4.2.1; Q 609. Back
pp 165, 166. Back
p 205; emphasis in original. Back
5010, para 4.7.1. Back
256, 505. Back
pp 66, 204-205, 210-211. Back
p 94. Back
p 67; Cm 5010, para 4.7.2. Back
5010, pp 100-101 and para 4.8.1. Back
pp 40, 133, 232. Back
p 133. Back
p 121. Back
pp 105-106, 142. Back
pp 150, 164. Back
534, 602. Back
5010, para 4.8.7. Back
paras 4.8.2-4.8.3. Back
pp 67, 215. Back
(1997-98) 520-II, p 136; Ibid, QQ 408-417; Evidence, pp
p 232. Back
127 Ibid. Back
585, 601, 603. Back
p 16. Back
pp 121, 142, 95. Back
5010, para 4.2.8. Back
para 1.2.1. Back
p 47. Back
QQ 193, 197. Back
p 201. Back
pp 222-225. Back
p 225. Back
452; Evidence, p 139. Back
Report from the Culture, Media and Sport Committee, Report
and Accounts of the BBC for 1999-2000, HC (1999-2000) 719,
para 22. Back
5010, para 5.8.7. Back
(1999-2000) 25-I, para 114. Back
5010, para 5.8.7. Back
p 105; QQ 189, 387-389. Back
p 47. Back
(1999-2000) 25-I, para 114. Back
5010, para 8.5.1. Back