Memorandum submitted by the Independent Television Commission (ITC)
We welcome the opportunity to appear before the Joint Scrutiny Committee on the Communications Bill at its meeting on 23 May 2002, and look forward to answering Members' questions and assisting with further information as necessary.
While the Committee has not formally invited evidence at this stage, I felt that it would be helpful in advance of our appearance before the Committee to set out what the Commission sees as the key issues in relation to the Bill, and we have done that in the attached paper, (summarised on pages 1 to 4).
Briefly, we believe that the Bill goes a long way to meeting the Government's objectives of creating the framework for a dynamic market, maintaining universal access to services of the highest quality, safeguarding citizens and consumers, and minimising regulation. In particular, we believe that:
the proposed liberalisation of media ownership rules will help to attract the investment needed to deliver enhanced services for consumers (paragraphs 5-6 of our paper); and
the Content Board, with strong representation from the nations and regions, should ensure that important "cultural" issues receive proper attention, allowing the main OFCOM board to focus on overall economic regulation and competition concerns (paragraph 27).
In other areas, while we agree with the general thrust of the Bill, we think further work is required. In particular:
while we welcome the concept of general public service requirements in clause 181 of the Bill, it will have little practical value if it is left entirely to licensees to decide how many of these requirements they will meet in addition to their relatively skimpy individual remits. We believe that the Bill needs to provide for more detailed PSB remits for individual channels (providing the necessary clarity for self-regulation), and for an effective mechanism through which OFCOM can address failings in a timely fashion;
the suggestion that OFCOM should only conduct a review of PSB once every three years would prevent it from retaining the up-to-date knowledge of public service broadcasting that it will need if it is to provide annual advice to broadcasters on their statements of programme policy, to ensure that broadcasters are living up to their statement commitments, and to respond effectively to consultation by Ministers on possible changes to the remits of licensed broadcasters, and if required to the remits of the BBC and the Welsh Authority;
while fully supporting the move towards a level playing field for public service broadcasters, we believe that this needs to be underpinned by the ability to apply sanctions to all broadcasters, including the BBC and the Welsh Authority; and
we welcome the requirement for nominated news providers to be adequately funded by the licensees who procure their services, since quality comprehensive news services are fundamental to a healthy democracy. By the same token, we believe that obligations on broadcasters in current legislation to provide an "adequate" news service should be carried forward into the Bill.
We should be happy to elaborate on these and any other points Members may wish to discuss at the session on 23 May, and to follow this up in writing with more detailed information if this would be helpful.
The ITC supports the objectives of the draft legislation and confines its comments to gaps addressed in the accompanying Policy Document or areas where the Bill is unclear. [Paragraphs 1 to 4 of the attached submission]
CREATING A DYNAMIC MARKET
The ITC welcomes the proposed liberalisation of media ownership rules, particularly as they are balanced by strengthened safeguards for pluralism in news and for investment in regional cultural activity. In a global market, those countries with the most investment friendly regulatory frameworks are likely to gain competitive advantage. [Paragraphs 5 to 6]
An integrated OFCOM, with concurrent competition powers, should be in a position to ensure the market works in a open way and to provide quick and effective redress against any abuse of a dominant position; it will need, in particular, to ensure genuinely open access to relevant networks and systems and real ease of access to consumers by competing service providers. [Paragraphs 7 to 8]
The opening of the sector to international investment should be allied with policies that ensure high levels of funding in original production for UK audiences and real accountability. Three important tools are:
The not for profit status of Channel 4.
OFCOM's powers to ensure pluralism in news, to set targets for original production as well as investment for production in the Nations and Regions and to assess the delivery of their remits by public service licensees. [Paragraphs 9 to 11]
UNIVERSAL ACCESS TO SERVICES OF THE HIGHEST QUALITY
The ITC supports the Three Tier concept of regulation and the carrying forward of core principles designed to underpin editorial standards, such as impartiality, fairness and decency. It recommends a "level playing field" in the equal application of sanctions, where necessary, to all broadcasters, including the BBC, and suggests the yield of any BBC fines that may be levied is devoted to training or similar mechanisms for supporting high standards to the benefit of audiences. [Paragraphs 12 to 14]
The Tier Three proposals for greater self regulation could work well, provided that each of the Public Service Broadcasters' distinctive contributions to the overall ecology is properly captured in their statutory remit. We believe further work is needed to achieve this. [Paragraphs 15 to 16]
The framework within which commercial licensees are responsible for annual statements of programme policy and performance also needs more focus if it is to work effectively. The current draft does not permit OFCOM to reach conclusions which provide guidance for individual services and risks creating a gap of several years between the identification of issues in the market and actions to meet audience concerns. [Paragraphs 17 to 18]
The Bill, in its final form, should include guidance on the relationship between spectrum pricing and trading and the obligation on public service broadcasters to make certain services universally available. The ITC also hopes the Committee will recommend mechanisms for ensuring the investment in programmes made by the not-for-profit public service broadcastersthe BBC and Channel 4is not put at risk by spectrum pricing. [Paragraphs 20 to 23]. Such mechanisms are available in relation to Channels 3 and 5.
A broad balance is also necessary between the must-offer and must-carry obligations of public service broadcasters as a necessary condition of universal availability of services on fair terms. [Paragraph 24]
SAFEGUARDING CITIZENS AND CONSUMERS
The ITC welcomes the formation of a strong Consumer Panel, able to give independent advice on service issues such as access, choice, price and value for money, and believes the Panel will be most effective if appointees have sectoral, business and consumer expertise. [Paragraph 25]
It recommends that OFCOM should have explicit duties not only to customers, but also to members of the public, whether as audiences of non-pay services or as citizens. [Paragraph 26]
The proposed Content Board should involve strong lay representation appropriate to upholding the public interest in what are, inevitably, subjective issues relating to quality, editorial standards and pluralism.
The statutory nature of the Content Board should demonstrate that content issues will receive proper consideration, reassuring stakeholders that such issues will receive due attention without unbalancing the focus of the Commission on economic and competition concerns. [Paragraph 27]
The ITC welcomes the proposed obligation on ITV to ensure the Nominated News Provider is adequately funded to fulfil its role. It supports the simplification of ownership rules for any nominated news provider, allied with continued commitment to the existence of independent supplier(s) of news to the sector as a whole. There is, however, one gap in the proposals, which fail to carry over from existing legislation the requirement for "a sufficiency of news" in peak time. [Paragraph 28]
The ITC welcomes the emphasis on representation of the Nations and Regions on the Content Board and believes OFCOM should provide an opportunity to create more accountability and a stronger presence in the Nations and Regions, supported by a combination of regional offices and dedicated Content Panels. [Paragraphs 29 to 31]
OFCOM should develop a new culture that avoids unnecessary or detailed intervention, whilst acting strongly and effectively when necessary to correct any abuse of power. [Paragraph 32]
It will bring together responsibility for spectrum policy (where government will necessarily retain significant powers of direction), regulation of networks and systems (subject to EU Directives) and content responsibilities, which are delegated to Member States and have traditionally in the UK been exercised independently of government. Parliament will wish to be satisfied that, in an integrated body, content regulationwith its implications for pluralism, impartiality and freedom of expressionwill continue to be undertaken as independently in the future as it has been in the past. [Paragraph 33]
1. The Independent Television Commission is a Statutory Corporation charged with regulating commercial Television in the UK under the Broadcasting Acts 1990 and 1996. Its current remit covers all television services except those licence-fee funded services provided by the BBC, and the Welsh language channel S4C. In addition to the commercial terrestrial services (Channel 3, GMTV, Channel 4, Channel 5 and Teletext), the ITC licenses a further 500 cable, satellite and digital terrestrial services. These include the large majority of the international foreign language channels uplinked in Europe, who have chosen to establish themselves in the UK because of the favourable regulatory framework.
2. The ITC is one of the five regulators whose functions will, under the Communications Bill, be incorporated into the new sectoral regulator OFCOM.
3. The ITC has consistently urged a new statutory framework for the communications sector which:
Uses competition rather than regulation whenever possible to secure the interests of citizens and consumers.
Is investment-friendly, so that the UK communications sector can attract the maximum amount of global capital, innovative technology and managerial and creative talent.
Meets audience expectations for protection from harmful or offensive material and for universal access to a wide range of high quality programmes, particularly from a strong Public Service Broadcasting (PSB) ecology.
4. The ITC believes that the draft Bill and its accompanying Policy Document go a long way towards meeting these objectives. The ITC's comments (in paragraphs 5 to 32 below) are organised round the Government's four declared objectives for legislation and concern issues raised in the Policy Document or those few remaining gaps in the Bill where policy intentions have not yet been fully captured in drafting.
A. CREATING A DYNAMIC MARKET
5. In the global competition for capital to fuel necessary investment by the communications sector, it is those countries with the most investment-friendly regulatory frameworks who are likely to gain competitive advantage. They will also be well placed to attract the best of technological innovation and talent.
6. The ITC therefore welcomes the Government's proposed liberalisation of media ownership rules, particularly as they are balanced by strengthened safeguards for plurality, and for investment in regional cultural centres.
7. The Bill will give OFCOM concurrent powers with the Director General of Fair Trading. In place of the hotchpotch of current competition powers held by the existing regulators, OFCOM will have the modern, best-practice competition powers enshrined in the Competition Act 1998 and European legislation. These powers contain real bite against, for example, operators found to be abusing a dominant position in the market. These concurrent powers, combined with the integration of the five regulators into OFCOM, should ensure that the new regulator can be an effective pro-competition authority right along the value chain from rights acquisition, through programming, infrastructure and distribution. This is becoming increasingly important with the entry of global, vertically integrated companies into the UK communications market; and with the reliance on competition powers rather than detailed ownership regulation in individual media markets.
8. The ITC welcomes the above changes. In particular, it endorses the recent recommendation of the Select Committee on Culture, Media and Sport that the final Bill "will need to make provision for clear ex ante rules ensuring genuinely open access (to networks and systems) to ensure genuinely open competition in the sector". The UK's communications sector will only remain economically vibrant and grow if it is open to investment from the best global companies. But the network business is characterised by bottlenecks at the point of supply to the home and is susceptible to market dominance, so regulators must use effective tools, (notably access requirements) to ensure competing service providers can reach audiences on fair terms.
Investment in Britain's creative industries
9. The ITC believes that the opening of the sector to international investment should be allied with policies that ensure high levels of investment in original production for UK audiences and real accountability. There are three main tools, consistent with the deregulatory thrust of the draft legislation:
The not-for-profit status of Channel 4.
OFCOM's powers to set targets and to review the performance of public service licensees.
10. The ITC recently commissioned an independent Review of Content Regulation in ten countries across Europe, Asia Pacific and North America. This concluded that regulators are moving away from detailed interventions designated to promote quality in domestic production, towards structural, funding-based solutions. It noted that only the US has a domestic market of sufficient size to be confident of the preservation of quality through a thriving indigenous production industry. But the UK, through its combination of an intensely competitive commercial market and public funding, comes a close second to the US in levels of spending on domestic content production (adjusted for market size) and well ahead of most other countries.
11. As the UK market is opened up to global competition it will be particularly important to maintain the support for investment in original UK content discussed in paragraph 9 above.
B. UNIVERSAL ACCESS TO SERVICES OF THE HIGHEST QUALITY
The Three Tier Framework
12. The ITC welcomes the emphasis in the Policy Document accompanying the draft Bill on "maintaining the role of public service broadcasting in the digital age", defined as "the availability of a wide range of high quality radio and television programmesfree at the point of use and encompassing information and education as well as entertainmentwhich reflects the needs and interests of all listeners and viewers".
13. The ITC supports the concepts underlying the proposed "Three Tier" arrangements for regulating PSB.
Tier IEditorial Standards
14. The Bill transplants the core principles which have successfully underpinned basic content standards, impartiality etc in broadcasting. It allows flexibility for their application to evolve in line with changing public expectations. The Policy Document raises the question of a "level playing field" in the application of sanctions for breaches of accepted standards to the BBC as well as commercial licensees.
The ITC has learned from experience that standards are most effectively set with the backing, if necessary, of sanctions. It accepts the argument that licence payers' money should not be diverted to the Treasury as a result of any fines for BBC breaches of standards, but hopes the Committee may find a constructive alternative, for example, payment to an industry training fund or similar mechanism relevant to supporting high editorial standards.
Tier IIIPublic Service Broadcasting
15. The ITC welcomes the deregulatory thrust of the "Tier Three" arrangements for Public Service Broadcasting. Following publication of the Government's White Paper, the ITC has tested this approach over the past two years, moving away from detailed "box ticking" regulation towards high-level outputs, leaving the broadcasters with greater freedom and responsibility to determine in detail how they deliver those outputs. In parallel, the ITC's Annual Reports have moved towards a more rigorous, factual analysis of the television ecology, drawing on detailed audience research. These provide an objective benchmark for public and Parliamentary debate about what is wanted from PSB and whether the current system is providing it.
However, as set out below, there are a number of respects in which the White Paper concepts have not yet been effectively translated into the draft Bill.
16. The Third Tier could work well, provided that each of the PSB's distinctive contributions to the overall ecology is properly captured in their statutory remit. We believe further work is needed to achieve this. The draft Bill sets out a full list of what PSB as a whole should achieve. But, thereafter, the remits for the individual broadcasters are at such a general level that it is impossible to assess sensibly what Parliament could expect each to contribute to that whole. This has a number of disadvantages.
First, the old dictum that if "everyone is responsible" in practice no one accepts responsibility could leave OFCOM in the position of arbitrarily assigning responsibility but unable to enforce it.
Second, there could be a mismatch between expectations and what is possible in a commercial environment. For example, the draft Bill assigns the same remits to Channel 5 and ITV. Despite recent, welcome, evidence of Channel 5's commitment to PSB, their role is currently clearly different from ITV's, as is their revenue. It is unreasonable to expect the same of both. It also slights ITV's contribution which, in addition to "high quality and diverse programming", plays a real regional role and makes a major commitment to original production and landmark programmes (which, throughout its history, from Jewel in The Crown to contemporary output such as Othello, Bloody Sunday, Bob and Rose and the Forsyte Saga have kept the BBC on its toes). Where public service licensees enjoy a high share of revenue, this should sustain an appropriate share of responsibilities. We believe ITV would, currently, accept a remit which captures their commitment to investment in original production (including well-funded landmark programmes), to investment in the nations and regions and to the provision of news, as well as to quality and diversity.
Third, the generality of the remits throws much greater weight on OFCOM "guidance" about the broadcasters' Statements of Programming Policy. This risks a return to a box-ticking mentality and reduces the flexibility which the "Tier Three" concepts seek to deliver.
Fourth, it may render nugatory the flexibility provided in the White Paper for the Secretary of State, on OFCOM's recommendation, to amend individual remits in the light of changing market circumstances. It is difficult to see how remits as general as those proposed in the Bill for Channels 3 and 5 could sensibly be amended, short of giving up public service status altogether.
Finally, the BBC provides the foundation for the public service ecology. As noted below, the Committee will, no doubt, wish to recommend how the Licence and Agreement should reflect the BBC's remit.
17. The ITC believes that the framework within which commercial licensees are responsible for self-regulation (through annual statements of programme policy and of performance) also needs more focus. The draft Bill requires broadcasters to draft their statements with regard to "guidance given by OFCOM" and "the most recent (triennial) report" from OFCOM which analyses the public service ecology. This raises a number of difficulties.
Although the Policy Document suggests that OFCOM should review annually licensees' reports on their own performance, such a review would inevitably be reactive and would not place the broadcasters' output in the context of the development of the Public Service Broadcasting ecology as a whole; this is to be reviewed only every three years.
In a fast-moving market, competitive analysis could, therefore, be three years out-of-date and may not provide relevant guidance as to the current range and quality of available programmes.
The lead time for programme commissioning is often up to two years, so there could be a gap of five years between OFCOM's ability to analyse a trend, apply its concern to a licensee's annual statement and remedial action.
OFCOM's powers to conduct triennial analysis of the overall delivery of public service only permit it to reach conclusions about services taken "altogether over the period as a whole"; so it is hard to see on what basis OFCOM can inform the annual statements of individual licensees.
OFCOM will need powers to obtain information from the BBC, as from the commercial public service broadcasters, if it is to analyse the sector as a whole.
18. The ITC is further concerned that an ineffective triennial review system would create pressures and frustrations which would come to a head around each review. This would put pressure on government to intervene and change the channels' public service remits, creating business uncertainty and an unsatisfactory alternation between self regulation and government intervention. The ITC believes a more effective but lighter tough regime could be delivered on the basis of OFCOM's annual report to Parliament, including a brief high level analysis of the output of public service licensees in the context of the market as a whole. This would provide a regularly updated framework within which licensees could judge whether their commissioning plans were delivering their remit.
19. The ITC welcomes the Government's plans to make available the draft of a new Licence and Agreement for the BBC, so that Parliament can take a view of how public service will be delivered across all relevant broadcasters. The ITC believes the Agreement could usefully be updated to emphasise:
The BBC's commitment to distinctive services; this should not mean limiting the BBC to a narrow remit or particular genres, buttaken as a wholeeach of its services should set standards for the industry and be clearly distinguishable from what is available in the commercial market.
The BBC's duty to make universally available attractive material likely to encourage take-up of new media and digital services.
The need to avoid any impact on the commercial market likely to be disproportionate to the quality of the BBC service supplied.
The BBC should condition the market rather than foreclose entry or undermine any part of it.
Spectrum Trading and Universal Public Service
20. The Government's Policy Document promises a response to the proposals of the Cave Report on Radio Spectrum Management during the summer and Government will announce as soon as possible thereafter if it intends to revise the spectrum provisions in the Bill.
21. The ITC supports the Cave Report's approach to spectrum pricing and trading as a means of ensuring more efficient use of spectrum. In the case of national public service networks, however, it believes incentives towards efficiency need to be balanced against obligations to provide universal services.
22. The ITC hopes that the Bill in its final form will include guidance for OFCOM on the relationship between spectrum pricing and trading and the obligations on public service broadcasters to provide universal services. It commends to the Committee the inclusion of universality in the Bill as part of the definition of public service broadcasting as it relates to national television networks.
23. If spectrum is designated as required for the delivery of universal public service, then the opportunity cost of using it for broadcasting is low and the price should reflect that. In the cases of Channels, 3 and 5, any spectrum charges can be taken into account, along with other costs, in setting the level of fees charged for their licences. Spectrum charges need not, therefore, actually divert investment away from programmes. The BBC and Channel 4, however, pay for licences in kind, through their remit, and not in cash. They are non-profit making organisations whose primary purpose is to invest in content for national audiences. The ITC hopes the Committee will recommend options for ensuring this investment is not put at risk by spectrum pricing. [The ITC's more detailed response to the Cave Report is attached to this submission].
Must Offer/Must Carry
24. The Policy Document notes [Paragraph 184.108.40.206] that clauses will be issued shortly to ensure that the public service broadcasters provide their services universally through all main distribution systems and that the operators of these systems carry the public service broadcasters' services. The issue in respect of satellite conditional access systems is about the terms of access. A broad balance between "must-offer" and "must-carry" is clearly a necessary condition for universal availability of PSB in an all-digital environment. The ITC welcomes the consideration being given to a duty on OFCOM to take account of the special position of public service broadcasters when regulating access terms. We note that there appears to be some uncertainty about how far this would be consistent with European Directives. The Committee may wish to satisfy itself on this important issue.
C. SAFEGUARDING CITIZENS AND CONSUMERS
The Independent Consumer Panel
25. The ITC welcomes the Bill's commitment to a strong Consumer Panel, able to provide independent advice on service issues such as access, choice, price and value for money. It believes this Panel, with appointments approved by the Secretary of State, will be most effective if its members have sectoral, business and consumer experience.
26. The Policy Document refers to citizens as distinct from consumers, reflecting the particular rights of individuals as members of society rather than as customers. At present, OFCOM's duties under the Bill refer only to customers and we recommend the Committee considers ways to ensure it is clear that OFCOM also has duties to:
Audiences, who are not "customers" in relation to free-to-air public service networks, and
Members of the public as citizens.
The Content Board
27. We welcome the proposed Content Board and its role in representing the public interest in the nature and quality of Radio and Television. This will allow strong lay representation on what are, inevitably, more subjective issues such as pluralism, impartiality and quality, while allowing the main OFCOM Board to focus on economic and competition issues. We believe that statutory support for a Content Board will reassure the public that content issues will receive proper consideration. At the same time, the fact of delegation will reassure other stakeholders that content issues will receive due consideration without unbalancing the focus and decisions of the main board.
28. The Content Board will be particularly important in advising OFCOM on issues of pluralism. As indicated in Paragraph 6, the welcome relaxation in media ownership constraints has particular implications for news and the need to ensure access for audiences to a range of agendas:
Plurality is, in essence a news issue. We believe that the Government is right, in current market conditions, to maintain the separation between the main commercial television networks (a key source of impartial news) and groups with a significant share of the press (which is also a vital source of both news and opinion). The proposals in the Policy Document preserve the independence of the Nominated News provider from Channel 3, while nonetheless allowing ITV companies to have a stake sufficient to allow them to be active and committed shareholders.
We welcome, in particular, the proposed obligation on ITV to ensure that the nominated News Provider is adequately funded to fulfil its role; that is, to be an effective nation-wide competitor with the BBC for domestic and international news. The ITC expressed concern in its most recent annual report that funding constraints on ITN, the current Nominated News Provider, threatened a reduction in the range and quality of output it could provide. We recognise the inherent tension between "adequate funding" and the competitive tender process set out in the current legislation. We believe, however, that, properly drafted, the proposed obligation should help stop and preferably reverse the current trends.
There is however one gap compared with current legislation: while ITV Channel 4 and Channel 5 will still be obliged to transmit news in peak time, there is no provision to ensure that this is anything more than at one extreme a short clip of headlines. OFCOM should not specify the precise duration or timing of peak time news bulletins; individual broadcasters are best able to judge the balance. But there should be a backstop power to prevent such an extreme case arising. Current legislation speaks of "a sufficiency of news". The ITC believes this should be carried forward.
The Nations and Regions
29. If OFCOM is to serve the interests of citizens and consumers throughout the UK, it will need effective offices in the Nations and Regions. The ITC believes these should amount to more than the integration of the existing ITC, OFTEL and Radio Communications Agency presence outside London. Over the coming year, and in anticipation of OFCOM, the ITC will develop its Viewer Consultative Councils in the Nations and Regions into more representative Content Panels, able to work with regional offices and inform the Content Board about interests particular to different parts of the UK. The Committee may wish to consider whether representatives of the Nations and Regions on the Content Board could be supported by streamlined Councils in the Nations and Regions, which they might also chair. (We assume, by the way, that the Bill intends to allow for offices in the English regions as well as the Nations).
30. Ownership liberalisation is likely to accelerate the trend towards consolidation. It is vital that this does not lead to vibrant cultural centres in broadcasting, such as Glasgow, Manchester, Leeds and Bristol, becoming mere "branch offices" of a London-centric or international operator. The ITC has pressed for a Charter for the Nations and Regions to sustain programming made in and for the regions, regional investment and greater local accountability. We welcome the Bill's inclusion of out-of-London investment targets as one of the mandatory requirements on Channel 3; and we are working with the ITV companies to develop and spread best practice in local accountability. It will also be important in the move to the "Three Tier" system for PSB not to lose the benefits of the licence commitments, voluntarily entered into by Channel 4 and Channel 5, to out-of-London commissioning. Channel 4 currently undertakes to commission 30 per cent of its output from outside London and employs a senior member of staff to champion the regional production centres. Channel 5's commitment to 10 per cent out-of-London commissions is a more modest but still useful contribution. Under the proposed new arrangements these commitments would become simply a part of the Channel's self-regulatory Statements of Programme Policy. It will be for Parliament to consider whether this is a sufficient safeguard.
D. MINIMISING REGULATION
32. The draft legislation creates a new framework for broadcasting in the UK which opens up the market to new players and gives competition a much bigger role in protecting the interests of listeners and viewers. It will be very important that OFCOM develops a new culture that avoids unnecessary or detailed intervention, whilst acting swiftly and effectively when necessary to correct an abuse of power.
OFCOM's role should also be to empower audiences directly through better consumer information, through OFCOM's Content Board, Content Panels and reporting systems and through its function of developing media literacy.
The Bill makes a number of specific deregulatory changes which we support, notably the explicit shift for internet and true video on demand services from a licensed framework to a self-regulatory one.
It will be important for OFCOM to work closely with and help develop existing self-regulatory initiatives. These include the Broadcasters Advertising Clearance Committee, which performs a valuable role in television and radio advertising self-regulation; and ICSTIS, which oversees basic consumer safeguards in premium rate services and is the industry ombudsman service for communications products and services.
33. OFCOM will bring together spectrum policy, where government will necessarily retain significant powers of direction, regulation of networks and systems, subject to overriding EU Directives, and content responsibilities which are delegated to Member States and which have traditionally in the UK been exercised independently of government. Parliament will wish to be satisfied that, in an integrated body, content regulation (with its implications for pluralism, impartiality and freedom of speech) will continue to be undertaken as independently in the future as it has in the past.
1 Report of the Select Committee for Culture, Media & Sport on Communications-HC 539-1-24 April 2002. Back
2 Comparative Review of Content Regulation. A McKinsey & Company report for The Independent Television Commission-May 2002. Back
3 Not printed. Back