Question 2. Are there any omissions from the proposed Guidelines and appendices?
The BBC's function in an election campaign is to facilitate debate, not to set arbitrary boundaries on debate or to "steer" voters towards a desired conclusion. The guidelines must therefore ensure that there is no repeat of the 2010 debacle. In doing so, the BBC will be returning to the good practice that existed in general elections prior to 2010. In the 2001 campaign, for example, the nearest equivalent to leaders' debates was the appearance of each individual party leader in a series of Question Time specials. The three programmes featuring the leaders of major parties that were standing throughout Scotland, England and Wales were broadcast on a UK-wide basis, while the two programmes featuring the leaders of major parties that were standing only in Scotland or Wales were broadcast only in the relevant nation. In this way, fairness was achieved in the coverage of the four-party contests in Scotland and Wales, and also the three-party contest in England. The 2005 campaign was slightly different, because all three leaders of the major London-based parties took part in a single Question Time edition, albeit they appeared in separate segments and did not debate with each other. As before, balance was achieved in Scotland and Wales by broadcasting a Question Time special in each country featuring the SNP or Plaid Cymru leader, which ensured that those parties received exactly the same amount of airtime as their three opponents.
These precedents point to elementary ways in which fairness can be achieved in any leaders' debates. One option is that the so-called "UK debates" from last time could form the template for debates to be broadcast only in England during the forthcoming campaign. (They did, after all, reflect the party system of England only, and not the rest of the UK.) Those debates could be fully replaced in Scotland and Wales with four-way or five-way debates that give equal airtime to the SNP and Plaid Cymru respectively. The obvious alternative option would be UK-wide debates in which the SNP and Plaid Cymru are fully represented. The guidelines should therefore make clear that the BBC must choose between these two equally-valid options, and that there will be no third option of excluding the SNP and Plaid from the main debates that are broadcast in Scotland and Wales, as happened in 2010.
The guidelines should also make abundantly clear that any second-string debates broadcast in Scotland and Wales in addition to UK-wide debates cannot in any way correct the imbalance that would be created by excluding the SNP and Plaid from the UK-wide debates. This is for two reasons - firstly, there is ample evidence from 2010 that the public quite rightly saw the extra debates as of much lesser importance and largely ignored them, and secondly, the extra debates would almost certainly include the three largest London-based parties, thus giving those parties even more airtime over and above the disproportionate amount they receive in the UK-wide debates. There would be absolutely no 'corrective' effect of the sort achieved by the extra programmes in 2005, which by featuring the SNP and Plaid Cymru leaders only successfully redressed the imbalance that would otherwise have existed.
The guidelines should also emphasise that no tolerance will be given to attempts to use sophistry to justify the broadcast in Scotland and Wales of unfair debates that exclude the SNP and Plaid Cymru. In 2010, it appears that the BBC knew perfectly well that they were departing from good practice in respect of parliamentary elections, and attempted to excuse their actions by redefining the leaders' debates as "Prime Ministerial Debates", ie. debates that were only for Prime Ministerial "candidates". The guidelines should restate the obvious - the UK does not have elections for the post of Prime Minister, and there is consequently no such thing as a "Prime Ministerial candidate". In the context of a parliamentary election, leaders' debates can only be justified if they are debates between the leaders of parties that have representation in parliament. By definition, this includes the SNP (who have had unbroken representation in the Commons since 1967) and Plaid Cymru (who have had unbroken representation in the Commons since 1974).
It should also be pointed out that the excuse offered in 2010 didn't make sense anyway - in a parliamentary system, it is perfectly possible for a party to supply the Prime Minister on the basis of a small minority of seats. There are countless examples from around the world of this happening. The best-known example from UK history is Ramsay MacDonald continuing as Prime Minister after his party (National Labour) won just 13 out of 625 seats in the 1931 general election.
The need for the guidelines to explicitly set out a requirement for fair debates has become even more apparent in recent weeks, with the revelation that the BBC have learned no lessons at all from the 2010 debacle, and are once again proposing to totally exclude the SNP and Plaid Cymru from the main debates to be broadcast in Scotland and Wales. Curiously, though, they are proposing to include UKIP this time, which weakens the 'logic' for the exclusion of the SNP and Plaid still further. The Chief Political Adviser to the BBC, Ric Bailey, recently claimed on a radio programme that the line-up for the debates was being determined on "very objective criteria", based on the result of the last general election (which of course was in any case tainted by the broadcast of unfair debates) and also opinion poll evidence since that election. And yet at the last election, the SNP won six seats, Plaid Cymru won three, and UKIP won zero. At present, opinion polls are suggesting that the SNP will be the third largest party in the next House of Commons, ahead of the Liberal Democrats and also well ahead of UKIP. There has never been a time since the last general election when the opinion poll average has suggested that UKIP will win more seats than the SNP - the reverse has always been predicted. The guidelines should therefore make clear that there is no objective criteria that could possibly justify the exclusion of the SNP from the main debates while UKIP are included.
The fact that the SNP are currently projected to become the UK's third biggest party in parliamentary terms (they're already the third biggest in terms of membership) ought to give the BBC pause for thought that extends beyond even the fundamental issue of fairness. If the SNP win 20, 30 or 40 seats in May and become the "kingmakers" in a hung parliament, viewers throughout the UK will be utterly bewildered that this development seemingly came out of the blue, due to the BBC and other broadcasters deliberately "hiding" a key part of the election story from them during the debates.
It's also worth noting that under the current proposals, the BBC will include all major parties that have a male leader, and will arbitrarily exclude all three major parties that have a female leader. It's obviously impossible to know whether this is merely an unfortunate coincidence, but at the very least it's not going to look good.
Lastly, the guidelines must address the dreadful error that was made in putting together the live audiences for the 2010 leaders' debates. Not only were the SNP and Plaid excluded from the debates themselves, but their voters were literally banned from being part of the audiences, due to the insistence that all audience members must come from the immediate vicinity of the debate's location in England. The guidelines should make clear that all debate audiences must be drawn from throughout the United Kingdom, thus enabling people who vote for all major parties to be fairly represented.
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Once again, if you'd like to make your own submission to the BBC Trust consultation, the link is HERE.