Take 2 : Let's all take a deep breath, and respond to the BBC Trust consultation yet again...

You might remember that after some of us sent submissions to the BBC Trust's consultation on election guidelines, which we were told was our golden chance to have a say on the grotesque proposal for rigged election debates, we all received an email implying that our views would be completely ignored because the consultation had nothing to do with the debates.  However, it was added that draft guidelines for the general amount of coverage to be received by each party during the campaign would be published in January, and would form a belated part of the consultation.  That process is now underway, and so with a slightly heavy heart I've made a second submission, which this time studiously makes no mention of the debates.  If you'd like to make your own submission, please click HERE.  (Email and postal addresses to send submissions to can be found towards the bottom of the main consultation PDF.)

There was nothing inevitable about the fact that most of the BBC coverage of the forthcoming general election seen by viewers in Scotland will be beamed in direct from London. Since devolution, the corporation has consciously chosen to retain the primacy of UK-wide news and current affairs programming, and has done so for a specific reason. It is a matter of record that in the late 1990s, the director-general John Birt sought the help of the Labour government in blocking the proposal for a "Scottish Six" (an integrated hour-long Scottish evening news programme covering Scottish, UK and international news), because he feared that it would "encourage separatist tendencies". To consciously act on the basis of that motivation was a flagrant breach of the BBC's duty of political impartiality.

As the rejection of the Scottish Six has not been subsequently reversed, it means that the nature of the BBC's election coverage will be to some extent shaped by the desire of an earlier director-general to suppress electoral support for one particular political party, and its perfectly legitimate flagship policy. Self-evidently this is a disgraceful state of affairs, and it now places a special obligation on the BBC to ensure that the party in question, the SNP, is in no way disadvantaged by the UK-wide prism that Birt insisted for political reasons must be imposed upon Scottish viewers.

The BBC claims that it is capable of accommodating Scottish distinctiveness within a UK-wide framework. These guidelines must in their final form be the first step towards making good on that promise at last. The excuse, whether made publicly or privately, that it would be "too boring" for English viewers to have to hear at length from Scotland's most popular political party, is totally unacceptable - or at least it's unacceptable unless the BBC's commitment to political impartiality is no more than a pretty fiction.

The acknowledgement in "Appendix I - Party Coverage 2015" that the SNP's support has increased markedly since the last general election, and that the coverage the party receives in UK-wide election programmes must therefore be increased, is to be welcomed. However, the proposed guideline on the degree of parity that the SNP can expect to enjoy with the so-called "largest parties" is utterly inadequate. The vagueness of the requirement that the SNP should receive similar coverage to those parties "on some occasions" is, to be frank, laughable. Does this mean that producers can largely treat the SNP as a fringe party, just so long as they treat it as a major party for half-an-hour every Tuesday lunchtime on BBC2?

The SNP is currently widely forecast to become the third largest party in the next House of Commons. (One of those forecasts carries the title "the Newsnight Index", so we must certainly take it seriously.) It is also forecast to win considerably more seats than the Liberal Democrats did in 1992, or than the Liberal-SDP Alliance did in 1983 and 1987, or than the Liberals did in the two 1974 elections. At the very least, then, the SNP should be accorded the same level of coverage enjoyed by the third parties in those elections - which amounted to near-parity with the Conservatives and Labour, and on a consistent basis (as opposed to a make-it-up-as-we-go-on "occasional" basis).

One of the factors that the appendix states will be taken into account in determining the amount of coverage is the number of candidates a party stands. It should therefore be noted that -

1) Two of the so-called "larger parties" (namely Labour and the Liberal Democrats) do not stand any candidates at all in one of the four constituent nations of the United Kingdom, so plainly the BBC has never deemed it essential for a party to stand on a UK-wide basis, and most certainly not in every constituency.

2) If it is to be inferred that a party standing in every constituency in Scotland (but nowhere else) will always fall below some form of threshold, then it is totally unjust that the threshold is not clearly specified. It would be perfectly possible for the SNP and others to artificially qualify as "larger" parties by standing hundreds of candidates that have no prospect of retaining their deposit, let alone winning - precisely as the Liberal Democrats do. But they can hardly be expected to take that step unless they have an assurance that it will get them over the required threshold, and that the goalposts will not then be conveniently shifted yet again.

3) There are three sister parties from the European Free Alliance standing in this election. Between them, the SNP, Plaid Cymru and Mebyon Kernow will put up over 100 candidates in England, Scotland and Wales. The SNP and Plaid Cymru work together as a single parliamentary group in the House of Commons. The alliance between the three parties is therefore in an equivalent position to the old Liberal parties, which in elections up to and including February 1974 stood only in some constituencies in England, Scotland and Wales. The Scottish Liberal party was organisationally separate prior to the merger with the SDP in 1988, with the only formal link to the English Liberals being at the parliamentary group level (as is currently the case with the SNP and Plaid). At a minimum, therefore, it's reasonable that the guidelines should ensure that the SNP, Plaid and Mebyon Kernow are afforded the same treatment that the Liberals enjoyed in bygone elections.

The background document on the electoral landscape is "not for consultation specifically", but due regard will be made to "factual remarks" in relation to it. Let me note therefore that there is no objective basis for the claim that "there is insufficient polling to confirm that these figures", ie. polls showing a huge SNP lead for Westminster, "establish a consistent and robust trend". Is it acceptable for the SNP to receive less than its fair share of coverage because there haven't been enough opinion polls published to remove the last remaining sliver of doubt from the drafters of the guidelines? The working assumption must surely be that if there had been sixty full-scale polls published since the independence referendum, they would show broadly the same trend that has been reported by the smaller number of polls there have actually been.

Lastly, I'm extremely troubled by the implicit rubbishing of the idea that a party's membership numbers are of any relevance. No-one is claiming that membership is in exact proportion to a party's electoral support, but it must surely be acknowledged that the SNP becoming the third-largest party in the UK, with more members than the Liberal Democrats and UKIP combined, is a development of considerable significance on its own merits.

*  *  *

Once again, if you'd like to make your own submission to the consultation, please click HERE.