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17|05|05

Minutes Of The Twenty-Seventh Meeting Of The Ofcom Content Board Held At Wales Office On 16 & 17 May 2005

Present

Richard Hooper Chairman

Sara Nathan Deputy Chairman

Sue Balsom Member

Floella Benjamin Member

Kevin Carey Member

Jonathan Edwards Member (minutes 1 – 14)

Pam Giddy Member

Rosemary Kelly Member

Matthew MacIver Member

Adam Singer Member (minutes 15 – 60)

Kath Worrall Member

Kip Meek Senior Partner, Competition and Content (Ofcom) (minutes 15 - 60)

Tim Suter Partner, Content and Standards (Ofcom)

In Attendance

[Withheld from published minutes]

* by telephone

Media Literacy: AV Content information research scope

1. [Withheld from published minutes] and [Withheld from published minutes] presented paper CB 63(05) which advised the Content Board of the proposed methodology for research into viewers’ preferences and habits related to information about the nature of audio visual content. It was NOTED that the aim of the research was to inform Ofcom’s work to encourage the creation of a common framework for content information (labels) and to give practical, operational guidance to Ofcom and stakeholders. It was NOTED that the prime concern in suggesting a common labelling framework was to ensure consistency in the presentation of information related to possible harm and offence, in particular to help protect young and vulnerable people from inappropriate material. Members were advised of the concerns raised by some stakeholders in the media literacy consultation in relation to the best way to inform viewers about the nature of content.

2. The Content Board NOTED that Ofcom had established an Audio Visual Content Information Working Group (AVCIWG), which included representatives of broadcasting and the British Board of Film Classification (BBFC); the internet and mobile industries; games industry and consumer organisations. It was anticipated that the group would help Ofcom progress work in this area and provide expert comment on the research plans.

3. Members NOTED the existence of two pieces of previous research undertaken by the ITC / BSC and the BBC , which had enabled the development of the research questionnaire. It was NOTED that 20 pilot interviews would be undertaken gaining a comparison of 2D versus 3D and time shifted viewing, at the end of May 2005. The Content Board NOTED that the research sample would be made up of approximately 50% of participants who had access to five channels and 50% of participants who had access to multi channels, with boost samples taken from viewers using Home Choice and PVRs. The research would be undertaken in three stages: an initial quantitative interview; followed by the introduction of four different viewing options and an opportunity to gather initial impressions of the options; and finally after a two week period (during which the participants would complete a number of related tasks) a telephone interview using similar questions. The two week period had been built into the research in order to record the interviewee responses both before and after a period of deliberation.

4. The Content Board gave consideration to the information contained within the paper and supporting presentation. The possibility of including an element to the research relating to filtering was explored. It was felt that filtering could affect how respondents viewed labelling and that it was important to have a common labelling framework which enabled filtering. However it was NOTED that it would not be appropriate to include filtering into the research at this stage, but that it could be considered at a later stage. It was also recognised that it was important to ensure a common labelling framework enabled the location of material desirable to viewers, as well as filtering out un-desirable material. The accuracy of labels produced by content providers was also discussed. It was NOTED that the participants would understand that the aim of a common labelling framework was to ensure consistency in the presentation of information related to possible harm and offence. It was NOTED that the BBC had indicated that they were keen to work with Ofcom and broadcasters to develop a common labelling framework. Following discussion, Members AGREED that Ofcom should carry out research into content information as discussed and the Content Board were supportive of the plans. It was NOTED that the results of the research project would be brought back to the Content Board later in the year, together with the results of the other strand of the research, into the market place and drivers for change.

PSB Review: Tier 2 Quotas for ITV Nations Programming

5. [Withheld from published minutes] and [Withheld from published minutes] presented paper CB 64(05) which contained a draft statement presenting Ofcom’s final decisions and recommendations on the issues contained in Phase 3 of the PSB Review, which was published on 8 February 2005. Phase 3 of the Review had sought responses to a consultation on proposals for programming in the Nations and Regions and options for the future of indigenous language broadcasting. The consultation had closed on 19 April 2005 and the draft statement had been subsequently drafted for consideration by the Content Board and Ofcom Board . It was NOTED that the Phase 3 proposals had recommended both immediate changes to licensees’ requirements and further changes to take place when the first UK region achieved digital switchover. It was further NOTED that the statement would be published (subject to Content Board and Ofcom Board approval) on 9 June 2005 .

6. The Content Board NOTED that the executives overall approach to regional programming requirements was to hold to the Phase 3 proposals, but to recognise that those proposals created challenges to long-term sustainability. Several steps were proposed to ameliorate those challenges in the short term. The Members reviewed the statement and recommendations made by the executive on the policy proposals and key areas addressed in the paper. Members were content with the proposal to implement the PSB 3 proposal, that minimum requirements for regional news and non-news programmes should be standardised across Wales , Scotland and Northern Ireland , at 5.5 hours per week and 4 hours per week respectively.

7. In relation to the proposal to introduce a range of measures to support sustainability in the short term (including: exemption of national licensees from paying for network programmes not broadcast; relaxing guidelines on co-productions; allowing some of ITV Wales’ non-news requirement to be met by additional regional news programmes and allowing the two Scottish licensees to share all their non-news programmes) [Withheld from published minutes]. Consideration was also given to the effect on scheduling of the proposed exemption of national licensees from paying for network programmes not broadcast. It was NOTED that the economic effect of this proposal would be factored into the licence renewal process.

8. The Content Board indicated its contentment with the proposal to allow National licensees to show regional current affairs in place of network current affairs, to create greater scheduling flexibility. In addition Members felt that the proposal to require the Scottish licensees to provide sub-regional opt-outs in their regional news services, but to leave a Scottish version of the 22.30 national and international news bulletin to their discretion and assessment of commercial viability, was sensible.

9. Members considered the proposal to reduce minimum non-news requirements in the Nations to three hours per week, and in the English regions to 0.5 hours per week, when the first UK region achieved switchover. [Withheld from published minutes].

10. [Withheld from published minutes].

11. Members considered the proposal to recommend that S4C and the BBC in Wales should develop a new relationship which would ensure S4C had control over the nature of its service, its programme strategy and the direction of investment. [Withheld from published minutes].

12. The Content Board NOTED that sufficient funding and in-kind support for a Gaelic digital channel could now be secured from a number of sources, and therefore it was proposed that the SMG ’s Gaelic broadcasting requirements be reduced gradually in return for a contribution to the new channel. It was NOTED that the BBC wished to be a partner in the digital service. Members expressed their contentment with the proposal; [Withheld from published minutes].

13. The Content Board considered the proposal to advise the relevant authorities to consider whether and how it might be possible for TG4 to continue to be broadcast in Northern Ireland after switchover. It was also recommended that a relationship continued between the BBC in Northern Ireland and the Republic of Ireland broadcasters, for example involving greater use of co-productions, as part of a long-term solution to meeting Irish speakers’ needs in Northern Ireland. It was AGREED that the tone of the proposal would be reviewed in order to ensure that the priority of consumer interests was adequately reflected and that an explanation of the service provided by TG4 would be included.

14. Following its review of the statement and consideration of all the issues, the Content Board AGREED that it should recommend the executive’s recommendations to the Ofcom Board , [Withheld from published minutes]. It was AGREED that the entire statement be reviewed in relation to tone of language to ensure that it accurately reflected the strength of Ofcom’s opinion and the evidence backing up Ofcom’s proposals. Members AGREED to send specific comments on the statement’s drafting to [Withheld from published minutes], who would then liaise with Kath Worrall on the re-wording.

Minutes of the Meetings held on 18&19 April 2005 ( Content Board Minutes 26(05)) and Matters Arising

15. The minutes of the Content Board meeting held on 18/19 April 2005 were discussed, with the exception of minutes 15-20 which had not been circulated, and a small amendment was AGREED. It was AGREED that Graham Howell would develop Ofcom policy in relation to the recording of attributable voting within the formal minutes and circulate his decision to Members. It was NOTED that the outstanding minutes 15-20 would be circulated for approval following the meeting, and members were asked to respond to [Withheld from published minutes] with their comments and/or approval within two weeks of distribution.

Content and Standards Group Report

16. Tim Suter updated Members in relation to recent discussions which had been held with:

the Central Religious Advisory Committee – in relation to its working relationship with Ofcom and Broadcasters;
the BBC ; and
ITV – in relation to their position on product placement.

Rolling Forward Plan of Content Board Agendas

17. Graham Howell introduced the schedule CB 65(05) which set out the rolling forward plan of the Content Board agenda to December 2005, the contents of which were NOTED. The Content Board NOTED that Food promotion and children would be brought to the Board for consideration over the following months.

Ofcom Board Meeting of 5 April 2005 and 26 April 2005

18. Kip Meek reported on the Ofcom Board meetings held on 5 April 2005 and 26 April 2005 . The main points to note were that :

The Board had been considering a number of spectrum management issues;
The Board had considered digital switchover rules which were to be published shortly and had received a presentation from [Withheld from published minutes] (Chairman of SwitchCo) ;
The Board had been involved in negotiations around the Telecommunications Strategic Review;
Consideration had been given to the draft Radio Formats paper; and
Ofcom had completed a period of redundancies, was undergoing a performance appraisal system, had recruited two external consultants which were looking at strategic and behavioural issues within Ofcom and had put together a diversity training programme to promote a better working environment, which would be attended by all colleagues.

Members’ Interests

19. The following interests were declared for incorporation into the register of interests:

Sara Nathan would be w orking for City Broadcasting producing a series of programmes, “The Commission”, to be transmitted by Radio 4 in the late summer 2005. (August/September 2005).
Kevin Carey was to take part in the production of a Radio 4 series regarding the history of Christianity.

[Withheld from published minutes].

Radio Review Phase 2: analogue proposals

20. [Withheld from published minutes] and [Withheld from published minutes] presented paper CB 72(05) which outlined responses received to the analogue regulation section of phase 1 of the Radio Review and the subsequent decisions of the executive, which would form the basis of phase 2 of the Radio Review in this area. Members were reminded that Ofcom had published phase 1 of the Radio Review for consultation in December 2005.

21. The Content Board NOTED that the proposal of the executive was to confirm the general approach suggested in the analogue regulation section of phase 1 of the Radio Review in relation to moving from input regulation to output regulation. In particular Members NOTED that the analogue section of the phase 2 report:

confirmed the specific proposals to relax the regulation of studio location and automation;
confirmed the networking rules and the way that Ofcom would regulate outputs, including the use of Format and Localness Files;
expanded upon what would be included in the Format and Localness File;
replaced the proposal to require a professional journalist to be present for all of the hours during which a station’s Format required it to provide local news with a guideline focused more on output;
amended the Localness Guidelines to take account of the above and to reduce the requirements for when local material should be broadcast within locally produced programmes; and
included a proposal, for consultation, as to how Ofcom would deal with requests for changes to station Formats.

22. Members NOTED that the responses to the analogue regulation proposals in our phase 1 Radio Review consultation had been broadly supportive. Most respondents had agreed with the proposal to slightly relax the current regulation regarding studio location and the clarification that stations were free to network outside the hours of locally made programming defined in their Format. However a few respondents objected to the proposal that all of the hours of local programming should be able to demonstrate elements of local material, stating that it went beyond what the legislation required and might not be in the consumers’ interests. Stations pointed out that they should be allowed to target their local resources at times of day when they could have greatest audience impact. The executive had therefore recommended that this proposal should not be pursued, due to the local material requirement being adequately covered by the Localness Guidelines.

23. The Content Board NOTED that the responses to the proposal to remove all restrictions on the use of automation by stations had been broadly supportive. However many stations objected to the proposal to increase transparency in this area, which was that all stations should publicise details of how much automation they were doing in their Format and Localness File. It was felt that publicising details of automation on a stations website could prejudice the stations security and safety of staff. As a result of these objections the proposal had been revised, and it was now proposed that Ofcom would collect data on automation from stations on a quarterly basis. It was AGREED that the first half of the last sentence of the paragraph referring to the use of the data collected by Ofcom would be deleted.

24. Members NOTED that the Phase 1 proposal to allow stations to use news hubs as they saw fit, in line with the move from input to output regulation, and to insert a clause in the localness guidelines that would require “each station to provide direct and accountable editorial responsibility, based within the licensed area, equivalent at least to full time professional journalist cover for all of the hours during which its licensed format specifies that it will provide local news programmes” had caused the largest negative response to the consultation. Many stations argued that this would be onerous and would not achieve the aim of moving from input to output regulation. It was NOTED that subsequently a number of station interviews had been undertaken to ascertain what the effect of the proposal would be in practice.

25. As a result the executive recommended that the proposal be replaced with a guideline focused more on output. The executive believed that for listeners, the quality, relevance, timeliness and accuracy of the news mattered more than where it was read from, and therefore recommended that any group of stations may operate news hubs in any way which made operational sense. However, in order to provide a comprehensive local news service in touch with the area it was covering, the executive had identified a number of minimum expectations which should be met by stations, which were laid out in the paper. A revised wording for this section of the guideline was tabled for consideration. It was NOTED that these guidelines could not be enforced directly, but would be used as a benchmark against which to measure the delivery of underperforming stations. It was AGREED that a number of drafting amendments would be made to the guideline.

26. The Content Board considered Ofcom’s ability to monitor the output of stations and publicise this monitoring. It was AGREED that the rules would be checked to ascertain whether Ofcom had the jurisdiction to oblige stations to promote to the public the content and location of their localness files and to interact with their local community in certain ways. It was felt that if this could be achieved then the local community would effectively monitor output locally. It was AGREED that if Ofcom had the required jurisdiction then this proposal would be incorporated into the report.

27. Concern was raised in relation to the effect of the news-hubs and automation proposals on the amount of hours stations would be manned. It was NOTED that a number of conditions contained within the localness guidelines were intended to try to prevent total automation and it was felt that the continued presence of local BBC stations would have a positive competitive influence in this area.

28. In relation to the regulation of Format changes, a paper on which had already been approved by the Content Board and the Ofcom Board , clarification had been sought on a number of areas. [Withheld from published minutes].

29. In addition Members NOTED that the executive had recommended a number of elements which should be included in the Format and Localness File; including a news bulletin schedule, details of recent news stories covered on air; the news team; the programme schedule; the programme origination schedule; details of automation hours and origination; how to complain to Ofcom; and the stations contact details.

30. Following consideration of all the issues, the Content Board AGREED that it should recommend the executive’s proposals to the Ofcom Board , with the proviso that the above recommendations were taken into account. In addition it was AGREED that the entire report be reviewed in relation to tone of language to ensure that it accurately demonstrated a consumer focus. It was AGREED that the revised draft would be re-circulated to Members when it was distributed to the Ofcom Board . The Content Board NOTED that further sections of the Radio Review – phase 2, which included proposals for Digital Radio and for the public purposes of radio, would be presented to the Board over the forthcoming months, for anticipated publication in July 2005.

Ofcom’s Plans for Access Services Review

31. The Content Board received an update from Tim Suter in relation to Ofcom’s plans for an Access Services Review. It was NOTED that following Content Board approval of changes to the Codes on Television Access Services and EPG ’s in March 2005, the use of abbreviations for subtitling, signing and audio description were already being used by some EPG ’s and had been included in some of the printed press. The Content Board NOTED that Ofcom was in the process of reviewing the list of channels required to provide access services. It was also NOTED that the intention of the executive was to review the Code on Access Services by mid 2006. In preparation for this review research would be undertaken to identify whether the Code was achieving its aims, the results of which would be available before the summer. It was NOTED that a consultation document would be brought to the Content Board for review towards the end of the year.

32. The Content Board discussed the forthcoming review and were supportive of the plans. It was NOTED that a check would be made on the first year of compliance with the Code as part of the annual reporting. It was SUGGESTED that Ofcom could sponsor a cross industry research project to identify who was using signing, to identify the cost benefit of this over subtitles and audio description. It was also SUGGESTED that Ofcom could speak to some of the multicultural broadcasters who were interested in this area.

Cross Promotion: Update

33. [Withheld from published minutes] provided an oral update to the Content Board in relation to Ofcom’s review of Cross Promotion, following the presentation of the initial research findings which had been made at the April 2005 Content Board . Members NOTED that the research had been completed and the executive had considered how section 316 should be applied in relation to competition. [Withheld from published minutes]. The Content Board NOTED that it would consider the proposals for revised Cross Promotion Guidelines at the June 2005 Content Board meeting.

Review of the Production Sector: Terms of Reference

34. [Withheld from published minutes] presented paper CB 66(05) which introduced the scoping document, incorporating the terms of reference for Ofcom’s Review of the UK content production and the independent sector. The Content Board NOTED that the review would involve a strategic review of the UK broadcasting content production sector (including the prospects for growth and the impact of regulation) and a specific review of the operation of the 25% independent quota and commissioning codes of practice. Members NOTED the recent market and regulatory history pertaining to these areas, and the proposed overall approach and timetable for the current review. It was NOTED that initial discussions with some external stakeholders (both broadcasters and producers) had taken place and that Ofcom had received positive feedback in relation to the review. The executive felt that the review would be an opportunity to test the thinking behind why the independent production sector required regulating. It was NOTED that the scoping document was due to be published in the first half of May 2005.

35. The Content Board gave consideration to the scoping document and terms of reference. It was confirmed that it was an intention of the executive to learn about smaller independent production companies through the review. It was NOTED that PACT and the Film Council UK had undertaken a survey of smaller independent and culturally diverse production companies. Members NOTED that the intellectual supply and demand argument for the source of benefit from independent production companies would be addressed within the review. [Withheld from published minutes]. It was SUGGESTED that Ofcom should speak to some children’s independent production companies as part of the review.

36. [Withheld from published minutes].

Content Board Annual Report to the Ofcom Board

37. The Chairman presented paper CB 67(05) which contained a draft of the Report from the Chairman of the Content Board to be contained within the Ofcom Annual Report and other sections of the draft Ofcom Annual Report which related to the work of the Content Board. Members NOTED that this information would form the basis for a report which would be made by the Chairman on behalf of the Content Board, the Fairness Committee and Content Sanctions Committee to the Ofcom Board in June 2005. It was anticipated that a similar report would be made on an annual basis to the Ofcom Board.

38. The Content Board NOTED the content of the paper and made a number of observations about the tone of the report. It was AGREED that Members with specific comments on the drafting of the report would forward their suggestions to Richard Hooper , copied to [Withheld from published minutes] by 20 May 2005 .

S4C

39. [Withheld from published minutes] presented paper CB 68(05) which contained background information in relation to S4C, the contents of which were NOTED. Members considered the current challenges faced by S4C and S4C’s view of the three options for the future raised by Ofcom through the PSB Review. In addition the Content Board were made aware of local issues impacting on S4C and its current funding status.

40. The Content Board thanked [Withheld from published minutes] for the presentation and a request was made that he should make a similar presentation to the next meeting of the Gaelic Media Service.

Ferryside: Digital Switchover trial

41. Members were shown footage of the Ferryside: digital switchover trial, following an introduction by [Withheld from published minutes].

General Election: Issues for Ofcom

42. [Withheld from published minutes] presented paper CB 69(05) which contained a summary of the main compliance issues raised by broadcasters and others during the course of the UK’s 2005 general election campaign. The paper also contained a summary of the main strands of election programming on the terrestrial networks. Following a general discussion, members NOTED the information contained within the paper.

43. It was AGREED that the presentation made at the 10 May 2005 Ofcom Board meeting would be circulated to the Content Board for information and that [Withheld from published minutes] would be invited to attend the June 2005 Content Board meeting to update Members in this area.

Expenses Policy

44. Graham Howell presented paper CB 70(05) which contained a copy of the recently reviewed and re-launched Ofcom Expenses Policy, which was NOTED by Members. It was REQUESTED that some thought be given in future, when launching such policies, as to the tone of the accompanying paper to ensure that it accurately reflected the flexibility to be applied to Non Executives.

Content and Standards Report

45. Tim Suter updated the Content Board on programmes which had been attracting complaints. The Content Board was also updated on the status of current Fairness and Content Sanctions cases.

Radio Licensing Committee ( 9 May 2005 )

46. Pam Giddy and Matt hew MacIver updated Members on the Radio Licensing Committee ( RLC ) meeting held on 9 May 2005 ; when a decision had been made on the award of the Banbury commercial radio licence and the East Midlands and Glasgow Community radio licences. In addition the Committee had made an initial consideration of the applications for the Ballymena commercial radio licence.

Matters for External Communication

47. [Withheld from published minutes] outlined Ofcom’s recent activities and forthcoming announcements. It was AGREED that a paper on the FA Premier League would be circulated to the Content Board for information, and that Kip Meek would provide an oral update on this issue at the June 2005 Content Board .

Advertising Co-regulation: Quarterly Report

48. [Withheld from published minutes] presented to Members the quarterly performance report from the ASA on Broadcast Advertising Complaints covering the period January to March 2005, which was NOTED by Members. The presentation contained a summary of the complaints received and resolved within the period and the ASA’s response times to those complaints. It was NOTED that since taking over broadcasting complaints from Ofcom there had not been a discernable change in the levels of complaints. [Withheld from published minutes]. In addition, the Content Board NOTED future policy initiatives and planned activity, the assessment of compliance in contentious areas and the key results of research projects on customer satisfaction and alcohol. Following the presentation, Members were shown two examples of advertisements which had received a high level of complaints.

49. The Content Board NOTED that the Chairman of the ASA, [Withheld from published minutes] would be attending the June 2005 Content Board to provide a report on the ASA’s Annual Report.

Broadcast Advertising of Alcohol: New Guidance

50. [Withheld from published minutes] presented paper CB 71(05) which contained new guidance by the Broadcasting Committee of Advertising Practice (BCAP), incorporating Ofcom’s revised rules on Alcohol Advertising (published in October 2004). It was NOTED that following strong industry representations by the drinks industry Ofcom had agreed, when publishing the rules, that the interpretative notes would be re-written by BCAP as separate guidance, as soon as possible. In addition to the BCAP Guidance Notes the paper contained the responses to BCAP’s consultation on the proposed guidance and the Advertising Advisory Committee’s ( AAC ’s) comments on the guidance. It was NOTED that Ofcom had agreed that the Content Board should approve BCAP rule changes on its behalf.

51. Following consideration of the information and issues contained within the paper, the Content Board APPROVED the BCAP Notes of Guidance for the Revised TV Alcohol Advertising Rules. [Withheld from published minutes].

Any other business

a) PSB Production Fund

52. It was NOTED that the fund had been announced by ITV plc and that two individuals had been named as responsible for the fund. [Withheld from published minutes]

b) ITV Networking Arrangements

53. [Withheld from published minutes] updated Members in relation to progress which had been made as a result of the consultation document ‘Review of ITV Networking Arrangements’, for which the closing date for responses was 8 April 2005 . It was NOTED that as a result of Ofcom encouraging and where necessary, facilitating the licensees to undertake the redrafting of the networking arrangements to bring them up to date themselves, the licensees were looking at their internal arrangements. Ofcom had received formal individual responses from each of ITV plc, Channel, SMG and UTV, plus responses from both PACT and Channel 4.

54. The Content Board NOTED that these responses generally supported the proposed Option 2 of minor updating to the networking agreements insofar as they dealt with external arrangements, and the reinforcement of the independence of the commissioning process. It was also NOTED that the ITV licensees submitted a collective response outlining the areas of agreement between them on proposed changes to the internal networking arrangements. The licensees had agreed to collectively negotiate a ‘Services Agreement’ between ITV Network, ITV plc and the non-consolidated licensees which would outline the non-regulated activities that ITV Network (possibly via ITV plc) would carry out on behalf of all licensees and the basis on which these services were to be paid for.

55. It was NOTED that there were a number of areas where disagreement between the licensees still existed and on which Ofcom would need to direct the licensees. [Withheld from published minutes];

[Withheld from published minutes; and
[Withheld from published minutes]

It was NOTED that the statement would be published at the same time as the Nations PSB programming obligations.

c) BBC Charter Review Green Paper

56. Tim Suter updated Members in relation to the proposed Ofcom response to the BBC Charter Review Green Paper, which was due to be submitted by 31 May 2005 . It was NOTED that the Ofcom Board would be asked to approve the final draft at its meeting on 24 May 2005 . Members NOTED that Rosemary Kelly’s comments had been forwarded to David Currie and Stephen Carter. It was AGREED that the draft would be circulated to Content Board Members.

d) Advisory Committees for the Nations and Regions

57. In response to a query arising from a set of Advisory Committee minutes, it was NOTED that draft minutes of Advisory Committees should not be circulated prior to ACNR member approval. Members were updated in relation to the timetable of appointment of the ACNR independent Chairmen.

e) Broadcasting Code Launch

58. Members were reminded that they were welcome to attend the Broadcasting Code Launch on 25 May 2005 .

f) Social event

59. Adam Singer reminded Members that they were invited to lunch at his house on 19 June 2005.

Date of next meeting

60. It was NOTED that the next meeting would be held on Monday 20 and Tuesday 21 June 2005 at Riverside House.