Is SBS in breach of its own advertising guidelines?

Tonight I began to watch "Race to the Pole", a program on SBS TV about the 1911 race between British and Norwegian expeditions to the South Pole . It looked and sounded reasonably interesting (despite being filmed in Greenland because dogs aren't allowed in Antarctica) though I was put off by the number of commercial breaks - three in the first half hour - which (1) disturbed the flow of the narrative and (2) seemed to take up an inordinate amount of time. I didn't time the breaks but my perception was that the SBS Advertising Guidelines were, if not not broken, stretched to the limit.

The Guidelines were introduced about six months ago when SBS effectively became almost a fully commercial network. The preamble to them states:

Section 45 of the Special Broadcasting Services Act, 1991 (SBS Act) provides that SBS may broadcast advertisements and sponsorship announcements before or after programs and during natural breaks and that run in total for not more than five minutes in any hour of broadcasting.

All decisions regarding commercial revenue are subject to the overriding principle that the integrity of the SBS Charter and SBS’s editorial independence are paramount and shall not be compromised in any way.

Decisions about the placement of advertisements in programs will be considered on a case-by-case basis and will have regard to program content and context. SBS will exercise sensitivity in the placement of advertisements. All advertisements will be clearly distinguished from SBS programming content.

The relevant sections state:

1.2 Natural breaks in documentaries and information programs

A break may be taken when:

(i) there is a change of topic, or

(ii) there is a change of method or treatment, or

(iii) recorded inserts occurring in live programs, or

(iv) new participants in a discussion program are introduced.

.....

2.1 Identification of breaks

SBS will assess programs to determine where, and if, there are natural breaks in content according to the definitions under section 1 of these Guidelines.

SBS will then decide which of these natural breaks will be used to carry advertising based on the five minute per hour limit and other considerations, including viewer experience.

2.2 Placement of breaks

Editorial considerations and the interests of viewer experience will be taken into account when considering the placement of breaks.

Within the definitions of natural breaks and the individual context of the program, the following schedule provides an indicative guide for the placement of internal breaks:

Scheduling Slot	Program Length	Parts/Breaks
Up to 10 minutes		No Break
30 minutes	25 minutes	3 Parts / 2 Breaks
45 minutes	40 minutes	3 Parts / 2 Breaks
60 minutes	52 minutes	4 Parts / 3 Breaks

Where the interests of viewers would be better served by a different format, for example to fit in with a particularly suitable interruption of continuity, there may be deviation from this guide. This will be assessed on a case-by-case basis applying these Guidelines in relation to natural breaks in accordance with the SBS Act.

How are "the interests of viewer experience" determined? By examining the entrails of a chicken? SBS is trying hard to sell its decision to increase advertising within programs : it's now prefacing some programs with an explanation along the lines of more ads, better programs, which is an indication that it's failed to convince viewers.

If it wants to "suceed" (as its on-screen announcement says) it should rethink its practices. Frequent breaks do have one advantage for viewers: they provide an opportunity to change channels or switch off, which is what I did tonight.