identity for Bermuda's winter season, a top official says.

The Department's $10 million media budget has a spending power of 25-30 percent less than it did at the start of the decade when Government froze it.

Officials say they have no real leeway to divert media money to the November to March off-season, which has been a perennial disappointment in terms of arrivals.

Almost all of its $10 million budget is committed to media spending to support the busier and highly competitive high season which attracts nearly 90 percent of visitors.

Mr. Peter Smith, Tourism's assistant director for marketing, said: "The summer is such a tough competitive situation we simply could not move money away from it in the face of a static budget.

"We spend so little money getting the message out. To really make an impression, we'd have to spend a lot more than we have.'' Tourism didn't always commit the preponderance of its media money to the April to October high season.

"But as the summer has become more competitive, we've allocated more money to it,'' Mr. Smith said.

For more than two decades, Bermuda marketed the off-season months as Rendezvous Season, a vague term scrapped a few years ago because it carried little meaning in the marketplace.

In its place, Tourism settled on "November to March'', an unadorned term that doesn't allow its advertising to hang selling points onto any overall theme.

Current advertising carries on the Bermuda Break theme from high season campaigns with November-to-March features such as the 68 degree temperature guarantee programme plugged into it.

But Mr. Smith indicated the Island's advertising budget is so restricted that its presence in the market is token at best.

Figures for 1994 995 show Tourism spending $1,273,600 in US media, about 12 percent of its total US media spending budget. The money is committed almost completely to newspaper advertising, with little for more expensive television and magazines.

"There is nothing being done to define Bermuda in the winter as a product,'' Mr. Smith said. "We know that's a problem.'' Tourism forecasts visitor arrivals will increase between three and five percent this winter -- continuing 1994's moderate growth.

But Mr. Smith said a three to five percent improvement in arrivals is not good enough for Bermuda's hotels which suffer operating losses in the off-season.

"We need to do better in the winter months,'' Mr. Smith said. "Hotels bleed in the winter. We need to have them break even in winter so that their summer profits become real profits.'' Analyses of the tourism industry maintain the November to March period holds significant opportunities for growth.

Currently, November to March draws a little more than 100,000 visitors, about 25 percent of the Island's total each year.

Mr. Smith believes that with the right marketing image and the right amount of money to push it, Bermuda could draw a lot more people.

"The solution is more money,'' he said.

Last night, Finance Minister the Hon. David Saul expressed surprise with Mr.

Smith's comments.

"The Tourism Minister, whom you know is no shrinking violet, hasn't put to me that he doesn't have enough money. This is entirely new to me.'' Dr. Saul said Bermuda was on the verge of absorbing significant costs in taking over the US military bases next year. As a result, Dr. Saul said Government departments, have been told there are no generous budget increases to be had.

Mr. Peter Smith.