Latest Submissions - updated 14th July 2017

VLV responds to DCMS proposal to move Channel 4

VLV canvassed its members to inform its response to DCMS proposals that Channel 4's HQ should move out of London and that its quotas for the English regions should be raised.

Having considered the options, VLV has opposed moving the Channel 4 HQ out of London but agrees that out of London quotas should be raised to reflect existing delivery of this quota.

VLV believes it is crucial that Channel 4 reflects life in the nations and regions and ensures it does all it can to support the growth of independent production companies from across the UK, so we have encouraged Channel 4 to become more engaged with producers in the nations and regions, possibly by having  a greater presence outside London.

The full response can be read here


VLV makes submission in response to DCMS Commercial Deregulation Consultation

VLV is concerned that many of the DCMS current proposals for Commercial Radio Degulation will reduce listener choice and lead to a reduction in the localness of local radio content. 

Local news and information encourage community cohesion and local democratic debate. Commercial local radio is very popular and has a reach far higher than BBC local radio. VLV would not wish any change in regulation to provide an incentive for commercial radio operators to reduce their provision of such content.

VLV agrees that the current format restrictions on the three national analogue services should remain. VLV agrees with the government’s preliminary position that there should still be requirements for national and local commercial radio to provide news and that this should be extended to include essential core information such as traffic and weather services. 

VLV would like to see a regulatory solution which ensures that existing requirements for FM/AM stations are carried over to their equivalent services on DAB after switchover. You can read the full submission here

VLV submits evidence to the Culture, Media and Sport Committee inquiry into fake news

VLV's evidence to the Culture, Media and Sport Committee's inquiry into 'fake' news makes a number of recommendations. These include: 

  • That Ofcom's work on media literacy should be reinvigorated.
  • Funding for news on broadcast platforms should be maintained so that it features more on the ground reporting rather than studio commentary.
  • Technology companies need to help address the spreading of fake news and offensive material on social media platforms.
  • Fact-checking services should be more prominent.
  • There should be greater debate among regulators and broadcasters about how newscasters should manage situations in which opinion is expressed which includes statistics and facts which are unverifiable.
  • The committee should explore whether impartiality regulation could become more scientific.
  • There should be a debate about whether politicians should have to subscribe to the standards set by the Advertising Standards Authority.

You can read the full submission here

VLV responds to DCMS Consultation on PSB Contestable Fund 

VLV has responded to the Department for Culture, Media and Sport's consultation on proposals for the institution of a contestable fund to support delivery of Public Service Broadcasting content. While we welcome the ambition to support better provision of public service content genres which are in decine, we have concerns about the feasiblity of this pilot. We are especially concerned that if the project continues beyond its pilot phase it should not be funded by licence fee revenue which could undermine the BBC's ability to deliver its mission and purposes. The full submission can be read here


VLV response to Broadcasting Code Review February 2017 

VLV has responded to Ofcom's Review of the Broadcasting Code which will apply to the BBC from April 3rd 2017 under its new Charter. The full submission can be read here


VLV response to Ofcom January 2017

VLV has responsed to Ofcom's rules on due impartiality, due accuracy, elections and referendums.  The full submission can be read here 


VLV Reponse to BBC Trust Assessment of BBC Studios, a proposed commercial service

VLV has responded to the BBC Trust's final consultation. VLV accepts that the model of establishing BBC Studios, while not ideal, is the best available course of action in light of the removal of in-house guarantees in the draft BBC Charter, as long as BBC Studios’ primary focus is to provide public service content for the benefit of licence fee payers.

The full document can be found here


A response to Ofcom's consultation on broadcasting, transmission services

VLV has responsed to the market review that Ofcom have published regarding the broadcasting transmission services.  The full document can be read here

A response to Ofcom's consultation on managing the effects of 700 MHZ clearance in PMSE and DTT viewers

VLV is concerned at the continued erosion of DTT spectrum resources and the clear threat to free-to-air television that this latest clearance imposes.  The full submission can be read here

A response to the DCMS consultation on a new broadband Universal Service Obligation (USO)

VLV’s primary concern is that public service broadcasting content should be available universally to the UK population. Therefore, we make this submission on understanding that until superfast broadband delivery is guaranteed for every home in the UK and considered robust enough to be able to provide content to the whole population simultaneously, it should remain a priority for Government to ensure that the technology and spectrum required to provide content on free to air television and radio platforms should be guaranteed.

The full response can be read here


A Future for Public Service Television: Content and Platforms in a Digital World

Ensuring the Future of Public Service Television for the benefit of citizens

Many of the arguments which informed the current BBC Charter were developed in Building Public Value, the policy document which the BBC published prior to the last Charter Renewal. The VLV believes that a vision where the benefits to the citizen are core to the mission of public service television is still valid today. 

VLV believes that public service television should be universally available, available to all free at the point of use, provide something for everyone, including impartial and accurate news and other high quality content for the benefit of the whole of UK society.

Read the full submission to the Puttnam Enquiry here.

(2 February 2016)


BBC Trust Service Review of the BBC Nations' Radio and News on TV and Online

VLV considers Nations content crucial for benefit of society and democracy across the whole of the UK as the transition inherent in devolution progresses. VLV believes that any proposals to improve delivery of content for audiences in the Nations should focus on television and radio platforms, rather than rely unduly on online provision. VLV believes that BBC proposals to rely more heavily on the internet to deliver its mission undermines the principle of universality which has always underpinned BBC services.  Not all regions of the UK have access to superfast broadband and not everyone can afford such provision.  

Read the full submission here.     

(19 January 2016)

Submissions and responses from 2015 

Please see our archive at Previous VLV Consultations