The BBC is planning to launch new stations to compliment and expand the output of existing stations Radio 1, Radio 2, Radio 3 and Radio Five Sports Extra. These will be largely created from existing content which is already available on the on demand BBC Sounds platform.
VLV welcomes the proposal to extend the broadcast hours of Radio 5 Sports Extra. We consider that this will increase the plurality of supply of sports content on live radio for citizens in the UK and therefore will be beneficial.
VLV believes the proposals to provide additional music radio stations will provide additional public value because they are cost effective and aim to increase support for new talent, UK musicians and provide more airtime for live music. However, we are concerned that these new additional stations must be genuinely distinctive in comparison with existing commercial services and they must achieve the targets set out in the proposals.
VLV made a submission to the Department for Culture, Media and Sport’s Review of the BBC Funding Model.
Our primary concern is that any funding for the BBC should remain universal – ie every citizen in the UK pays for the BBC and in return it provides a service which is available across the whole of the UK free of charge and is relevant to all citizens in some way.
We also believe that the funding model should not be decided before it is established what the Government, Parliament and citizens want the BBC to provide.
VLV recommends that the Government should consult citizens before making any decisions on the funding model. It should also commission full independent analysis of the impact changes to the BBC funding model are likely to have so that citizens can make an informed decision about their national broadcaster. Any changes to the funding model should be fully debated in Parliament prior to the Government making any final decision.
VLV would oppose advertising, direct taxation and government grant as funding models for the BBC. We also want the way in which the level of BBC funding is decided to be reformed. Currently the BBC’s independence from Government is undermined by the fact that Government has the power to cut its income.
On the basis of currently available evidence, VLV’s preferred option for the BBC funding model would be some form of universal means-tested household levy.
The Channel 4 license is due to expire on December 31st 2024. As part of the process to renew the licence the Channel 4 Corporation (C4C) has requested changes to some of its existing licence obligations. While recent Ofcom annual reviews of C4C’s performance have found that it is broadly delivering well against its remit and duties, managing the transition from being primarily a linear broadcaster to one which is digital, delivering content online and via its on demand platform, requires some changes in approach.
VLV agrees with all the conditions proposed by Ofcom for the new Channel 4 licence, including that it should be renewed for a 10 year period. In an ideal world we would prefer that some of the quotas in the Channel 4 licence were increased to ensure greater value for audiences in regional representation, for example, but we recognise that the economic environment for broadcasting is likely to remain uncertain for the coming 10 years and increased quotas could undermine C4C’s sustainability.
This is a timely inquiry into the future of news in the UK at a time when Ofcom’s effectiveness of regulating impartiality on broadcast news channels is being questioned.
VLV focuses its response to questions of whether the Media Bill which is currently being debated in Parliament could improve the regulation of impartiality.
VLV considers that a healthy news ecosystem is essential to democracy. We are concerned by the decline in public trust of the media and urge the Committee to explore how this decline can be reversed through better regulation of broadcast media. We consider that impartiality regulation of broadcast content in the UK could be significantly improved. We do not believe that current legislation provides clear definitions of which content should be impartial. We believe that existing Ofcom guidance on active politicians presenting programmes on news channels should be reviewed, along with other elements of Ofcom’s Broadcasting Code and Guidance.
The community radio sector is a growing and vibrant sector with over 300 licensed stations, which VLV welcomes because of the benefits it brings to citizens across the UK.
However, we note concerns that there is a lack of opportunity for new entrants to apply for an FM licence to serve their community.
VLV considers it important that when considering any changes to the licensing regime the DCMS ensures that there is greater access for new entrants to the sector in future. This will ensure there that the diversity of stations is maintained and that innovation is encouraged. VLV also encourages the DCMS to engage with Ofcom to immediately restart the process of licensing new analogue community stations across the whole of the UK.
VLV believes it is crucial to maintain analogue provision for the benefit of audiences not yet on DAB.
Along with considering possible future licensing models, we would encourage the DCMS to seek views on how best to assess social gain which is a primary purpose of community radio and should be taken into account when regulating the sector.
The Government is gathering evidence to inform its decision about how best to distribute TV in the future as broadband access improves and more viewers enjoy content streamed over the internet.
As part of this process VLV has responded to a Call for Evidence from Ofcom on the Future of TV Distribution.
This issue is of interest to citizens because it is essential that free to air Public Service Broadcasting remains universally available if its benefits are to be felt by everyone equally. VLV believes every citizen should be able to access high quality content relevant to their lives in the UK without paying extra for it once the TV Licence is paid.
There are suggestions that Digital Terrestrial TV which we receive through rooftop aerials could be replaced by IPTV, which is delivered via the internet. There are many challenges still for IPTV – it is not universally available, it is vulnerable to cyber attack, we don’t yet have enough capacity for everyone to use it at the same time and it will cost citizens more because they will have to subscribe to a broadband package to receive it. Currently 7% of households do not have broadband access in the UK – either by choice or because it is not available.
VLV suggests that a hybrid approach should be taken until such a time as IPTV is proven to be resilient enough, if that time comes about. We oppose any plans to switch off DTT for the foreseeable future. We also recommend strongly that the Government should consult with citizens before making any decisions on the future of TV distribution.
VLV supports the renewal of local TV licences for a further 10 years from 2025 with some caveats. VLV recognises the potentially important role local TV plays in the UK PSB ecology, however, in some regards VLV considers that the local TV ‘project’ is not achieving the original ambitions envisaged when it was launched in 2013.
The original goal was for local TV channels to provide a range of local content to better engage citizens in the area in which they live. In reality, financing these channels has been challenging and consolidation in the local TV sector means that today much of it is owned by two companies. Much of the content they broadcast is not local. Most local TV channels have asked Ofcom for permission to cut their local programming during the past decade.
Another issue which is causing some concern is that TalkTV is now broadcasting on 8 local TV channels. This content is not local and is considered by some to be controversial because it features sitting MPs as presenters. Ofcom is considering whether this contravenes the Broadcasting Code. While TalkTV is available on Freeview 237, affording it the prominence of the local TV slot on channel 7 or 8 is seen as inappropriate.
Another problem with local TV is that it is not universally available to all UK audiences – only to 15 million homes, in those areas where it is profitable to provide it – which means its public value is limited.
While VLV considers that the concept of local TV has its merits and some channels do support local journalism and have a strong local identity, others should deliver more value for local audiences in return for the prominent position they are guaranteed on the EPG.
VLV considers that as part of this review of whether to renew the local TV licences it is important that the government reconsiders whether all local TV services as a whole continue to adequately deliver the objectives set out in local TV legislation.
VLV’s submission to the earlier consultation on this subject in October 2022 supported a revision to the COSTA rules because we believe it is important to ensure the sustainability of the commercial PSBs which are under financial pressure. However, VLV recommended that Ofcom should keep the number of commercial impacts constant, which it hasn’t chosen to do.
At the time of our earlier submission Ofcom’s research into audience attitudes to advertising had yet to be published. Now that it has been published, VLV is not convinced that the evidence is strong enough to justify Ofcom’s proposed approach. There is no strong evidence that the changes will lead to a financial benefit for the commercial PSBs and the qualitative research shows that audiences do not welcome the idea of more adverts on TV.
VLV is concerned that Ofcom dismisses audience opposition to an increase in adverts on PSB channels too easily. The recent Ofcom research is consistent with previous research which shows that audiences generally prefer to not have their viewing interrupted by adverts.
VLV is aware of concerns that these proposals could result in damaging consequences for other commercial broadcasters. They could undermine smaller, niche commercial channels which serve cultural minorities which could lead to a reduction in audience choice. There are also concerns, acknowledged by Ofcom, that these changes could lead to a reduction in the volume of news on the commercial PSBs if they were to show the maximum allowable minutes/hour of advertising in their news hours. VLV considers that this would be detrimental for citizens and society as a whole and should be guarded against.
The Media Bill Memorandum sets out the ‘overall purpose of the Bill’ which is ‘to reform the legal framework for the regulation of PSB and radio in the UK, to enable UK public service broadcasters …and UK radio to thrive in the long-term. The Bill will mean audiences can more easily access and enjoy quality, British-originated content and it will help to maintain a strong and diverse British broadcasting ecology.’
While VLV supports many of the provisions in the draft Bill, we do have concerns especially about the redefining of the Public Service Broadcasting Remit and missed opportunities to reform some regulation, such as that governing impartiality.
VLV largely supports Ofcom’s recommendations in this consultation which should make the process of running BBC competition assessments more transparent and streamlined.
However, in its submission VLV recommends that Ofcom and the BBC make greater efforts to publicise consultations so that the general public are aware of them.
Since 2017 the number of responses by members of the public to consultations about the BBC has declined significantly. BBC Trust consultations used to be advertised on TV, radio and online and received thousands of responses. In contrast, the most recent BBC consultation received 25 responses. This lack of public engagement is due to the fact that neither the BBC nor Ofcom publicise their consultations widely.
Since public value is an essential element in the discussion of any BBC service changes, VLV believes it is essential that licence fee payers are encouraged to make their views heard about the expansion or reduction of any BBC services.
VLV broadly supports Ofcom’s goals as set out in the Annual Plan. These emphasise the objective of providing for the needs of citizens and consumers, recognising that those needs are not uniform across the market and across demographics.
The VLV is committed to securing a healthy future for Public Service Broadcasting (PSB) and strives to protect its place in the communications market. We value in particular its wide range of content freely available to viewers and listeners through Digital Terrestrial Television (DTT), Digital Audio Broadcasting (DAB) and analogue transmissions of radio services.
VLV’s primary concern is that public service television and radio services should be universally available across the UK free at the point of reception. Viewers and listeners should not be obliged to pay additional fees for the delivery of PSB content. The role of the 600MHz band that currently supports independent delivery of Freeview services is a vital part of PSB itself and needs to be protected.
The BBC has requested that some of the commitments required of it should be changed, largely in response to changes in the market and financial pressures.
VLV supports the proposal for live news and current affairs on Radio 5 Live to be reduced from 75% to 70%, on the basis it will result in an increase in sports coverage.
We agree with a proposed change to the BBC Radio 2 Licence to set the level of new live music to 68 hours per year.
VLV agrees to a number of changes proposed to News quotas which will return local news bulletins to their pre-pandemic length, allow BBC Breakfast to drop one local news bulletin and change the running order of the UK weather so it directly follows the 10pm news bulletin.
We do not however agree with proposals to reduce the volume of national and regional non-news opt out programming. VLV considers that the proposals to reduce the volume of English current affairs programmes and the volume of non-news opt out programmes will lead to a reduction in services which are crucial to the engagement of audiences in their local regions around the UK.
As set out in its Media White Paper, the government is considering whether to update the Listed Events regime so that it includes digital rights as well as broadcasting rights for sporting events of national interest.
Currently the regime only guarantees that such events are broadcast on linear TV channels but as more people use digital platforms to view content, such as on-demand streaming platforms, it is important that digital rights are also included.
When the 2021 Olympics were held in Tokyo there was a 9 hour time difference which meant that many key events were held in the middle of the night for UK audiences. Time-shifted viewing was particularly valuable for those who wanted to be able to view the events at a more convenient time.
In order to ensure that the original intention of the Listed Events regime continues to be delivered VLV recommends that it should be updated so that viewing is guaranteed on both free to air linear TV channels and free to air digital platforms so that citizens are not forced to pay additional charges or subscription fees to be able to view sporting events of national interest.
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VLV responded to this Call for Evidence by Ofcom because it is important that citizen interests are represented in the debate about how much advertising there is on public service TV channels.
Ofcom is considering whether existing rules should be updated because they are more than 30 years old. The existing rules are stricter for the PSB channels (ITV, STV, C4, C5 and S4C) than they are for the non-PSB channels.
The challenge for the regulation of advertising on commercial TV channels, specifically in the context of the public service broadcasting system, is to ensure that the quality of viewing experience for audiences is maintained, while ensuring the commercial PSBs remain financially sustainable and their PSB Licences remain viable at a time when they are facing significant challenges in an increasingly competitive market.
VLV believes that the existing rules, which favour the non-PSB channels, are distorting competition and therefore we believe they should be revised so that there is a level playing field for the commercial PSB channels and the non-PSB channels. Additionally we would support reform of online advertising regulation which is far more relaxed than that for TV and favours online platforms.
VLV recommends that the existing rules should be revised so they eliminate the current market distortion. We would support a ‘middle way’ – potentially increasing the volume of advertising on all channels but not to the current levels seen on non-PSB channels. This would aim to keep the number of commercial impacts roughly constant. We would also, in principle, support increased flexibility for the PSBs with regard to scheduling as long as there were limits set on the total volume of adverts allowed/hour.
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The World Radiocommunications Conference (WRC) is held every three to four years and Ofcom will be representing the UK’s interests at the next conference.
One of the items on the agenda is how spectrum is managed.
VLV’s interest lies in there being enough spectrum guaranteed to ensure the continuation of universal access in the UK to Digital Terrestrial Television (DTT). We are concerned that mobile network operators will try to get access to this spectrum because they are always hungry for more spectrum so that they can provide mobile data services for consumers.
In this submission VLV urges Ofcom to ensure that the existing spectrum used by DTT is protected so that British audiences can continue to enjoy free to air television and radio services.
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Ofcom is proposing to change the way it regulates the BBC. Ofcom is suggesting that it should step back from detailed regulation of the BBC in return for the BBC being more transparent. It proposes that the BBC should be allowed to set its own annual targets and report back on its delivery of these, rather than it having quotas which are set and monitored by Ofcom.
VLV is very concerned by these proposals, many of which it strongly opposes, because it considers the new approach is likely to lead to less independent, robust regulation of the BBC and could lead to a further decline in genres of programming which have declined significantly during the past 20 years.
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VLV responded to this consultation which presents a proposal to increase the amount of content on the BBC iPlayer.
VLV supports the proposal because we believe that if there is a greater range of content on iPlayer and more content, this will benefit audiences and increase the BBC’s public value.
Unlike other broadcasters, the BBC is prevented from putting all its content online. This is because regulators are concerned that, as a publicly-funded body it shouldn’t over-dominate the market. The BBC states that a previous increase of content on the iPlayer doesn’t appear to have had a negative impact on the viewing of other broadcasters.
While VLV acknowledges the concern that the BBC should not over-dominate the market, we recommend that Ofcom should track the impact of this change to assess the impact it has on the rest of the market. If it is clear that it is having a detrimental impact on other broadcasters, the extension can be reversed.
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VLV has sent in comments in response to the Ofcom Spectrum Roadmap paper.
VLV believes that spectrum should continue to be reserved to provide free to air broadcasting to citizens. We do not believe that it is safe to relegate all public communications to online-only provision. The present wartime conditions in Ukraine have confirmed our view on this matter.
We are therefore concerned by the erosion of the spectrum allocated to Digital Terrestrial Television (DTT) in recent years and remain concerned about its future, given the demands of the mobile network operators.
In the future increased flexibility may be required in spectrum usage which means Ofcom, as regulator, will need to recognise and support innovation at an early stage. VLV suggests this can be achieved by developing better planning tools to improve precision in predicting service coverage, interference levels and reception equipment performance.
It is important to consider the performance of consumer reception equipment and its contribution to spectrum efficiency. It is also important to recognise that consumers will not wish to change their receiving equipment too often.
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VLV has sent in comments in response to the Ofcom Discussion Paper on Meeting Future Demand for Mobile Data.
VLV welcomes the comprehensive review provided by this paper.
VLV has a special interest in supporting Public Service Broadcasting (PSB) in the communications market. We are keen to ensure that the PSB services fulfil their purposes, as set out in the Communications Act 2003, and that the spectrum supporting them remains available. We are therefore concerned by the erosion of the spectrum allocated to Digital Terrestrial Television (DTT) in recent years and remain concerned about its future, given the demands of the mobile network operators.
We believe that there is much that the mobile network operators can do to improve performance across their networks by using new technologies and techniques and by better exploitation of the spectrum they already have.
Considering the public value of DTT to the UK public, we urge Ofcom to resist any attempt by the mobile network operators to gain access to the 600 MHz band in the UK and more widely in Europe. The UK has a strong and successful media industry which should not be compromised by loss of DTT spectrum.
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The BBC is asking Ofcom for permission to increase the amount of acquired content (which could include non-UK content) and animation it commissions for CBBC. It says it wants to make this change to strengthen the appeal of CBBC.
VLV does not agree with Ofcom’s provisional assessment and the proposal. VLV believes that Ofcom should take a more considered approach to these changes. Before allowing them it should put in place measures to ensure that they do not undermine the BBC’s delivery of its mission to children’s audiences.
VLV believes there is a risk that these changes could compound the existing market failure in content for British children unless Ofcom puts in place proper safeguards to ensure that they do not not lead to a further decline in the volume and range of UK culturally specific content for children.
VLV notes that this request occurs at a time when hours of original content have already been significantly reduced on CBBC since 2020.
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VLV’s primary concern is that BBC services should remain universally available to citizens across the UK. Our view is that they should be funded by everyone, for everyone to enjoy free at the point of access.
VLV research shows that real terms BBC funding has declined by 25% since 2010. The BBC now faces a potential deficit of up to £5bn during the coming 6 years if it continues to provide its existing services.
VLV recommends that the BBC’s funding model should continue to be household- based but not be dependent on consumption of BBC services. It should also be more progressive, costing less for those on lower incomes.
VLV opposes the BBC becoming a subscription service because this will undermine its universality which is key if it is to continue to be the national broadcaster and bring the nation together.
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The VLV responded to this Call for Evidence to highlight how important it is for the government to continue to ring-fence spectrum currently used by Digital Terrestrial Television so that British citizens can continue to enjoy universal, free to air television services.
VLV is concerned to protect these vital and valued services from potential spectrum erosion brought about by the growing demands by Mobile Data Network Operators as they seek to extend their Wireless Infrastructures.
VLV has concerns about the forthcoming World Radio Conference to be held in November 2023 at which the matter of re-allocation of current DTT spectrum is likely to be discussed.
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This consultation asks whether video on demand platforms, such as those provided by broadcasters (eg ITV Hub, All4, My5) as well as the streaming platforms like Netflix and Amazon Prime, should be regulated according to the same rules as TV channels.
VLV believes that on demand platforms which provide content which is TV-like should be regulated in the same way as TV channels. The current system is confusing for audiences because there are at least four different levels of regulation for TV-like content in the UK – the BBC is most rigorously regulated; then there are different rules for other broadcast TV channels which are licensed by Ofcom; video on demand platforms which are registered in the UK have to follow a less rigorous code (the ODPS rules); and there are some on demand platforms which are completely unregulated.
VLV proposes that all TV like content should be regulated according to the Broadcasting Code and that there should be consistency in the protection tools and warning systems put in place to protect younger audiences.
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This consultation marks the beginning of Ofcom’s review of BBC regulation, and will form the basis of its advice to government for its mid-term Charter review.
VLV agrees with the scope and approach of the review but opposes proposals in the consultation to reduce quotas for content, replacing them with more qualitative obligations.
VLV acknowledges that there may be some need to change regulation of the BBC as it adapts to changes in audience behaviour, especially with more viewing of content online. While the BBC needs to be allowed flexibility to ensure creative freedom and to innovate to meet audience needs and expectations, VLV does not believe this should be at the expense of robust regulation to ensure it delivers the missions and purposes set out in the Charter for the benefit of licence fee payers.
The disadvantage of quotas is that they can incentivise broadcasters to focus more on meeting the actual quotas rather than on how ‘services meet the needs of audiences’, but if a specific volume of content is not required from broadcasters, there is incontrovertible evidence that the availability of such content declines. After quotas were removed for arts, religious and children’s programmes the volume of such programmes on the PSBs declined dramatically. Additionally VLV is concerned by the the reduction of non-news international content which has been historically tracked by the International Broadcasting Trust. These declines in valuable PSB content are detrimental for audiences.
As the BBC competes in an increasingly competitive market with 25% less public funding in real terms than it received a decade ago, it is under significant pressure to increase commercial income from international sales. VLV is concerned that the BBC will be forced to focus on content which will appeal to global audiences, such as drama, rather than the PSB genres which are less popular and are in market failure. Without quotas, VLV does not believe that there will be adequate commitment to these genres at a regulatory, commissioning or editorial level.
Responding to government proposals to privatise Channel 4 the Lords Communications and Digital Select Committee launched an inquiry into the Future of Channel 4, focusing on the remit and ownership of the publicly owned corporation.
VLV opposes the government’s proposals to privatise Channel 4 because we believe that if it is taken into private ownership this will have a negative impact on audiences. It is our concern that a private owner will aim to attract the largest possible audience to maximise commercial success and as a result Channel 4 output will become less distinctive.
Channel 4 is currently delivering its remit in a way which benefits audiences, citizens and the creative community in the UK. VLV believes that its recent performance demonstrates that it will be able to continue to do so going forward. As we show in this submission, there is at the very least a strong possibility, and perhaps probability, that many of these benefits would be lost, or at least significantly impaired, if it were to move into private ownership. Therefore, the onus is on government to provide the evidence and research to demonstrate the need for such a change.
The DCMS last considered privatising Channel 4 five years ago and decided against it, largely because the sale wouldn’t raise significant funds.
This summer the government announced in a consultation that it intends to privatise Channel 4 to ensure its future sustainability.
VLV opposes this move because we believe that privatisation of Channel 4 will have a negative impact on audiences. It is our concern that a private owner will aim to attract the largest possible audience to maximise commercial success and as a result Channel 4 output will become less distinctive.
Channel 4 is currently delivering its remit in a way which benefits audiences, citizens and the creative community in the UK. VLV believes that its recent performance demonstrates that it will be able to continue to do so going forward. As we show in this submission, there is at the very least a strong possibility, and perhaps probability, that many of these benefits would be lost, or at least significantly impaired, if it were to move into private ownership. Therefore, the onus is on government to provide the evidence and research to demonstrate the need for such a change. The consultation document completely fails to do this.
Channel 5 has requested Ofcom to consider a change to its licence to allow it to broadcast a single hour-long early evening news bulletin at 5pm rather than two half-hour bulletins at 5pm and 6.30pm.
VLV approaches this issue by considering the impact on audiences and their choice of news programmes.
VLV considers that the proposal by Channel 5 will benefit audiences; we believe it will maintain news provision, while hopefully improving it, and that these changes will also improve the range and choice of PSB news programmes available to audiences.
VLV agrees with Ofcom that there is ‘value and general benefit to viewers in there being a choice of PSB news programmes at various times, as this is likely to appeal to a broader range of audiences. The proposed change is likely to benefit overall PSB news delivery.’
VLV welcomes the proposal to reinstate the BBC Three broadcast channel. In 2015 VLV opposed the closure of BBC Three as a broadcast channel because we believed this would limit the reach and impact of its content and undermine the BBC’s ability to engage fully with younger audiences.
VLV generally welcomes the proposals set out in this consultation document, however we have a concern that they abandon a highly valuable aspect of BBC Three’s programming – international content which fulfils Purpose 1 of the Charter.
VLV values the contribution BBC Three has made by engaging all audiences, especially younger adult audiences, with issues which are important to all of us, delivered in a style which is innovative and engaging. BBC Three is notable for providing a range of content which reflects UK culture and issues of concern to young people in the UK.
As the dominance of the global online streaming platforms grows, it is increasingly important that the BBC focuses on providing innovative and distinctive UK content. It is notable that some of the most distinctive UK programmes in recent years have gone out under the BBC Three brand. These include Fleabag, This Country, Angels of the North, The Young Offenders, and Reggie Yates’ and Stacey Dooley’s investigations.
VLV’s aim is to ensure that the interests of UK citizens, who are the intended beneficiaries of public service broadcasting (PSB), are represented in the policy debate. In our submission to Ofcom’s fourth PSB Review we highlight the distinction between citizens and consumers. Consumer interests are based on individual benefit, whereas citizen interests are based on wider societal benefit. Citizen interest broadcasting is not just provided to people who can afford it; it goes beyond the choices of individuals, to provide broader benefits to democracy, culture, identity, learning, participation and engagement; and it benefits those who do not even make direct use of it, in much the same way as schools help create an educated society.
The UK’s public service broadcasting system is considered to be one of the best in the world but it is being eroded by increased competition, especially from subscription and online services. The public service broadcasters are investing less each year in content because their incomes are declining. Ofcom’s consultation looks at what can be done to support our PSB system better.
In its response VLV recommends that UK broadcasting and online regulation should be reformed so that what is known as the PSB compact is updated. The PSB compact is the balance between the benefits public service broadcasters receive, such as funding, prominent slots on the TV guide or free access to spectrum, and the responsibilities placed on them as PSBs to provide what is considered to be societally valuable content, such as news, current affairs, content from the nations and regions etc.
We recommend that regulation should become platform neutral, so that it doesn’t matter where you view or listen to content – TV, online and streamed content is all regulated equally. This would help the public service broadcasters because it would mean their content would be prominent on all platforms and they would not be disadvantaged by more restrictive advertising regulation, for example. This would make it easier for audiences to find their content regardless of how they access it.
VLV opposes the Ofcom suggestion that the PSB system should be opened up to allow new providers of PSB content. We believe this will undermine the existing PSB system, not guarantee impact or delivery of the PSB purposes and will fragment PSB delivery.
As part of its PSB Review Ofcom put out a call for evidence regarding the Terms of Trade requirements which govern negotiations between independent producers and the Public Service Broadcasters.
In its submission VLV recommends that the government should review the Terms of Trade requirements so that they provide more revenue to the PSBs by them retaining a larger percentage of the intellectual property rights of the content they fund.
When first introduced in 2003 this regulation aimed to address an imbalance in the bargaining power between independent producers and the PSBs, which had considerably more power than the independent producers, and to improve the competitiveness of the UK production sector. It is clear that the balance of power in the market has now shifted away from the PSBs. It is no longer a buyers’ market as more outlets have been created, reducing PSB power.
The Terms of Trade requirements only apply to the PSBs which disadvantages them when other platforms are allowed to negotiate freely with independent producers. VLV believes that the Terms of Trade should be applied only to companies below a certain size, thus supporting smaller independent producers who need help the most. They should not discriminate so heavily against the PSBs and they should better support the PSB system which is under financial pressure due to declining income.
If the PSB system fails this will be disastrous for the independent production sector and for UK citizens, therefore VLV considers it is in the interests of independent producers to be open to these proposals.
In response to the DCMS consultation on the best approach for the renewal of the multiplexes which currently provide Digital Terrestrial Television (DTT) for UK citizens, VLV argued the case for spectrum to be guaranteed for as long as possible to allow digital TV and radio to be available to UK citizens on a free to air platform.
The licences which allow digital TV and radio (Freeview) to be beamed across the UK are up for renewal in 2022 and 2026. While technology is developing fast, these multiplexes are still the best option for the foreseeable future to deliver a universal service across the UK while ensuring high quality which broadband doesn’t. If we are to continue to receive free to view digital TV and radio it is essential that these licences are renewed, but there is significant competition for the use of spectrum from the mobile phone companies who need it to extend their services. VLV encouraged the government to renew the licences without any caveats until 2034.
VLV is lucky to have among its members some of the experts who designed the UK’s digital TV system, so we are afforded significant expertise to argue the case on behalf of citizens and we are most grateful to them for their input into this work.
Access to spectrum is essential if we are to continue to receive free to view digital TV and radio.
VLV opposed an earlier ban on high fat, salt and sugar products’ (HFSS) advertising on television on the basis that a wider-ranging, more holistic approach would be required if obesity was to be addressed. While VLV therefore supports in principle the Government’s more multi-faceted approach in its current obesity strategy , we believe that the present proposal falls short of what is required.
VLV still questions why the objective of the policy proposed in this consultation is to restrict children’s exposure to online HFSS advertising, since children generally do not control which food and drinks are bought.
VLV believes that any approach to restricting HFSS product advertising should be platform-neutral. Following the ban of HFSS adverts around children’s programming, Ofcom found that TV advertising spend declined in the years 2005-2009 but spend on press, online, outdoor and cinema advertising increased. VLV is concerned that if a restriction on HFSS advertising is imposed on online platforms, advertisers will simply displace their promotions onto radio, print media, cinema, billboard and outdoor advertising. It is notable that other advertising platforms are not within the scope of this consultation. VLV does not believe any policy decision on whether to increase restrictions on TV and online advertising should be taken without taking into consideration other advertising platforms which could influence obesity rates.
The Importance of Universality: VLV believes that everyone, including the vast majority of households who pay the licence fee, has an interest in maintaining a system in which the BBC is properly funded on a consistent basis. If evasion rates go up, as seems highly likely under a civil enforcement system, and the cost of collection will rise too; this will be detrimental to audiences because BBC income will decline. The BBC will have to make cuts to services and that will have a negative impact on all citizens, because of the reduction in the quality of the public service broadcasting for which they have paid. As a society we will all suffer from a BBC forced to make do with less.
Although digital radio now accounts for around 57% of all radio listening, analogue stations remain an important platform for millions of listeners who still use FM and AM radio services every day.
A number of FM and AM licences are due to expire from early 2022, including those for Classic FM and TalkSport. Ofcom does not have the power to renew these licences for a longer period under current legislation.
Therefore, the government sought views on whether analogue licences should be renewed for a further period and if so, how long they should be renewed for.
VLV believes a relicensing process for analogue commercial radio licences would be likely to prove expensive and distracting for licence holders. Although competitors might emerge in such a process, VLV believes that those proposing new services would have alternative digital pathways to the market. Ofcom would also face a significant burden if there was a rolling programme of relicensing in the first half of this decade.
VLV therefore supports the DCMS’s view that it would be better to continue with the existing system of licence renewal. VLV believes that five years would be an inadequate amount of time by which to extend licences, as licensees might feel inadequately motivated to invest in the continued transition to digital if they doubted whether they would be able to retain their licences beyond 2027. A lengthier extension – of eight years, to 2030 – therefore seems to be a better idea, to give licensees greater certainty and motivation to invest in the continued transition to digital.
VLV has made a submission to Ofcom opposing proposals by the BBC to reduce the number of broadcasts of the children’s news bulletin, Newsround, on CBBC from three bulletins to one per day. Ofcom is currently considering proposals put forward by the BBC, which the BBC says are cost-neutral, to move more content online for this age group.
VLV has concerns about any reduction in regulated public service content and in the context of research highlighting the shortage of UK produced, UK-specific public service content now being made for children, VLV on principle opposes the proposed reduction to the BBC’s existing broadcast quotas for children’s news from 85 hours per year to 35 hours per year.
VLV believes this will only exacerbate the problem of the shortage of original UK-produced public service content for children on television.
VLV gathers from the consultation document that Ofcom broadly supports the BBC’s proposals and, if that is the case, VLV would suggest some measures to mitigate the impact of the proposals under consideration.
VLV has submitted evidence to the DCMS Committee for its session on changes proposed by the BBC to its TV licence fee for those over 75.
The one-off session oral evidence session was held on 17 July and is part of the Committee’s remit to examine the work of the BBC, with its findings included in the MPs’ annual examination of the BBC’s annual report and accounts.
The majority of our members is that the cost of free TV licences should be borne by Government and not by the BBC. We believe that it is wrong in principle for the BBC to be determining the policy, and bearing the cost, of what is essentially a welfare benefit. It is not the BBC to determine welfare benefits, nor to meet their cost. The energy companies do not determine the level of the winter fuel allowance, nor do they meet its cost. The BBC’s role in this potentially compromises its vital independence from Government and from Government policy-making.
We are concerned that, even without taking on board the cost of funding this benefit, the BBC was already facing a cut in its income in real terms, as a result of flat licence fee settlements and the top-slicing of its licence fee income, resulting from Governments diverting licence income towards largely unrelated initiatives. This is set out in more detail in our attached submission. The BBC estimates that across the last decade, its budget for services for UK licence payers has been cut by about 20 per cent.
We noted in our submission to the BBC that we have consistently pressed for a more open, inclusive and transparent process for determining BBC funding. Traditionally, these negotiations have been conducted in private, behind very closed doors, with all the scope for arm-twisting and horse-trading inherent in such a process. Not even Parliament is involved.
This is simply not acceptable in today’s world. We were pleased to see the Chairman of the BBC endorsing a more open and transparent process in his comments accompanying the BBC’s announcement on free TV licences for the over 75s.
We believe this is the single most important issue in respect to the future of the BBC and we hope the Committee will support this new approach.
You can read VLV’s submission to the committee here.
VLV has made a submission in response to a DCMS consultation regarding government proposals to introduce further advertising restrictions on TV and online platforms for products high in fat, sugar and salt.
Since 2007 there has been a ban of such adverts around children’s programming but the government is proposing to extend this ban to all broadcast and online platforms beween 5.30am and 9pm.
VLV believes that the case for a proposed extension of ban on advertising of HFSS products has not been made at this time, because the Government’s proposals not do not adequately address the root causes of obesity.
The obesity crisis is one that requires a holistic multi-faceted approach. There is a risk that a simplistic ban of the kind proposed doesn’t tackle the fundamental issues. There is no convincing evidence that it would be effective; indeed there is some evidence to suggest the contrary. What is not in doubt is that it will have a significant negative impact on the finances of the commercial public service broadcasters, to the detriment of the public good. The VLV believes it would be wrong to incur this known detriment unless it is included in a far more holistic, multi-faceted approach to obesity which is currently not being proposed by the Government.
You can download the submission here:
VLV has made a submission in response to this inquiry highlighting the distinction between the needs of citizens and consumers.
Policy to support consumers’ interests is driven by the wants of consumers at an individual level and for private benefit. These tend to have a short term focus. Policy to support citizens’ interests, in contrast, is driven by the needs of community and society as a whole; it is also driven by public rather than private benefits. Public service broadcasting provides content which reflects UK culture; it provides news relevant to UK audiences; it supports the UK’s creative economy; and it enriches our lives as UK citizens.
VLV is concerned that the existing public service broadcasting system in the UK is being undermined by the growth of subscription VOD services, such as Netflix and Amazon Prime. These services are focused on drama and entertainment and are increasingly popular, especially among younger audiences.
This is leading to a decline in the reach of the public service broadcasters.
You can download a PDF of the submission here:
VLV has made a submission in response to a BBC Public Interest Consultation on its proposals to extend the viewing time allowed to watch content on the iPlayer.
In December Ofcom ruled that it had concerns about the BBC’s proposals which were included in the BBC’s Annual Plan 2018/19. Ofcom ruled that these proposals would need to be subject to further consultations because of concerns they might impact on the BBC’s competitors. VLV made a submission to the consultation, saying that it supported the proposals because they represent better public value for audiences. The BBC’s proposals come at a time when it is clear that time spent by audiences watching content on video on demand platforms is increasing while live TV viewing is decreasing. The BBC faces enormous competition from streaming subscription services, especially for younger audiences, and these proposals have been developed to ensure it maintains its reach in a competitive market.
You can read VLV’s submission in the PDF below:
VLV has made a submission to the BBC in response to its Consultation on Age Related TV Licence Policy which closed on 12 February. In order to respond to this consultation, VLV consulted with its members by sending out a questionnaire in December 2018.
Analysis of the responses to the questionnaire shows that VLV members overwhelmingly oppose the agreement made between the government and the BBC in 2015. This agreement has led to the BBC taking on responsibility for funding free TV licences for the over 75s. They would like a reversal of this decision. They do not support the BBC being responsible for what they consider to be ‘welfare policy’ by deciding who should be taxed and who not. VLV members believe the cost of paying for the free licences for over 75s should revert to being paid by the Government.
VLV recommends that the process whereby BBC funding is decided should be completely reformed with the creation of an independent body to advise the government on how much money the BBC should receive. This process should be open to Parliamentary and public scrutiny in order to improve transparency and accountability to the TV licence fee payers who fund the BBC.
You can read VLV’s full response in the PDF below:
A recent survey of VLV members revealed they overwhelmingly opposed the BBC taking on the cost of free TV licences for the over 75s. Read a full report on this survey.
VLV will be highlighting this issue at its Spring Conference on May 9th. Find out more about the event.
VLV has made a submission to the BBC in response to its Editorial Guidelines consultation which closed on 12 November. While we welcome the ambition of the Editorial Guidelines we do not believe they are a useful tool for producers in their everyday work. Producers are contractually obliged to abide by the Guidelines and VLV does not consider this to be a reasonable request.
VLV has recommended that the Editorial Guidelines document should be retained as a reference document and referred to by senior Editorial staff and those in the Editorial Policy Unit when they advise producers. Alongside that we believe a separate set of Guidelines should be published for producers in which the emphasis is shifted towards an understanding of the ethical principles which are at the heart of the Editorial Guidelines. This set of producers’ guidelines should be shorter, less abstract, with more concrete examples which bring the principles of the Editorial Guidelines ‘to life’ and which highlight the principles and ethics of the BBC. In this way, we believe that producers will find it easier to keep the principles of the Editorial Guidelines at the front of their minds in their everyday work.
You can read VLV’s full response in the PDF below:
Ofcom is conducting this review because the existing regulations which are meant to ensure prominence for the PSBs are out of date. They are proposing to make a few changes to the Electronic Programme Guide which is how the majority of people still watch live TV but they are also looking for recommendations on how prominence should be maintained beyond the traditional TV set with an EPG.
VLV has proposed that regulation of PSB prominence should apply across all platforms where a substantial proportion of viewing is conducted if the intention of Parliament to maintain PSB prominence is to be fulfilled. This will be beneficial for audiences because PSB content which they value will be easier to find and there will be a greater uniformity of approach across platforms and devices.
You can read VLV’s full submission in the PDF below:
Every 4 years the World Radiocommunication Conference (WRCs)is held to ensure that spectrum bands are harmonised across international borders. Ofcom represents UK interests at the WRC meetings. Most of us make direct use of spectrum in our everyday lives when we use mobile phones, laptops, tablets and when we watch television (which may receive signals from transmitters on the ground or from satellites that orbit the earth).
VLV is concerned about spectrum policy because we need adequate spectrum for broadcast services. In recent years mobile operators have been asking for more spectrum so they can provide mobile data services for their users and this has squeezed the amount of spectrum for broadcasting.
VLV made a submission to Ofcom’s consultation on its preparations for the next WRC which will be held in November 2019. While there is no specific agenda item at the conference to reduce spectrum for broadcasting, we were keen to highlight the need to protect this spectrum in negotiations.
You can read the full submission in the PDF below:
VLV supports the provisions as set out in the draft distribution policy, but we have a few broader concerns about the future of free to air broadcasting which we outline in this submission. VLV is concerned that BBC content should be as widely and easily accessible as possible in order to maximise the public value of the services provided by the BBC and to ensure maximum possible value for licence fee payers. VLV is concerned that while the BBC’s strategy to ensure it is ready for the switch to IP delivery is sensible, the BBC should not actively encourage viewers to move away from live TV viewing which will potentially undermine the popularity of DTT.
You can read the full submission in the PDF below:
As part of its responsibility for regulating the BBC, Ofcom will conduct ad hoc thematic reviews of the BBC’s delivery of its mission and purposes. This consultation is on the terms of reference for its first thematic review of the BBC which is focused on Purpose 4 of the Charter: to reflect, represent and serve the diverse communities of all of the UK. VLV has made a submission in response to the proposed terms of reference suggesting that the scope of this review is too narrow because it ignores radio output and only focuses on representation and portrayal, ignoring other elements of the purpose.
VLV highlights its concerns about Ofcom’s approach to spectrum allocation and stakeholder engagement in its submission to Ofcom’s Annual Plan 2018/19 consultation. It is crucial that adequate spectrum is guaranteed for digital terrestrial television if public service broadcasting (PSB) is to be available universally but mobile data services are competing for this spectrum and this could undermine PSB delivery. During 2018/19 Ofcom will be publishing its first report on the BBC’s delivery of its mission and purposes now that it is regulating the BBC. VLV would like there to be more stakeholder engagement with licence fee payers during this process.
In its submission to the Ofcom Review of children’s content VLV proposes that there should be new conditions in the commercial PSB’s licences. From VLV’s perspective, the main argument for having children’s content on mainstream free to air TV platforms is a civic one related to issues of cultural identity and diversity, including access to information and knowledge. All of these are reflected in PSB Purposes and Characteristics, which reflect the type of environment we might wish our children to grow up in.
This response follows a decision by the Secretary of State for Digital, Culture, Media and Sport to refer the proposed acquisition of Sky by 21st Century Fox to the Competition and Markets Authority on media plurality and broadcasting standards grounds.
In its subimission VLV urges the CMA to put the interests of citizens first in its consideration of the proposed takeover. There are clearly concerns on both these aspects, given the extensive media interests already held in the UK by Fox and associated companies and aspects of the way Fox news has behaved in the US, and we welcomed the Secretary of State’s decision to refer both these aspects to the Competition and Markets Authority.
VLV generally welcomes the provisions in the draft framework for complaints. Our primary concerns about the framework consultation are related to accessibility, transparency and accountability. VLV considers it essential that the transparency and accountability of the BBC should be maintained under the new governance and regulation model. We do not believe that currently the BBC complaints website is well signposted enough on the BBC homepage.
VLV is also concerned that information about complaints should be available for those who lack digital skills or internet connectivity. This information should be available in print and over the telephone. It should include details of how to make a complaint, what your complaint should include and the other parameters which determine whether a complaint will be considered.
We note that there is no detail in the consultation document about how the BBC will report and publish complaints. VLV would welcome further information in the framework regarding how the BBC will ensure it is accountable and transparent in reporting complaints.
We consider that most of the proposals in the new BBC Operating Licence are proportionate, although we are concerned that some of the proposed quotas place too much emphasis on volume rather than quality and this might undermine the BBC’s ability to deliver a range of high quality content for audiences. VLV is concerned by the removal of a number of quotas for radio output because we believe these are important to maintain BBC delivery of its mission and purposes and to maintain BBC distinctiveness.
VLV is concerned that under the new system of regulation and governance there could be a reduction in transparency, accountability, audience consultation and audience engagement. Ofcom’ expertise until now has been engaging with industry stakeholders. It is VLV’s concern that in future consultations on BBC performance it is industry stakeholders who will be most engaged and that licence fee payers will not be aware of Ofcom’s consultations or feel they have the necessary resources or expertise to enable them to respond. VLV continues to engage with Ofcom and the BBC on this issue.
The evidence, both theoretical and practical, presented in this consultation makes a good case for believing that the remedies for interference caused by mobile data servcies to DTT reception have, so far, largely been effective for networks operating in the 800 MHz band. It is argued that these same remedies will be effective in protecting new broadcast transmissions in the lower frequencies as television reception is now moved further downwards and out of the 700 MHz band where it is currently located. Nonetheless VLV has concerns that those with set-top aerials may be affected by the proposed changes. Additionally the clearance programme to move DTT transmissions out of the 700 MHz band will have some early and adverse effect, unconnected with interference, on some viewers’ experience. This will be caused by the engineering work required to move DTT transmissions and thus require viewers to retune receivers and possibly replace aerials. Viewer support will be essential during this process in addition to that needed later when interference may be expected.
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.
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.
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.
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.
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.
VLV has responsed to Ofcom’s rules on due impartiality, due accuracy, elections and referendums.
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.
VLV has responsed to the market review that Ofcom have published regarding the broadcasting transmission services.
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.
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.
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.
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.
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