Latest Submissions - updated 17th February 2017
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
BBC Trust consultation on the Future of the BBC's Supply arrangements
Overall VLV believes that the Guiding Principles laid out in the BBC Trust Review of the supply arrangements for the BBC published in June 2015 are the correct principles to guide any future changes to the BBC’s content supply arrangements. While we welcome many of the principles underlying the BBC Executive’s British, Bold Creative BBC Studios document, we do not believe it provides enough detail on the operational model for BBC Studios for VLV to be able to fully support the proposals. In many instances the proposals are expressions of aims which, while they are admirable, do not explain how the BBC will deliver the outcomes necessary for this model to be successful. We look forward to seeing more detail of the operating model and organisational design promised in these proposals.
Read the full submission here
(20 November 2015)
BBC Trust - Tomorrow's BBC Consultation - creating an open, more distinctive BBC
1. VLV would like the BBC to continue to maintain its existing role as a broadcaster of distinctive world-class radio and television on traditional broadcast platforms, while also exploring how best to provide content for audiences on other platforms.
2. VLV considers that the BBC is currently striking the right balance between traditional broadcasting and focusing on new ideas.
3. We believe the proposals announced by the BBC in the British, Bold, Creative document on September 7th 2015 mark a distinct departure from traditional broadcasting and we are concerned that they rely too much on content delivered via the internet.
4. In its concern to be at the leading edge of new developments the BBC must not ignore its largest supporter group: listeners and viewers.
5. VLV believes that the approach of these proposals for the BBC 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.
6. BBC Newstream: While we recognize that mobile platforms are becoming increasingly popular to access news content, VLV would not want investment in broadcast news services to be reduced to support an online streaming news service.
7. Local and nations news: VLV welcomes the ambition of the BBC to better support local, regional and national news across the UK. Therefore, we welcome the BBC’s proposals to work in partnership with local and regional news organisations to provide improved services for the public. We support the proposal for a shared data journalism centre and news bank and for strengtheningBBC news in Scotland, Wales and Northern Ireland.
8. We support the proposal to build on work already achieved in partnership with Arts Council England but would like to see this work extended to arts organisations in the other nations of the UK.
9. While VLV fully supports the work of the World Service, we would only support additional investment in the World Service if this is funded by income which is additional to existing licence fee income.
10. In principle VLV supports the ambition for the BBC to collaborate with other organisations to improve its provision of content which is focused on knowledge and culture, however we are concerned that there could be issues of quality control and a dilution of the clear branding of the BBC as a service which provides content produced by and for the BBC.
You can read the full submission here.
(4 November 2015)
DCMS BBC Charter Review Green Paper Response
The Voice of the Listener and Viewer (VLV) has responded to the Government’s Green Paper on BBC Charter Review and proposes the establishment of a statutory body, the Licence Fee Body, to determine the level of future licence fee settlements.
VLV’s 55 page submission includes details of a survey conducted with VLV members, who come out strongly in support of the licence fee as the best way to fund the BBC and are in favour of reform for BBC Governance. To inform its decision on the best model for BBC Governance, VLV brought together leading figures in the broadcasting policy world. You can read the key points of their discussion here.
Key points made in the Green Paper response are:
- We need to protect the BBC’s independence from government in order to maintain its credibility and integrit
- There should be no more top slicing of the licence fee of the kind seen in the settlements of 2010 and 2015
- The BBC needs to have enough funding to remain of a scale to be able to deliver its mission to a range of audiences
- The BBC needs to continue to work hard to provide a range of high quality and distinctive content which appeals to a wide range of audiences, is universally available and is free at the point of access
- While ensuring it successfully engages younger audiences, the BBC must ensure that it continues to deliver content which is universally available free-to-air on television and radio
- The VLV is also proposing changes to the BBC’s governance, with the creation of a new public interest body to represent the interests of licence payers.
You can read the full response here
(8 October 2015)
BBC Trust: Provisional Decision of Proposed Changes to BBC Three, BBC One, BBC iPlayer and CBBC
- VLV made a submission to the BBC Trust’s first consultation on these proposed changes in February this year and we refer to that document when making this submission.
- VLV values the contribution BBC Three makes to engaging all audiences, including younger adult audiences, with a range of innovative, engaging content which broadens our understanding of the world, especially through its current affairs output which is distinctively different from any other current affairs programming available on television in the UK.
- Taking into account conditions made by the BBC Trust in its Provisional Conclusions on proposals for BBC Three, BBC One, BBC iPlayer, and CBBC, VLV’s position has not changed significantly since it made its submission to the BBC Trust in February 2015.
- We oppose the closure of BBC Three as a broadcast channel because of the concerns highlighted by the BBC Trust in its Provisional Conclusions and the lack of definite assurance from the BBC Executive on the volume of original BBC Three content which will be broadcast on BBC One and Two.
- VLV considers that the BBC needs to work harder to engage a young adult audience so that this sector of the audience maintains and develops a loyalty to the BBC. We agree that by moving content onto online platforms, some of this audience may be engaged, but there is a significant risk that some of it will also be lost and we are not convinced that the conditions required by the BBC Trust have been specific enough or met by the proposals of the BBC Executive.
- There are indications that the public is looking for more innovation in broadcast content and BBC Three is the most innovative of the BBC television channels. Its scores for delivery of innovation have risen consistently in the Ofcom Annual PSB Reports since 2008.
- The proposal to move content from a platform which is free at the point of use to one where the user has to pay extra for a broadband service undermines the fundamental principle of BBC broadcast services which are provided universally across the UK via DTT and radio.
- While we understand that the proposals under consideration will lead to an extra investment in BBC Drama of £30million, we do not believe this is adequate justification for converting a potentially valuable broadcast channel into an online offering which only a proportion of the UK public will be able to enjoy.
- VLV supports the BBC Trust’s decision not to allow a BBC +1 channel.
- While we welcome the proposals to be more innovative with the iPlayer, reflecting trends in the rest of the market, we do not believe that this should be at the cost of BBC Three remaining on a broadcast platform. We believe that the BBC’s online platforms should play a complementary role to the BBC’s broadcast services.
- While VLV has argued in the past that it would be beneficial to extend the hours of CBBC until 9pm to provide viewing for older children, we do not believe that this should be a priority over BBC Three’s continued existence on a broadcast platform.
6 October 2015
Ofcom: 700MHz Clearance - Management of transitional coverage issues
VLV is anxious to preserve the public value of Public Service Broadcasting (PSB) and robustly to protect its place in the Communications market. We value in particular its free availability to consumers through the medium of Digital Terrestrial Television (DTT) which depends upon adequate amounts of Electromagnetic Spectrum that are crucial to its future evolution. We are concerned at the continued erosion of DTT spectrum resources.
We have concerns about the ability of the remanent spectrum to absorb all current services completely with no loss of quality of service and coverage and no erosion of technical standards eg interference levels used in planning models. We also note that this reduced spectrum will be subject to sharing in the future thus placing further pressure on it.
Stakeholders in PSB include consumers who hitherto have had little direct say in the recent changes to broadcasting infrastructure which has led to costs and disruption. VLV expects that there will be further cost and disruption for consumers as a result of any 700 MHz band clearance. VLV also expects that such costs are soundly justified and that they are minimised.
It is to be expected that during the engineering work there will be some disruptions to services; these should be minimised. Furthermore it would be of great value to consumers to be kept fully informed of work in their respective regions so that confusion is minimised especially for consumers with special needs.
It is also imperative that there is a visible and responsible body to oversee the project that is readily available to consumers and is empowered to resolve issues as they arise.
6 October 2015
Ofcom Consultation on a Framework for Spectrum Sharing
- VLV is anxious to preserve the public value of Public Service Broadcasting (PSB) and robustly to protect its place in the Communications market. We value in particular its free availability to consumers through the medium of eg Digital Terrestrial Television (DTT) and Digital Audio Broadcasting (DAB) which depend upon adequate amounts of Electromagnetic Spectrum that are crucial to its future evolution. We are concerned at the continued erosion of DTT spectrum resources and the potential sharing of PSB bands with other services as yet undefined.
VLV is well aware of increasing demands for limited spectrum resource and the pressure that this generates on existing services both commercial and public.
- Whilst we have no wish to prevent efficient spectrum use in PSB bands we would expect that entry on both regulatory and technical levels is carefully evaluated before licensing is permitted. In principle sharing is not a major threat to PSB PROVIDED that:
Regulatory and Technical measures and controls are in place to define the authorisation, licensing and operation of new services;
- Reliable and fully tested tools are available to analyse, plan and subsequently approve applications for novel services;
- Supervision is in place to monitor the new services in action, particularly if those services are fixed but intermittent and thus likely to cause confusing intermittent interference, or are mobile thus injecting varying geographical levels of interference across a given PSB service area and may also stray into an adjacent PSB service area where interference will be caused there;
- PSB requirements take precedence as the incumbent service;
We would expect that these conditions will form a permanent basis to the planning of any sharing regime in the PSB bands.
2 October 2015
CULTURE, MEDIA AND SPORT COMMITTEE INQUIRY INTO THE BBC CHARTER REVIEW
- VLV does not consider the BBC’s scale and scope are limiting the development of a successful broadcast market.
- We do not agree with the suggestion in the DCMS Green Paper that audiences might be better served by a more narrowly-focused BBC.
- The VLVhas been impressed with the achievements of the BBC Trust in engaging with licence fee payers and industry and we would like to see this element of the Trust’s work continue under a new governance model.
- VLV members support public funding as the primary source of the BBC’s income. 61.2% support the continuation of the current system of the licence fee.
- VLV strongly opposes the process of negotiating the licence fee settlements of December 2010 and July 2015. VLV urges that there should be no more top slicing of the licence fee during this Charter Review period.
- VLV considers that through the setting of the licence fee especially, the Government has undue political influence on the BBC’s delivery of its mission.
- We therefore propose the institution of a statutory body, the Licence Fee Body, to determine the level of licence fee settlements. This would help to underpin the independence of the BBC, including providing protection from the Government ‘top slicing’ the licence fee and diverting it to fund other projects.
- VLV would welcome further study of the option of the household fee as a model to fund the BBC. We oppose subscription as a funding model and funding through general taxation and we believe the BBC’s funding should not be associated with any government spending review or budget as it has been since 2010.
- VLV does not see a convincing logic to full or part privatisation of BBC Worldwide.
- VLV members support the second of the three strategic Governance options recommended in the Green Paper for a standalone regulator model.
You can read the full submission here
30 September 2015
LORDS COMMUNICATIONS COMMITTEE INQUIRY INTO THE BBC CHARTER REVIEW
1. Under the current Charter delivery of the six Public Purposes is central to any assessment of the BBC’s performance. As an organisation which represents the interests of listeners and viewers we believe that licence fee payers concerns should play an important role in deciding what the purposes of the BBC should be.
2. VLV believes that the Public Purposes are relevant today and are central to any assessment of the BBC’s performance. Along with their accompanying purpose remits and when taken together with the Service Licences, they provide a detailed articulation of what the BBC should do to fulfil its mission.
3. VLV does not consider there is evidence to suggest that the BBC’s scale and scope are limiting the development of a successful broadcast market.
4. We do not agree with the suggestion in the DCMS Green Paper that audiences might be better served by a more narrowly-focused BBC. If this happens, the BBC will be restricted mostly to broadcast ‘worthy’, less popular content and its popularity will decline, making a universal fee unsustainable; and this in turn would undermine the model upon which the BBC is based.
5. The VLV has been impressed with the achievements of the BBC Trust in engaging with licence fee payers and industry but believes the BBC’s governance model needs to be reformed.
6. VLV strongly opposes the process of negotiating the recent licence fee settlement of July 2015 and that of December 2010 which were both conducted hastily without any public or Parliamentary scrutiny. Both settlements have diverted money from BBC budgets, have undermined the BBC’s independence from government and compromised its ability to deliver its mission.
7. Whatever the outcome of this Charter Review, VLV urges that there should be no more top slicing of the licence fee during this Charter Review period and VLV would like the commitments made in the 2010 settlement reversed.
8. VLV wants the BBC to remain independent of Government control. Currently we believe that through the setting of the licence fee especially, the Government has undue political influence on the BBC’s delivery of its mission.
9. VLV therefore proposes that the current system for setting the licence fee should be completely changed with the institution of a statutory body, the Licence Fee Body, to determine the level of licence fee settlements. This would provide protection to the BBC from the Government ‘top slicing’ the licence fee and diverting it to fund other projects.
10. VLV members support public funding as the primary source of income for the BBC. In the coming Charter period we would suggest that the current system should remain in place for collecting the licence fee but it should be modernised to include catch up TV.
11. VLV would welcome further study of the option of the household fee as a model to fund the BBC. VLV believes that the BBC should not follow an advertising model because this would have a negative market impact on other advertising funded broadcasters and advertising impairs the experience of some viewers and listeners. We also oppose subscription as a model for funding the BBC because once the BBC loses its universality, its income will be dependent on the popularity of content and this will be a precursor to a decline in less profitable genres which are nevertheless important for delivering the BBC’s public purposes. VLV believes that any model of funding needs to be universal because this is the only way to keep down the cost of individual licences and ensure that the system is equitable.
12. VLV opposes funding through general taxation which would reduce the BBC’s independence from the government and believes that the BBC’s funding should not be associated with any government spending review or budget as it has been since 2010.
13. VLV opposes the use of licence fee income on any services where are not provided by the BBC.
30 September 2015
BBC Trust: Review of local radio, regional news and current affairs in England
VLV believes that the BBC’s local output is a distinctive and vital addition to local democracy and community cohesion. It makes available the kind of in depth services that local commercial stations do not have the resources, motivation or ability to provide. For this reason, these services are highly valued by VLV members.
VLV, in common with the BBC Trust’s Audience Councils Annual Review 2014-15, considers “ there is a great deal of distinctive, engaging journalism in regional news and current affairs programmes, much of which is significantly different from that available on the national news.” We welcome the increasing emphasis on BBC Local Radio to hold those in positions of power and responsibility to account. We also welcome the introduction of specialist local political reporters. The local current affairs series, Inside Out, deserves a special mention for its contribution to our more detailed understanding of local issues.
VLV questions whether the remit for BBC Local Radio in its service licence should state that the target audience for this service should be listeners aged 50 and over who are not well-served elsewhere. It is our view that local news and sport should be able to attract cross generational audiences. The inclusion of the need to attract a wider audience, including younger age groups, will include those who are at home with technology and may be able to encourage older listeners to use it.
With reference to local news and current affairs, VLV believes that these services deliver very good value for money.
VLV believes that any further reductions in funding for local services will make it very difficult for BBC local radio to deliver its service licence commitments in the future.
We make recommendations that the service licences for BBC One and Two should include a provision in the Conditions of these services to reflect the statutory commitment of both channels to provide a minimum level of regional programming in order to guarantee delivery of such content.
We would like to see provision in the service licence for local radio to ensure that it has a commitment to provide educational content, to reflect local arts and music and include the work of local writers as part of a station’s speech output.
28 September 2015
BBC Trust: Draft Distribution Framework for BBC Services and Content
VLV is committed to supporting the principles of Public Service Broadcasting [PSB] and is anxious to preserve the public value of freely available PSB Services and in particular to ensure that those Services reach the public by all practicable and economical means.
We therefore welcome this re-iteration by the BBC Trust of its policy regarding distribution of BBC Services and welcome the opportunity to support its provisions.
In particular VLV would wish the BBC robustly to protect the Ultra High Frequency [UHF] spectrum and the use of DTT technology as a means to deliver those Services because the majority of viewers use this means of access. Despite other emerging technologies that make claims on the UHF spectrum DTT remains robust and we would expect it to remain so for the foreseeable future well beyond 2020.
The widespread use of the internet as a means of accessing BBC Content adds value to viewers and listeners’ experiences but remains inconsistent and somewhat unreliable in quality. Until these alternative means of access fully emulate the high quality of service of DTT they should not be given undue preference.
13 July 2015 Read full submission here
DCMS: Review of the Balance of Payments between Television Platforms and Public Service Broadcasters
1. VLV agrees with the policy goal in the consultation document that any regulatory framework governing payments between television platforms and public service broadcasters should be to ensure world class content produced by the UK’s public service broadcasters [is] both prominent and easily accessible to viewers.1
2. VLV believes that the Government should reconsider its position on the balance of payments as stated in its Connectivity, content and consumers paper in 2013 where it suggests that its preferred option would be zero net charges, where the fees for access to the main platforms and for PSB channels cancel each other out2.
3. PSB content forms a significant proportion of pay TV channel viewing. It is VLV’s view that pay TV platforms benefit financially from being able to provide subscribers with content from the PSBs. According to BARB 48% of viewing on pay TV platforms is to the main PSB channels, including their +1 channels.
4. VLV believes the current PSB compact regulatory framework delivers well for the consumer but could be improved if pay TV platforms paid for rebroadcasting PSB content which would bolster funding for investment by the PSBs in UK public service content which has been on decline in recent years.
5. If the balance of payments was changed in this way VLV believes the PSBs should be compelled to reinvest this funding into UK produced PSB content.
6. While VLV supports the benefits which competition brings to the market in maintaining standards and encouraging investment, we do not believe that the current regulatory regime should be deregulated to encourage competition if this risks the availability of PSB channels on all TV platforms, including pay TV platforms, and their easy discoverability.
7. The PSB system safeguards the production of certain types of programming that is in the public interest. PSB content delivers cultural and social benefits that might otherwise be undersupplied.
8. VLV believes the current regulatory framework supports public service broadcasting in the UK by providing the PSBs with certainty that the content of their main channels will be prominent on EPGs and that therefore their reach, impact and the income of the commercial PSBs is maintained. We believe that if there were any change to current regulation it would need to be carefully managed to maintain market security to ensure continued investment in public service content.
9. VLV would not therefore want the must offer/must carry obligations on broadcasters and platforms to be removed because this is the surest way to guarantee that the PSBs’ content is broadcast on all TV platforms in the UK thus providing it with universal reach.
10. VLV believes the Government should continue to regulate to ensure the prominence of the Public Service Broadcasters at the top of the Electronic Programme Guides.3 In recognition that increasingly viewers are consuming content on platforms without linear EPGs, we would welcome the development of proposals to achieve prominence for PSB content on smart TVs and VoD platforms.
11. VLV welcomes the Government’s ambition to prevent online services from exploiting PSB content without permission or the payment of copyright fees.
29 June 2015
DCMS: TV Licence Enforcement Review
VLV welcomes David Perry's review because we understand that TV licence enforcement is a complex issue, which requires careful examination of all the implications before any change is introduced.
VLV wants a licence fee enforcement system that maximizes licence fee income whilst being proportionate to the offence of non-payment of the licence fee.
We do not want people who find it difficult to pay their licence fee to be more severely penalised than they are already under the existing enforcement regime.
We are concerned that non-payment of licence fees reduces the BBC's income, which is not fair to those that pay for a licence, so we welcome any recommendations that emerge from the Review, which might discourage avoidance.
Although perhaps not within this review's remit, we want to take this opportunity to highlight the need for catch-up viewing to require a licence.
We would recommend that any change in the current enforcement system needs to be thought through carefully. We believe it should include a cost benefit analysis of the options, including their impact on licence fee evasion and income for Public Service Broadcasting (PSB).
We would welcome the possibility of more out of court settlements being introduced because we believe this would lead to less court time being devoted to licence fee enforcement and therefore be beneficial to taxpayers.
We believe that if non-payment of the licence fee becomes a civil offence, there is a possibility this could be at least as injurious to some offenders as the current system because it might impact adversely on their ability to obtain credit in the future as well as exposing them to action by bailiffs. We would welcome the publication of any evidence which demonstrates whether this might be the case.
We believe that regardless of the system which is adopted, defendants must purchase a TV licence as part of the punishment if they wish to continue to own and use a television.
1 May 2015
BBC Trust: Arrangements for the supply of Television and Radio content and Online services
Overall VLV believes that the principles laid out in the BBC Trust document are the correct principles to guide any future changes to the BBC’s content supply arrangements.
While we endorse the principles set out in this consultation we understand they will be affected by the BBC Executive’s plans to create an independent production unit to supply BBC content. We will wish to comment on those proposals once they are published in more detail.
It is VLV’s view that news and a significant amount of current affairs content should be made in-house, along with a significant proportion of work in other key genres (Drama, Children’s, Comedy and Entertainment).
We echo the Director-General’s view that the BBC should not become a publisher broadcaster and that the principle of choosing the best ideas regardless of their source is an important one and should be supported.
However, we do not believe that removing production guarantees for in-house productions will necessarily guarantee the delivery of more original content. In our view a BBC with strong in-house production departments is beneficial for licence fee payers and provides a vital seed bed for innovation.
We agree with the BBC Trust that the current supply arrangements appear to be working well, although VLV is concerned that the existing terms of trade should be reassessed in light of the growth of 'super-indies' and the trend of global media organisations to buy UK independent production companies. While we recognise the benefits of a healthy, diverse and competitive production sector, VLV does not believe the use of the licence fee effectively to build an independent production sector to compete with the BBC should be a primary objective in itself.
(20 March 2015)
Ofcom's Third Public Service Broadcasting Review:
Public Service Content in a Connected Society
This is an important time for Public Service Broadcasting (PSB). The broadcasting world is currently in a state of transition which is leading to a widening generation gap in usage trends and a slow move away from the viewing of live television for some audiences. However, we note that this trend to move away from live television has not proved to be as great as anticipated in the last PSB Review and VLV believes that live and recorded viewing and listening will remain the primary means by which the public consume public service content for at least the coming decade.
VLV is very concerned by the continuing decline in investment in first run UK content by the PSBs which could undermine the current PSB system. While audience satisfaction levels appear to remain high, we fear that in time this reduction in investment will inevitably lead to a reduction in the distinctiveness and quality of UK specific content.
VLV believes that the chief threats to the future of PSB are:
- further reductions in the purchasing power of the BBC licence fee through top slicing or an inadequate licence fee settlement
- the loss of cultural distinctiveness in programming partly as a result of increased sub-contracting of programme production to US-owned, multi-national companies
- the privatisation of Channel 4
- the increasing challenge to ensure prominence and discoverability of the PSBs as more and more people access television on a range of devices including mobile.
Read the full submission here.
(26 February 2015)
Ofcom's Review of Channel 4 Corporation's Delivery of its Media Duties (2010 - 2013)
We generally agree with Ofcom’s provisional findings that C4C is effectively delivering its media content duties in an evolving broadcasting landscape and provides a broad range of content which is distinctively different from the other UK public service broadcasters and which appeals to a diverse audience. We note that audience appreciation levels appear strong especially for international content and content which is perceived as diverse
The main channel, Channel 4, plays an important role in providing plurality of supply in key genres alongside the other PSBs, but most importantly it acts as a foil to the BBC. We believe that the main channel is particularly successful in challenging established views and promoting new perspectives.
Additionally the main channel, along with its portfolio channels, plays an important role in attracting a broad range of viewers, especially younger adults.
BBC Trust service review of network speech radio: BBC Radio 4,
BBC Radio 4 Extra, BBC Radio 5 live and BBC Radio 5 live Sports Extra
These four radio stations - BBC Radio 4, BBC Radio 4 Extra, BBC Radio 5 live and BBC Radio 5 live Sports Extra – are core listening for many of our members and Radio 4 has been central to the concerns of VLV since our foundation in 1983. We have encouraged our members to make individual responses and this submission is from the Trustees and other senior policy advisors within VLV.
We have focused our comments mostly on Radio 4 and Radio 5 live. We would not want it to be assumed that because we have not commented widely on Radio 4 Extra or Radio 5 live Sports Extra that we do not support them in the mission to deliver the BBC’s public purposes, we just do not feel we have the necessary expertise to comment on their performance in detail.
(23 February 2015)
The BBC Trust Public Value Test of the BBC Executive's proposals for the closure of BBC Three as a broadcast channel
VLV welcomes the opportunity to respond to this BBC Trust consultation and looks forward to the BBC Trust’s second period of consultation once it has conducted the public value and market impact assessments of the BBC Executive’s proposals.
High quality, engaging content on television across a range of genres which appeals to a range of different ages and demographics is essential if we are to be a well-informed society and maintain our democratic engagement with the world around us.
VLV values the contribution BBC Three makes in engaging a younger adult audience (16-34 year olds) with issues which are important to all of us. It achieves its most important purposes through current affairs and factual output which are distinctively different from other programming available on television in the UK, and therefore we oppose its closure as a broadcast channel.
(16 February 2015)
Draft Radio Spectrum Policy Group Opinion on Common Policy Objectives for WRC-15
The VLV welcomes the opportunity to respond to the European Commission's (EC) RSPG consultation regarding its opinions published as preparation for the forthcoming World Radiocommunication Conference in 2015 (WRC-15). In June 2014 the British telecommunications regulator, Ofcom, opened a consultation inviting contributions from stakeholders and interested parties that would assist Ofcom in preparing for WRC-15. VLV responded to that consultation which closed on 19th September 2014. The comments that follow are based on that consultation response.
VLV interests are solely focussed on the degree to which spectrum policy affects the wellbeing of Public Service Broadcasting (PSB) distributed and made available to all citizens free at the point of use. We believe it is vital that PSB services are available in this manner and that they should also be free of the potential editorial interference that might come from non-PSB platform gatekeepers. Our comments are therefore limited to a consideration of the allocation of the Ultra High Frequency (UHF) bands to television broadcasting between 470 MHz and 694 MHz, as well as the related prospects for the 700 MHz band (694 to 790 MHz), and the potential for the re-allocation of all or part of that spectrum to other uses, in particular to MT and WBB services.
Read here in fullRSPG papers
( 12 January 2015)
Draft RSPG Opinion on a long-term strategy on the future use of the UHF band [470-790 MHz] in the European Union
VLV is anxious to preserve the public value of DTT and its Public Services and robustly to protect the UHF spectrum that will remain after the 700 MHz band is re-allocated. We welcome the RSPG opinion that the band 470-694 MHz should remain available for DTT until at least 2030. We would oppose any attempt by the forthcoming World Radio Conference, WRC-15, to allocate this spectrum on a Co-Primary basis because it will undermine DTT in Europe at this time.
VLV is deeply concerned at the growing demands of Mobile Telephone and Wireless Broadband operators for the Ultra High Frequency (UHF) spectrum currently used by Digital Terrestrial Television (DTT) to be re-allocated to their use. We oppose any such step by WRC-15 but realise that some of that spectrum, the 700 MHz band, will probably be re-allocated.
Read here in fullLong term strategy
( 12 January 2015)
Consultations and submissions - 2014
Response to Ofcom’s call for inputs to the media plurality measurement framework
(27 November 2014)
VLV believes this work is vital if Ofcom is to be able to assess media plurality adequately and thus fulfil its primary duty to further the interests of citizens and consumers in communications matters. It is crucial that such a framework is in place so that any future issues of media plurality can be assessed against accepted and established criteria, rather than as an 'ad hoc' response to a particular set of circumstances.
Read the full response here
BBC Trust Service Review of BBC Music Radio
(29 October 2014)
VLV believes BBC music radio makes a valuable contribution to the cultural landscape of the UK. While we understand the rationale behind grouping music services together for this review, we believe that these services have little in common with each other and in many cases do not share the same listeners. The audience is fragmented by different tastes – classical, popular, easy listening, Asian etc. Therefore we will consider each service individually in our response as far as is possible where we believe there is evidence to support our conclusions.
BBC Radio 2 and 3 are core listening for many of our members. We have encouraged our members to make individual responses and this submission is from the Board and Trustees of VLV.
VLV's concerns about the position of radio within the BBC:
VLV’s members appear to be mostly concerned with the future of Radio 3, partly perhaps because they are avid Radio 3 listeners and party perhaps because they fear it may be more vulnerable to cuts because it is considered niche and less popular than other channels such as Radio 1 or 2. VLV encourages the BBC Trust to consider the comprehensive delivery of a range of music to a range of audiences. Radio 3 is highly valued by its loyal listeners and we would encourage the Trust to consider this when making its recommendations.
VLV values the speech element of all these stations and would not want that element to be ignored in this Review despite the characterisation of these services as ‘music radio’.
Read the submission here
Response to Ofcom's consultation on the UK preparations for World Radiocommunication Conference 2015 (WRC-15)
It is clear from the Ofcom document that the WRC conference covers a very wide range of spectrum issues and Digital Terrestrial Television (DTT) is one small part of that range. Our interests are wholly focused on the issue and principle of the universal availability of DTT and of public service broadcasting (PSB), distributed and made available to all citizens free at the point of use. We believe it is vital that PSB services are available in this manner and that they should also be free of the potential editorial interference that might come from non-PSB platform gatekeepers. We therefore limit our response to comments on the implications of proposals for DTT in the UK and in Europe.
Consultation on the future use of the 700 MHz band - cost-benefit analysis of changing its use to mobile services
VLV believes that the case for moving the broadcasters and their viewers from the 700 MHz section of the electromagnetic spectrum has not yet been made. We believe that Ofcom’s proposals give insufficient weight to the damaging impact of such a change on broadcasters using the DTT system and the consequent detriment to consumers and citizens. The public broadcasters depend on DTT to provide citizens with a full range of services, on a universal basis and free at the point of reception - a principle that has underpinned the ecology of UK broadcasting for many decades and which could be seriously endangered if broadband became the reception mechanism on which audiences had routinely to rely. In particular, the BBC’s ability to ac