Consultations - 2012 -13

One of the major areas of VLV's work is to respond to public consultations on broadcasting held by government, regulators and broadcasters. VLV has responded to many major public consultations concerned with broadcasting and media policy - making the case for public service broadcasting and ensuring that the interests of viewers and listeners are kept in mind.

Latest Submissions

Response to DCMS Consultation on Media Ownership and Plurality

(October 2013)

VLV believes it is important that understanding the historical context of the current media plurality debate is essential if we are to avoid undermining what is a largely healthy ecosystem.

VLV agrees that any legislation and regulation of the media, as, for example, the work of Ofcom should include online content and platforms.

We wish to reinforce arguments which we have said before that a plural supply of news and current affairs is essential, but we would now argue that it should not only be these genres which are measured to ensure a plural supply of views and content.

We agree with Ofcom that plurality should be considered across television, radio, the press and online.

It would be curious to undertake any meaningful survey of media plurality without taking into account the output of the BBC or indeed the other public service channels.

This consultation moves the plurality discussion on to include the issue of a plurality of audiences as well.  VLV welcomes the raising of this issue, since
it is important that all citizens’ and consumers’ interests are represented in
any discussion of media provision

Read the full submission here


Response to Ofcom's consultation on the Renewal of the Channel 4 Licence
(October 2013)

While we realise that this consultation on the renewal of the Channel 4 licence is confined to the main channel, as a civil society organisation we are interested in the range, diversity and quality of C4’s overall portfolio and programmes, including online services, websites and download services.

In general it is our view that Channel 4 provides a welcome and distinctive addition to the system of public service broadcasting in Britain, especially in respect of its extensive peak time news and current affairs, its coverage of international issues, its provision for younger viewers (though not for younger children), its extensive web and online services and its provision for mobile web users.

We welcome the new requirements introduced by the 2010 Digital Economy Act(DEA) including, specifically, an extension of C4C’s remit to ‘champion and promote creativity and new talent across all its digital media services’, to ‘appeal to the tastes and interests of a culturally diverse society’ and the new emphasis on support for British film through investment in ‘high quality films intended to be shown to the general public at the cinema in the United Kingdom’. We also welcome the  DEA requirement to ‘stimulate well-informed debate on a wide range of issues… by providing access to information and views from around the world and by challenging established views’ (Ofcom, 2013: 9-10).

Read the full consultation here

Response to the BBC Trust's Consultation on The Governance of the BBC World Service, via an operating licence

(September 2013)

  • VLV broadly agrees that the draft Operating Licence for the World Service describes the characteristics and other features of the World Service as they are currently provided.
  • VLV endorses much of what is expressed in the accompanying BBC Trust Paper, BBC World Service: a licence fee funded service, especially the commitment to ‘ensure that the distinctive service offered by the World Service is protected and enhanced’.
  • However, we have comments to make about whether the current organisational structure of the BBC - and the associated financial arrangements - are appropriate to ensure that the ethos and programme standards of the World Service are maintained.
  • VLV is concerned that there is not enough representation of the World Service at top management level within the BBC Executive to maximize its weight within the BBC organisational structure and to recognise its unique standing as a UK national asset in its own right.
  • We make a re-drafting suggestion for World Service Objectives, Priorities and Targets
  • Should the overall governance of the BBC change, VLV would wish to consider ensuing implications for the World Service.

Read the full response here


Response to the European Commission's Green Paper on preparing for a fully converged audiovisual world: growth, creation and values

(August 2013)

VLV understands that the Commission's aim is to explore the need (or not) for new legislation with the details for legislation to be worked out in the medium term.

VLV's view - reflecting what we see as the concerns of consumers and citizens - is that the need exists and that it is urgent. We think that - without advocating an unnecessarily meddlesome 'top down' approach -  detailed work should start soon, lest rapid market or technological developments render subsequent regulatory responses outdated or inadequate.

There is intensified and increasingly complex commercial competition in the UK marketplace, notably between BSkyB and other consortia such as YouView and Freeview - where BT and other telecommunications players are embarking on content provision through alliances with the BBC and other major broadcasters.  These media groupings can produce attractive content and service packages but they carry also the risk of confusing consumers or locking them into the technological system of one competitor or another. This may  take place at the platform level, at the broadband level  or within the technology of the new generation of connected-TV sets.

Developments in the UK - for both linear and non-linear audiovisual services - presage the likely subservience of consumer choice over accessing individual services to higher level decisions taken by vertically integrated telecommunication companies as to which services they are prepared to carry on their broadband distribution platforms.

Unregulated competition will not deliver the protection we seek for ordinary users. This demonstrates the ongoing need for the EU to preserve genuine choice to access public service programmes and premium content. Key issues are the future of the 'must carry' provisions for the BBC and other public service channels, along with the scope for a range of (mainly) smaller commercial companies to retail their interactive and other supplementary services via the main platforms.

Against this competitive market we see the current public consultation by the EU and potential subsequent legislative response as an opportunity to confirm and reinforce core principles, notably those of media pluralism and freedom of expression, quality and diversity in audiovisual content, and easy convenient access for Europe's public at large.

Read VLV's full response here

Ofcom's Consultation on the future use of the 700 MHz Band
(4 July 2013)

Many of our comments and concerns are unchanged from our response to the original UHF spectrum review in 2012. The re-planning of the UHF spectrum seeks, among other things, to exploit spectrum more intensively than hitherto.  The demands on spectrum will intensify as time progresses and this will stress planning rules to their limits including a potential need to relax parameters such as protection ratios.  VLV expects a robust protection of public services.

VLV welcomes the clarification of Ofcom's role, especially the primary objective expressed in the consultation to protect the DTT platform and to reduce the disruption and costs to consumers which could result from a change of use of the band.  We expect that the protection afforded Public Service Broadcasting [PSB] and other closely related services that make up the Freeview platform will not be compromised.  VLV also welcomes the explanation of the international dimension to the use of the 700 MHz band of spectrum in the UK as part of the European community.

The full submission can be read here

DCMS Consultation on changes to the Office of Communications' (Ofcom's) statutory duties and functions
(26 June 2013)

VLV accepts that at a time of austerity it is important to ensure public bodies such as Ofcom undertake their duties in an efficient manner and at a suitable regularity. However we are very concerned that these changes are to be introduced via two Statutory Instruments. The Public Bodies Act 2011 allow for this way forward, however we consider that several of these proposals make significant changes to the regulation of Public Service Broadcasting and the role of the Secretary of State and should be more widely debated in Parliament.

A Communications White Paper is expected this summer and these changes should be included in this Parliamentary legislation and receive the full scrutiny they require and merit. We elaborate further on this in detailed comments below.

The full submission can be read here

VLV has submitted its response to the BBC Trust's BBC Children's Services Review (30 May 2013).


BBC services for children - especially television - stand out from the content shown on other broadcasters because:

  • They broadcast high proportions of domestic content – between 70 and 80% of transmissions
  • They broadcast a greater variety of live action formats and different genres including much less animation than their rivals (less than 30%)
  • They broadcast a greater range of content in terms of terms of themes and issues addressed, including themes and issues that are of direct relevance to British children
  • There is no advertising and no commercial imperative (although of course many shows are supported by extensive licensing and merchandising campaigns)
  • The dual role of continuity presenters as show presenters reinforces the range of UK accents that is unique to BBC Children’s channels (although more diversity in accents used to voice animation is necessary)
  • The embedded approach to ‘learning through play’ (particularly on CBeebies) is distinctive from the more formal pedagogic education formats originating in the US.

VLV has three main concerns:

  1. CBBC has an upper age limit of 12, possibly even younger. This seems to be self imposed.  "The remit of CBBC is to provide a wide range of high quality, distinctive content for 6 to 12 year olds" (from the CBBC service licence). Effectively, the BBC does not serve or represent a developmentally very important period in young people’s lives, 13 to 14,  – the time when they are beginning to grow up, but are not yet grown up, and hence a period of dramatic change and potentially fertile for programme makers.
  2. There appears to be a significant reduction in the role of Sustaining citizenship and civil society. For example, in the case of CBBC this is met through the provision of news and current affairs with programmes such as Newsround and Blue Peter. However, Blue Peter is now only shown once a week and Newsround appears to have been curtailed to short bulletins, which might suggest that this type of content is under pressure from other programming priorities.
  3. In radio the BBC has reduced its commitment to distinctive children’s radio to a substantial degree, relegating it to a reduced presence on the digital channel BBC Radio 4 Extra.  VLV wonders whether BBC Radio 4 Extra is really the best place for encouraging ‘family listening’.

The full submission can be read here.


Channel 3 and Channel 5: proposed programming obligations: Proposals for amendments to obligations for Channel 3 and Channel 5 ahead of a new licensing period.

VLV welcomes the fact that Channel 3 and Channel 5 have not proposed any changes to their national and international news and current affairs obligations.

We also welcome that no changes have been proposed to the original production or independent production quotas by either channel.  It is especially important to encourage and require investment in original programming in the British public service broadcasting sector. In their report to the Secretary of State on the Licensing of Channel 3 and Channel 5 in July 2011 Ofcom note that – at 2010 prices – investment by PSBs in original programming reduced from £2.7 billion in 2004 to £2.3 billion in 2010.

VLV does have concerns about the extension of ‘peak time’ to 11pm. This is too late for many viewers and will allow broadcasters to move regional programming into a less popular slot, depriving many viewers of the opportunity to view it at a reasonable hour. (2 May 2013)

You can read the full submission here.


VLV has submitted evidence to the House of Lords Select Committee on Communications as part of the Committee’s inquiry into Media Plurality. (30 April 2013)

 VLV believes that:

  • the objective for media plurality policy should include ensuring a range and diversity of content as well as a plurality of supply
  • it should recognise the civic role, described by Lord Patten in relation to the BBC, that the media plays
  • public service media such as the BBC and Channel 4 should be included in the assessment of media plurality
  • its scope should encompass not only news and current affairs but a wide range of genres
  • media plurality should be reviewed periodically, at intervals of four or five years
  • any measurement of ‘sufficient plurality’ should include wholesalers of news content
  • the final decision on such issues should be made by an independent media regulatory body and by appropriate competition authorities.

The full submission can be read here
(30 April 2013)


 VLV has submitted its response to the Communications Consumer Panel's draft Work Plan 2013/14 which you can read here.

VLV's response is limited to the fifth key area of the plan, the coexistence of new services in the 800 MHz band.  VLV has taken an interest in this issue since the use of the spectrum freed up by the switch to digital broadcasting for terrestrial television became a subject of public debate. 

VLV has exceptionally asked the Panel to consider adding long term spectrum coexistence to the areas under review for 2013/14.  In particular VLV asked  the panel to seek assurances that the needs of citizens using DTT are protected, when the mobile technology companies buy more spectrum; ask to see the government long term strategy for spectrum use; and ensure that any lessons learnt from the impact of the current 800 MHz exercise are used in developing future plans. (15 March 2013)


VLV has submitted its response to Ofcom's consultation on its Draft Annual Plan 2013/14 which you can read here.  particular, VLV has concerns about the redeployment of the UHF spectrum, specifically the reduced amount of spectrum allocated to PSB on the DTT platform, its impact on consumers and the viability of DTT going forward.  

VLV is also concerned that the change of approach to protecting PSB services from interference caused by new 4G services is significant and a departure from tradition.  The use of mitigation measures in those areas expected to be adversely affected by 4G transmissions are unprecedented and are based on predictions of behaviour.  The reality of the degree of disruption remains to be seen and so VLV advises caution until 4G services begin and the actual effects are known.  (20 February 2013)

VLV has submitted its response, which you can read here, to the BBC Trust’s BBC Online and Red Button Service Review which considers how well both services are performing, their future strategic direction and whether the service licences need to be changed.  Full details about the scope of the consultation can be read on the BBC Trust’s website(23 January 2013)

In its response to the BBC Trust Review of Purpose Remits, VLV said it was glad that the Trust put at the centre of the review the needs of listeners and viewers in making the BBC Purpose Remits more easily understood by licence fee payers.  The full submission can be read here.

(6 December 2012)


VLV Responses to 2012 Consultations

Responses to the BBC Trust

Responses to DCMS

Response to the House of Lords Select Committee

Responses to Ofcom