Latest submissions - updated  June 2019

DCMS PROPOSALS TO EXTEND BAN ON ADVERTS for high fat, sugar and salt content

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 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 responds to BBC draft Editorial Guidelines

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:


VLV's response to Ofcom's Review of Rules for Prominence of Public Service Broadcasters and Local TV

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:


Response to Ofcom consultation on Preparations for the World Radiocommunication Conference (WRC) Submission made 12 September 2018

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: 

BBC Consultation on the BBC Draft Distribution Framework Policy

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:

Ofcom Consultation on the Terms of Reference for its Thematic Review of the BBC

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.

You can read the full submission here (PDF).

Ofcom Annual Plan 2018/19

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. You can read the full submission here (PDF).

Ofcom Review of Children's Content - January 2018

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.

You can read the full submission here  (PDF).

Proposed acquisition of SKY by 20th Century Fox - October 2017

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.

You can read the full submissionhere

BBC consultation on the BBC Complaints Framework - August 2017

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.

The full submission can be read here. 

Ofcom consultation on BBC Operating Licence and Performance Framework - July 2017

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 full submission can be read here 

Ofcom consultation on the co-existence of new services in the 700 MHZ band with digital terrestrial television - July 2017

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. 

The full submission can be read here   

VLV responds to DCMS proposal to move Channel 4 HQ - July 2017

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

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

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

The full response can be read here

DCMS Commercial Radio Deregulation Consultation - May 2017

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

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

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

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

Culture, Media and Sport Committee inquiry into fake news - March 2017

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

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

You can read the full submission here

DCMS Consultation on PSB Contestable Fund - February 2017

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

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

Ofcom Consultation on due impartiality and accuracy rules - January 2017

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

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

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

The full document can be found here

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

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

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

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

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

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

The full response can be read here

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

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

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

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

Read the full submission to the Puttnam Enquiry here.

(2 February 2016)

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

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

Read the full submission here.     

(19 January 2016) 

Submissions and responses from 2015 

Please see our archive at Previous VLV Consultations