Response to Ofcom's Draft Annual Plan 2013/14

VLV welcomes the opportunity to comment on Ofcom’s work plan for 2013/4.  Whilst the Ofcom remit is wide, VLV’s specific interests are confined to spectrum, broadband and public service broadcasting (PSB) regulation matters.  You can read the full submission here. 


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.

The extension of internet access via broadband to all citizens is a valuable and worthy goal.  Both the reach of broadband (i.e. the proportion of the population to whom internet services are available), the take up (i.e. the proportion of those served that actually use internet services) and the data speeds available need improvement.  VLV supports any initiative that will effect such improvements.

Insofar that some of these improvements will be delivered by means of wireless technologies that will demand spectrum allocation, there is concern that other, existing and valued services that require spectrum allocations may suffer as a consequence.  It is clear that an equitable balance will be needed.

VLV has concerns that Ofcom’s five revised strategic purposes appear to include only one that is relevant to issues of quality, diversity, impartiality, universal accessibility and trust in public service broadcasting.

This is Ofcom’s revised strategic purpose: ‘Contribute to and implement public policy defined by Parliament’.  From a VLV perspective, this must be taken to include active monitoring of compliance - quotas and standards - in British PSB, since these services are used on a daily basis by the vast majority of the UK population.  In particular VLV also urges Ofcom to seek appropriate remedies in respect of the continuing decline of investment in PSB content creation.

VLV notes and appreciate the work that Ofcom has completed to date on media pluralism and on the definition and concept of a ‘fit and proper person’, applied as a criterion of licence-holding, as existing law requires.  VLV urges continued readiness to comment and where appropriate intervene on these matters.

In conclusion, in respect of the regulation of public service broadcasting VLV urges Ofcom to seek all means for maintaining and improving quality and diversity in public service broadcasting. PSB programmes are valuable not only in respect of leisure activities but as importantly in respect of understanding, tolerance, public debate and practical support for the exercise of well-informed citizenship.

Published by: VLV

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