APPENDIX 4
Memorandum submitted by BECTU
1. BECTU's background views on some of the
issues being considered by the Committee have been set out both
in our response to Government on the Communications White Paper
and in our submission to the Committee's earlier Inquiry on this
issue. We await the impending consultation on media ownership
and of course the Communications Bill itself.
2. Rather than respond on each of the points
raised in the Inquiry we would like at this stage to focus on
the development of digital broadcasting.
3. To place our remarks in context, our
key views and concerns, as already expressed in the submissions
mentioned above, include:
— The centrality of public service
broadcasting (PSB) to the future of British broadcasting.
— A preference for strong content regulation
in relation to programme quality and original production, with
a separate and specific focus on content within OFCOM.
— Concern at the increasing concentration
of ownership in ITV and the need, as a quid pro quo, for a strengthened
commitment to regional production.
4. We note the Committee's interest in "defining
and providing public service broadcasting". The recent Communication
from the European Commission on "The Application of State
Aid Rules to PSB" is obviously highly relevant to any such
debate, stating as it does that "definition of the public
service mandate falls within the competence of Member States".
We have written to the Secretary of State asking how and by who
such a definition will be drawn up in the UK. We still seek clarity
on this issue and would therefore wish to defer our own comments
at this point.
5. Against a background of these general
views, we welcome the development of digital broadcasting by means
of satellite, terrestrial and cable delivery systems. We believe
the development of a digital market with a programme and audience
base sufficiently to justify analogue switch-off will depend on
healthy growth via all three platforms.
6. We note continuing evidence—both
from the Consumers Association and from market research groups—that
a significant proportion of the population is not currently interested
in switching from analogue to digital. Thus, while nearly 40 per
cent of TV households currently have access to digital TV, perhaps
a third of the population have no plans for such a switchover—which
poses a significant problem for Government if it is to realise
its target of 95 per cent digital penetration leading to analogue
switch-off between 2006 and 2010.
7. We further note the serious problems
currently faced by the digital terrestrial television (DTT) platform
in the form of the ITV Digital consortium. With investment to
date of £800 million and an estimated further £400 million
required before break-even, we recognise there is a distinct possibility
that the DTT platform might fail altogether.
8. In our view this would be a highly undesirable
development:
— DTT is technically the best means
for ensuring that digital broadcasting reaches 100 per cent of
the UK population—thereby preserving universal coverage
for our broadcasting system.
— By the same token, DTT is and should
remain a vital component of the Government's strategy for achieving
95 per cent coverage by 2006-10.
— DTT is the platform with the greatest
emphasis on free-to-air channels, as opposed to the subscription-based
satellite and cable platforms.
9. We therefore welcome in principle the
proposed digital coalition by which PSB terrestrial broadcasters
could offer free multichannel digital TV through a basic set-top
box (which could in time be upgraded to receive subscription channels).
10. We further recognise that Government
has a key role to play in shaping a digital broadcasting system
accessible to all.
11. The White Paper makes a welcome commitment
that the free to air PSB channels will continue to be available
after digital switchover; that "must carry" obligations
for PSB channels will apply on cable and satellite; and that such
channels should receive due prominence in electronic programme
guides.
12. However, the increasing revenue streams
now available to the subscription-based platforms make it harder,
in our view, to justify the much lower level of content regulation
which the White Paper proposes for BskyB. Despite the "new
market" justification for lower regulatory standards for
satellite in the past, the balance of forces in the converging
digital market make it increasingly feasible to apply standards
on quality and original programming to BskyB which are comparable
to those applying to the terrestrial broadcasters.
13. Given the uncertainty surrounding the
future of DTT, we believe there are other measures which could
be given consideration even in advance of the forthcoming legislation:
— The Government's Digital Action Plan
could be given more bite and focus by the appointment of a "Digital
Champion" to promote the development of digital broadcasting.
— The problems being experienced by
ITV Digital, taken in conjunction with the serious and unforeseen
downturn in ITV advertising revenue (with perhaps a 16 per cent
fall in 2001 and no immediate upturn in prospect), might also,
in our view, justify a readjustment of ITV license payments—with
the proviso that any savings should be wholly earmarked for investment
in digital broadcasting.
14. We recognise that the Inquiry is due
to consider a range of other issues. We believe, however, that
digital broadcasting—and in particular the future for a
digital terrestrial platform with a central component of free-to-air
PSB channels—is a key aspect of the current debate.
15. We look forward to the Committee's consideration
of these issues.
27 November 2001
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