Memorandum submitted by the Environment
The Environment Agency is responding to the
Select Committee's request for written evidence for its inquiry
into Communications. The Agency will provide evidence in relation
the issues faced by public bodies
in contributing to the provision of diverse high quality digital
communication services, as exemplified by the Agency's extensive
experience of using digital media to broaden accessibility to
safeguarding the rights of citizens
and consumers to easy access to public information via the most
appropriate media, particularly that relating to environmental
issues and emergency incidents;
determining a definition for public
service broadcasting to include coverage of information and services
funded by the public purse;
the development and promotion of
digital broadcasting, including radio, as a communication tool
for public information, especially at a local level;
The Environment Agency has a strong interest
in the communication of public information. It has been investigating
new media for the dissemination of information and provision of
services since its formation in 1996. Its aims are to engage public
interest, inform and change behaviour with respect to environmental
issues. It views digital communications as a key means of achieving
The Agency is leading Government in the provision
of public sector information through emerging media. It uses content
management to enable material to be authored once for dissemination
via a multitude of interactive digital content platforms. Its
scaleable internet service was the first in Government to be able
to serve more than 1 million requests per day with no noticeable
loss of service.
The Agency was also the first Government body
to develop a real time (24 hour updated) digital information and
alerting service (for flood warning), which operates through the
internet and will shortly also be broadcast via digital radio.
Much of the Agency's information is relevant
at a local level (eg flood warnings, beach quality, pollution,
landfill). The Agency is exploiting the opportunities raised by
digital channels to provide communities with accessible information
about their locality. The use of interactive media will allow
two-way communication, so that the Agency can both gather and
disseminate local information via this service.
The Agency is working in partnership with a
public service broadcaster (the BBC) and a European-wide standardisation
body (the European Broadcasters' Union) to develop its digital
radio services for dissemination of community-specific information.
The Agency is currently investigating a strategy
for the dissemination of information and services via the medium
of digital interactive television (iDTV), in line with the Government's
"evolution rather than revolution" approach.
Its development of digital communication tools
to disseminate emergency and other environmental information has
given the Agency a clear insight into the value ascribed to these
services by the public. It has also illustrated the potential
of interactive communications for educating and informing in a
more engaging way than traditional media.
During its investigations, the Agency has, however,
encountered many issues that will also be pertinent to other public
bodies when they come to embrace these technologies. Several of
these issues are likely to be significant obstacles in achieving
the targets set by Government. The Agency has identified the specific
factors that it believes should now be considered by the Committee,
and hopes that, by highlighting these, the obstacles will be removed
to enable the future use of these channels by public service bodies,
swiftly and without additional cost to the taxpayer.
Access to high quality diverse services
The Agency is keen to provide high quality interactive
information to the general public and other bodies, in order to
educate and change behaviour regarding the environment. It sees
iDTV and other digital media as a means of reaching the largest
possible percentage of the population, and of informing them without
appearing didactic. The Agency finds that the current charging
model for the development of such iDTV services is an obstacle
which is likely to prevent or restrict the development of such
services by the public sector. Government's failure to specify
a standard technological platform for iDTV services exacerbates
this situation, as material needs to be prepared in numerous different
formats (at corresponding extra cost) in order to be broadcast
across all platforms, and ensure social inclusivity. Digital providers
are able to exploit the current situation by developing exclusive
"walled gardens" of selected lucrative content. Consequently,
the status quo strongly discourages diversity and quality, being
biased towards the broadcasting of information for which there
is commercial rather than educational justification.
Safeguarding of citizens and consumers
The current charging model for iDTV operates
on the basis that an information provider will pay to broadcast
on an iDTV channel, while the user will also pay in order to have
access to that information. Also, given the need for information
providers to pay multiple times for transmission of their material
on a range of technological platforms by different broadcasters,
this model is not conducive to wide dissemination of important,
high quality, non-commercial material by public sector bodies.
It clearly represents an injustice to the taxpayer, who, having
already paid the public sector body to generate and broadcast
the information, has then to pay again to access it. Much Agency
and Government information (for instance, live flood warnings)
is, in fact, likely to provide broadcasters with a strong selling
point for their services. The current charging model appears totally
inappropriate for the transmission of public sector information.
Definition and provision of public service broadcasting
The Agency strongly believes that public service
broadcasting should embrace information funded by the public purse
and provided by the public sector. New media, such as iDTV and
digital radio, should be used to add value to public information
and provide it in an accessible, engaging and interactive way
to diverse audiences. There is an increasing expectation from
the public that Government information and services will be available
digitally. This expectation currently extends as far as the internet,
but will include iDTV and digital radio as soon as these media
are widely available. It is vital that a framework is put in place
to enable public bodies to utilise these media in order to match
developing expectations. In the Committee's Second Report on Communications
(point 119), AOL UK was reported as questioning "whether
public service broadcasting will still be central or important
to consumers' live in five or 10 years' time or whether the choice
of content and services and of platforms over which these can
be accessed will be so diverse as to end the need to safeguard
public service broadcasting." The Agency would argue that
there is, in fact, a greater need to safeguard public service
broadcasting in the face of purely commercial competition.
Inclusion of local/community services
Digital media can lend themselves to the development
of services that are targeted to particular localities, because
of the nature of the broadcast method. The Agency is keen to exploit
such possibilities, in particular because so much of its environmental
information is geographically dispersed. The Agency would encourage
policy decisions that would facilitate full and even coverage
of the country by broadcasters. It is concerned by the limited
provision of some services, particularly cable, to rural areas,
as well as "shadows" which prevent complete coverage
by satellite and terrestrial broadcasters. A further issue is
the variation in size between multiplexes in flat areas of the
country, which tend to be large, and those in hilly areas, which
tend to be small. This makes provision of equivalent information
to communities in different locations more difficult. While the
Agency appreciates that there is not likely to be a "quick
fix" for this problem, Government should be aware of and
acknowledge the issues it raises.
Inclusion of digital radio
The Agency is keen to exploit this medium, and
is already undertaking a pilot study. Given that a technical standard
already exists for digital radio, development of services is reasonably
straightforward. Take-up is principally restricted by the price
of receivers. This medium is largely unpublicised at present,
and urgently needs to be promoted, in order to stimulate a rise
in the number of services it carries and a corresponding reduction
in the cost of receivers. Until take-up is greater its impact
will remain low.
The Agency favours healthy competition between
digital communication service providers, but in the context of
a "level playing field" with agreed technical standards
for each medium. This is clearly not yet the case for iDTV. The
use of incompatible technologies as weapons in a battle for clear
and inclusive communication channels is not in the public interest.
The Agency believes that the Government should seek to identify
technical standards for this and other new media, while allowing
market forces to compete freely in other respects. This will not
only benefit public sector organisations, but also any other body
who wishes to utilise these emerging communication platforms.
The definition of public service broadcasting
should be clarified, in order to safeguard the public's ability
to access key information from public sector bodies over the full
range of new media.
Government should consider legislation that
would oblige digital broadcasters to carry public service information
on the basis of a more equitable charging model, in order to safeguard
the taxpayer's right to this information at a justifiable price.
Government should encourage technical standardisation
for iDTV broadcasting, in order to make the medium more accessible
to public bodies and other content providers, thereby encouraging
a higher quality and diversity of broadcasting.
The effects that the "walled garden"
model has on the diversity, quality and inclusivity of digital
broadcasting should be addressed. The Agency recommends that implementation
of a technical standard for iDTV should be accompanied by a legislated
move to a single open broadcasting environment.
Digital media should be promoted where standards
are already in place (eg digital radio), to maximise the available
benefit from these communications channels.
Government should pursue the need to achieve
blanket coverage of the UK in the form of digital broadcasts.
Without this, Government bodies such as ourselves cannot fulfil
our remit to be socially inclusive.
31 January 2002