Vulnerable groups
80. The Government is going to require the BBC to
establish assistance schemes to ensure "the most vulnerable"
do not lose access to television services post switchover. Free
or subsidised provision will be available to households where
someone is aged 75 or over, or where someone has a severe disability.[137]
Additional support will be offered to those who are registered
blind. The Ofcom Consumer Panel believes that, by restricting
free installation, equipment and instructions only to older people
on pension credit, the Government is moving away from the principle
of free TV reception for everyone over 75 regardless of income.[138]
David Sinclair of Help the Aged thought it "absurd"
to means test a set-top box;[139]
he was particularly concerned about the 250,000 older people who
were failing to claim this benefit.
81. In July 2004, the Secretary of State for Culture,
Media and Sport had asked the Ofcom Consumer Panel to consider
what measures might be necessary to protect the interests of "the
most vulnerable" consumers during digital switchover. The
Panel, which is independent of Ofcom, came to the key conclusion
that "most vulnerable" in this context is most usefully
defined in terms of social isolation; the latter can come about
through a variety of factors such as age, disability and low English
literacy. The Consumer Panel's evidence made clear its "strong
disappointment" that the Government has tied its assistance
package to the benefits system, effectively ignoring the analysis
based on social isolation.[140]
Help the Aged thought it vital that research be carried out to
identify the vulnerable.[141]
Leen Petre, RNIB, thought there was a danger that the definition
of vulnerability would be informed by cost considerations.[142]
The Government's evidence acknowledged the work of the Ofcom Consumer
Panel, and it noted the potentially important role of charities,
social workers, the local community and neighbours.[143]
82. The scope of the Government's targeted assistance
programme is too restricted and fails to acknowledge those who,
by dint of income or social exclusion, are in genuine need. With
analogue switch-off beginning in only two years, this matter requires
urgent consideration.
83. The problem of identifying vulnerable consumers
and delivering a package of assistance needs to be clearly owned.
Giving oral evidence, Colette Bowe of the independent Ofcom Consumer
Panel said: "I think a very pointed question would be who
owns this issue of identifying vulnerable consumers and working
out what they really want and then delivering it. At the moment
there seems to be a plethora of diffuse responsibility."[144]
84. Ofcom's written evidence noted that consumer
issues are primarily the responsibility of Government and Digital
UK.[145] The present
digital switchover programme structure indicates that responsibility
for targeted assistance rests with the Department for Culture,
Media and Sport.[146]
Digital UK are, however, involved in ongoing work to identify
those who fall outside the targeted assistance scheme but who
may need additional help with switchover.[147]
One concern of Help the Aged is that the voluntary sector should
be adequately financed to play its key role in providing practical
help with switchover.[148]
85. Responsibility for the administration of the
targeted assistance scheme for vulnerable groups must be clearly
assigned. The scheme should take into account the need to provide
adequate funding for the voluntary sector, which will play a vital
role in providing practical assistance to vulnerable groups.
86. The Government and the BBC have been running
a pilot project in Bolton to find out how much assistance elderly
people need to convert their TV sets to digital.[149]
This builds on work of an earlier technical trial in Llansteffan
and Ferryside, which showed that many elderly people required
significant levels of support.[150]
In Bolton, Freeview was delivered at no cost to participants though,
as an alternative, subsidised cable or satellite options could
be taken. Few chose either of the latter two platforms, despite
their greater functionality.[151]
In oral evidence for Help the Aged, David Sinclair expressed concerns
that older people could find themselves excluded from the services
that increasingly will be made available via broadband or interactive
television.[152] We
recommend that the targeted assistance scheme should include the
provision of advice about the capabilities of competing digital
TV platforms and the varying opportunities and facilities they
offer to vulnerable groups.
87. DTT trials like those at Llansteffan and Ferryside
and, more recently Bolton, are essential for identifying practical
challenges that switchover sets. Issues include the provision
of technical assistance and the need to recruit and train volunteers,
such as the WRVS, Community Service Volunteers[153]
and students (as in Berlin).
88. We recommend that further trials are conducted
with the aim of identifying groups who are potentially left vulnerable
by analogue switch-off. The trials should include people with
disabilities, low income groups, the socially excluded, and involve
the voluntary sector.
89. BSkyB is concerned that the Government's support
package for vulnerable people appears to focus on the cheapest
digital option - invariably DTT.[154]
A memorandum from the Department for Culture, Media and Sport
acknowledged that "targeted assistance is based on the lowest
cost option".[155]
With regard to targeted assistance, the Minister for Creative
Industries and Tourism noted the technology neutral nature of
the Government's policy, adding: "In those areas where DTT
is not the cheapest option then we will make the cheapest option
there available to them (probably satellite)
"[156]
The extent to which the emerging package of targeted
assistance can be deemed to be platform-neutral and thus compatible
with European competition law will have to be monitored and checked
with care.
90. Switching over to digital television will pose
more than a financial challenge to some vulnerable groups. A Help
the Aged survey showed that 57% of the elderly respondents saw
digital television as a threat and not as an opportunity;[157]
more generally, Colette Bowe referred to estimates suggesting
that around 10% of households might be either reluctant or unable
to go digital. She highlighted widespread unfamiliarity with digital
technologies together with a range of practical problems associated
with finding, purchasing and using suitable equipment.[158]
There was a consensus among witnesses that the voluntary sector
had a key role in ensuring digital switchover worked.[159]
But the sector would need financial support:[160]
according to the Ofcom Consumer Panel, mobilising and training
volunteers to help vulnerable people acquire and install equipment
would cost about £100 per household.[161]
This is in addition to the cost of the equipment itself.
91. On the practicalities of making payments for
services, such as aerial installations, the Confederation of Aerial
Industries suggests that the support package for vulnerable groups
could operate by means of a mechanism similar to heating allowance,
rather than a voucher system or, worse, a "clumsy system
of reclaiming expenses".[162]
92. The total cost of the targeted assistance scheme
is uncertain,[163]
and it has not been factored into the BBC's proposal for a licence
fee settlement well in excess of inflation.[164]
Interestingly, targeted assistance is not included in the Government's
cost-benefit analysis: it is treated as a transfer cost because
the cost to the licence payer will, it is argued, be offset by
the benefit gained by those in receipt of assistance.
93. It is planned to fund the scheme through the
TV licence fee, the appropriateness of which will depend in part
on the extent to which this is considered a broadcasting or a
social cost. In its Second Report of 2005-06, the House of Lords
Select Committee on BBC Charter Review argued against the Secretary
of State's assertion that the targeted assistance scheme is a
broadcasting cost: "We can see no reason why help for the
over 75s, and other vulnerable viewers, with the costs of switchover
should be borne by the BBC when the Government already accepts
that it is responsible for bearing the costs of the licence fee
for over 75s."[165]
94. Caroline Thomson told us that the BBC was "content"
to go along with the Government's request to fund targeted assistance
from the licence. However, her contentment was on the basis of
four criteria: "that the licence fee is not being used as
a substitute for social security payments, which clearly would
be totally inappropriate, that any scheme meets all the state
aid requirements and is platform neutral, that it does not in
the end, partly because of the flat rate nature of the licence
fee, put an unreasonable burden on the licence fee payers that
would put the long-term future of the licence fee at risk, and
that it is not at the expense of our core services."[166]
95. Written evidence from the National Consumer Council
stated: "There is also a question of how the targeted assistance
programme is being funded. Using funds raised from the television
licence fee has the advantage of retaining a link between the
funds and how they are used. It is also relatively cost-effective
to collect. But it is not in line with the core purpose of the
licence fee, which is to support programming, and NCC believes
it would be false economy to direct money away from that. Using
the licence fee is also likely to magnify the worst aspects of
unfairness inherent in a flat-rate fee, where the burden is heavier
on low-income households. As Government anticipates switching
will deliver some financial benefit to the Treasury some of that
money should be diverted to offset the burden for consumers."
We agree. While transmitter upgrading is clearly a broadcasting
cost the provision of television and other receiving equipment
is a social cost in recognition of the need to provide compensation
to vulnerable groups. We believe that the use of Exchequer funds
to meet this cost is more progressive and justified given the
value of the spectrum released. It also places accountability
properly on a Minister's desk. We recommend that the Government
should reconsider this option.
96. More specific issues arise from the importance
of securing the availability of suitable equipment for receiving
subtitled services and audio description on different platforms.
There will be specific help for blind people; in particular, the
Government is proposing that they should be able to benefit from
the additional narration provided by audio description facilities.
Currently there is only one DTT set-top box which offers these,
and at £99, it is relatively expensive.[167]
The RNIB has also called for cable systems to provide audio description.
[168]
97. Ofcom (along with the DTI, DCMS and some broadcasters[169])
has carried out extensive research into the usability of digital
TV equipment, estimating that one in 20 adults could encounter
considerable difficulty. Ofcom's written evidence went on: "It
is proposed that Digital UK should keep in mind the needs of users
with the range of physical impairments, including hearing and
sight loss, and should work to encourage availability of easy
to use receivers with subtitles and audio-description." Leen
Petre, RNIB, doubted whether the market alone would provide "intuitive,
usable and accessible equipment."[170]
In written evidence, the Government commented that through what
it termed "the procurement process" it will be possible
"to ensure" that equipment meeting relevant specifications
is produced.[171] The
Government should do more to ensure the timely availability of
digital receiving equipment and remote controls which are affordable
and easy to use by people with cognitive, visual, hearing or physical
impairments.
98. An increase in the proportion of television programmes
that are audio described would also act as an incentive for the
blind and partially sighted to switch over to digital.[172]
According to the Government, there are around 375,000 registered
blind and partially sighted people in the UK. The RNIB estimates
that a further 750,000 people could register but have not done
so.[173] Other charities
such as Hearing Concern have made similar points in relation to
the provision of subtitles for the deaf and hard of hearing. The
Government and Ofcom should take steps to ensure that access to
a wide range of subtitled and audio described programmes is available
on all digital television platforms.
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