Memorandum submitted by PublicMedia
OFCOM AND
THE DIGITAL
DIVIDEND REVIEW
We are writing on behalf of a range of VCS,
public sector, community media and broadcast groups to raise some
concerns about Ofcom's proposals for the "Digital Dividend"
ahead of the joint oral evidence session on Ofcom's Annual Plan
for 2007-08 on 17 April.
Under the Communications Act of 2003, Ofcom
have a principal duty to "further the interests of citizens
in relation to communications matters." However, in proposing
that all of the spectrum freed up by Digital Switchover is sold
at auction, Ofcom are effectively excluding public service, social
action and community broadcasters from being able to use what
is in essence the largest bundle of spectrum to be released since
the post-war years.
The simple market auction approach is not only
skewed against the social value sector because of lack of resource,
but ignores the transactional costs of getting a large number
of small organisations to bid together; and Ofcom has not really
explored the possibility that the result will be market failure
in terms of social value generated.
Ofcom's defence of the simple market auction
approach has been that citizen groups are not actively being excluded,
as they are free to use other platforms, and to participate in
the auction should they be able to obtain funds. However, the
principal duty does not oblige Ofcom to act in a way that does
not exclude citizen interests, rather it obliges Ofcom to actively
enable broadcasting that is in the interests of citizenship in
the UK.
Not only do the proposals outlined during the
Digital Dividend Consultation period not reflect this duty, but
the independent research on which Ofcom have based their proposals
was conducted in a way that biased the interests of the consumer
over those of the citizen from the outset. Holden Pearmain and
ORC international, who were commissioned by Ofcom to conduct this
research, have ascertained the popularity of certain platforms
and the benefits to consumers and citizens through what is essentially
economic modelling and lay reporting.
Whilst complex matrices have been developed
for economic value and indicators of consumer benefits, the benefits
of spectrum to citizens have been looked at in far less detail
with a few general questions asking if "new technologies
could enable better access to public services (for example, education,
healthcare, local government)," and without giving any level
of detail as to how these technologies are already used to deliver
access to public services. Furthermore, answers to these questions
have been translated into monetary indicators of value only.
As such, the level of research necessary to
devise an awards process for releasing spectrum in a way that
is of benefit to citizens has not been undertaken, nor have those
citizens on the other side of the "digital divide" been
surveyed. Our concern is that the financially poor, the digitally
disenfranchised and visually and aurally impaired people will
ultimately lose out, as will all individuals who consider themselves
"UK citizens."
We therefore urge you, and the members of the
DCMS and DTI committees who will be scrutinising Ofcom's annual
plan, to ensure that Ofcom release the Digital Dividend spectrum
in a way that:
— Makes a sufficient amount of
spectrum available for public, citizen, social and community uses.
— Facilitates universality/ access
to services for all.
— Ensures that digital services
are available for all at a national, regional and local level.
These points, and others, have been raised in
our submissions to Ofcom, which can be obtained by contacting
us individually, or logging on to http://www.ofcom.org.uk/consult/condocs/ddr/responses.
We would welcome a meeting with members of the
DCMS and DTI committees to discuss these issues further.
April 2007
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