Memorandum submitted by Teachers' TV
I am writing to you to ask for your help on
an important issue. I am well aware that your Committee has discussed
the Digital Dividend Review and given your advice, however I should
be most grateful if you could consider our position on this matter.
As you are well aware, Ofcom is in the middle
of a major consultation exercise on what should be done with the
spectrum that will be released as "part of the switch from
analogue to digital broadcasting—"the digital dividend
review".
At the moment Ofcom is proposing that this valuable
spectrum be sold to the highest bidder. It would seem that you
and your colleagues support this general proposition. We would
want to argue that this would mean, in effect, that a lot of smaller
organisations, charities, and broadcasters who provide socially
valuable but non-commercial services would miss out. Mobile phone
companies and big international communications giants are likely
to snap up the entire available spectrum.
My view is that Ofcom's proposed auction, whatever
its advantages, will not result in an increase in the stock of
quality public broadcasting, and that instead the best way to
achieve a result that is good for society is to reserve some of
the spectrum for socially valuable broadcasting. This spectrum
would allow Teachers TV, and others like us, increased access
to Freeview, the UK's rapidly growing digital terrestrial television
(DTT) platform.
Ofcom has recognised, through consultation,
that broadcasting with a social rather than commercial value might
be disadvantaged in the auction process. It also has a statutory
duty to ensure that its broadcasting policy provides value to
people in their role as citizens as well as consumers.
Teachers TV, along with other broadcasters,
fall into a group whose sole purpose is to provide content that
delivers social value. In our case, we offer programming, as well
as extensive website content, for teachers, other professionals
in education, parents, and citizens, all of which is entirely
in line with what Ofcom regards as "broader social value".
However we are disadvantaged in doing more by
lack of access to Freeview. We currently have just two hours per
day available to us during daytime, when most parents and teachers
are unable to view.
If Ofcom were to place social value front and
centre its DDR plans, then providing some spectrum for content
of social value, such as Teachers TV, on DTT would be a key part
of its plans. We need all the support we can get to persuade Ofcom
to think again and in particular to look at the broader social
benefits that could arise from the digital switch over.
Our arguments are set out in more detail in
the briefing note which I attach.
This is a significant moment for the future
of UK broadcasting and I would welcome the opportunity to discuss
it with you in more detail. I will ask my office to get in touch
with yours to establish whether a meeting would be possible.
TEACHERS TV BRIEFING NOTE
THE DIVIDEND
OPPORTUNITY—WHAT
OFCOM SHOULD
DO WITH
RELEASE SPECTRUM
Introduction
Communications regulator Ofcom is currently
deciding what to do with radio spectrum that will be freed up
as the UK moves from analogue to digital broadcasting.
At the moment Ofcom is proposing to sell all
this valuable spectrum to the highest bidder. This means, in effect,
that a lot of smaller organisations, charities, and broadcasters
who provide socially valuable but non-commercial broadcast services
will miss out. Mobile phone companies and big international communications
giants are likely to snap up most of the available spectrum with
the rest going to purely commercial broadcasters.
The Teachers TV View
— Ofcom's proposed auction is good
for government revenues but not for quality of public broadcasting.
— The best way to achieve a result
that is good for society is to reserve some of the spectrum for
socially valuable broadcasting like the material we and others
provide, while the majority goes to the highest bidder.
— Currently, access to digital terrestrial
television ("Freeview") is driven by market forces and
Teachers TV and other non-commercial social broadcasters are failing
to fulfil their potential for social impact due to very restricted
access.
— Ofcom should amend its auction model
to achieve greater social value from the released spectrum.
Background
The UK Government is committed to a switch over
from the old analogue service to digital broadcasting. The process
has already begun and will be completed by 2012 when the analogue
service will be turned off.
Digital services use far less radio spectrum
than analogue, so there will be spectrum released by this process.
Ofcom, the government regulator responsible for spectrum use,
calls this the "digital dividend".
Ofcom is currently considering the responses
to its Digital Dividend Review (DDR) consultation before making
the final decision on how this spectrum should be used. Ofcom
has reached a preliminary conclusion that the released spectrum
should be auctioned off to the highest bidder, probably as a series
of packages.
Ofcom has decided this mainly on the basis that
it is impossible to predict what the best use of spectrum in the
future will be, and it is therefore best to leave this to market
forces. And—although this is not directly acknowledged by
Ofcom—this method will maximise the revenue that the Government
gets from the released spectrum.
Ofcom has finished its initial consultation
on the auction proposal. It is likely to present preliminary conclusions
in July 2007 which may lead to a further consultation.
The alternative view
Ofcom has recognised in its consultation that
broadcasting with a social rather than commercial value might
be disadvantaged in the auction process. It also has a statutory
duty to ensure that its brcadcasting policy provides value to
people in their role as citizens as well as consumers. Finally,
it is required by law to achieve the "optimal use" of
spectrum.
Many organisations and commentators—including
Teachers TV—have responded to Ofcom to point out that the
auction approach is not likely to support these objectives.
Teachers TV, along with other broadcasters,
falls into a group whose sole purpose is to provide content that
delivers social value. In our case we offer programming (as well
as extensive website content) for teachers, other professionals
in education, parents, and citizens which is entirely in line
with what Ofcom regards as "broader social value".
However we are disadvantaged in doing more by
lack of access to Freeview, the UK's rapidly growing digital terrestrial
television (DTT) platform. We currently can have space for only
2 hours per day, and not at a time when most parents and teachers
will be watching.
As one of our survey respondents commented:
"air times on Freeview are appalling. I would watch more
Teacher's TV if it was on in the same manner as Sky". We
share this frustration.
Ofcom acknowledged that increased access to
broadcasting that provides social benefit is an important opportunity
provided by the digital switch over. However, the consultation
paper failed to demonstrate how this sort of "social broadcasting"
will be protected in an auction system.
If Ofcom wants to place social value front and
centre of its DDR plans; then providing some spectrum for content
of social value on DTT would be a key part of its plans. Teachers
TV is arguing that there are a number of ways in which some spectrum
could be protected for this use, whilst still allowing the majority
of spectrum to be put out to auction in order to generate revenue
and support the market principles promoted by Ofcom.
We need all the support we can get to persuade
Ofcom to seriously consider these options.
About Teachers TV
Teachers TV is a channel whose mission is to
raise standards in schools. It is funded by the Department for
Education and Skills against robust key performance indicators
and its contribution has been strongly welcomed by ministers,
educationalists and the education workforce.
The channel has 24 hour distribution on satellite
and cable as well as all its content being available on the web.
Independent research conducted for the DfES
shows that for the core schools' audience and a wider audience
of interested stakeholders and parents, Teachers TV delivers significant
value. In particular it is clear that teachers are building skills
and implementing new ideas in the classroom as a result of watching
the channel.
The most recent research shows that the channel
is steadily increasing reach and maintaining its previous high
scores for loyalty and viewer value. Teachers TV loyalty scores
at 76% are considerably higher than other niche channels we have
surveyed, and viewing compares well with educational strands on
the (far better-resourced) BBC4 and Discovery channels.
May 2007
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