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Memorandum from United for Local Television
About
United for Local Television
United
for Local Television ("ULTV") is a coalition of local TV operators and
campaigners, from both commercial and not-for-profit sectors, formed to promote
the universal availability of public service local television ("local TV"). The
group campaigns for reserved access to the digital terrestrial television
("Freeview") platform and other measures to support the development of local TV
in England, Wales and Northern Ireland. Proposals for
local TV in Scotland
have been developed separately by the Scottish Local TV Federation, with which
ULTV works closely.
ULTV is often asked a
number of questions relating to its proposals and how they could work. The
following is not intended as a comprehensive response to all questions but,
rather, a summary of some of the issues which have been raised. More detail is
contained in ULTV's formal response to Digital
Britain
The Interim Report (March 2009).
ULTV
is also willing to make two reports available to the Committee's Inquiry which were
submitted confidentially to the Department for
Culture, Media and Sport ("DCMS") in April 2009: (i) a study
for DCMS of four local TV stations in Belfast, Cardiff, Immingham and York; and, (ii) a summary for DCMS of
discussions between ULTV and other organisations.
1. Local TV is well developed in many
other countries. Why not the UK?
1.1. Discussions relating to the development of
local TV in the UK
are not new and date back to the creation of ITV,
set up in 1954 as a federation of 15 individual companies, based in 15 regions.
1.2. Even at that time many argued that the ITV
'regions' were arbitrarily drawn and there was seldom a sense of community in
the service. Nevertheless, the regional programmes and regional news produced
by the 15 ITV companies were an
important part of ITV's public
service broadcasting remit. The standard of the programmes, covering the arts,
history, culture, music, politics, religion, current affairs and other subjects
rooted in the region, plus the news bulletins and magazine programmes, was
often very high. Contrary to claims sometimes now made many of the well-known
regional programmes were popular with viewers, achieving consistently high
Audience Appreciation Indices; they were also an important part of the
democratic process, providing both information about, and a context to life in
that region.
1.3. Over time ITV reduced the
emphasis given to its regional programming and many non-news programmes were
sidelined. In early 2009, all non-news programmes were axed by ITV plc in England
and they have also now reduced their news regions in England
and Wales
to just 9 (with some additional 'opt outs' for news headlines).
1.4. The demand for a more local form of provision has long been recognised
by policy makers. At the time of the creation of Channel 5, there was a lobby
to use these 'spare' frequencies for a local TV network, although the cost of
re-tuning videos helped to ensure that option was not realised.
1.5. The 1996 Broadcasting Act
introduced Restricted Service Licences (RSLs) intended to be used to roll out
local TV across the towns and cities of the UK. However, there were a plethora
of problems with the regulatory regime, many relating to the manner in which it
was implemented by the then regulator, the ITC. One critical factor related to
the ITC's inability to identify almost any adequate frequencies to implement
the scheme (at least partially due to deliberate obstacles placed by the
incumbent PSB broadcasters on the spectrum planning group).
1.6. ULTV believes that digital switchover provides the opportunity to
develop a viable network of local TV services available to virtually all UK citizens.
ULTV believes this requires public policy intervention as set out below.
2. Is it true there is no spare capacity
on Freeview so viewers would have to lose a channel if a video stream was
reserved for a universal service across England,
Wales and Northern Ireland
on an existing PSB multiplex?
2.1. ULTV
believes it is not acceptable for
any UK
citizens to be denied access to a local TV service due to lack of spectrum. The
government has already reserved around 70 per cent of the spectrum currently
used by analogue television for Freeview multiplexes at switchover and has the
ability to reserve capacity within this spectrum for local TV.
2.2. Under ULTV's proposal for 'Channel 6' in England, Wales
and Northern Ireland,
no channel which would have been available on Freeview post-switchover would
lose access to Freeview. All that would happen is that ITV
plc (or another commercial broadcaster) would be expected to move one of their
non-PSB video streams from a so-called 'PSB multiplex' to a 'commercial
multiplex'. This would free up a video stream on a universal multiplex capable
of being used (by adopting 'add/drop' technology) to deliver a different
"Channel 6" franchise area at every major Freeview transmitter site.
2.3. The Channel 6 proposal utilises spare
red-button capacity available pre-switchover and additional capacity freed-up
by mode change at digital switchover. Furthermore, a new encoder from Tandberg
Television has been launched which is reported to cut the amount of bandwidth
needed for an MPEG-2 standard definition TV channel by at least 15 per cent,
generating additional capacity for even more new services on Freeview. ULTV
argues at least some of this incremental capacity should be reserved by government
for the advancement of under-supplied genres of PSB and not purely to generate
supernormal profits for Freeview's near-monopoly spectrum gatekeepers.
2.4. ULTV has also put forward proposals for 'interleaved'
spectrum, where available and demand exists, to be made available to supply
incremental local TV services in England,
Wales and Northern Ireland.
In Scotland, the Scottish
Local TV Federation has put forward alternative proposals to deliver local TV
(and potentially other 'public service' channels) using spectrum available to
launch a universal '7th multiplex' for Scotland.
2.5. Channel
6 would guarantee that all citizens have access to at least one channel dedicated
to local news and information. The service would be granted the benefits
associated with public service status including 'must carry' on Freeview, cable
and, subject to the approval of the BBC
Trust, the iPlayer. Priority status on the DTT electronic programme guide (e.g.
"channel 6") is an important part of the proposal.
3. Do not proposals to integrate Broadband
in Freeview receivers mean that local TV can develop on main TV's without
access to spectrum?
3.1. As is often reported, approximately 39 per cent of UK homes who
have access to broadband choose not to subscribe, often because they cannot
afford to do so. In contrast, 69 per cent of UK homes currently have at least
one Freeview receiver, even though Freeview is only currently available in approximately
73 per cent of households. Freeview has become the 'default' platform for TV in
the UK.
3.2. ULTV welcomes the government's announcement, in the Budget,
that it intends to explore how the licence fee's so-called 'switchover surplus'
could be used to help fund the universal delivery of broadband and promote
take-up. However, any heavy use of video on demand applications on broadband
requires high data limits. ULTV understands there are advanced plans to
integrate broadband connections into Freeview receivers but this would almost
certainly need to be coupled with broadband subscriptions which include unlimited downloads - far beyond the monthly budgets of many of the most
vulnerable in society.
3.3. ULTV strongly supports the principle of encouraging
on-demand video on home TVs on all platforms - cable, satellite and terrestrial
- and understands the market is moving towards this. However, the continued
high demand for Freeview capacity suggests the market continues to expect
Freeview to be critical to the business model of free-to-air broadcasting for
the foreseeable future.
4. Has not Ofcom
made provision for the development of local TV in its Digital Dividend Review?
4.1. No. ULTV strongly opposes the proposals
made by Ofcom to auction spectrum "suitable but not reserved for local television"
to the highest bidder with no obligations to fulfill PSB purposes (and with the
remainder of the interleaved spectrum gifted to a monopoly Band Manager with no
obligations to local TV). This will almost certainly lead to one single
monopoly holder of the spectrum suitable for local TV in any given area. Any third party seeking
to deliver a local service would be forced to negotiate with a monopoly
controller of the local spectrum who would be under no obligation to release
capacity in a manner that is fair, reasonable and non-discriminatory.
4.2. Rather than charge its true
market value (probably close to nothing at many small relay sites where there
is expected to be a surplus of interleaved frequencies), a Band Manager would
be incentivised to refuse to release capacity until a monopoly rent is paid,
forcing a service provider to seek additional funding. It is difficult to see
how this is in line with Ofcom's
statutory duty to secure the optimal use of spectrum. Unregulated monopolies are
rarely in the public interest but least of all when the monopolist is granted
the power to hold society to ransom over such public policy objectives as the
promotion of informed democracy and educated citizenship.
4.3. ULTV understands that Ofcom applied pressure on Arqiva, the main
commercial Freeview multiplex operator, not to participate in the first two
auctions of DDR spectrum on the basis it would be politically unacceptable for
incumbent local TV operators to be out-bid, potentially leading to pressure for a
re-writing of the rules for later auctions. Arqiva evidently responded to this
pressure but there is no guarantee they will do so in later auctions - they
have made known their intention to participate and to seek to become the Band
Manager for all interleaved spectrum.
4.4. ULTV argues Ofcom's
current proposals for the 'ad hoc' development of local TV where spectrum is in
low demand fail to enhance the opportunities for synergies to be exploited by
neighboring local TV operators and the development of scale. This appears to be
finally recognised by Ofcom itself
who said in their PSB Review Statement of 21 January 2009 (paragraph 10.28):
"We believe
the potential for DTT capacity to support local television should be kept open
for further consideration."
4.5. ULTV's position is that access to local news
and current affairs on television should be universal. It would not be
equitable if, in some areas, constituents are able to see their elected
representatives, councillors, MPs, public service providers, business leaders
and prominent members of the community engaged in debate on local TV but, in
other areas, they are not. Access to local TV should be a matter of public
policy, not postcode lottery.
4.6. ULTV understands that Ofcom
is reviewing its proposals for the release of 'digital dividend' spectrum.
However, this is not on its own enough to allow local TV to flourish. The
interleaved spectrum is made up of 'spare' frequencies not used by the main
Freeview multiplexes in certain locations. Ofcom
has confirmed that interleaved frequencies will deliver inferior coverage to the
six Freeview multiplexes even in the implausible scenario that local TV
operators manage to consistently out-bid all other operators to secure them.
The only method to ensure all citizens in England,
Wales and Northern Ireland
have access to a local TV channel is to ensure at least one video stream (out
of 30+ on Freeview) is reserved as a local channel.
5. Does ULTV support Ofcom's proposal for Independently
Funded News Consortia to apply to provide regional news on ITV1 or Channel 4?
If implemented, what impact could this have for the business model for local
TV?
5.1. It is important to distinguish between local TV, as advocated by ULTV,
and moves to merely prop-up the 'status quo' in regional ITV,
as Ofcom and some others have
recently suggested. ULTV does not believe that thirty minutes a night of
regional magazine programming slotted into the Channel 3 schedule is adequate
to meet the need for news, information, sport, culture, religion, debate,
history and other programming focused on local communities. ULTV sees Digital
Britain as an opportunity to improve upon Analogue Britain and believes that
simply subsidising regional news on ITV1,
post-switchover, could damage new entrants seeking to build sustainable
business models built on a more local form of provision.
5.2. ULTV believes Ofcom has, in
effect, prematurely allowed ITV plc
'off the hook' in terms of its nations and regions PSB commitments. UTV in Northern Ireland
concedes its existing news obligations are commercially sustainable. ITV plc Chairman, Michael Grade, indicated the
company was committed to continue regional news on ITV1
(in partnership with the BBC) until
"at least 2016" (subject to other
forms of regulatory relief) immediately prior to Ofcom
publishing its PSB Review statement in January 2009. Indeed, a major factor why
ITV plc is not able to take full
advantage of the savings offered by the BBC
partnership proposals, in the short-term, is because it is tied into long-term
property leases across England.
This is hardly a justification for providing state subsidy.
5.3. ULTV expects a dedicated local TV service to be a far more effective
carrier of local news and local programming than ITV1,
or indeed any other UK
network. In the world of on-demand digital platforms, the concept of one thirty
minute slot for regional news once a day appears increasingly anachronistic. It
is inconceivable viewers would be incapable of discovering local news if a
24-hour local TV option were available on the front page of the Freeview
programme guide. Critically, local TV could also provide current affairs,
factual, social action, in-depth interviews and other programming of interest
to localities.
5.4. It is regrettable
that ITV1 is no longer a federation
of independent stations in England.
However, the crisis facing local media cannot be solved simply by subsidising
regional news on ITV1. On the
contrary, there is already significant intervention in the regional TV market
in the form of the BBC who provide the
most watched nations and regions news programmes in the UK.[1] It
is questionable whether ITV1
provides adequate 'plurality' with the BBC
by offering an essentially similar service, especially one that is increasingly
regarded as inferior by discerning viewers.
5.5. As Ofcom suggested in its discussion paper New News, Future News[2]:
"...localised models thrive in
some overseas markets, and may become more viable in UK conditions in a digital market.
It may not be necessary for plurality to depend on identical 'regional' models
on both BBC and ITV."
5.6. ULTV's business model for local TV stations is predicated on the
assumption that windows will be provided for advertising to local businesses
who, at present, have no cost-effective TV advertising opportunities. In contrast,
ITV plc generally chooses not to
place advertising in its regional news programmes in order to move these
minutes to the 7-9pm hours which tend to rate more highly. ULTV fears that Ofcom's proposals would simply entrench the monopoly
status of ITV plc in the effective
sale of local advertising on terrestrial TV and do so at the public's expenses.
6. What
level of public demand has Ofcom
identified for local TV?
6.1. The research commissioned by Ofcom for its Digital Dividend Review confirmed the
view that local TV could have a special role to play in promoting Digital
Britain. Ofcom's research demonstrated that local TV on Freeview
was the number one new application
demanded by consumers, ahead of both "extra
SD channels" and "HD on Freeview".[3]
Importance to you personally of services that could
use digital dividend spectrum[4]
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Order of popularity
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Application
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Mean average score out of 10
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1
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Local TV on Freeview
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6.3
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2
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Extra SD channels on Freeview
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6.2
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3
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Better mobile phone coverage and mobile broadband
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5.9
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4
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Wireless home networks
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5.7
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5
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HD on Freeview
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5.6
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6
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Mobile TV
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3.3
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6.2. The greatest demand for local TV came from low income sub-groups, the
over-65's and those with minimal interest in digital technology. In the latter
category, a remarkable 50 per cent of the entire group rate local TV on
Freeview as their preferred application.[5] That is
why one of the most appropriate mediums to promote local education, training,
employment opportunities and other public services in any given area is a
free-to-air terrestrial local TV station.
6.3. Some
of the most important research to consider is the audience appreciation of the
non-news regional programmes until recently broadcast in ITV1
regions. Ofcom erroneously seeks to
argue non-news programmes suffered from low audience demand and seeks to site
poor ratings as evidence. However, in recent years poor ratings were most often
the direct result of being sidelined on the outer fringes of the ITV1 schedule. The most valuable yardstick is the
Audience Appreciation Indices for these programmes which were invariably high
and often in the high 80s and 90s.
7. Has
ULTV put forward proposals for enhancing training and apprenticeships in
community media projects?
7.1. At present, a great deal of training in media outside of post-graduate
courses is 'ad hoc' with local grants and projects different from area-to-area.
Whilst there are benefits to targeting funds on local projects designed to meet
local demand, ULTV has also suggested that a 'citizens' media' fund may be
worthy of exploration, potentially helping to fund structured training in local
communities and to support innovative media projects.
7.2. Often
working alongside existing local media providers, local TV would develop new
opportunities for employment, training and community participation in media
across the UK.
8. What
types of programmes would Channel 6 show and who would produce them?
8.1. The local programme
schedule for Channel 6 licensees would be developed following local research.
ULTV recognises that a typical viewer may not watch Channel 6 all evening - to
do so would imply the abandonment of all other consumption. However, there is a
wealth of evidence demonstrating the demand for local news, supplemented by
current affairs, sport and information. ULTV envisages that a local news
magazine would be one of the flagship programmes produced by Channel 6
licensees. It is possible that a local news programme would be shown several
times during the course of the evening (rebroadcast and/or repackaged).
8.2. The nature of local TV
is that it is not difficult to supplement local news with other programmes at
marginal incremental cost. If suitable facilities are available then filming
additional programmes, for example interviewing local politicians, sports
personalities or other members of the community, becomes a possibility. A local
TV station is therefore able to become part of the fabric of a community,
providing resources for citizens to produce programmes both for a linear
service and for online.
8.3. Crucially, there are
often many community organisations, universities, sports clubs, museums,
churches/mosques/temples, youth associations, charities, small independents and
individuals able and willing to contribute to local TV. Public service content
of this nature is not easily discoverable if it is not part of a schedule. The
primary benefit of a linear service is that local news acts as a 'magnet' for
other programming covering topics such as the arts, sport, culture, history,
wildlife and religion. A local newscast draws a high reach every day and then
allows this to be inherited by other programming.
8.4. A Channel 6 network
centre would be able to attract advertising to fund additional programmes, both
sourced from its own local station members and acquired or commissioned. ULTV is in discussion with a number of parties,
including the BBC and Community
Channel, about potentially providing programming and support to the Channel 6
network centre. This would provide an attractive spine of programming to which
each individual local TV station could opt in and opt out, thus complementing
their own local service.
8.5. ULTV
regards Channel 6 as an important opportunity for existing local media
operators to expand their businesses profitably. ULTV is actively engaged in
discussions to encourage existing media owners to play a role in developing
Channel 6 either by applying for licences (on their own or as part of local
consortia) or by working with stations to supply news under contract or to
share resources.[6]
9. What
do ULTV want the government to do?
9.1. The
development of digital platforms brings with them the challenge of new
competitors and fragmented audiences. However, they also bring the opportunity
of more economic entry levels, greater opportunity for citizen participation
and the ability to reach new audiences innovatively through continuously
connected devices.
9.2. One
of the purposes of digital switchover was to open up terrestrial broadcasting
to new entrants. However, the main barrier to entry preventing the launch of
many services from new 'public service' entrants is the undersupply and
consequent cost of Freeview capacity.
9.3. It is within the power
of government to reserve video streams on any of the six Freeview multiplexes,
including the so-called 'commercial' multiplexes, for services meeting public
service purposes. It is equally within the power of government to require Ofcom to ensure that interleaved spectrum, almost
all of which is to be held by a monopoly Band Manager, is used to deliver
public service purposes. These are valuable regulatory assets which have already been granted by the state but
which risk not being optimised for the delivery of maximum public value.
9.4. ULTV
calls upon the government to recognise the important contribution local TV can
make to the development of public service broadcasting, to assign suitable
capacity to ensure all citizens have access to at least one local TV service
and to put in place the mechanisms to enable the public, private and voluntary
sectors to work in partnership to develop effective channels of communication
for local communities.
9.5. The most urgent and
pressing deficiency in UK
broadcasting is in the lack of local TV provision. ULTV urges the Government to
take decisive action to introduce a local TV order (as provided in Section 244
of the Communications Act 2003) and encourage Ofcom
to start licensing services for launch in 2010/2011.
May
2009
[1] The only
areas where the early evening bulletins on ITV1
beat BBC1 are Northern Ireland (UTV)
and Border. Source: Ofcom (May
2008), The Communications Market 2008: Nations and Regions English Regions
[2] Ofcom (June 2007), New News, Future News - The challenges for television news after
Digital switch-over
[3] Ofcom (November 2007), Digital Dividend Review Market Research 2007 Executive Summary, London: Ofcom
[4] Q8.3a "For each of these services
please score each on a scale of 0 to 10, where 10 means extremely important and
0 means not at all important to you personally" (mean scores are shown).
Source: Ipsos MORI survey 2007 Base: UK adults 1,049
[5] Ofcom (November 2007), Digital Dividend Review Market Research 2007
Executive Summary, London:
Ofcom
[6] ULTV
submitted a briefing paper on "How
Channel 6 would work" to the second phase of Ofcom's
PSB Review which is in the public domain: http://www.ofcom.org.uk/consult/condocs/psb2_phase2/responses/ultv_annec.pdf
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