18-03-2010, 18:03
Ofcom's stance on viewer expectations is obviously a concern for people working on the channels also.
This is the views of people in the industry:
The signatories to this letter collectively request that, in respect to the current PTV consultation, careful regard is taken by OFCOM of the potentially profound and negative human cost that would follow a decision by OFCOM to introduce significantly more onerous and restrictive regulations which would effectively close down the free to air babe sector.
Such would be the inevitable consequence were OFCOM to introduce a form of regulation which undermined the existing economics of an industry that creates significant direct and indirect employment across a number of businesses in the Media, Telecoms, Transmission, and Production sectors.
It would also adversely affect a huge number of freelance producers, presenters and support staff who are unlikely to be able to find immediate employment elsewhere in the current recessionary environment, which is already causing significant redundancies in the TV broadcast and production industries.
We are making this petition because we see no compelling reason why it is in the public interest for the free to air babe sector to be subject to further regulation that might undermine its viability.
There seems no justification for this regulation on the basis of causation of harm or offence or the receipt of consumer complaints. We believe that all of the only 40 or so complaints received by OFCOM in the last 5 years have been made anonymously by industry competitors, a fact that is known to OFCOM, as is the fact that the complaints are primarily from companies involved in the encrypted adult business that stand to gain enormously should OFCOM introduce regulations which effectively close down the free to air babe sector.
OFCOM's own research has borne out the fact that viewers and participants do not feel they are being misled in any way. All participants in OFCOM’s research commissioned from Essential have found the proposition of this type of programming transparent. That is why there has not been any bona fide (i.e. genuinely consumer originated and impartial) complaint upheld by either OFCOM or PPP in the hundreds of thousands of hours of broadcasting by this sector over the last 5 years. Given the apparent total absence of genuine consumer complaints about this sector and the absence of any evidence of harm or offence to viewers we do not see how can it be in the public interest to destroy the livelihoods it creates.
Unless OFCOM are able to prove otherwise, we are of the view that the free to air babe sectors have the lowest level of genuine consumer complaints of any genre broadcast on any platform.
We believe that at least 2,500 people will lose their jobs if the sector is regulated out of existence (i.e. as many as those thus far made redundant by Marks and Spencer).
We feel that in considering the real human and economic impact of any change in regulation OFCOM should also have regard to the following:
There are some 27 channels involved in the free to air babe business. This represents revenues of some £7million per annum to bandwidth providers such as Arqiva and Globecast. Fibre and connectivity suppliers such as BT, Colt and AboveNet stand to lose up to £1.5million per annum in circuit charges.
In a recession where advertising supported channels are already finding it tough to survive it is very unlikely that these providers will be able to find start up niche channels who can generate sufficient income to support take up of this level of bandwidth.
There are also numerous and diverse broadcasters who rent capacity or airtime to free to air babe operators. It is unlikely they will easily find replacement clients in the current market. There are already some 2O Sky TV channels currently for sale. The average market price for Sky EPGs has declined by an estimated 65% in the last 4 months. This is a further illustration of the severe effects of the recession on the broadcast industry.
There are numerous telecoms service providers involved in this business both in the provision of IVR and SMS services. Some providers depend fairly exclusively on this business and for most it represents a significant and not easily replaceable source of revenue. Even where the business represents a minority portion of their revenue its sustainability could be the difference between profit and loss.
There are more than 2,000 individuals from production staff, presenters, call centre operatives, management and administrative staff whose livelihoods depend directly or indirectly on the free to air babe business.
We are not aware of any proposal by OFCOM to put forward a job or business replacement program for those who would be impacted on by regulations which effectively undermine the viability of the free to air babe channels.
The shareholders of the companies operating these businesses face evaporation of their investments in certain liquidation. There would be a trickle down effect as they defaulted on factoring arrangements with Banks and other credit providers.
The television industry as a whole is going through terribly tough times suffering from significant cuts in advertising budgets, these are leading to redundancies in broadcasters and production companies. It is unlikely that there will be any takers for the 27 channels of capacity that will become available for the same reason. Even in better times, few niche channels could survive on advertising alone. In the current economic environment this is impossible.
This is the views of people in the industry:
The signatories to this letter collectively request that, in respect to the current PTV consultation, careful regard is taken by OFCOM of the potentially profound and negative human cost that would follow a decision by OFCOM to introduce significantly more onerous and restrictive regulations which would effectively close down the free to air babe sector.
Such would be the inevitable consequence were OFCOM to introduce a form of regulation which undermined the existing economics of an industry that creates significant direct and indirect employment across a number of businesses in the Media, Telecoms, Transmission, and Production sectors.
It would also adversely affect a huge number of freelance producers, presenters and support staff who are unlikely to be able to find immediate employment elsewhere in the current recessionary environment, which is already causing significant redundancies in the TV broadcast and production industries.
We are making this petition because we see no compelling reason why it is in the public interest for the free to air babe sector to be subject to further regulation that might undermine its viability.
There seems no justification for this regulation on the basis of causation of harm or offence or the receipt of consumer complaints. We believe that all of the only 40 or so complaints received by OFCOM in the last 5 years have been made anonymously by industry competitors, a fact that is known to OFCOM, as is the fact that the complaints are primarily from companies involved in the encrypted adult business that stand to gain enormously should OFCOM introduce regulations which effectively close down the free to air babe sector.
OFCOM's own research has borne out the fact that viewers and participants do not feel they are being misled in any way. All participants in OFCOM’s research commissioned from Essential have found the proposition of this type of programming transparent. That is why there has not been any bona fide (i.e. genuinely consumer originated and impartial) complaint upheld by either OFCOM or PPP in the hundreds of thousands of hours of broadcasting by this sector over the last 5 years. Given the apparent total absence of genuine consumer complaints about this sector and the absence of any evidence of harm or offence to viewers we do not see how can it be in the public interest to destroy the livelihoods it creates.
Unless OFCOM are able to prove otherwise, we are of the view that the free to air babe sectors have the lowest level of genuine consumer complaints of any genre broadcast on any platform.
We believe that at least 2,500 people will lose their jobs if the sector is regulated out of existence (i.e. as many as those thus far made redundant by Marks and Spencer).
We feel that in considering the real human and economic impact of any change in regulation OFCOM should also have regard to the following:
There are some 27 channels involved in the free to air babe business. This represents revenues of some £7million per annum to bandwidth providers such as Arqiva and Globecast. Fibre and connectivity suppliers such as BT, Colt and AboveNet stand to lose up to £1.5million per annum in circuit charges.
In a recession where advertising supported channels are already finding it tough to survive it is very unlikely that these providers will be able to find start up niche channels who can generate sufficient income to support take up of this level of bandwidth.
There are also numerous and diverse broadcasters who rent capacity or airtime to free to air babe operators. It is unlikely they will easily find replacement clients in the current market. There are already some 2O Sky TV channels currently for sale. The average market price for Sky EPGs has declined by an estimated 65% in the last 4 months. This is a further illustration of the severe effects of the recession on the broadcast industry.
There are numerous telecoms service providers involved in this business both in the provision of IVR and SMS services. Some providers depend fairly exclusively on this business and for most it represents a significant and not easily replaceable source of revenue. Even where the business represents a minority portion of their revenue its sustainability could be the difference between profit and loss.
There are more than 2,000 individuals from production staff, presenters, call centre operatives, management and administrative staff whose livelihoods depend directly or indirectly on the free to air babe business.
We are not aware of any proposal by OFCOM to put forward a job or business replacement program for those who would be impacted on by regulations which effectively undermine the viability of the free to air babe channels.
The shareholders of the companies operating these businesses face evaporation of their investments in certain liquidation. There would be a trickle down effect as they defaulted on factoring arrangements with Banks and other credit providers.
The television industry as a whole is going through terribly tough times suffering from significant cuts in advertising budgets, these are leading to redundancies in broadcasters and production companies. It is unlikely that there will be any takers for the 27 channels of capacity that will become available for the same reason. Even in better times, few niche channels could survive on advertising alone. In the current economic environment this is impossible.