Memorandum submitted by Teletext Limited
Teletext Limited is a public service broadcaster
and has, since 1993, provided the public teletext service on Channels
three and four. During that time the weekly audience for the service
which the company delivers has risen from circa 12 million in
1992 to circa 24 million in 2000. The company attributes this
growth in usage to its commitment to the highest levels of editorial
quality and relevance and consumer confidence in the integrity
of its commercial activities. Teletext is regulated by the Independent
Television Commission (ITC). In its most recent Annual Review
the ITC reported that "For Teletext, 1999 was another year
of expansion and achievement . . .", and commented positively
on the launch of our new service for Scotland and improvements
in the editorial range and depth of our content.
Teletext welcomes much of the thrust of the
White Paper. In particular, we support the wish to create a vibrant,
diverse and dynamic market for communication services and to make
public services universally available. We are encouraged at the
intention to ensure "must carry" status for public service
broadcasters and to insist on corresponding "due prominence"
in listings publications, including electronic programme guides
(EPG's). We believe this commitment to be entirely consistent
with the stated objectives for public service broadcasting as
set out in the White Paper, namely to provide diversity and encourage
We would be happy to see more detail on the
powers OFCOM will have in the area of economic regulation as we
believe that in the new economy rapid reaction to unhealthy concentrations
of market power and access to speedy remedies will be essential
if dynamism and entrepreneurial behaviour are not to be stifled.
The UK communications landscape has changed radically over the
last 10 years and now consists of a small number of highly integrated
participants with considerable market power.
In this regard we have continuing concerns about
the commercial activities of the BBC. As a publicly financed broadcaster,
the BBC occupies a privileged position in the UK broadcasting
landscape. It is in a position to exercise unmatched market power
with no exposure to any commercial risk. This alone places it
at a significant advantage over smaller, creative, entrepreneurial
companies such as Teletext Limited which must remain mindful of
commercial risk. However in addition, the BBC's practice of providing
its content free of charge effectively removes the opportunity
for new commercially financed services. This distortion of the
risk/reward relationship is likely to inhibit the development
of a vibrant, diverse and dynamic market. Teletext believes that
the current commercial activities of the BBC will have the effect
of holding back the emergence of exciting new services and the
growth of exciting new companies. In this regard we believe the
White Paper could go further in setting out the role of OFCOM
in regulating the BBC.
The Internet offers enormous opportunities for
citizens and for commerce. It also brings considerable challenge
to those charged with regulating this new medium. Teletext believes
that notwithstanding the difficulties in developing a regulatory
regime and in particular an enforcement system, the need for regulation
should not be denied. Amongst its various purposes regulation
identifies those things of which society disapproves; the absence
of regulation may suggest that such things are condoned.
Teletext considers that as a first step, public
service broadcasters should be required to bring the same editorial
and commercial standards to their online services as apply to
their broadcast services. Moreover this could be effected within
a self-regulation framework such as exists at present in the newspaper
Teletext wishes to express particular support
for the comments in the White Paper relating to the potential
of teletext on digital television. As technology evolves teletext
services can offer much of the richness of the Internet in a more
familiar, convenient and cost effective manner thus bringing the
benefits of the information age to a wider proportion of society.
In this regard we would hope that more broadcast spectrum can
be made available for digital television and that more can be
set aside for public teletext services.
Teletext believes that the White Paper addresses
many of the issues confronting industry and the community as the
new communication landscape emerges. We support the concept of
"light touch" regulation backed up by statutory instruments.
We believe that a vibrant, diverse and creative approach to the
provision of new services will only be possible if distorting
concentrations of market power are prevented. We further believe
that the difficulties in enforcing regulation on the Internet
should not persuade us to abandon the task of setting out that
which is acceptable.