Regulation of Participative TV

Regulation of Participative TV

Issued January 31, 2007

Observations

BT supports a review of Participative TV and will look to the formal consultation with interest.  We believe the major issues for all players within industry is that regulation is focussed, specific, clear and appropriate such that all understand how to comply and can readily implement processes to ensure identified gaps in consumer protection are closed.

Whilst consumer protection is welcome where needed we request that Ofcom note that a host of regulatory bodies are mentioned in this paper and that many are, or have been involved in recent consultation exercises. There is a real danger that if regulatory boundaries and responsibilities are not clear that remedies may overlap or contradict such that any given organisation is placed in a position where they are not able to understand to whom they are responsible for compliance on what aspect of their activity.  We would welcome some statement in the Consultation on Ofcom proposals in relation to how they will liaise with other bodies and their related activities to ensure any proposed remedies are consistent and supportive of each other.

We would be keen to avoid a situation where unwarranted or inappropriate regulation simply results in a range of new non-compliance opportunities for players without necessarily producing any consumer benefit and we would trust that any new remedies are evidence-based and subject to cost-benefit analysis.  There is also the question of Ofcom's own resource implications for managing compliance and enforcement action.

BT considers that regulation, if new regulation is appropriate, ought to be centred on the broadcasting elements rather than the communications access aspect of Participative TV whilst considering what future potential Internet Protocol TV offers in terms of range and scope of access.

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BT would welcome any comments on the contents of this document. Comments should be addressed to Michael Traynor by e-mail to michael.traynor@bt.com.