The below are my answers to the BBC Trusts’ Consultation on On-Demand Syndication, which closes very soon, on the 21st of July. Note that the link to the PDF of the questions seems to be broken, the correct link is here. The full text leading in to the questions can be quite long, in which case I have elided all but the closing part of the questions.
- Q1. … The BBC Executive would therefore like the Trust’s on-demand Syndication Policy amended to make clear that BBC programmes should always be made available in the context of a BBC package (such as a BBC TV channel (BBC1 for example) or via the BBC iPlayer on a PC, TV or mobile phone) in order to deliver the public purposes more effectively.What are your views on this proposal?
While I sympathise with the desire for editorial integrity, if the choice is to be a binary choice between:
a) The ability of device manufacturers (commercial or otherwise; hardware or software) to innovate
b) The ability of BBC to tightly control devices, and to deny access 3rd party access to content
then I would suggest the public interest is served far, far more by the former than the latter. I would suggest that the BBC Trust ensure that any guidelines seek to protect 3rd party innovation above all else.
- Q2. Do you agree with the BBC Executive that the Trust should place more emphasis on value for money in its syndication policy?
Yes, I do.
A very important aspect to value for money is 3rd party access. Such access allows multiple 3rd parties to innovate and make new products available to the public, independently of the BBC and *without* the BBC having to spend money.
As an example, 3rd party iPlayer applications have allowed people to construct ‘media-centres’ for themselves, building on commodity PCs and Linux (XBMC); have allowed a wide-range of Android based phones to access iPlayer (unlike the official BBC Android iPlayer which works only on a limited range of the newest phones); have allowed general Free Software users to access iPlayer. All of these were produced without cost to the BBC. In all but 1 case, they enabled access on platforms which the BBC does not consider ever worth supporting, and in the final case it enabled broader access long before the BBC produced its limited access.
It is clear therefore that 3rd party innovation allows greater access to BBC content by UK users who generally are entitled to access that content. Thus this furthers the BBCs’ chartered goal of providing as wide access as possible, while doing so at no extra cost to the BBC.
Unfortunately, to date, the BBC have taken the view that such 3rd party access must be restricted as much as possible. The BBC has regularly taken technical steps to shut off access to any 3rd apps. This is most unfortunate and, given the above, on the face of it somewhat at odds with the BBCs’ remit.
- Q3. The BBC Executive agree that wide syndication is good for audiences, but they are concerned about the cost of developing different versions of packages like the iPlayer for growing numbers of platforms and devices. To make the iPlayer or other packages of content widely available across a range of platforms in a more cost-effective way they propose to develop ‘standard’ software (notably for the iPlayer) that can work on many devices. Manufacturers can build this into their products when designing them. The BBC would publish details of how decisions on which standard software products to develop would be taken.
What do you think about this proposal?
This proposal is ridiculous. Provably so given the history of there already being a number of independent iPlayer applications available for a number of platforms which the BBC does not support, at no cost to the BBC. Rather than the BBC investing so much energy into denying access to these 3rd party applications, the BBC could save its resources AND promote wider platform access simply by desisting from trying to block such applications.The BBC would be much better off publishing the technical details for supported access to its streams, and communicating with 3rd party device makers (commercial or otherwise; software or hardware). This step alone would ensure that iPlayer access was effectively universal (at least, relative to what the BBC has the resources to achieve), at very little cost to the BBC.
- Q4. Do you think that the BBC should, in principle, be prepared to invest in developing special non-standard technology for other devices at the BBC’s expense?
The BBC should not at all be aiming to be the developer of end-user devices, beyond whatever prototypes required to verify its delivery infrastructure. It is quite wasteful of resources that the BBC has taken on this role for itself – a role it can never properly fulfill. Instead, the BBC should, as is its long-standing practice in broadcast TV, contribute to industry standards bodies (for the case of internet technologies, these would be the IETF and the W3, nota bene) and publish the technical information needed for devices to access its content using such standards. Thus, the responsibility for the development and marketing of devices ought to be borne by the free market. This arrangement has been proven to be the most economical way of developing products for public use.
It is disturbing that the BBC wishes, by use of the technology-shift from broadcast to online for TV, to acquire complete control over TV devices. This is quite clearly anti-thetical to a healthy free market. That we must then talk about which platforms the BBC then should or should not support – rather than allowing a free market to decide – is the result of this unhealthy control.
In short, let the free market invest to develop that ‘non-standard’ technology. Let the BBC publish, not decisions about which platforms it deigns to support, but technical specifications that allow such a free market to operate. This is how the market for TV devices has worked for many a decade – the BBC should not be allowed to change the fundamental economics simply because the technology details change.
- Q5. Is audience reach the best criterion for setting priorities? If so, what number of potential users should be taken as the threshold?
Yes it is. The number of users is irrelevant – the free market should be allowed to decide, as elaborated in my answer to Q4.
- Q6. Should the BBC also publish its criteria for prioritising any non-standard software development?
Yes, the BBC should endeavour to operate transparently, in all things.
- Q7. An alternative is that, provided the BBC has the resources available, a manufacturer would have to pay the BBC’s costs for the development of a customised iPlayer that worked for its platform. What do you think about this?
See my answer to Q4. Obviously, my answer would be ‘no’. Rather, the BBC should make content available in industry standard ways (thus, IETF or W3 for internet technologies). Thus the BBC invests its resources once, so allowing many others to invest theirs (likely without even having to contact the BBC) to develop software for whatever platform they wish. The BBC should seek to support a free market in devices. The public interest is served by the innovation and breadth of products a free market brings – it is not served by having the BBC centrally plan the device market.
- Q8. A further alternative is that manufacturers should be free to develop their own versions of the iPlayer or other technology (known as ‘self-build’) to show BBC content.The BBC Executive do not think this should be allowed because they do not think the BBC would be able to ensure editorial standards or the high quality that viewers expect from the BBC.
What do you think about this?
I agree there should be a free market in devices (commercial or otherwise; software and/or hardware). I believe the BBCs’ role should be to support such a market by investing in industry-standard (i.e. non-discriminatory, royalty-free – W3 and IETF for internet) delivery interfaces.As an example, the BBC at present has an HTML video / CSS based iPlayer – a fully industry standard version, which would work on a wide variety of devices which the BBC does not support at present, such as generic digital TV sets which are internet enabled (but lack Flash, and lack the power for Flash) available from a variety of asian manufacturers. The BBC could trivially make this interface available to all devices, but it chooses to restrict it to Apple iPads, Sony PS3s and a small handful of other types of devices.
If the Trust were to decide the BBC ought not to have such tight-fisted control of device access, then the BBC could tomorrow start the process of enabling much wider access, using standard delivery technology the BBC already has developed.