Youview Response to the BBC Trust November 2013

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YouView Response to the BBC Trust November 2013

Executive summary

YouView welcomes the opportunity to respond to the BBC Trust review of YouView. YouView exists to enable the evolution of free to air television in the UK. It is an open platform for content providers, and consumers can connect a YouView device via any UK Internet service provider. Devices are available from retailers for a one off cost or from ISPs as part of a phone, broadband and TV package. YouView is different from most other TV platforms because it does not own or retail content, produce devices or enter into contracts with the end consumer. Instead, it enables these relationships on behalf of its partners, which include content owners, ISPs, device manufacturers and retailers. YouView is currently the UK’s fastest growing TV platform, largely as result of the range of content it offers, the fact that it is free at the point of use (unless a consumer decides to pay for additional services), its ease of use and set up and the fact that the two ISP shareholders are subsidising the cost of equipment. Retail sales, though currently small, are an important element of the YouView story and already less than 18 months after launch boxes are readily available for £229 and in some cases less. YouView intends to develop its retail presence further by encouraging manufacturers to bring a range of devices to the market. We believe that YouView has had a major beneficial impact on the UK digital TV market providing the core free to air DTT audience with an easy upgrade path from Freeview. We have preserved the principles of PSB prominence in linear television and extended them into on demand services meaning that PSB content is readily and easily discoverable for consumers. This has been achieved by considerable investment in the design of the interface and also by investment in common metadata standards which allow for aggregated search and browse across the full catalogue of content available on YouView. Taken together these will help ensure universality of delivery for the PSB services as they push into new forms of delivery. We also believe that we have achieved market leading parental controls meaning that YouView is a safe environment for families and are well on the way to achieving market leading accessibility provisions. We believe that a purely commercial player in this market would not invest to the same extent that YouView has, and continues to invest, in these areas. In this Response we make specific comments concerning areas in which YouView has direct control (access and sign posting) as well as control provisions relating to syndication in the YouView Shareholders’ Agreement which were proposed at the time of BBC Trust approval. We also address the issue of BBC cross promotion as requested by the Trust. On accessibility, YouView is delighted to have the opportunity to work closely with a range of organisations (including the BBC Trust) to develop the requirements of the platform which extend beyond those proposed at the time of the original proposal. We believe that the relationships we have fostered with these organisations, and the principle of “accessibility first” we have engendered in all aspects of the YouView product development, have enshrined a culture of accessibility awareness which will extend beyond the specific terms of approval. In our Response we summarise the nature of our engagement with third parties our specific accessibility functions, the future development plans for our roadmap and some of the issues we have encountered en route.

We acknowledge that the timetable for implementation of accessibility features extends beyond that initially agreed with the Trust, but we believe all parties recognise the additional work undertaken by YouView, particularly to explore the most appropriate features and then consequently the need to work with third party manufacturers to drive software into devices. YouView does not directly contract for content but enables any content provider to run services across the YouView platform using any business model. We currently provide the full range of PSB on demand players as well as a range of services from commercial providers. As YouView does not control access to programme rights we believe we have increased the distribution of shareholder content and have had an overall positive impact on the distribution of content to consumers. We believe our signposting of content is market leading in linear television and at least as good as other devices for on demand content. This is an area we are constantly reviewing to ensure we provide the best viewing experience possible. In terms of the application of the BBC’s cross promotion code, we think the BBC should go considerably further in promoting YouView to licence payers and this could happen within the rules of the current code. We are happy to elaborate on any points contained within this submission.

1. YouView Accessibility Features

Overview Further to the BBC Trust requirements, YouView scoped its post-launch delivery through expert advice on user need. YouView has reviewed the BBC Trusts' accessibility requirements for YouView in light of the advances in technology since 2009 and the capability of the YouView UI and device (which was unknown in 2009). To understand user needs and to validate our approach, product requirements and design YouView has engaged with key industry organisations, including RNIB, British Dyslexia Association, British Telecommunications plc (BT), BBC and Scope. Engagement with these organisations included: • reviewing requirements and interaction designs with the RNIB, both via email and face-to-face meetings; • access to expert consultants from the RNIB to conduct reviews and advise on design changes and improvements; • demonstrations of products the RNIB endorse, with discussion (e.g. Goodmans set top box); • in-depth sessions with experts at the BBC across all areas of the proposed delivery; • reviews of requirements and products (e.g. Text to Speech capability) with experts at BBC, BT and RNIB; • workshop with Scope regarding how keyboards, games controllers and on-screen remote could most usefully work for a user with motor dysfunction; • trialling of YouView’s keyboard and on-screen remote with users and expert technologists at Scope’s Beaumont College, the learning centre for people with a broad range of physical and learning disabilities; and • identification of third parties that might be interested in using YouView APIs to develop applications for accessibility use. This engagement resulted in YouView proposing a revised list of deliverables, which delivered the desired end results for the BBC Trust through bringing real benefits to users with accessibility needs. This approach was reviewed with both the BBC and BBC Trust.

Deliverables User Benefit Deliverable Delivered by Dec 2013 Improve zoom to allow a visually impaired Additional functionality to P users to browse the UI whilst still in a zoomed enable interaction with UI state when in zoom

Ability to change the colour scheme of the Setting for alternative high P YouView UI for users with colour perception visibility colour scheme issues or who are visually impaired

Ability to remove moving images when the UI is Setting to turn off moving P invoked to allow users with ADHD to more images (keep audio) when easily navigate YouView UI invoked

Audio feedback to confirm key presses on RCU Audio Feedback – to Help P for key accessibility buttons e.g. AD button for Scheme specification blind or visually impaired users

An accessible YouView companion application Accessible YouView App: for smartphones for blind and visually impaired Delivering ‘discover-to- users: play’ audible user journeys

• High visibility interface P

• Enable user to complete high-value end-to- (Planned for 2014) end journeys without need for standard remote control • Text-to-speech enabled via app integrating P with mobile platform screen-reader functionality e.g. VoiceOver for iOS

Support ability for an intermediate device Enable third party device displaying an ‘onscreen keyboard or RCU’ to to emulate YouView RCU work with Switch devices to control YouView key presses, supporting box: an onscreen keyboard / RCU for use with Switch • This is likely to be through the publication of device P an API or specification to emulate RCU key presses

Support for the most commonly used USB- Enable a USB keyboard to devices that are able to navigate the YouView work with YouView device UI e.g. keyboards, for users with moderate motor skills impairment:

• RCU controls can be mapped onto keyboard P to remove need for RCU

A plan and proposed toolkit for third parties Define relevant and wanting to create accessible services for the appropriate ‘toolkit’ for YouView platform, based on demand and ability third parties wanting to for YouView to deliver without breaching create accessible commercial requirements (e.g. access to MAS): YouView services

• The APIs required to be defined through P further interaction with wider industry

Design principles

YouView has adopted the following design principles to deliver these requirements: • provide solutions for a wide range of accessibility needs: - address the accessibility needs of different groups from the visually and audibly impaired through to those with cognitive and motor skills impairment; • design these solutions through on-going collaboration with experts at the relevant organisations: - blind and visually impaired (RNIB); - deaf and hearing impaired (RNID); - physically disabled (Scope); - motor skills impaired (and cognitive disability) (Scope); and - learning, cognitive and developmental disorders (e.g. the British Dyslexic Association); • adopt a companion screen focused approach, delivering access for a wider group of accessibility needs in a shorter timeframe: - most cost and time efficient approach; - utilise existing development on mobile platforms to deliver better accessibility for blind, partially sighted and users with motor skills impairment; - develop around devices, or software, that users may already be using in home e.g. Grid2 software on PC’s for use with Switch devices; and - YouView will lead delivery, as opposed to supporting a third party, to ensure a high quality end-to-end journeys; and • update and enhance the existing YouView device UI as appropriate to make as accessible as possible, while incorporating accessibility as a design principle for all future development: - e.g. ensure the UI can be made as legible as possible, review error messages that block journeys and so on.

Feature rollout

The detailed scoping of accessibility features has taken more time and required consultation than anticipated. We believe this was worth it. Throughout this process, YouView has worked closely with the OEMs to encourage their implementation of these features, all of which are at their cost. YouView’s revised accessibility releases for the remainder of 2013 are as follows: • December 2013 - Support keyboards as alternative to remote control NB: Now fully supported - Support intermediate device displaying an on-screen keyboard and RCU to work with switch devices - Interactive zoom - Audio Feedback NB: Now included, having been previously blocked by a YouView OEM partner - Plan to develop toolkit of APIs for use by third parties who wish to build alternative second screen experiences for the accessibility market

• Roll-out across YouView’s manufacturing partners - In the above timelines these accessibility features will be available on retail devices. - BT/Humax are likely to release all of the above in January and TTG/Huawei devices are to be confirmed, but Q1 2014 is probable.

The approach and timing to deliver the remaining mobile accessibility requirements will be subject to feedback from the BBC Trust. YouView is currently in consultation with the BBC.

YouView compared with other platforms Overall, the various features that YouView has now invested in incorporating are at least comparable to and in some cases exceed such functionality of other TV platforms in the UK.

Features YouView Sky Virgin Media Freesat • Subtitles and AD P P P P • Alternative colour P û Partial P û scheme but only on V+ - being phased out with TiVo • Text to speech P P P û 2nd screen app Sky Talker 2nd screen app • Accessible P Partial P P û Companion app NB: lacks TTS integration • Accessible font P û û û • Audio feedback P Partial P P û limited • Zoom P û û û • Alternate UI P û û û • On-screen keyboard P û P û for use with switch or but not a mobile application compatible with with TTS keyboard Switch - requires RCU

Uptake among groups with disabilities YouView does not retail set-top boxes directly to consumers. That being the case, YouView does not have formal mechanisms in place through which it measures uptake levels or user satisfaction. YouView has worked with the RNIB and Scope to carry out some initial user testing (in October 2013), and is commissioning a formal user trial at the end of 2013 when the full functionality will be available. Visually impaired triallists for the RNIB conducted reviews of the box itself, with the inclusion of the alternative high contrast user interface, and also for the YouView Text to Speech app. The reviews were positive, and also included helpful feedback where further improvements can be made, a lot of which are included in the software upgrade coming in December of this year.

“Generally speaking this box has many great features many of which can be found on other subscription boxes. In terms of accessibility, it has the potential to be a cut above the rest if the zoom feature was fixed particularly and a few minor changes to the positioning of content as stated above. Having said that, I think the high contrast option is worth its weight in gold and will be upgrading my current BT Vision + box to this.” Reviewer with Aniridia, October 2013

Scope has also tested the effectiveness of the Grid 2 software implementation for YouView. This allows those with motor skills disabilities to control the YouView box via a different access devices. Working with students at Beaumont College, Scope tested the effectiveness of YouView’s Grid2 implementation with 4 different access methods – touchscreens, switch devices, a head mouse and a joystick. When asked if they could see themselves using the YouView grid at home, responses included:

"Yes, I can do it independently, I don't have to shout anyone to come and help me",

"Yes because it would make me more independent",

"Yes it's easier than a remote".

Although we do not collect statistics concerning uptake or satisfaction, we are encouraged by the above comments. We believe that these examples suggest that uptake among groups with disabilities is likely to be high with strong levels of satisfaction.

Future roadmap

Integrated Text to Speech YouView is engaging with device manufacturers to create a generic capability to mix a local audio source which could also mix in locally generated speech audio. However, to enable this there would be work to be done on YouView's side in terms of technical work to be delivered, commercial rationale and product / user experience, as follows:

• From a technical perspective: - time / investment to identify the possible solutions for speech synthesis on the device and to determine the their suitability for YouView, which includes:

§ the memory and processing power required with an eye on the first generation of memory starved devices;

§ the output audio format in relation to the local mix capability being developed (as above);

§ how we might surface this capability to the YouView UI (and possibly CP applications); and

§ the quality/suitability of the speech itself.

• From a business / commercial perspective:

- the size of the opportunity (ROI) of investing in TTS, to be agreed by all 7 shareholders;

- the opportunity cost of committing this into delivery (cost versus uptake) for YouView and its OEMs;

- whether any other YouView roadmap features are impacted in terms of deliverability by adding an on-device capability. Once a solution had been identified, further commercial issues would need to be resolved relating to who would pay per device royalty (if any).

• From a product perspective: - the benefit over TTS via second-screen, - the benefit if only the YouView UI (and not CP apps) was TTS enabled - the level of change required to the UI or navigational paradigms to exploit the speech synthesis capability across the YouView UI (how much work, and when this could be done in conjunction to the rest of the roadmap).

Second Screen YouView plans to continue to develop its mobile application to incorporate remote control functionality and beyond, all of which shall be accessible and voice enabled.

User Interface Enhancements Following YouView’s accessibility trials, to be conducted in December, any improvements proposed by triallists to make the overall YouView experience more accessible will be reviewed and prioritised along with all other proposed features and upgrades. As such, accessibility requirements will remain an intrinsic part of YouView’s product development process.

Consumer and Industry Feedback YouView is open to feedback on ways to further refine our accessibility features for the benefit of our users. We maintain a forum where users are encouraged to make comments on the functionality of our platform. We also have good on-going relationships with key industry organisations and we welcome feedback from these organisations.

2. Impact on Content Syndication Platform access

Background

YouView believes that it has had a beneficial impact on the distribution of shareholder content by providing an easy to use, free to air service which enshrines the principle of PSB prominence in its listing policies.

We see no impact of YouView on the appetite of shareholders to syndicate their content widely in the market as we have no commercial relationship in the purchasing or syndication of that content. YouView’s role is confined to ensuring that all content listed on the platform is easy to discover and view.

Since YouView’s launch shareholders agreed distribution of content on a range of platform and YouView is not the only platform on which all PSB content (both linear and on demand) is available.

Company Objectives Since its incorporation in September 2010, YouView’s Articles of Association have required it to ensure that access to listings on the EPG is “on a fair, reasonable and non-discriminatory basis” (Article 2.9). YouView has met this obligation and continues to do so.

TLCS Licence In 2013, YouView obtained a TLCS Licence from Ofcom for its EPG. The TLCS licence stipulates that YouView must (amongst other things) “not enter into or maintain any arrangement, or engage in any practice, which is prejudicial to the fair and effective competition in the provision of licensed services or of connected services.”

EPG Listings and UI Positions on YouView:

DTT YouView is not responsible for allocating logical channel numbers ("LCNs") to channels broadcast using DTT; this is the responsibility of Digital UK Limited. YouView reproduces in the "Guide" section of its UI the ordering and numbering of DTT channels as they appear on the DTT platform.

On Demand and IP-Delivered Channels YouView currently allocates:

§ UI positions to on demand portal players (“On Demand Players”); and

§ LCNs to IP-delivered linear channels.

The User Interface and Search Policy In September 2011, YouView published for consultation a draft User Interface and Search Policy (the “Policy”) setting out YouView’s approach to allocating positions to content providers in the YouView UI. Following two rounds of consultation, YouView received input from a wide range of companies and individuals, including Sky, Virgin, LoveFilm, UKTV and members of the general public. YouView implemented the Policy on 25 May 2012.

A copy of the final version of the Policy is available at: https://industry.youview.com/pages/content/ui-policy/.

Allocation of UI Positions and LCNs The Policy was developed with reference to the principles set out in the Ofcom Code of Practice on Electronic Programme Guides. The overriding objective of the Policy is to ensure that LCNs, UI positions and search results are awarded on a fair, reasonable and non-discriminatory basis.

The allocation of listing positions and UI positions and the configuration of search results is undertaken without regard to whether the content provider is a YouView shareholder. Where a YouView shareholder who is also a content provider is awarded a listing or a UI position, the basis for such award must be objectively justifiable, having regard to the principles of fairness, reasonableness and non-discrimination on which all UI positions will be awarded. The ordering of search results must also be objectively justifiable, again having regard to the principles of fairness, reasonableness and non-discrimination.

Example - Sports Channel Allocation Prior to IP channel launch, two competing sports channel providers sought to be awarded LCNs for their channels. One of the channel providers was a YouView shareholder. A more prominent LCN position was awarded to the non-YouView shareholders’ channels, as the allocation was based upon the fair, reasonable and non-discriminatory principles set out in the Policy.

Amendments to the Policy As YouView has developed, amendments have been required to the Policy to cover new services. Substantive amendments to the Policy have been subject to industry and public consultation with the aim of maintaining fair and equal access to the platform and a non- discriminatory approach to EPG listing.

The launch of IP-delivered channels required a substantive amendment to the Policy. In accordance with the above process, YouView published for consultation a draft User Interface and Search Policy covering the listing of IP-delivered channels on 10 September 2012. Following consultation, the draft policy was revised and then made available for further short consultation on 3 December 2012. The final Policy covering the listing of IP- delivered channels was made available on 8 February 2013.

The two versions of the Policy were consolidated on 7 August 2013.

Cost-recovery basis

The Shareholders’ Agreement requires that YouView is delivered on a cost-recovery basis. YouView continues to operate on this basis and the rate cards in operation comply with the Shareholders’ Agreement. Provision of a wide range of content and services

There is a wide range of content available via YouView through On Demand Players and IP- delivered linear channels (of which there are currently over 75). YouView is continuing to add new on demand players and channels and to work with content providers to facilitate greater growth. The uptake in IP-delivered linear channels has been particularly impressive, and the range of content available on the platform continues to increase, providing greater choice for consumers.

On Demand Players

YouView offers content providers the chance to make available On Demand Players to users. At the time of writing, the on demand content providers that have entered agreements with YouView to make their content available on demand are:

• BBC iPlayer (BBC); • BT Vision (BT); • 4OD (Channel 4); • Demand 5 (Channel 5); • Dave (UKTV); • ITV Player (ITV); • milkshake! (Channel 5); • Now TV (BSkyB); • STV Player (STV); • TalkTalk TV (TalkTalk); and • TVX Player (Portland Broadcasting).

IP-Delivered Linear Channels

IP-delivered linear channels are services listed in the “Guide” section of the YouView UI. It is encouraging that a wide range of channel providers have been allocated LCNs - a current total of 80 – with plans for a further 24 channels to be carried by the end of 2013. For a full list of channels and channel providers, please see the Appendix.

YouView Services

Through contractual relationships with affiliate ISPs and set-top box manufacturers, YouView provides a range of services to enable content to be made available via the YouView platform, whether this is listed in the EPG or via On Demand Portals.

YouView also offers services which content providers can use to assist viewers to discover content more easily. Such services include the backwards EPG, the search function, filters, MyView and our mobile application.

3. Appropriate Sign-Posting

The YouView user interface was designed to deliver concise information on any film or programme, whether related to that content’s rating, accessibility attributes or programme information, within one click of the remote control.

YouView has adopted industry standard sign-posting and related processes for linear, and is best in class in relation to VOD. This includes the development of cross-platform parental controls that can be set to meet the individual user’s requirements, resulting in a consistent user experience, regardless of content provider.

Compliance with YouView’s standards are mandatory for all content providers and include a consistent YouView “look and feel” to reassure consumers. This extends across all YouView devices and its mobile application. Linear Content YouView uses metadata provided by broadcasters to populate channels and programmes in the TV Guide.

In addition to metadata received over the air, YouView’s content partners can enhance linear programmes with additional ‘enhanced metadata’. This includes content ratings and programme attributes, such as subtitles or sign language.

Users can easily access information about any programme in the YouView UI by pressing the i button on the remote control to open the ‘Action Panel’. The Action Panel includes:

• Full guidance text and guidance iconography • Content rating (if supplied) • Iconography for programme attributes: • Including Sign Language, Subtitles, Audio Description, Surround Sound and High Definition. • Iconography is supported by accompanying text on the Action Panel Details tab.

In addition to the Action panel, YouView also present the (G) icon to indicate the presence of Guidance Text in the following areas: • Linear search results. • MyView Recordings. • MyView Scheduled Recordings.

Action Panel: Programme information including Guidance Text and Icon

Action Panel: Detail View including programme attributes

Linear search results: Guidance Icon displayed

On Demand Content On demand content providers must supply enhanced metadata with each on demand asset, including a mandatory content rating. YouView has three rating schemes to support Content Providers compliance processes: - The Denton rating scheme, indicating Guidance or Watershed - A BBFC-style rating scheme for film content. - A YouView rating scheme offering age restrictions.

YouView presents BBFC-style ratings within the UI to help users identify the suitability of content. If a content provider opts to rate content using either the Denton or YouView scheme, then YouView business rules mandate that content providers supply Guidance Text to inform users why the content may not be suitable for all audiences. BBFC-style ratings and Guidance Text iconography is displayed in the following areas of the YouView:

- On Demand – in the single and double carousels, and in series roll up pages. - On Demand Search - In the Action Panel, including in ‘More Episode’ tiles

In addition to ratings information, YouView also indicate whether a piece of on demand content is: - Free to view - Available with subscription - Available to rent

On Demand Single Carousel: Content rating displayed

On Demand Double Carousel: Guidance Text icon displayed

Parental Controls YouView has a platform wide parental control system, allowing users to restrict access to programmes across YouView. Users can enable parental controls during the YouView set up process, and can configure the level of protection in settings. Users can restrict access to: - Recordings made after the watershed (between 21:00 and 05:30). - Rated On Demand content. - Channels in the TV Guide, by securely hiding these using the PIN - Mandatory PIN protection is applied to linear premium subscription film services whenever a 15-rated film is broadcast between 05:30 and 20:00.

MyView Recordings: PIN required for playback, Guidance Icon displayed

Adult Content

By default, YouView parental controls restrict access to browse Adult On Demand content. Users can customise parental controls to hide Adult On Demand content. Linear adult channels can be securely hidden in the TV Guide using the YouView PIN. Additionally, the Adult channel filter in the Guide can be hidden through YouView settings.

YouView does not include adult content in search results or search suggestions.

The YouView Mobile Application The YouView mobile application provides a similar level of signposting to the YouView set top box. For instance:

• the programme information page includes iconography for all airing attributes (based on CP supplied metadata);

• platform text-to-speech engines (e.g. VoiceOver) have been configured to read the full attribute (e.g. “Audio Description Available”, rather than the abbreviated icon [AD]); and

• search results display programme attributes, for example indicating whether a programme has Audio Description, Subtitles or Sign Language available.

YouView App: Subtitles and Audio Description

YouView App: Subtitles and Content Rating

YouView App: Search Results Showing Programme Attributes

YouView Guidelines for Content Provider Players

In addition to YouView’s own UI, YouView mandate certain behaviours within a content provider’s player to ensure users receive a consistent and informed experience: - content providers must use YouView APIs to determine whether parental controls have been enabled, and present the YouView PIN challenge as required:

§ where a payment PIN is also required, this can also be used to validate parental controls; - content providers can use YouView APIs to provide users with the most relevant content where available;

§ for example, presenting a signed or audio described version of a programme where available; - the Action Panel within a content provider application must include a rating or Guidance text when applicable, and programme attributes including AD, Subtitles and Sign Language must be shown; and - accurate pricing must be displayed within the player.

Future roadmap YouView will continue to improve its sign-posting, through responding to consumer feedback. Future enhancements are likely to include the ability for a user to more easily identify programmes or films that are free or that they have already subscribed to.

4. The BBC cross-promotional code

YouView exists to enable the evolution of free to air television in the UK. It is an open platform for content providers and consumers can connect a YouView device via any UK Internet service provider. Devices are available from retailers for a one off cost or from ISPs as part of a phone, broadband and TV package. YouView is different from most other TV platforms: it doesn’t own or retail content, produce devices or enter into contracts with the end consumer. Instead, it enables these relationships on behalf of its partners, which include content owners, ISPs, device manufacturers and retailers. Since inception, the YouView shareholders have tasked YouView with building a brand and raising awareness of the product with consumers. Significant amounts of shareholder funding have been invested in promoting the YouView service to end consumers. This funding has been augmented by more direct “call to action” promotion from ISP shareholders and also with a degree of on-air and digital promotional activity by YouView’s commercial PSB partners. There has been no direct promotion of YouView on any BBC service either on-air or on-line (although there were references to YouView in the BBC’s generic “get connected” campaign earlier this year). In this sense, the BBC is the exception amongst the YouView shareholders with consumer facing businesses. The YouView shareholders set YouView’s marketing budget on the presumption that shareholders would contribute, as far as regulations allow, complementary marketing to bring the service to the attention of consumers. This has by and large happened but not on BBC services. The BBC code on cross promotion recognises that:

The BBC has a specific Public Purpose to take a leading role in the switchover to digital television ("digital TV"). The BBC has an important role to play in this respect and can influence significantly the penetration, uptake and usage of digital platforms and services. The Trust recognises the benefits that trailing can bring in promoting this Public Purpose.

Given that digital switch over is now complete the next phase in television evolution is to connected devices with services such as those provided by YouView to maintain the universality of BBC services (both linear and on demand). This is one of the reasons why the BBC decided to invest licence payers money in creating YouView. Given the significance of the entry of YouView into the digital television market and the fact that licence payers’ funds have been partially used to support the development and launch of YouView we believe that the BBC could go significantly further in its promotion of YouView and still remain within the strictures of the BBC cross-promotion code and the undertakings given to the OFT by the BBC. The code defines major digital TV platforms as those having more than 500,000 users. YouView has had more than 500,000 users since the summer of 2013 and is currently the fastest growing TV platform in the UK. Under the code definition, YouView now qualifies as a major digital platform. On this basis, we believe that the BBC could and should do more to bring YouView’s services to the attention of consumers. This is particularly the case since YouView has been explicitly designed to bring next generation television services to the free to air television audience while maintaining principles of PSB prominence and free access to the full range of services from the UK’s PSBs.

We believe that we offer a natural upgrade path from Freeview to consumers and that it is therefore consistent with the BBC’s remit to promote the availability of YouView’s services alongside other digital TV services.

Our commercial PSB shareholders have been able to provide a significantly greater degree of cross-promotional support, within the rules of the Ofcom codes, than the BBC has felt able to do. This seems counter intuitive to us and as a result, we believe that the cross- promotional code is not working effectively in relation to YouView and that the BBC is interpreting the code conservatively. In our view, there is a clear benefit to licence fee payers in being made aware of this new venture, which offers seamless access to free to air services, and in which they have invested.

Appendix – List of IP Linear Channels

Channel Provider Channel Channel Provider Channel Fox International Fox UK Channel Watch Channels Management / UK Fox HD Gold Services / UKTV New Ventures NGC Europe Limited National Geographic Gold Channel Alibi Nat Geo Wild Good Food Nat Geo HD Home Nat Geo WILD HD Eden

Sci Fi Channel Europe SyFy BT BT Sport 1 SyFy HD BT Sport 2 NBC Universal Global Universal Channel BT Sport 1 HD Network UK BT Sport HD 2 E Entertainment UK E! ESPN

The Walt Disney Disney Channel ESPN HD Company Eurosport SAS British Eurosport Disney Junior British Eurosport 2 Disney XD

BSkyB Sky 1 AETN UK History Sky 2 Crime and Investigation Sky Living Network Sky Livingit History HD Sky Arts 1 Crime and Sky Arts 2 Investigation Sky Sports 1 Network HD Sky Sports 2 Sky Sports 3 Turner Broadcasting Cartoon Network Sky Sports 4 System Europe Sky Sports F1 Boomerang Sky Sports News Turner Classic Sky Movies Movies Premiere Cartoonito Sky Movies Action &

Discovery Discovery Channel Adventure Communications Sky Movies / Disney Europe Sky Movies TLC Showcase Animal Planet Sky Movies Family Discovery Home and Sky Movies Comedy Health Sky Movies Sci Fi & Horror Nickelodeon Nickelodeon Sky Movies Greats Nick Jr Sky Movies Crime & MTV Networks Europe MTV Thriller MTV Music Sky Movies Select MTV Base Sky Movies Drama & MTV Hits Romance MTV Dance MTV Rocks Asia TV Ltd Zee TV

MTV Classic Star India Private Ltd Star Plus MTV HD Star Gold

The Paramount UK Comedy Central Star Life Partnership Star Jalsha Comedy Central Extra Comedy Central HD