Age-Related Tv Licence Policy in the Crown Dependencies

AGE-RELATED TV LICENCE POLICY IN THE CROWN DEPENDENCIES

Summary of consultation responses Contents

1. Purpose ...... 3 2. Introduction ...... 3 3. Consultation responses ...... 4 4. Bailiwick of Guernsey ...... 5 5. Bailiwick of Jersey ...... 8 6. Isle of Man ...... 12 7. Conclusion ...... 15

1. Purpose

The BBC held a consultation between 30 July and 10 September 2020 to seek feedback on proposals for age-related licence fee policies in the Bailiwick of Guernsey, Bailiwick of Jersey and the Isle of Man (the Crown Dependencies). This document summarises the responses the BBC received.

2. Introduction

In 2015 the UK Government took the decision to stop funding free licences for over 75s and in 2017 the UK Parliament – through legislation – gave the responsibility to the BBC Board to make the decision on the future of the concession in the UK.

Following a public consultation, the BBC Board decided that, from 1 August 2020, any UK household with someone aged over 75 in receipt of Pension Credit is entitled to a free TV licence paid for by the BBC.

This is the fairest option to help the poorest older pensioners. It is also the fairest option for all licence fee payers as this means everyone will continue to receive the best programmes and services that the BBC can provide.

At the request of each Government, the BBC’s responsibility to determine a concession for older people was extended to the Bailiwicks of Jersey and Guernsey, and to the Isle of Man.

The BBC was required to consult, before deciding what age-related concession, if any, should be in place, funded by the BBC. Each of the Crown Dependencies’ Governments, however, retains its local powers to set and fund welfare benefits including for TV licences, so are able to pay for further concessions should they wish.

While the Crown Dependencies are separate territories with their own system of government, TV licence rules are broadly equivalent to those in the UK.

The consultation documents, published in July 2020, set out the BBC Board’s initial thinking that that it would be fair for the BBC to fund a similar concession for older people in the Crown Dependencies as the UK so that all licence fee payers were treated broadly in the same way.

That would mean that the BBC would fund free TV licences for the poorest pensioners aged over 75 in Jersey, Guernsey and the Isle of Man. To determine who would be eligible for a free TV licence paid for by the BBC, the BBC Board proposed to use existing criteria set by the respective governments wherever possible.

This consultation was an opportunity for people to provide the BBC Board with any information they thought the Board should take into account when making a final decision, especially information specific to the territory concerned.

To raise awareness of the consultation the BBC contacted more than 200 stakeholders across the Crown Dependencies including political stakeholders, age-related charities; veterans charities; disability organisations and debt advice bodies.

The consultation was promoted on BBC Radio Jersey and BBC Radio Guernsey with the BBC’s Controller of Policy conducting interviews on both stations. Local BBC Online also reported the details of the consultation and other local media outlets across the islands were contacted with details at the start and towards the end of the consultation period. In Guernsey, the Government promoted details of the consultation across its social media channels.

The consultation was open on the BBC’s website and paper, audio and braille copies of the consultation documents could be requested via a telephone line.

The consultation was open from Thursday 30 July to Thursday 10 September 2020.

3. Consultation responses

The BBC received 78 consultation responses from across the Crown Dependencies – 63 were from members of the public with a further 15 from stakeholder organisations including the Governments of Guernsey, Jersey and the Isle of Man.

The responses the BBC received are summarised below. As the current arrangements vary between the Bailiwicks of Guernsey and Jersey and the Isle of Man, the summaries are organised by each territory. Each of these are set out in the same way, starting with the current provision in each Crown Dependency; the consultation proposal and the BBC Board’s thinking followed by a summary of responses structured as follows: those indicating support for the BBC Board’s thinking; those indicating disagreement with the BBC Board’s thinking; those making alternative suggestions and; other points raised.

In these summaries, we reference an approximate level of support to provide a point of comparison using a standard set of quantifiers:

• Most • Around half • Just under half • Just over a third • Around a third • Just under a third • Just over a quarter • A small number

The BBC does not routinely publish the responses of individual members of the public, however stakeholder responses, where permission has been given, are published alongside this summary. The BBC Board would like to thank all those who engaged with and responded to the consultation.

4. Bailiwick of Guernsey

Current arrangements:

In Guernsey and Alderney a free TV licence is available to residents over pensionable age (currently 65 years and 2 months) in receipt of income support, and to all those who turned 75 before 1 September 2016.1

The BBC’s power to set age-related concessions for TV licences was extended to the Bailiwick of Guernsey earlier in 2020. Before making this decision the BBC was required to consult. The States of Guernsey retain local powers to set and fund welfare benefits, including for TV licences, so are able to pay for further concessions should they wish.

Consultation proposal:

The BBC Board’s initial thinking, as set out in the consultation document, was that it would be fair for the BBC to fund a similar concession for older people in Guernsey as the UK so that all licence fee payers are treated broadly in the same way. The BBC Board believed that this would be the fairest option – helping the poorest pensioners and protecting those most in need. The Board also believed that this would be the fairest option for all licence fee payers by minimising the impact on services.

In determining its initial thinking for Guernsey and the other Crown Dependencies, the BBC Board considered it helpful and appropriate to apply the three criteria used in its decision in the UK: fairness, financial impact and feasibility.

The Board recognised that while the Bailiwick has its own system of government and circumstances, by convention, the aim is that residents are treated with parity to those in the UK in respect of TV licence rules and BBC provision.

That would mean that the BBC would fund free TV licences for the poorest pensioners aged over 75 in Guernsey and Alderney. Consistent with the UK decision, the BBC did not think it should set welfare policy or determine thresholds of poverty. Rather the Board proposed to use welfare criteria already set by the States of Guernsey to assess eligibility so the BBC would fund a free licence for the sole or main residence of any household where someone is over the age of 75 and in receipt of income support.

The BBC Board’s initial thinking was that such a scheme would not be available to residents in Sark because of the lack of a formal welfare system.

Responses:

The BBC received 23 responses from members of the public and five responses from stakeholder organisations including Government of Guernsey and the Government of Sark.

1 a free TV licence was available to all over 75s until September 2016 when Guernsey’s government (the States of Guernsey) changed the concession policy

Responses supportive of the BBC’s proposal and rationale:

Around a half of responses from members of the public were supportive of the BBC Board’s thinking and agreed that the scheme should protect the poorest by helping those that need it the most. Around half of those were also supportive of the principle of parity with the UK and other Crown Dependencies. A small number also expressed concerns about potential cuts to local services should a broader scheme be offered.

The BBC received five responses from stakeholder organisations, of which two were fully supportive of the Board’s proposal and reasoning. Two did not express a view on the proposals but commented on broader issues.

The submission from the Government of Guernsey agreed with the BBC Board’s thinking, expressing support for the principle of parity with the UK scheme and agreeing that this would ensure fairness in how licence fee payers were treated in the Islands compared with those in the UK. The response stated ‘we have no objection to the BBC Board making a determination that respects these principles’. The response also welcomed the acknowledgement by the BBC that this should not affect the ability of the States of Guernsey to set and fund welfare benefits, including for TV licences in Guernsey and Alderney.

A submission from the Chairman of the Guernsey Alzheimer’s Association also agreed that the proposals were fair and struck the right balance between helping those in need against the use of limited resources for programmes for everyone.

Responses unsupportive of BBC’s proposal and rationale

Just over a quarter of responses from members of the public were unsupportive of the rationale set out in the consultation document. A small number of respondents argued against the scheme on the basis that Guernsey pensioners do not get equivalent welfare benefits to those in the UK and argued that factors such as a higher cost of living on the Island, compared to the UK, should be taken into account. One respondent pointed to a higher life expectancy in Guernsey. Another felt that the proposal failed to take into account the contribution made by those over-75s to funding the BBC through previous licences or acknowledge their broader contribution to society as a whole.

With regard to the island of Alderney, one respondent suggested the Board should consider the demographic make-up of the island and stated that as a higher proportion of the island’s population is over the age of 75 than in the UK – the need for a broader scheme is greater than in the UK.

No responses were received from stakeholder organisations that were expressly unsupportive of the Board’s proposal.

Responses that suggested alternative or additional arrangements:

Just over a third of all respondents made suggestions for alternative schemes. Of these, more than a half suggested limiting the free licence to households where all occupants are over the age of 75; a small number argued for a discount that could be offered to all

6 over-75s; one suggested that the age threshold could be raised to 80 and another argued for preserved rights for those currently in receipt of a free licence and another stated that age should not be used to determine need.

One respondent argued that residents of the island of Sark were unfairly excluded from the scheme as set out by the Board. They suggested that as economic deprivation in the island is high the BBC should consider including the island’s system of means-tested loans as a passport to a free licence for those in need.

This point was also raised by the Government of Sark in their response. The Government requested that the BBC Board consider extending the scheme to include the means- tested system of loans, administered by the island’s Procureur. They also pointed out that Sark is geographically remote location with an older population who depend on the BBC for information and entertainment.

Other issues raised:

A number of other issues were raised by respondents – both those supportive of the proposals and those not. Just over a quarter of respondents mentioned the importance of TV as a means of combating loneliness and a source of information for older people. Just under a quarter also suggested that there should be ways of making it easy for those eligible for a free licence to access one, for example by allowing the BBC direct access to social security records.

A response from U3A, did not express a view on the Board’s initial thinking but did state any reduction in access to educational programming would be “detrimental” to their members and later life learning in general.

Another stakeholder suggested that their members felt the policy would be implemented regardless of the consultation. They sought clarification that those aged over 75 and blind or severely sight impaired but not qualifying for a free licence would be entitled to the 50% blind discount.

5. Bailiwick of Jersey

Current arrangements:

Since 2006 Jersey has had a means-tested benefit scheme which funds the cost of a TV licence for low-income islanders over the age of 75.

The BBC’s power to set age-related concessions for TV licences was extended to the Bailiwick of Jersey earlier in 2020. Before making this decision the BBC was required to consult. The Jersey Government retains local powers to set and fund welfare benefits, including for TV licences, so are able to pay for further concessions should they wish.

The Consultation proposal:

The BBC Board’s initial thinking, as set out in the consultation document, was that it would be fair for the BBC to fund a similar concession for older people in Jersey as the UK so that all licence fee payers are treated broadly in the same way. The BBC Board believed that this would be the fairest option – helping the poorest pensioners and protecting those most in need. The Board also believed that this would be the fairest option for all licence fee payers by minimising the impact on services.

In determining its initial thinking for Jersey and the other Crown Dependencies, the BBC Board considered it helpful and appropriate to apply the three criteria used in its decision in the UK: fairness, financial impact and feasibility.

That would mean that the BBC would fund free TV licences for the poorest pensioners aged over 75 in Jersey. Consistent with the UK decision, the BBC did not think it should set welfare policy or determine thresholds of poverty. Rather the BBC Board proposed to use welfare criteria already set by Jersey’s Government to assess eligibility – namely the existing benefit defined in Jersey legislation for older people in Jersey whose income was below defined thresholds. Under such a policy any such household would qualify for a free TV licence, paid for by the BBC.

Responses

The BBC received 15 responses from members of the public to the consultation and four from stakeholders including the Government of Jersey.

Responses supportive of the BBC’s proposal and rationale:

Just under half of responses from members of the public were supportive of the BBC Board’s initial thinking and agreed that the scheme protects the poorest by helping those that need it. Most of those were also supportive of the principle of parity with the UK and other Crown Dependencies. Around half also expressed concerns about potential cuts to local services or impact on quality.

The BBC received four responses from stakeholder organisations, all of which were broadly supportive of the Board’s initial thinking

In their response, the Government of Jersey stated that they were supportive of the BBC Board’s thinking noting that it was equivalent to the existing scheme currently funded by the Jersey Government and would continue to make an important public service available free to those most in need.2 They agreed with the Board’s assessment (as set out in the Equality Impact Analysis in the consultation document ) that there was unlikely to be any impact on those over the age of 75 as the position of those in receipt of a free licence would not change. They also strongly agreed with the principle of parity with the UK and other Crown Dependencies. ‘Whilst different jurisdictions within the British Isles have slightly different systems, the aim should always be to ensure that all licence fee payers are treated as equally as possible within those systems.’ They noted too that the age threshold of 75 was in keeping with the principle of parity. The submission also agreed that it was not for the BBC to determine poverty or income levels and therefore agreed with the use of Jersey’s existing means-tested benefit system as the passport to a free licence.

The Jersey Government’s response also agreed with the BBC’s financial assessment of the likely cost to the BBC of funding the concession as outlined in the consultation.

They also agreed that the proposal struck a fair balance between the needs of older audiences and the interests of all licence fee payers.

With regard to the transition to the proposed new system, the Government noted that it is working with the BBC to simplify and streamline the process for notifying those eligible for a free licence and would seek to work with the BBC to ensure the measures are in place by the proposed date of implementation – 1 January 2021.

A response from Jersey’s Veterans’ Associations agreed that the proposal would support those most in need and with the principle of parity with the UK, stating that: ‘Any decision therefore by the BBC to fund TV licenses for those mean-tested beyond 75 - given that 75 years of age provides parity with the UK - from a Veterans perspective - is wholeheartedly supported.’

2 The response also noted that the Government Plan 2020-2023 had committed to continue funding for the islands existing means-tested benefit for the duration of the plan (5 years) so the benefit would continue regardless of any decision made by the BBC Board.

A submission from Eyecan, the Jersey Blind Society, also supported the proposal, considering that it would help those most in need engage with the wider world.

Responses unsupportive of BBC’s proposal and rationale

Just over a quarter of responses from members of the public were unsupportive of the Board’s rationale, with a small number of those highlighting the high cost of living in Jersey. One respondent also stated that the licence fee represents poor value for money for Islanders and that other public service and commercial broadcasters offered better content and services.

There were no responses from stakeholder organisations that were expressly unsupportive of the BBC Board’s proposal.

Responses that suggested alternative or additional arrangements:

A small number of responses from members of the public made suggestions for alternative schemes in their submission. Two argued that a discounted scheme for all over-75s would be a fairer system. One respondent stated that there should be free TV licences for all over-75s.

Other issues raised:

A number of other issues were raised by respondents – both those supportive of the proposals and those not.

Just over a third of respondents mentioned the importance of television as a companion and source of information for older people. This point was also raised in all of the stakeholder responses. The response from Jersey’s Veterans’ Associations also mentioned the impact of Covid-19 coupled with the geographical isolation of the Island, suggesting that this had led to an increased risk of loneliness and isolation amongst older people. The current pandemic had also increased reliance on television for essential news and information.

The responses from Jersey’s Veterans’ Associations and Eyecan both raised the importance of television to those living with a disability. Eyecan commented that whilst sight loss would impair enjoyment of TV, it still remained ‘a familiar and comforting source of light, information and enjoyment’. Jersey’s Veterans’ Associations commented that service veterans may face increased disability/mobility issues due to service-related injuries.

Single responses from members of the public also mentioned BBC salaries; an end to the TV licence fee; and the affordability of the TV licence.

One response from a member of the public and one stakeholder response raised concerns about the take up of the scheme and that those eligible for a free licence may miss out. The stakeholder response, whilst agreeing with the principles behind the BBC Board’s thinking, suggested that thought be given to allowing local officials some

10 discretion in administering the scheme by perhaps issuing vouchers to those who may qualify, but be unwilling, to claim income support.

The response from the Jersey Government noted that the BBC’s consultation document included the financial thresholds that the Jersey Government uses to establish eligibility for its means tested benefit It commented that as these are established by statute and linked to income tax thresholds for older people they are subject to updates as tax thresholds are reviewed.

The Jersey Government’s response also noted that if the Government were to decide to extend the benefit to a wider group, or different age range, the costs would need to be met by the Jersey Government. The response also noted that they expected any changes would seek to keep parity with the UK scheme.

6. Isle of Man

Current situation:

In 2002 the Isle of Man Government introduced and paid for free TV licences for those aged 75 or over, mirroring the concession introduced in 2000 by the UK Government to help reduce poverty amongst the oldest pensioners.

The BBC’s power to set age-related concessions for TV licences was extended to the Isle of Man earlier in 2020, at the request of the Isle of Man Government. Before making this decision the BBC was required to consult. The Isle of Man Government retains local powers to set and fund welfare benefits, including for TV licences, so are able to pay for further concessions should they wish.

The Consultation proposal

The BBC Board’s initial thinking, as set out in the consultation document, was that it would be fair for the BBC to fund a similar concession for older people in the Isle of Man as the UK so that all licence fee payers are treated broadly in the same way. The BBC Board believed that this would be the fairest option – helping the poorest pensioners and protecting those most in need. The Board also believed that this would be the fairest option for all licence fee payers by minimising the impact on services.

In determining its initial thinking for the Isle of Man and the other Crown Dependencies, the BBC Board considered it helpful and appropriate to apply the three criteria used in its decision in the UK: fairness, financial impact and feasibility.

The Board recognised that while the Isle of Man has its own system of government and circumstances, by convention, the aim is that residents are treated with parity to those in the UK in respect of TV licence rules and BBC provision.

That would mean that the BBC would fund free TV licences for the poorest pensioners aged over 75 in the Isle of Man. Consistent with the UK decision, the BBC did not think it should set welfare policy or determine thresholds of poverty. Rather the BBC Board proposed to use welfare criteria already set by the Isle of Man Government - Income Support – a means-tested benefit that operated in a similar fashion to Pension Credit in the UK.

Summary of responses:

The BBC received 25 responses from members of the public and a further six from stakeholder organisations including the Isle of Man Government and Age Concern Isle of Man.

Responses supportive of the BBC’s proposal and rationale:

Just under a third of responses received by members of the public were supportive of the BBC Board’s thinking as set out in the consultation document. Most of these agreed that the proposed scheme would protect the poorest and least able to pay. Most responses in support also mentioned that they agreed with the principle of parity of the scheme with the UK and other Crown Dependencies.

One stakeholder response expressed limited and qualified support of the proposed scheme should there be no alternative to free TV licences for all over-75s.

Responses unsupportive of BBC’s proposal and rationale

More than half of the responses from members of the public were unsupportive of the proposals, with most of those responses expressing views that the Isle of Man derives significantly less value from the licence fee than other Crown Dependencies and the UK. The lack of dedicated local services – no dedicated local TV news bulletin or dedicated BBC radio station – was mentioned by most respondents.

This point was also raised in two stakeholder responses – the Isle of Man Government and Jason Moorhouse, MHK. The Isle of Man Government’s response, whilst recognising the fairness of the principle of parity, stated that there were a number of factors specific to the Isle of Man that should be taken into account before the BBC Board makes a decision: the lack of dedicated local services compared to those available in the other Crown Dependencies; and that the BBC’s Royal Charter does not reflect the Isle of Man’s status as a separate nation. The submission notes that discussions have been taking place between the Isle of Man Government and the BBC (delayed due to Covid-19 pandemic) around service provision and the value the Island derives from the licence fee. However, ‘the IOM Government strongly believes that the BBC should fully fund a TV licence concession for all households in the Island with a person aged 75 or over. This would help to address the longstanding deficit in value for money IOM licence fee payers receive from the BBC compared to other licence fee payers.’

A small number of responses from members of the public stated that the proposal failed to take into account the Island’s higher cost of living compared with the UK.

Two stakeholder responses raised points around the affordability of the licence fee for those not on income support – Age Concern Isle of Man and Live at Home. In their response, Age Concern stated that it was a high cost for those on low and fixed incomes. They also stated that many over-75s were living with additional age-related and disability costs (such as additional heating, home help with essential tasks) which reduced disposable incomes. In their view many, who do not qualify for income support, could struggle to meet the costs of a TV licence, suggesting that it could lead to choices between essential services. They expressed particular concern for those who fell just outside of the Isle of Man’s threshold for income support. Live at Home expressed concern that should there be a change in support from the Isle of Man Government this could mean that almost 5,000 householders may have to pay for a licence from 2021.

‘This is of concern to us as a charity that some may have to decide if they can afford to pay for something that is of such importance and this may add to their feelings of isolation and vulnerability that has been exacerbated by the coronavirus pandemic in recent times.’

Two stakeholders commented on the implementation timetable. Age Concern called it ‘unreasonable’ unless it ‘requires no action from older citizens’. Age Concern and Live at Home stated the importance of the BBC having the necessary communication and support channels in place between the Board’s decision and the implementation date. Live at Home suggested an extension to the concession may be required so that the overall concession position can be made clear and that those affected have time to consider the impact on them financially and determine if they need to apply for income support. Both organisations raised points around the potential distress that could be caused to vulnerable people – challenges for those used to receiving a free licence for many years; particular challenges faced by those with cognitive impairment/decline; the risks of non-payment being subject to criminal penalties. Both were also concerned that many of TV Licencing’s processes were internet based and confusing.

Additionally, Age Concern argued against implementing the policy over the Christmas/New Year holiday period – a time of increased loneliness for many.

Age Concern asked for more specificity as to when the Board would make a decision and stated that an ‘Autumn decision’ does not allow time for discussions between the BBC and Isle of Man Government or for the Government to respond.

Age Concern also stated that it was not the BBC’s role to withdraw a benefit that had been extended by the Isle of Man Government. They urged greater consultation between the Isle of Man Government and the BBC before any decision is made.

Responses that suggested alternative or additional arrangements:

Just under half of responses from members of the general public expressly asked for the continuation of a universal concession. Most stakeholder responses also stated that they wished to see the universal concession continue.

Should this not be possible, a small number of responses suggested alternatives. One response from a member of the public suggested a tapered discount scheme starting at the age of 65. One stakeholder suggested the age threshold could be raised to 80. Age Concern argued that the current funding arrangement – whereby the BBC part funds the universal concession - should continue and represented ‘a far more satisfactory way’ of addressing parity between BBC licence fee payers in the Isle of Man and the UK.

Other issues raised:

A number of other issues were raised by respondents – both those supportive of the proposals and those not.

The importance of TV as a companion to older people and as a source of entertainment and essential information was raised by most stakeholders, including Age Concern, the Manx Retirement Association and Jason Moorhouse, MHK, as well as in a small number of responses from members of the public. A small number raised concerns about the potential impact of a change to eligibility may have on loneliness and social isolation, particularly for those with disabilities or reduced mobility. One stakeholder also raised the particular importance of access to information during the Covid-19 pandemic.

Two stakeholders – Age Concern and Live at Home – also mentioned higher rates of digital exclusion amongst the over-75s and increased reliance on television as a source of essential news.

Concern about levels of take up of income support was raised in one response from a member of the public.

Just under a third of responses from members of the public mentioned other ways the BBC should seek to raise or save money – suggesting the BBC takes advertising or other funding means or that BBC salaries are too high.

A small number of responses from members of the public wanted to see an end to the TV licence system.

The Manx Retirement Association also argued that if, as the BBC consultation document states, older people are primary users of BBC content then BBC content should better reflect this, suggesting it reflects much younger age groups.

Two stakeholders had questions about the consultation process. Jason Moorhouse, MHK, strongly questioned the level of promotion of the consultation and the BBC’s engagement with those who would be most impacted by a potential change. Another stakeholder asked for clarification on what formats the consultation documentation had been available in.

7. Conclusion

This document provides a summary of the responses received, which the BBC Board has considered, and the Board would like to thank all those who took the time to engage and respond. These responses have helped to inform the BBC Board’s final decisions in relation to each of the Crown Dependencies. The BBC Board’s final decision can be found here.