BBC iPlayer Pre-booking functionality Explanatory Note - Issued November 2008
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BBC iPlayer Pre-booking functionality
Explanatory Note
Issued November 2008
1The Trust’s decision
After a 28 day public consultation, the BBC Trust has decided to approve BBC
management plans for the addition of pre-booking functionality to the BBC iPlayer. Pre-
booking will allow users to select programmes from the iPlayer schedule up to 7 days in
advance and download them for viewing on their home computer. The Trust has also
asked BBC management to report reach and usage data for pre-booking six months after
pre-booking is launched on the BBC iPlayer. The Trust will make a public statement after it
has considered the impact of this on the BBC iPlayer’s reach and usage.
Background
On 30 April 2007, the BBC Trust approved BBC management’s proposals for on-demand
services with some modifications after subjecting them to a Public Value Test. For
example, the Trust rejected some types of downloads, such as classical music and
audiobooks. In its approval the Trust set out the scope of this new service as part of the
Service Licence for bbc.co.uk. The scope of the on-demand service included provision for
a seven day catch up service including series stacking, now launched in the form of the
BBC’s iPlayer. The scope of the service, based on BBC management’s application at the
time, did not include pre-booking functionality.
In May this year, BBC management sought the Trust’s approval to amend the terms of the
licence to include a pre-booking facility. The Trust did not consider this change to be
significant to the extent that a Public Value Test was necessary, but it wanted to provide
third parties the opportunity to express an opinion. The Trust decided therefore to hold a
28 day public consultation about BBC management's proposal to add pre-booking
functionality to the BBC iPlayer and launched this on 30 June 2008.
The consultation closed on 28 July 2008. We received two responses which we are
publishing in full with their permission (see Annex B and C). In light of the consultation,
we raised further questions with BBC management and we are publishing their response
at Annex A.
This Explanatory Note sets out the reasoning behind the Trust's decision to approve the
addition of pre-booking functionality to the BBC iPlayer. It also sets out why the Trust
does not consider that this new feature constitutes a significant change to the BBC's UK
Public Services and why it followed the process it did to reach its decision.
2How the Trust has arrived at its decision
If the Trust decides that a proposed change to a UK public service provided by the BBC is
a ‘significant change’, it can decide to launch a formal Public Value Test (PVT) assessment
to ensure the public value obtained by such a change is not outweighed by any negative
market impact. The Trust has decided that the addition of pre-booking to iPlayer is not a
significant change. In arriving at this conclusion, the Trust has taken account of the four
considerations set out in clause 25(2) of the Framework Agreement, as detailed below:
Financial implications
The Trust has considered the financial implications of the proposal and decided they are
not significant and the cost is low. As provided in BBC management's proposal, the BBC's
downloading costs are fixed and BBC management consider that the BBC will not
therefore incur further downloading costs as a result of introducing the pre-booking
functionality. As regards software development and roll out costs, BBC management has
clarified that the physical infrastructure used for pre-booking is the same as for the BBC
iPlayer and the only additional cost to implement pre-booking is approximately £30,000
The financial implications are therefore not significant.
Novelty
There is virtually no novelty in pre-booking, a feature that has been widely implemented
on other platforms for some time. Pre-booking is simply an additional feature of the BBC
iPlayer which allows users to pre-select a programme for download, currently up to 7
days in advance of broadcast. Although this is new functionality for the BBC iPlayer, it is
not in and of itself novel when compared to other services available in the wider market.
Duration
The duration of the pre-booking functionality on the BBC iPlayer will, in principle, be
unlimited. However, this alone does not mean it is a significant change, taking account of
the other factors that we have set out.
Impact
Based on the information provided in BBC management's proposal, the further
information provided by BBC management, and taking into account the issues raised by
the respondents to the public consultation (set out below), we consider that the likely
impact of pre-booking functionality is limited. The Trust considered, but rejected
requesting a trial to establish usage and reach data because the costs involved
outweighed those of implementing the service. However, owing to the inherent lack of
data available in advance of launching this new functionality, we have asked BBC
management to return to the Trust six months after launch to provide further usage and
reach data in order for the Trust to review impact at that time.
3Conclusion
Having taken into account the above considerations and the points raised during the
consultation the Trust has approved the the addition of the pre-booking functionality to the
BBC iPlayer. The Trust does not consider this constitutes a significant change to the BBC’s
UK public services. In arriving at this decision, the Trust has also borne in mind its duties
under the Charter and Agreement as well as regulatory requirements in considering BBC
management’s application.
We have requested additional information on the impact of pre-booking when this is
available. To that end we have asked BBC management to report to us six months after
the feature is launched on the BBC iPlayer with information on reach and usage. The Trust
will consider this information and make a public statement at that time.
Key points arising during the public consultation
The two responses that we received during the public consultation differed in terms of
their support for the BBC iPlayer pre-booking functionality. One of the respondents, the
Audience Council for Wales, was supportive of the proposal and considered that it will
increase value for money and will mean the BBC iPlayer provides a function available on
other internet catch-up services. The other respondent, British Sky Broadcasting (“Sky”),
queried the proposal as it currently stands and on the basis of the information provided
by BBC management.
In this part of the Explanatory Note we provide details of how we have considered the
relevant key points raised during this consultation, primarily by Sky. However, this
Explanatory Note is not intended to address every point raised by the two Respondents.
We also refer to BBC management's responses to further questions that were submitted by
the Trust. BBC management's responses are also set out in Annex A to this Explanatory
Note.
1. Access to pre-booking functionality by third party providers of BBC on-demand
content
Sky queried whether the addition of the pre-booking functionality to BBC iPlayer should
be subject to specific requirements on the BBC to "facilitate the simultaneous launch of the
pre-booking functionality on other services and platforms which distribute BBC on-
demand content." Sky also queried the responsibility of the BBC to support the
introduction of pre-booking functionality on other platforms and services that distribute
BBC content, for example, through the provision of advance BBC schedules and
programme assets.
With reference to BBC management's proposal, the pre-booking function is only
proposed in respect of the BBC iPlayer internet offering, as opposed to on-demand
4content provided over cable television where audiences with DVR technology will have
access to very similar functionality.
The syndication of BBC iPlayer content is primarily through links back to the BBC iPlayer
and only in certain cases are partners permitted to host and serve BBC assets (when a
partner is unable to link to BBC services, for example). Consequently, the BBC does not
currently syndicate the functionality of iPlayer (as distinct from the content within it) on
third party websites. BBC management has, however, recognised that it may be beneficial
to licence fee payers to make pre-transmission BBC content available to syndication
partners. We expect BBC management to comply with the Syndication Policy and
guidelines in this respect.
As to whether the BBC is required to provide links to pre-transmission BBC content at the
same time as it launches the pre-booking function on iPlayer, we do not consider it
necessary to delay introducing pre-booking on the BBC iPlayer until such links can be
provided to syndication partners. The Trust has reached this position taking into account
the public value in offering pre-booking on iPlayer as soon as possible, that syndication
arrangements are the subject of commercial negotiations between the Executive and third
parties, the expectation that the likely impact of the pre-booking functionality on third
parties that syndicate BBC on-demand content will be limited (see below) and the absence
of evidence of any negative market impact caused by the introduction of the pre-booking
functionality on the BBC iPlayer submitted in response to our consultation. The Trust does,
however, expect the BBC to comply with the Syndication Policy and syndication guidelines
and continues to monitor syndication arrangements by way of six monthly updates from
the Executive.
2. Usage and reach of the BBC iPlayer pre-booking functionality
Sky also requested information as to the current usage and reach of the BBC iPlayer, as
compared with the BBC’s previous projections, and how the usage and reach will
increase as a result of the addition of the pre-booking functionality. Further, Sky raised
concerns that the proposal fails to consider the impact that pre-booking would have on
the use of the BBC iPlayer by consumers and consequently the impact on third party
platforms and services that syndicate BBC on-demand content and, more broadly, other
relevant markets. Relevant markets are taken to be DVDs and other VOD services as
referred to in BBC management's proposal.
We submitted further questions to BBC management as to the anticipated effect of pre-
booking on the reach and usage of the BBC iPlayer. BBC management's view is that pre-
booking is more likely to increase usage of downloads via BBC iPlayer in terms of viewer
hours than to increase the number of consumers actually using the BBC iPlayer (i.e.
reach). Indicative figures provided by BBC management as to the current usage of BBC
iPlayer as against original projections provided as part of the iPlayer PVT application
show that usage is about half that expected. BBC management therefore consider that a
5small increase in the usage of downloads via BBC iPlayer, as a result of the pre-booking
functionality, is unlikely to result in the original BBC iPlayer projections being exceeded.
Further, BBC management consider that since pre-booking does not add to the reach of
the BBC iPlayer, it is unlikely that suppliers of broadcast, cable and satellite services will
be affected, any impact on the sales of PVRs is likely to be minimal, and it will not lead to
diversion from other relevant markets. Since BBC management consider that pre-booking
does not add to the reach of iPlayer, our expectation is that the impact on the current
syndication partners of BBC content would also be limited. In light of the information
provided by BBC management we consider the likely impact of the pre-booking
functionality on the usage and reach of the BBC iPlayer as not significant. We have
however asked BBC management to provide further information on the impact of pre-
booking six months from launch and we will review this again at that time.
3. The effect of pre-booking on peak streaming rates
A further query was raised during the consultation as to whether pre-booking will address
download times and the anticipated cost reductions for Internet Service Providers (ISPs).
As outlined in the proposal and also in the response to the further questions submitted to
BBC management, BBC management expect the addition of the pre-booking functionality
to result in users adopting pre-booking partly in substitute for streaming and for it to
reduce peak streaming rates. It is our understanding that with the addition of the pre-
booking functionality, downloading will occur in the background whenever personal
computers are on. As such, it is BBC management's view that it is likely that downloading
will occur more at off peak times resulting in cost reductions for ISPs. BBC management
also consider that their view is shared by ISPs.
4. Parental Guidance
The Audience Council for Wales questioned whether the Parental Guidance function
would be available when pre-booking programmes. Parental Guidance is an option that
is available on the BBC iPlayer and BBC management have confirmed that it will
automatically be extended to pre-booking.
Information required six months from launch
As outlined above, the Trust has asked BBC management to provide further information to
the Trust six months from launch of the pre-booking functionality on the BBC iPlayer.
Specifically the Trust has asked BBC management to provide:
(1) Assessment as to the effect that pre-booking has had on the reach and usage of
downloads via the BBC iPlayer, including comparative iPlayer download data alongside
the number of pre-booked programmes;
6(2) Assessment as to the effect that pre-booking has had on the reach and usage of
streaming via the BBC iPlayer, including comparative iPlayer streaming data alongside
the number of pre-booked programmes;
(3) Assessment of the impact of pre-booking on each of the services identified by Ofcom
in the iPlayer MIA with reference to usage data;
(4) Assessment of plans by other providers to launch pre-booking functionality and the
likely impact of the BBC’s pre-booking service on these;
(5) With reference to usage data, an assessment of whether the launch of pre-booking
elevates iPlayer into a more significant alternative to linear viewing.
The Trust will review this further information from BBC management, in particular in
relation to the impact of the pre-booking functionality. If the Trust finds that the addition of
pre-booking functionality has a significant effect on reach and usage of iPlayer, it can
suspend pre-booking and may decide to subject it to a full Public Value Test. In any case,
the Trust can request further data from the Executive and maintain a watching brief on the
impact of pre-booking until it is satisfied as to the impact of pre-booking. It may also ask
for pre-booking to be subject to further scrutiny when the BBC iPlayer is looked at as part
of the review of the on-demand service scheduled towards the end of 2009.
7Annex A
BBC management responses to further questions
A. Response to questions
1. Is the infrastructure to supply pre-booking functionality in place, or will it
require additional spend (ie how easy would be it be to run a trial)?
The physical infrastructure needed to offer pre-booking is the same as that used for iPlayer
today, and therefore has no extra cost. We estimate the additional software development
and rollout costs to be in the region of £30k.
2. Has any audience testing been carried out in terms of unattended downloads -
what will users think of leaving PCs etc on overnight?
No audience testing has been carried out specifically for pre-booking.
Some users may choose to leave their PCs on overnight to facilitate downloading. Audience
testing during the iMP trial and user behaviour in iPlayer suggests that immediacy of delivery
is important to audiences. On this basis, if pre-booking is the only way to instantly access
HD content (for example) it is possible that users will see the benefits of overnight
downloads.
However, the benefits of pre-booking can be realised without requiring users to leave PCs
on overnight; downloading will happen in the background whenever PCs are on. Other off
peak periods exist, such as weekends, when pre-booked peak time programmes could be
pre-delivered days in advance.
3. What evidence is there that pre-booking will reduce peak streaming rates?
This is hard to prove, but we expect pre-booking to reduce peak streaming rates because
• Users will not stream while watching a pre-booked programme; and
• We expect pre-booked viewing to peak at the same times as streaming.
Our view is shared by ISPs and has been noted in the widely respected Telco 2.0 blog:
“The BBC is planning to introduce a “bookmarking” feature to the iPlayer which will allow pre-
ordering of content and hopefully time-of-day based delivery options. This is a win-win-win
enhancement and we can’t see any serious objections to the implementation: for the consumers it is
great because they can view higher-quality video and allow the download when traffic is not counted
towards their allowance; for ISPs it is great because it encourages non-peak hour downloads; and for
the BBC it is great as it will potentially reduce their CDN costs”
84. What is the evidence that audience behaviour will support pre-booking as
opposed to 'anytime, anywhere' consumption via streaming?
All things being equal, the evidence of iPlayer suggests that audiences do choose ‘anytime,
anywhere’ consumption via streaming. However, pre-booking / downloading does have
advantages:
• The capability of internet connections varies considerably, making streaming
not always possible, particularly for higher resolution content and for homes
in remote areas.
• Until mobile streaming is ubiquitous, downloading / (and therefore pre-
booking) represents the only way for many to consume rich media on
portable devices
• Pre-booking, when combined with series stacking functionality, can be more
convenient for users. In these cases, audiences will be able to watch pre-
booked content immediately as if it was streamed.
5. What evidence is there that adding pre-booking will not materially increase
the reach and usage of the iPlayer service? Can the Executive provide current
reach and usage figures compared to the projected figures in the PVT
application?
Even after launch it will only be possible to estimate the impact of functionality like pre-
booking on overall reach and usage of iPlayer. However, pre-booking is more likely to
increase usage than to bring new users to iPlayer.
We note that although reach so far seems to roughly as expected in the PVT forecasts,
usage (i.e. hours viewed) has been about half what was expected. See below for an update
on reach and usage compared to project figures in the PVT application.
6. What steps has the Executive taken to ensure adding this function does not
affect providing content on a platform neutral basis (so far as allowed by VFM
and technological considerations)? This will apply to both current syndication
arrangements and future arrangements.
Pre-booking functionality in no way impacts the BBC’s syndication policy. Decisions to
syndicate content and functionality such as pre-booking are subject to the BBC’s syndication
guidelines and monitored by the Trust on a six monthly basis.
Syndication decisions are made on a non exclusive basis and subject to technical feasibility
and value for money considerations. No decision has yet been made by management
whether to make pre-booking functionality available to existing and future partners
9B. Metrics update
Summary
• Usage: In terms of viewer hours, usage is below the PVA forecast by around 50%.
Current trends suggest that over 2008 there will be around 100m viewer hours,
whereas the PVA predicted 195m viewer hours
• Reach: Current metrics (based on cookie-counted unique users) do not allow for a
reliable, like-for-like comparison with PVA forecasts (expressed in 15-min
consecutive weekly reach). However, direct comparison, made for indicative
purposes only, suggests that average reach for 2008 will be just over the PVA
model’s forecast, at around 1.4m users per week (versus a forecast of 1.27m). Panel-
based data will be available in the coming months which will allow for a more
meaningful comparison.
Usage
The PVA document does not provide usage forecasts for this year: it only does for 2012
(pars 7.3.5 and 7.4.1). However, appropriate figures exist the underlying model. 1
The PVA model: For 2008, the model predicts 195 million viewer hours (and 1,898 by 2012).
Current data: Estimates 2 of actual monthly viewer hours are shown in Exhibit 1 below.
Exhibit 1: iPlayer observed monthly views (stream starts plus download starts) to date, and implied
viewer hours.
1
Throughout this update, PVA figures have been shifted by one year to reflect the delay in iPlayer’s launch.
Accordingly, all references made here to PVA forecasts for, e.g., year 2008 can be found in PVA document
and/or model under year 2007.
2
Using the number of streams and downloads initiated, multiplied by an average viewing time of 22
minutes.
10Implied viewer hours are calculated assuming average viewing times of 22 minutes for the
case of streaming, Sources: MC&A (views), FM&T Distribution (average viewing time).
Assuming that usage in June and July is representative of 2008 (which is reasonable in view of
the chart above), leads us to expect that by the end of the year users will have viewed
around 100 million hours – that is, around half of what was expected in the PVA.
Regarding the pre-booking functionality discussed in the attached document, although (as
noted) we expect impact on usage to be minimal, we note here that any small increase in
usage is unlikely to cause iPlayer beyond forecasts. 3
Reach
For reach it is more difficult to provide a like-for-like comparison between PVA forecasts
and current figures. This is because the measure of reach given in the PVA 4 is not being
directly monitored at present, nor can it be easily extrapolated from the information that is
available. However, it is possible to provide an indicative comparison using cookie-counted
weekly unique users.
The PVA model: The PVA model, (as well as figure 21, p 73 and par 7.4.1) predicts an
average (weekly 15-min) reach of 2.1% in all TV households for the first year of operations
(now 2008), and 19.8% by the fifth (now 2012). For 2008, multiplying 2.1% times 25.6m (TV
households - BARB) times 2.3 (persons per TV households – BARB) yields 1.27m persons
reached per week.
Current data: Exhibit 2 below shows observed weekly cookie-counted unique users to date,
averaged for each month:
Exhibit 2: Observed weekly unique users to date. Source: MC&A, cookie-based
3
In terms of bandwidth used, this suggests that impact has been even less than 50% of what was modelled
by Ofcom in its 2006 MIA, given that streaming users (who account for the vast majority of iPlayer usage)
only download what they consume.
4
Weekly 15-min consecutive reach – see footnote 68 and Figure 21, p 73 in the PVA application
11From Exhibit 2 it is reasonable to expect that the months of Apr-Jun will be representative
of 2008, which suggests that average reach for 2008 will be around 1.4m – that is, slightly
over the PVA’s forecast.
However, these figures should be treated as indicative only, as cookie-counted reach is not
in any way equivalent to 15-minute consecutive reach. Specifically:
• Multi-user viewing would result in cookie-based figures being an under-estimate
• Users accessing iPlayer from more than one computer in a week (e.g. from work and
home) would result in an over-estimate
Panel data will be available in the coming months 5 that will allow for a more meaningful
comparison with PVA forecasts.
5
The Nunwood New Media Tracker (recently commissioned, as a replacement for TNS)
12Annex B – Submission by Sky
Response of British Sky Broadcasting Limited (‘Sky’) to the BBC Trust consultation on BBC
Management proposals for the introduction of pre-booking functionality to the iPlayer
Summary
1. Sky cannot comment meaningfully on the BBC Management (‘the BBC’) proposals for the
introduction of pre-booking functionality to the iPlayer (‘the Proposals’) due to the lack of
information and robust analysis regarding their impact. For example, the Proposals fail to
consider the impact that a significant increase in the amount and range of content listed in
the iPlayer would have on usage, and rely on spurious and unsubstantiated assertions as to
consumption of BBC programme to allege that the Proposals will have no impact.
2. The BBC Trust (‘the Trust’) should reject the Proposals on this basis alone, and should
require the BBC to resubmit its application for approval with adequate evidence in support
of any analysis as to their impact, which can then be put to stakeholders as part of a
legitimate consultation process.
3. Any subsequent approval of the Proposals (following further consultation) should be
subject to specific requirements on the BBC to facilitate the simultaneous launch of the
pre-booking functionality on other services and platforms which distribute BBC on-demand
content. Failure to do so would breach the BBC rules on the syndication of on-demand
content and the Competitive Impact Principle.
4. If the relevant supporting data does not exist, then the Trust should consider approving a
limited and time specific trial to generate the necessary data. Only then can the BBC make
any statement as to the public value or market impact of the functionality. The results of
any trials must be published in support of any future consultation to enable stakeholders to
comment meaningfully.
1. The consultation is flawed
1.1 The BBC document setting out the description of the functionality, its public value and
market impact fails to provide any basis for adequate consultation. The Trust should
reject the application for approval on this basis alone. An explanation of the failings
of the BBC’s proposals and assessment is set out below in more detail below in
section 3.
1.2 Should BBC wish to pursue this functionality, the Trust should provide clear
instructions to BBC as to the quality and detail of information and analysis required in
order to enable the Trust to consult stakeholders in a meaningful and worthwhile
manner. For example, although the proposals refer to recent survey evidence in
support of the proposals, the BBC has chosen not to make the report by Human
Capital available to stakeholders. Irrespective of the BBC’s perception of the relative
importance of a particular proposal, it must be supported by an appropriate level of
evidence and analysis. This is clearly lacking on this occasion and the absence of
1Pre-Booking Functionality
Sky Response
such evidence and analysis is a serious failing. One would anticipate that, had the
Trust had such information, it would have been able to challenge many of the
unsubstantiated assertions made by the BBC prior to publication of the proposals and
consultation with stakeholders so as to avoid wasting valuable time and effort of all
concerned.
2. Non-discriminatory access to BBC on-demand content
2.1 In the event that the Trust does subsequently permit the Proposals, the BBC is obliged
by its Syndication Guidelines and the Trust’s Syndication Policy to facilitate the
introduction of similar functionality across all platforms and services which distribute
BBC on-demand content. Failure to support such functionality, for example through
the provision of advance schedules and programme information, as well as advanced
access to actual programme assets to facilitate efficient downloads, would be a
breach of the guidelines and policy.
2.2 Furthermore, in the light of the BBC’s obligation under the Competitive Impact
Principle, which requires the BBC “to endeavour to minimise its negative competitive
impacts on the wider market”, the BBC must consider whether pre-booking
functionality can be implemented on the iPlayer before it has enabled competing
providers of BBC on-demand content to provide similar functionality.
3. The BBC’s assessment of public value and market impact are inadequate
3.1 As described, the BBC pre-booking functionality will operate as follows:
a) iPlayer users will be able to “pre-order the download of a TV programme before
it has been broadcast”;
b) After the user has ordered the programme the corresponding file will be
downloaded to the user’s computer at “the optimum time for the user, the UK
internet and the BBC”, which may be before the scheduled (linear) broadcast
of the programme, and therefore, before the programme is made available to
view on an on-demand basis via the iPlayer or other user interface;
c) The pre-booked and downloaded programme would only become available
to view after the linear broadcast, and, it is assumed, at the same time as
non-pre-booked versions would be available to view; and
d) The rights window for a programme downloaded via pre-booking will be the
same as if the programme had been downloaded on the day it is broadcast
(see paragraph 7 of the BBC document setting out the Proposals).
3.2 The Proposals fail to deal with the fact that this description of the pre-booking
functionality would result in a significant increase in the amount of BBC on-demand
content being listed in the iPlayer (whether for immediate viewing using the
streamed content, for immediate download or download at a later date).1 The
amount of programming listed could double in volume. Instead of making available
1 Sky notes that currently the iPlayer lists schedules for three days in advance, marking content as
either “Coming soon”, “Not available” or highlighted for immediate viewing if the programme
is a repeat of a programme that is currently available to view due to an earlier showing.
Although not the subject of this consultation, Sky is concerned about the use of repeats within
iPlayer to extend the period within which content may be viewed beyond the “seven day catch-
up” window agreed by the Trust. As requested in this response, the Trust should bring forward
its review of the BBC’s on-demand proposals, and consider this as a matter of urgency.
2Pre-Booking Functionality
Sky Response
the previous seven days’ programmes, the iPlayer will list 14 days of programming
which consumers can either select to download immediately, or over the coming
seven days. No consideration appears to have been given to the impact that
increasing significantly the volume of content available via the iPlayer will have,
either from a public value perspective or with regard to the ‘market impact’.
3.3 Sky submits that the amount and range of programming that can be accessed via a
particular interface, such as the iPlayer, are important factors in determining the
usage of on-demand services by consumers. The greater the volume and range of
content available from a single interface, the less likely consumers are to use other
similar applications to search for and view on-demand content, or indeed watch
other sources of programming, such as broadcast services. This is overlooked by the
BBC assessment of the proposals, and is a significant shortcoming that prevents any
meaningful commentary on the proposals.
3.4 Moreover, the BBC’s assessment of the public value and market impact of the
proposals appears to comprise solely self-serving assertions which are not supported
by evidence or analysis.
Impact on public value
3.5 In relation to “Reach and usage of BBC content”, the BBC states that it “does not
expect pre-booking to have an incremental impact on overall usage of the iPlayer service
to the extent that it would require adjustment of the forecasts outlined when the service
was first proposed” due to the fact that “[t]he overall level of consumption of BBC
content is unlikely to change as a result of pre-booking, as consumers would watch these
highly-valued programmes regardless, either live or through retrospective viewing using
iPlayer’s catch-up”.
3.6 The BBC’s assessment is simplistic and unsupported by any published evidence of
consumer behaviour. For example, this assessment fails to take into consideration:
a) the increase in the volume and range of content that will be listed in the
iPlayer at any one time;
b) the comparative ease with which programmes may be pre-booked for
viewing later against the inherent delay of the current downloading
functionality which has driven consumers to prefer streamed viewing;2 and
c) the likelihood that users will use the pre-booking functionality to create
large, ‘automatically-generated’ (post-broadcast) libraries of downloaded
programmes.
3.7 Furthermore, no attempt has been made to quantify the current reach and usage of
the BBC on-demand content via the iPlayer as compared to the projections contained
in the BBC PVT application,3 or how such use would increase were pre-booking to be
2 See BBC press release -
http://www.bbc.co.uk/pressoffice/pressreleases/stories/2007/12_december/13/iplayer.shtml
and Sky notes Ashley Highfield’s comment of 14 January 2008 that “Streams are outnumbering
downloads by a factor of eight to one. I would imagine that eventually this might settle at one
download for every three streams, especially when we have implemented bookmarking (pre-
ordering of programmes to be downloaded, possibly ahead of transmission so that they are available
in your "download manager" immediately after the programme has aired)….”
http://www.bbc.co.uk/blogs/bbcinternet/2008/01/iplayer_launch_first_indicatio.html
3 See Section 7 of BBC Executive's application document
http://www.bbc.co.uk/bbctrust/assets/files/pdf/review_report_research/pvt_iplayer/bbcexecutive
s_pvtapplication_pva_annexg.pdf.
3Pre-Booking Functionality
Sky Response
permitted. Sky notes that the Trust’s PVT did not consider the impact of streamed
on-demand content but rather of downloaded content only. Streamed on-demand
content was only introduced to iPlayer distributed on-demand programming at the
re-launch in December 2007 and may have contributed to a significant increase in
viewing of BBC on-demand content as compared to pre-re-launch, in addition to the
BBC removing the requirement on users to pre-register to use the service. No data
has been provided analysing the difference these changes made against the usage
forecast for the PVT, and the changes now proposed.
3.8 The BBC’s assumption that consumers would not watch more, or different, content as
a result of pre-booking functionality because they are already watching all the
“highly-valued” BBC programmes that they wish to through linear or existing catch-
up services is not only counter-intuitive, but also unsupported by evidence. This
assertion is also contradicted by later assertions in the BBC proposals that seek to
emphasise the benefits that pre-booking will achieve (for example, it assumes that
despite enhancing the consumer impact of the BBC’s online delivery interface, there
will be no commensurate increase in usage, or as a result of improvements in “ease
of use” and simpler user journeys (Paragraph 20 of the Proposals)).
3.9 The BBC’s assessment of “Quality and Impact” is nonsensical:
“Pre-booking will enhance iPlayer’s consumer impact: trialists of the iMP
prototype commented that the impact on their viewing behaviour would have been
greater if download times had been shorter. Thanks to its immediacy, pre-booking
will help address this shortcoming. … pre-booking does this without forcing users
to compromise on image quality; this results in higher quality for the proposition
as a whole.”
3.10 Pre-booking will not address download times, which are dependent on broadband
download speeds and usage. Furthermore, pre-booking is not ‘immediate’ but relies
on delaying downloading until a later date, and therefore risks confusing consumers
who might think that they will be able to download a programme to view
immediately, when the opposite will be true.
3.11 It is not possible to assess whether the “quality for the proposition as a whole” will be
increased without information as to the current level of downloads versus streamed
viewings and projections as to changes expected as a result of the introduction of this
new functionality. This information is also necessary in order to comment on the
BBC’s assertion that users will substitute pre-booking for streaming, resulting in a
reduction in the BBC’s costs (see Paragraph 23 of the Proposals).
Market impact
3.12 The BBC’s assessment of ‘market impact’ is similarly flawed, in particular due to the
illogical and unproven assertion that pre-booking “cannot lead to any diversion of
demand away from other relevant markets” due to the fact that audiences are already
compelled to consume all the ‘high-quality’ BBC programming they can handle by
any and all means available.
3.13 Indeed, according to the BBC, there is no correlation between the increased
likelihood that a consumer will download a programme resulting from the
introduction of pre-booking functionality, and the likelihood that they will actually
watch the programme. This reasoning is also employed by the BBC to dismiss
previous Ofcom concerns regarding substitution from broadcast services to internet
TV services. No evidence has been provided to support this assertion or to deal with
the potential for increased usage identified above.
4Pre-Booking Functionality
Sky Response
3.14 In addition, the BBC refers to an Ofcom consumer survey (without providing any
further details of this evidence) in support of its assertion as to the relative
unimportance of this functionality. This evidence appears to support the rationale for
catch-up services, rather than any view as to the lack of requirement for pre-booking
functionality as part of a catch-up service. Contrary to the public value assessment, in
this context, pre-booking is considered to be a “minor piece of functionality” unlikely
to drive usage.
3.15 Sky notes that the BBC has made no attempt to assess the impact of the Proposals on
third party platforms and services that syndicate BBC on-demand content. Without
any evidence as to current and forecast usage, it is not possible to comment
meaningfully on such an impact, but it is logical to assume that were such
functionality not available on other platforms and services (as appears to be proposed
by the BBC), there would be some negative impact. The BBC’s failure to consider this
aspect of the Proposals ‘market impact’ is a serious failure and may result from the
apparent absence of any third party input into the assessment of the Proposals prior
to publication.
3.16 Moreover, it is not clear upon what basis the BBC asserts that “watching pre-booked
content on a PC will never be an exact substitute for watching content on a television.”
This would appear to contradict Ofcom’s findings in its MIA and the BBC’s own
assertions in its proposals which envisage a world of perfect substitution for BBC
content between linear and on-demand services.
3.17 Furthermore, the statement that “[t]here will always been some circumstances when
viewers will prefer to use the iPlayer in preference to watching pre-booked content via
PVR (e.g. at work or when commuting)” would also appear to contradict the BBC’s
assertions that use of online on-demand services does not increase viewing of BBC
content (because someone viewing a downloaded BBC programme on a laptop, for
example, might be watching a programme that they would not otherwise have had
time to view, and will therefore have increased the amount of television
programming they watch on a day to day basis as a result of that content becoming
available to download). It is also of note that BBC appears to condone consumers
viewing BBC on-demand content “at work”. This statement suggests that the BBC has
information relating to usage that would suggest increased levels of viewing rather
than the static picture it paints to support its contention that pre-booking will not
increase demand. Without disclosure of such information, Sky cannot comment on
the BBC’s proposals, and we are surprised that the Trust did not see the need for
such information to be disclosed.
4. Reducing BBC on-demand bandwidth requirements
4.1 The BBC’s assessment of the impact of the Proposals on ISP costs is surprisingly
cursory given the significance of this issue for ISPs, and the fact that it was raised as a
concern by Ofcom in its MIA.
4.2 Sky would have expected the BBC to provide a more detailed assessment of current
usage, and the anticipated cost reductions for ISPs should pre-booking be adopted
and usage meet expectations. Without such information it is not possible to
comment meaningfully on this aspect of the proposals.
5. Limited approval
5.1 If the BBC does not have the necessary information to support the Proposals (which
Sky considers unlikely), the Trust should consider allowing a limited and time specific
5Pre-Booking Functionality
Sky Response
trial to generate the necessary data and to enable assessment of the impact of the
proposals, particularly whether the functionality would lead to an increase in the
volume of content downloaded and viewed by consumers. This information could
then be disclosed as part of any future consultation on the functionality.
Sky 1 August 2008
6Annex C
Memo
To: The BBC Trust - BBC iPlayer programme pre-booking consultation team
From Audience Council for Wales
Date: July 2008
Re: BBC iPlayer programme pre-booking Consultation
The Audience Council for Wales is supportive of the iPlayer pre-booking proposals and
believes it will bring the service into line with other internet catch-up services (such as
4OD). The Council agrees it will provide another useful means for audiences in Wales to
view the BBC’s content. iPlayer pre-booking will act as a simple and effective method of
ensuring the content is delivered to the user’s computer and as outlined in the proposals,
appears to be an easy, reliable method of ensuring content can be viewed. This is pertinent
especially for the series booker, which will allow viewers to catch up on individual episodes
which may have been missed and also offer the facility to book the whole series for the
viewer to watch at their discretion.
Pre-booking is particularly important in the context of the BBC’s Welsh language television
programming broadcast on S4C. The BBC’s Strategic Partnership with S4C enforces a 7-day
exclusive transmission window for S4C and the Council believes that pre-booking
programming through the new system would ensure that viewers of BBC Cymru Wales’
programmes broadcast on S4C were not put at a viewing disadvantage. The 7-day delay
could result in people forgetting to download by current means, whereas the pre-booking
system guarantees the programme will automatically arrive on their computer.
Although a Parental Guidance option is available on iPlayer, the Council is eager to ensure
that this is extended to pre-booking to ensure that children are not accessing content
contrary to the wishes of their parents.
The Council agrees that introducing pre-booking will increase value for money. If the
proposals are approved, audiences in Wales will have yet another means of accessing BBC
content.
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