BECTU response to UK Radiocommunication Agency paper Spectrum Pricing 1999

29 November 1999

I write on behalf of BECTU in response to the Agency document on Spectrum Pricing and in particular to Appendix 2 on Programme Making and Special Events. BECTU is the trade union for the technicians and other workers in the film, broadcasting and entertainment sectors, including freelance sound recordists.

A number of our members have contacted us expressing extreme concern at the astronomic increase in licence fees proposed for general use radio microphones. This means that individuals such as freelance sound recordists who currently pay £160 for an annual licence for a block of frequencies in the UHF spectrum (channel 69) are faced with a proposed fee of £8,397. In effect, they are faced with a licence fee increase to 52 times its current level. This is unprecedented in our experience and seems totally unrealistic and unjustified.

The members we represent are typically individual freelances (in some cases working through one person service companies). They are sound recordists working on television or film productions (with a smaller number of camera people working on news or documentaries). Their clients are broadcasters and independent/film production companies who typically have no or very few sound recordists on staff and who rely on our freelance members to undertake this function. Radio microphones are required in any context in which it is impossible to use conventional microphones in the field eg because of background noise or because the subject is moving or too far away.

We can appreciate that the Agency is seeking to achieve a reasonable return from licencing the use of the spectrum and we are aware that other potential users (eg for mobile telephones) are also interested. However, we cannot believe that individuals - who have no choice but to use this equipment and who are relied on to provide it by the companies they work for - should be expected to bear the cost of licence fees set at levels appropriate for corporate users.

Our members work in a labour market which has seen a significant degree of casualisation in recent times and usually have no choice but to operate as freelances. They may work for up to 4 or 5 different companies in a week and are hired on the basis that they can turn up to the designated site with the relevant equipment. There is no realistic alternative of hiring the equipment from the companies themselves.

With the best will in the world, we believe that such a massive increase in the licence fee to such an unrealistic level - probably 2 1/2 times the cost of a radio microphone itself - will only lead to the growth of an unlicensed sector from among individuals who simply cannot bear such an increase in costs. We are not advocating such a response but we believe this is a predictable outcome - which would undermine the rationale of licensing in the first place.

We hope the Agency will give careful consideration to these arguments. We believe that a 52-fold increase in the fee may be conceivable for corporate licence holders but is totally unreasonable and unrealistic for individuals. We hope you will amend your proposals accordingly.