Ofcom, the communications regulator is an easy target. It appears to be big, powerful and omnipresent, releasing an endless stream of directives to the world.
Some broadcasters even claim to have been forced to take on extra people just to deal with the Ofcom paperwork – although this may be something of an urban myth.
What is certain is that over the next 18 months the Ofcom in-tray will be brimming over with serious issues central to the future of British broadcasting.
They range from what to do to try to reverse the decline in original children's programming, to how many minutes of advertising should be allowed on commercial television and on to the weighty subject of the funding of public service broadcasting in an internet age.
Ofcom is particularly stung by the criticism that it is some kind of perpetual motion machine, continually generating work for others. Most of what it does, the regulator insists, is mandated either by UK legislation or diktats coming from Brussels.
Then the major players themselves stimulate waves of regulatory activity by their own actions – satellite broadcaster BSkyB suddenly buying a big stake in ITV to block a Virgin takeover, or wanting to launch a pay service on Freeview. Virgin, BT and Setanta then get together on a formal complaint on the effects of BSkyB's market power and another inquiry is off and running.
Once a quarter at Ofcom strategy meetings, chief executive Ed Richards tries to strike out work that is not central to the regulator's purpose – though it is not clear how far he succeeds.
One of the more satisfying attacks on Ofcom – at least for journalists – involves the current crisis in children's programming.
First there is the symmetry of Ofcom apparently failing to prevent ITV pulling out of original children's programming while hitting revenue by imposing severe limits on junk food advertising. Then Ofcom just wrings its hands at the terrible turn of events and calls for solutions. Unfortunately, this conspiracy theory doesn't quite work.
Investment in original children's programming by the commercial public service broadcasters has been falling for more than five years and Ofcom had no powers to prevent ITV pulling out although its displeasure was registered. On junk food ads, the primary player was the Government and there are still politicians arguing for no high-fat, high-salt food ads before the 9pm watershed – something that would have a serious impact on television advertising revenues if ever implemented.
Right now, Ofcom is concentrating on trying to ensure that the BBC, itself under financial pressure, does not become the only source of original children's production although, so far, Five has continued to invest in this area. One idea clearly coming to the fore is that Channel 4 should have a redefined, and strengthened programme remit for 10- 16-year-olds.
Another contentious area is advertising – an issue flowing from Brussels. Within overall limits, Ofcom will at least explore the possibility of a more flexible, laissez-faire approach. The theory goes that broadcasters would not be stupid enough to try to cram in too many ads, in the manner of the American model. Such an approach would both annoy viewers and drive down advertising rates.
But the big question is the future of public service broadcasting. Here, radical change is likely. Richards has made no bones about his belief that dramatic change in the world of television is inevitable and that, by implication, some of the institutions of broadcasting will have to change, too.
The Ofcom chief has long been a proponent of the creation of a Public Service Publisher to meet an anticipated deficit in the amount of public service broadcasting delivered to viewers. He is not, though, in favour of an institution such as an Arts Council of the Air to distribute the funds.
Apart from that, almost everything is up for grabs. Future options for consideration will include "top-slicing" the BBC licence fee to distribute to other broadcasters for public service or trying to find other sources of finance for original British production.
While the ideal will be to have competition in the provision of public service programming, a minimalist option will have to be considered – that people may not want to pay more and will be happy with what the BBC and other broadcasters manage to provide amid ever increasing competition for eyeballs.
Ofcom's enduring reputation will depend on how well it handles such conundrums – in the public interest.
Only a DAB hand prevails
DAB radio seems to be about as popular at the moment as the Archbishop of Canterbury.
Commercial broadcasters are clambering over themselves to dump channels and claim they can see no way of making it pay – some of them after investing the odd £80m.
The reality is that very little of substance has changed. The Core and Oneword collapsed – the latter in a head-to-head battle with the BBC.
Then last week GCap announced the disposal of Digital One and with it the closure, if buyers are not quickly found, of Planet Rock and theJazz.
It looks bad, of course, but one of the key reasons behind the cost-cutting at GCap was the botched merger that created the company.
There is also an underlying principle that applies more widely than radio. While the world of broadcasting is self-evidently changing – it is not changing quite as much as people might think.
Listeners are mainly using DAB to listen to existing stations and newcomers had better be good to get attention.
By the end of this year there should be nine million sets out there and a raft of new stations from Channel 4 to compete with the BBC, which remains committed to DAB.
Despite appearances DAB is not quite dead yet.
Saved by the neuroscientists...
It used to be said, and endlessly repeated, that half of all advertising is a complete waste but nobody knew which half.
That was then. That was before the neuroscientists got involved. Later this month Thinkbox, the body set up to market the power of television advertising, will host a seminar on TV and the brain.
You can be sure that considerable emphasis will be given to the fact that television plays to the emotions and the emotional mood is particularly good for absorbing commercial messages. Science can also help with measuring "Engagement" – the new mantra for the marketing classes. All of this "proof" comes at a handy time for broadcasters, just as revenues start to take a further turn southwards.
The trouble is that the neuroscience of advertising is also a competitive business. The Newspaper Marketing Agency deployed neuroscience last year to prove just how effective newspaper advertising is.Reuse content