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Luke Gibbs, the independent policy advisor and founder of the Ofcomwatch blog, finds PSP problematic for two reasons.

"It's public money - so it should be government driving the policy," he told us.

"If you're saying that you need to create a new BBC or Channel 4-type model, then that's industrial policy. It needs to be approved by Parliament and at the moment it's Ofcom making the suggestions about how public money is being spent. That's quite a hard sell, and it's not for Ofcom to be selling it."

The other is Ofcom's assumption that what applies to broadcast media should apply to the very different world of new media.

"The BBC and others have been privileged in being allowed sole use of a scarce public resource, from an era when people had little or no choice. In return for use of this scarce public resource, they were expected to adhere to certain principles.

"But in the online space how do you classify these obligations? And you haven't got the same scarcity of resources - material is likely to be too small within a vast ocean to be worth anything."

Saving content, by killing telly

Then there's the underlying assumption that TV is in terminal decline.

A history of technological innovation in media shows that after a period of disruption, every "new" media tends to validate and refresh the old, rather replacing it.

After the upheaval, the same media owners are usually in place - and typically more concentrated. It's quite unlike the history of transportation, where one technology (for example, the train) supersedes another (for example, the canalway) for economic reasons. So in assuming that TV is in a fatal condition, Ofcom is merely hastening its demise.

Ofcom quoted us figures suggesting that 10 per cent of 16 to 24 year olds had defected to the web: these are included in the report. But in addition to ignoring the impetus the internet provides for TV, the figures also show this is a generational factor: older adults value TV much more than the 16 to 24s. Once they have families, these viewers return.

Wouldn't good, relevant TV win them back? Ofcom told us its role was to cater to everyone - but the message appears simple. It's got the web religion, and from now on it's "computers or bust".

"Public Service Broadcasting has traditionally meant TV, and Sunday night dramas andd BBC Current Affairs shows. But we've got to look further ahead," Bates told us.

"We think there's a gap in the provision of content for new media networks - that's the context of the PSP debate. But no one is pretending the PSP is anything other than part of a solution to a wider challenge."

Even in the converging world of IP-based TV, there's little sign of "sit forward" more interactive services such as Joost, and "lean back" traditional TV, where an audience wants to be absorbed and entertained.

Also unacknowleged anywhere in the 57-page report is the rapid growth of "Mycasting" - which enables people to view their favourite TV shows remotely using Sling Media's Slingbox, or Orb Networks' software. Again, this use of technology enhances, rather than replaces traditional broadcasting.

Without acknowledging such developments, Ofcom's PSP authors offer a very narrow vision of the future.

Falling between the two stools, a PSP could find itself providing material for a cable channel or websites no one wants to watch.

As Ovum noted this week, only the biggest brands, such as YouTube, have made the leap from "sit forward" to "sit back". And there are very few of these major web content brands, confirming Gibbs' view that old media assumptions don't often apply to the new.

So stripped of its voguish web-centric sales pitch, is there really a reason for a £100m gatekeeper to exist?

How to respond

The consultation period ends today at 5pm. It's only gathered nine responses so far, so yours could make a difference. Details about the PSP can be found here - and readers can send their thoughts on the PSP to Ofcom via this handy form. ®

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