Submitted on Sat, 23 Jun 2018 - 10:52 AM
The former NBTC Commissioner analyses Order No. 9/2561 that provides assistance to digital television operators, reinforcing the pressure conditions of coup politics. The assistance provided contains inconsistencies: a moratorium on fee payments but with control over content; advertisements on state television; subsidies for state- and military-owned networks. In the end who does this help? She suggests that the NBTC should do its own duty, clarifying the road map in response to the spectrum problem.
Head of the NCPO Order No. 9/2018 was issued to assist digital television operators who were facing the problem of not being able to pay the license fees for use of their frequencies according to schedule. It allows them to apply for a delay of payments for up to three years and subsidizes the rent for digital TV networks (MUX) for 24 months. If you read to the end of the order, you will come up with a number of questions.
Item 9 empowers the Office of the National Broadcasting and Telecommunications Commission (NBTC) to determine which operators are eligible for a debt moratorium. If any digital TV operator breaches the conditions by producing programmes that are contrary to ‘the law and good morals of the people’, the NBTC Office may consider cancelling the moratorium. Does this order seem to use the operators’ need for survival to block presentation of news or the production of programmes that are critical of the government? Past media blackout incidents may provide obvious clues.
On the subject of rent subsidies for digital TV multiplex networks or MUX, which is in Item No. 8 of the Head of the NCPO’s Order, the NBTC, the NBTC office, or the Executive Committee of the Broadcasting and Telecommunications Research and Development Fund for the Public Interest are to provide support for 50% of the rental fees to the providers, i.e. the Public Relations Department, the Army, the MCOT and the Thai Public Broadcasting Service (ThaiPBS). Does this mean that the subsidies will go to the service providers owned by the government (either wholly or partially) or not? Isn’t this like moving money from the left pocket to the right one?
Another interesting item is permission for the Department of Public Relations to ‘earn revenue from advertisements as necessary and sufficient for programme production according to its objectives, not aiming to seek commercial profits’. Even with the phrase ‘not for profit’ added, the Department acquired the frequencies for its television broadcasting operations without having to join the auction and is now empowered to compete for a share of revenue in the advertising market with all other operators who had to fight tooth and nail to obtain a frequency. Is this not unfair competition?
How is this second part of the order related to the rescue of digital TV? Is it a matter for the NCPO Head’s hidden agenda or not?
With the debt moratorium and the rental fee subsidy, digital television ends up facing competition from state television for advertising income, as well as possible censorship of content. Is this really a rescue?
These numerous questions about the Head of the NCPO’s Order go straight to the independent organization that regulates and manages frequency spectrums, the NBTC, which has taken a passive stance, waiting for the order to frame its work even though it is within their authority to act on these matters. Is the NBTC really independent? How does such a stance reflect the relationship among the NBTC, the Board of the NBTC and the military government?
Prachatai has taken all these questions to discuss with Supinya Klangnarong, a former NBTC commissioner, whose term of duty ended in 2017 and who is currently an expert member of the National Press Council of Thailand. Supinya’s answers reflect the comprehensive chronic problems of the digital television business, covering the post-coup economic and political fronts, the possibility of going back to the frequency concession system of the past where the government negotiated directly with the private sector, which we had tried to escape from, the free airing of the ‘Forward Thailand’ programme in the system where frequencies cost millions of baht in the auction. She also questions the independence of the supposedly independent NBTC, which has obfuscated the aim of the digital television rescue, asking who in fact is to be rescued, the private operators or the military and NCPO.
Supinya Klangnarong, a former NBTC commissioner
Question in large print on the ‘difficulty of doing business – content control’ in the digital TV rescue
Supinya stated that the solutions imposed by the Order under Section 44 and based on the justification that the operators face difficulties in conducting their business lead to questions of fairness and equity in the arena of digital television and telecommunications. Tying the operators’ eligibility for assistance to the content they broadcast reinforces the direct effects of post-coup politics that squeezes out other shades of news, leaving only one. Imposing such a condition is like bringing the mass communications business back to the concession system under state-imposed conditions.
‘With regard to my own position during the time I worked as NBTC commissioner, I would never agree with the use of Section 44. It would be like handing over the power of the NBTC to the authority above it in making decisions. Then there would be no accountability, no check or balance by others who disagree. Also there may be other solutions if the NBTC is allowed to solve the problems itself, such as amending the notification itself, because utilizing section 44 is like negating its own notification.
‘If we were to resolve the problems ourselves, we could do it via public consultations. But my understanding is that if an amendment to the notification or payment by instalment is used, they may be sued in the future, whereas section 44 is not actionable. However, it is in conflict with the rule of law because it is the exercise of unaccountable power. In terms of general principles, it should not have got to that stage from the outset. I can understand the situation in which digital television issues had been outstanding for a long time without the NBTC daring to make decisions.
‘If you ask what my actual position is, I disagree that payments should be deferred because digital television faces problems in doing business. If assistance is to be provided, particularly by involving the power of the NCPO, it should be based on the fundamental principle of whether the policy of the state or the NBTC has affected rights and freedoms and what difficulties it has caused for digital television. This principle should be used to determine the cause and result because if we do not use this principle there will be loopholes for people to ask questions. Stations whose bids did not win in the auction in the first place will think that if they had known this, it would have been better to win. There would be never-ending arguments. And telecommunications companies like True and AIS may say that if it’s like this, we have to get some help so that we can carry on. The basic principle behind this solution will not be strong enough if it is about helping businesses because the rules are too strict. That should not be a good reason because it will affect other cases as well.
‘If digital television is to be assisted it should be for the clear reason that the mass media, particularly television, has clearly been affected by politics. After the auction, politics changed. There was the coup. Initially all television stations were closed down. The NCPO issued announcements greatly limiting freedom of expression and news reporting. In particular, the 7 news channels that had won the auction were almost unable to provide the colourful, rainbow-like competitive diversity of shades that we had intended as part of a marketplace of ideas and political and social news. But after the coup there was only one shade because of legal restrictions. So it became difficult for news channels to survive because there was general news on other channels. So of the 24 channels whose bids won, the ones experiencing the most difficulty were the news channels like The Nation, Spring News, Khun Tim, Voice TV and others, because they have not been able to find a selling point that differentiates them from other variety channels because the news is the same and their airtime has been taken over by programmes like Returning Happiness, Mai Het Prathet Thai or various live broadcasts.
‘If the explanation is that the NCPO appropriated airtime, affecting the private operators’ business, and there must be compensation, this is an acceptable reason. But they did not use this reason. What is more, when it came out, there was a condition attached which prompted concerns about control of content. People asked if this was a way of the NCPO saying ‘If I help you, you must not criticize me’.
Or does the attached condition mean that the channels that have been very critical of those in authority and have violated NBTC rules and have been blocked or received repeated warnings may not receive (assistance)? If so, it is even worse because it would be an exercise of power that lacks the rule of law and takes us back to the pre-NBTC system or concession system of the past that gave the government or the authorities of the time the power to decide who should be given concession rights to conduct media, telecommunications or satellite businesses in exchange for certain conditions that restrict freedom.
'That was the original system that we tried to avoid by establishing the NBTC to liberate the media so that they have more freedom without being tied up in in the sense that after they have acquired concessions from the state, they cannot use their freedom because someone did something for you so you must give them something back. This was the old system that we have been trying to reform for 20 years and the reason why we needed the NBTC. But if the NBTC creates conditions like this, it is equal to destroying the dignity of an independent organization, because the NBTC system does not make the NBTC the owner of power, but has it manage the frequency spectrum, issue licenses, and set conditions and rules in advance. Any one breaching these can be punished, but the injured parties can also file complaints against NBTC in court. There exist checks and balances. But when it is linked to government power, especially an abnormal government equipped with Section 44 as now, checks and balances do not exist, and the system regresses to a semi monopoly, i.e. the patronage system takes precedence over the rule of law.
‘If it is a remedy, because all channels are affected in the same way, they must receive the same treatment. This is a different matter from content regulation, which is the normal power exercised by the NBTC. Any channel that commits many offences can be fined by the NBTC, or warned, or have its license withdrawn; there is no need to link this measure to assistance.
‘I saw in the news that the Secretary-General of the NBTC is inviting all channels to a consultation on a moratorium on license fees on 7 June. It seems like they are sending a signal and we have to see what the signal is about, and what compliance with the rules entails. If it does mean regulation on content, it may be difficult because society is criticizing the current norms of content control by the NBTC, such as the case of expletives in dramas and political programmes. People have been making comparisons and asking why some channels, such as Voice TV, receive severe penalties, while others are not criticized.
'The NBTC measures to regulate content are problematic and have already been heavily criticized. If they are to be used to identify which channels get more punishment than others, unfairness can result. It can create suspicions as to whether the punishments were really fair, especially when in the past four years, no legal action could be taken against political punishments. For example, when Voice TV went against an NCPO Order, the NCPO issued an Order to protect the exercise of power by the NBTC which stated that penalties given to channels that violate NCPO orders are not liable to criminal or civil lawsuits.‘If this is the case, it makes the number of channels facing complaints very large because they cannot fight in court, as is the number that may not have received compensation or remedy. This is not fair for those channels that have been judged in this way.
‘In conclusion, the normal duties that the NBTC are carrying out with mechanisms to give penalties according to the rule of law should not be linked as a condition to the current assistance package because that is the equivalent of going back to the patronage system and using the power of patronage to control the media’ Supinya said.
Elections on condition that the media behave themselves: the NBTC under the patronage system
Supinya is of the opinion that the right to receive assistance has been linked to content because it will have a ripple effect from the media to the election arena and make the NBTC take on the duty of regulating content will have an effect on competition among the media which may result in an electoral advantage for those in power.
‘Now is an atmosphere of patience. Everyone is waiting. If there is political competition, that will bring a better atmosphere as everyone can compete in ideas and the people have the right to choose. But at that time, the media itself should be impartial. This doesn’t mean that they have to be neutral and not take any side, but they must have certain standards in carrying out their duty. Television media in particular, which are thought to reach the public and occupy frequencies, should perform their duty in a more accurate manner than online or other media, which may have more freedom.
'Television media are governed in the use of public frequencies by rules and regulations and protocols, so it is up to the NBTC as referee to decide how it wants to control the game. If there is no control, there will be winners and losers and those who are in power may gain more advantage in the election if they support someone in the election. This puts those who are not in power at a disadvantage. This is something that should not be allowed to happen. So the NBTC and the Election Commission should work together. This does not mean they should help each other to swing toward any party that has power, but they should support the rules of fair competition among political parties, and not let those who have power at the moment use that power to interfere more than necessary and create bias in the election,’ Supinya said.
‘Everyone is currently concerned that things are moving in that direction, because the NBTC itself has already been under the patronage system since 6 October last year. The present NBTC was reappointed under Section 44 when the six-year legal term of the first NBTC expired on that date. But the NCPO issued an announcement allowing them to stay on, since a new NBTC could not yet be selected. This is in fact an acting NBTC. They probably feel that they are here because of the powers that be.
'This makes it even more difficult for society to have hope, because if even the NBTC itself is under the patronage system, it will lead to a system of privilege. Both patronage power and privilege capitalism are things that should not happen in this era. This is a situation where some groups of capital, some groups of channels receive the privilege of not being regulated due to their patron’s power. In this case, it will be difficult to have regulation based on the rule of law, because everyone is under the condition of having to be considerate and fearful of causing offence to their patron.
‘I can remember that at the beginning when the NCPO came in, the NBTC was scrutinized and society itself cheered when the NLA raised objections about its use of budget and when the Budget Disbursement Monitoring and Auditing Committee came into existence, society also urged it to dissolve or audit the NBTC. But now it’s turned around. The NCPO is propping up the NBTC, and the NBTC returns the favour of this patronage by fully supporting NCPO policies. This does not look good and destabilizes the whole system of regulation. It also has an effect on the industry, because a number of channels are beginning to wonder if they can survive if they do not engage in the patronage system.
The state-military benefit from allowing state television to advertise – subsidizing MUX rents; NBTC must have a clear plan for digital television
Supinya made the observation that allowing the television and radio broadcasting operations of the Department of Public Relations to earn income from advertising is a serious breach of the principle of media reform because it raises the issue of double budgeting, and the question of patron-client relationships between the government, state enterprises and other private businesses involved in advertising. Competition in the digital television business will also be disrupted by a player who does not have to bid for frequencies like the other 24 channels at a high cost. But the state still uses prime time at 6:00 pm every Friday for free to make announcements.
‘It really shouldn’t be like this, but it is tiring to oppose it because it is a serious breach of the principles of media reform. Channel 11 and Channel 5 did not participate in the auction, but instead automatically received frequencies and their operations were already semi-commercial. Channel 5 in particular also carries advertising but still calls itself public television for security. This is not right. The case of Channel 11 is even worse. It already receives government budget like Thai PBS, but still asks to sell advertising space. What would people say if Thai PBS requested the same thing?
‘So it turns out that they are using state money and still need to compete for advertising with private businesses who are at a disadvantage because of having to bid for frequencies, which they don’t have to do. It is also open to criticism about whether the state is going to ask certain businesses or state enterprises to advertise, whether it is about shifting money from one pocket to another or an indirect way to get private sector support by buying advertising time even though there are not many viewers. This is already wrong according to the principles of media reform because public media should not be involved in business like this as they do not compete in an equal and fair manner with the private sector. From a political point of view, apart from being a propaganda tool, it could also provide business opportunities. We don’t know for sure who is benefiting from it in the end.
‘If it were 10-20 years ago, there would have been a lot of opposition from the media, academics and NGOs, myself included. But right now everyone seems exhausted and fed up, so not many have come out against it. I was somewhat perplexed by it (the order) because it seemed there was something hidden in it as there was no rhyme or reason for resorting to Section 44. The people began to look for the real purpose that brought this matter up and the digital television issue was added to it. But it was an awkward attempt with so many conditions attached to it. I sympathize with the digital television operators who have been competing in the new system. They have made full payments to the state and have to give away free air time to the state.
‘On this matter I have to say that it is really unfair. No country in the world uses as much free television air time on private channels every Friday at 6 o’clock. It has been like this for over four years now. If you add up the cost of air time I don’t know how many tens of billions it would be, very high indeed, and no channel dares to complain or dares to sue. If it were any other business, for example the government requesting the use of hotel space every Friday evening, they would one day have to pay on the invoice submitted. There is no way they could use the space for free. Using air time for free is like demanding a free service when the operator has had to bid and pay for it. Under the old concession system, the government may have been able to ask for a service at any time.
‘But as soon as it is a new system, the government asks to use air time at any time and no one says anything, not even the NBTC itself. I have said this before, but if the channels do not raise their voice, it is difficult. They probably have to put up with it for fear that any resistance could lead to them being dropped from receiving assistance.
‘Regarding the networks, the first thing that should have been done is that the NBTC should have ensured fair pricing of network fees from the beginning, because the fees that were calculated in the past were excessively expensive: 9-10 million per month for HD and 3-4 million for SD. Half of the 50% subsidy probably constitutes their profits. The NBTC has the right to regulate prices according to conditions. I have said from the beginning that prices needed regulation, and the channels themselves know this. But I lost in the vote count, so nothing was done until now. Charging high fees affects the survival of the channels. 50% is probably the real cost, maybe even including a little bit of profit. But the 50% reduction is not at all a reduction because the government is subsidizing it. The fact is that they can recover the actual cost even without the subsidy.
'Try calculating how many billions Army Television Channel 5 receives per year if each private channel pays 10 million monthly (for network rental) and there are 10 of them. And the rental term is as long as 15 years, so you may not recover the costs in the first two years but one day soon enough, as 15 times one billion is already over 10 billion. Channel 5 in particular has a lot of customers. Others, such as MCOT, may face more difficulty filling the slots and several wised-up customers refused to pay because the price is not proportionate to the quality and they have complained to the NBTC to settle the dispute.
'The standing resolution is that cutting off the signal is prohibited no matter how long payment is delayed because of the impact on consumers. Some channels have used this resolution to delay payments until they get a fair price. As I understand it, several channels have got together to withhold payments in full or in part. This is one of the reasons why the order was issued. But in the end, it is only to provide a state subsidy and not to reduce the price.
‘Multiplexing services are not for generating profits, but constitute domestic infrastructure for a public utility, like electricity and water, so user fees should be based on actual costs. If there are many users, they can surely make some profit, being semi-monopolistic organizations where customers have only a limited number of providers to choose from. And the contracts are for as long as 15 years. Thai PBS has done the calculations and confirmed that they are making profits even with fewer customers than Channel 5.
‘The painful conclusion is that we made a mistake in giving 2 MUX network licences to Army Television Channel 5. That’s the reason why they have more customers than other networks. At that time, we proposed this deal in exchange for their early exit from the analogue system. They agreed to drop the system from Channel 7 earlier than Channel 3. But since then they already made a lot of profit. While other channels are struggling, the ones that operate at full profit in the whole digital television supply chain are the MUX networks, and among them, Army Television Channel 5 is the least troubled of all, as it continues to earn rental income.
'But it will be in trouble if their customers go out of business one by one, which will mean no rent income 10 years from now if no one makes any offers in the auction. So it is understandable that even if you don’t want to, you need to come out and support them to remain in business. Bluntly speaking, it is a conflict of interest as they are the Army’s customers. But if the assistance is only piecemeal like this, the benefits will end up with the same players, i.e. the state agencies that control the game and provide the networks.
'What is sad is that the NBTC, which regulates everyone in the system and is in fact placed above them all as the licensor of the networks, and which can see the whole picture, should ensure that there is fair competition. Right now it is unfair. The rules that came out look like they help but in fact those with the best advantage continue to benefit, i.e. state agencies that have the right to provide network multiplexing services. I admit that we made a mistake in conducting the negotiations that gave Army Television Channel 5 more networks than others in return for an early exit from the analogue system. I don’t know if it was worth it.
‘But one small good thing is that it creates ties between the channels and the networks so that the digital television channels cannot be left out in the cold no matter what, because they are bound together. Even though Channel 5 is affected as a channel, they probably won’t mind much because as a network, they earn more money and it goes to Channel 5 just the same. This is why they have to provide support for the future of digital television. If the support fails, they will have no income in the long run. The networks they have installed would be empty shells. When that happens, the NBTC may have proof of its mistake, unless it has a vision and moves to solve the problem in time by expediting the creation of a roadmap for appropriating frequencies, or a spectrum roadmap, and announcing that we will bid to retrieve the frequencies for use in telecommunications.
'Society may say that there will be fewer channels, but if we just wait for them to die out, and finally they really cannot survive, we will be left with empty network towers without a plan as to what the frequencies can be used for next. By that time, the NBTC will be facing accusations of not solving the problem. In order to alleviate the situation, the NBTC should conduct a study now, I don’t know if it’s been done, to deal with calls for a spectrum roadmap or a plan for frequency allocation, in order to assess in advance the situation over the next 3-5 years, whether it will be bearable. If all the frequencies are returned, what will they be used for? Further auctions to earn revenue for the state, or a proactive model as in the US?
'This is where the state takes back the bids, not by paying cash to the private sector, but by waiving the remaining payables fees, and in return the state earns more revenue from auctioning off the retrieved frequencies. With this model, it is possible to explain to society, but the NBTC needs to plan in advance. It is understandable that the current NBTC has not done that yet because they probably assume there is no knowing how long they will stay on. As it is a time of transition, there may be a high level of playing safe. It is unfortunate that this interim NBTC is lasting so long. It is a lost opportunity because any interim commission would avoid getting engaged in large matters because there is no way of knowing what obligations these may entail.’
Supinya stated that what the NBTC should do, as an independent organization enjoying a great deal of welfare and privileges, is to start preparing a clear backup plan in case the operators can no longer continue in business.
‘The NBTC must conduct an assessment and have the courage to make decisions in case the situation is really untenable. Will they take the frequency bids back, or must they amend the rules so that they can really sell them. The pros and cons need to be assessed and a study report published. If amendments are needed, a proper procedure must be carried out, including public hearings. If there are complaints, that is the end. If there are no complaints, the amendments can be made. The steps can be taken, but I don’t know if the current Commission will do it because, as I said, it is just biding time.
'The channels are also wondering what to do. Should they keep the frequencies for resale or what? If they split, another channel may complain and ask again for an amendment. That won’t look good. It will be like the complaints will never end. If there is a problem we make an amendment. Shouldn’t the NBTC, as the referee, propose a solution once and for all, clearly laying down options one, two, three, which it thinks the industry wants to see? By not exercising power itself and instead relying on Section 44, the Commission has opened the way for Section 44, as a patronage system, a big brother system, to destroy the freedom and dignity of being private media and a channel. It’s a pity.
‘Society will question the need for an NBTC even more because after a difficult birth they have a relatively high level of benefits and privileges, high salaries, good welfare coverage, full authority, and numerous employees. The intention was for it to be a truly independent organization, enjoying autonomy in its work without having to rely on the government, as its revenue comes from the fees directly collected from the licensees. Society may not know this, but the NBTC is a truly independent organization, unlike the Election Commission (EC) and the National Human Rights Commission (NHRC), which cannot themselves generate income and must request their budget from parliament.
'The NBTC is a special case because the law stipulates that it shall collect license fees and retain a portion of them. The revenue from frequency auctions must be handed to the treasury, but every year the NBTC collects fees directly from the likes of AIS, True, DTAC and the different channels and uses the money to pay salaries. This is guaranteed by law, similar to the case of Thai PBS which operates by tax money, but it is clearly stipulated how much it gets each year, so it is difficult for the state to interfere in its operations as it was designed with a high level of independence with its own board which is not directly under a ministry.
'The NBTC also has its own board with full authority and the legal means to earn its own income. The intention was for the NBTC to be a professional organization that was truly independent from any political interference since the politics of the past was causing chaos, as was seen in the concessions for satellites and mobile telephones which were subject to complaints, including ITV. There was no free competition; it was the patronage system. But there was no freedom either; the analogue media of that time did not dare to criticize the state because if they did, they might be deprived of their concession.’
Section 42 of the Act on Organization to Assign Radio Frequencies and to Regulate the Broadcasting and Telecommunications Services stipulates that the NBTC revenue comes from the annual business license fees to be prescribed by the NBTC at the rate of not more than 2% of the licensees’ income before deduction of expenses, including the fees for SIM cards that we all use at the rate of 10 baht per number. With only this small proportion of the frequency treasure trove, the NBTC’s revenue is already tremendous.
‘The law says that no more than 2% of the business operators’ annual income can be collected, but in fact 2% in the telecommunications business amounts to a lot of money because their gross revenue is in tens of billions. Even though the actual fees are not really at 2% due to a number of discounts, it is still a large amount. The NBTC’s revenue includes fees from the use of telephone numbers as well; when we pay for 40-50 baht for a SIM card, the company has to pay 10 baht to the NBTC. Imagine how many SIM cards have been issued. The annual revenue of the NBTC is 8 to 9 billion baht per year, more than it can spend, which is about 4-5 billion per year, more than Thai PBS, the 24 hour television station that also employs news reporters to work in the field.
'Thai PBS spends just over two billion, compared to the NBTC, the regulator, whose main duty involves meetings and some monitoring, but no production and no 24 hour work. Its main cost is the remuneration of staff and the board at 2-3 billion; the rest covers meetings and seminars which are prolific. TDRI and others have commented critically several times already about expenditures such as foreign travel, hospitality and other problematic items. The advantage and strength of the NBTC lies in its independence from interference according to the design of the law that governs it. But this strength will turn into a weakness and disadvantage. If they are paid more than government officials but function just like then in carrying out the policies of the government, why have it at all?’ said Supinya.
‘There are many issues that the NBTC has accomplished with benefit to the country, such as organizing frequency auctions to gain money for the treasury. In the last two years, the country would probably have suffered without this revenue. To its credit, the NBTC did help the nation. But that is not enough. Its regulatory work is still poor. Many people may view that it is not worth the high expense. Even though frequencies were allocated and money received by the state, that is their duty. Apart from the money that goes to the treasury, the NBTC has revenue directly from fees.
'To change this may require changing the NBTC law to reduce the percentage from two to more than one or one, or to set a minimum ceiling as in the case of Thai PBS of no more than three or four billion according to the calculations. This is because it just keeps going up as more people use mobile phones. The mobile phone networks get richer and so have to pay more in fees to the NBTC. When the law was being drafted, no one thought there would be this loophole. Those who drafted the law had good ideas and high expectations of the NBTC. I myself (Supinya) had a part in pushing this law with high expectations that the NBTC needed to be independent and able to function like in other countries.
During the Yingluck administration, there was also some deference to the government, but not as much as now, because this government has stayed on for four years and its power under Section 44, its power under the coup, is greater. So the NBTC is leaning more towards those in power. In the Yingluck era, there was some deference, as shown in the censorship of the drama Nuea Mek 2, which criticized the government. People started to detect deference towards the government, but it became much more obvious during this government.
'Instead of acting as a buffer between the media and the government, it has become an arm of the government, functioning like the Office of the Prime Minister, which we already have. We already have the Department of Public Relations too. Should the NBTC be functioning like the Office of the Prime Minister or the Department of Public Relations? Is this the right thing to do? People should raise these questions,’ the former NBTC commissioner suggested.