Sky has argued that an "ever expanding array" of valuable content is now on offer in its response to Ofcom's review of public service broadcasting.

The pay TV operator used its submission to the review to reject the regulator's view that PSB provision is under threat. "We disagree fundamentally with the pessimistic diagnosis contained within the consultation document, which is at odds with the actual consumer experience of a competitive, dynamic marketplace delivering real benefits with ever more choice, innovation, value and plurality," said the statement.

"Sky believes that, instead of looking for new ways to intervene, government and regulators should remove outdated regulations, safeguard incentives for private investment, and step back and allow the market to deliver. Existing PSB institutions may be threatened by the pace of change, but it is viewers who are, and will continue to be the winners."

Among several particular points made by Sky, the company said the BBC should not be bidding for films and US television series. It should instead be "focusing first on those areas that the market is not serving well, where there is a real deficit in provision".

"The BBC should step back entirely from other areas," said the submission. "In particular, there is no justification at all for the BBC using public money to outbid commercial broadcasters for Hollywood films and US series.

"The fact that the BBC continues to spend a £100m a year on acquired programmes and appears to be increasingly aggressive in this area is a clear signal that its existing remit and governance structure is fundamentally flawed."

In addition, the company opposed the prospect of PSB obligations being removed from ITV and Five while they are allowed to retain gifted spectrum and prominent EPG positions. "After all, spectrum used for terrestrial television broadcasting – including gifted DTT capacity - is scarce and remains highly valuable, as Ofcom points out frequently in the context of the Digital Dividend Review."

Sky believes Ofcom has given too little consideration to publicly valuable pay-to-view content such as the "14 dedicated news channels, over 50 channels catering to foreign language or ethnic audiences, 15 channels dedicated to religion and faith, and 29 channels for children" carried on its satellite service.

"...Ofcom appears to be arguing that this method of funding public service content should be discounted because only content that is made available 'free-to-view' can be considered as PSB... This makes no sense. People are accustomed to paying for entertaining, informative and educational content in other areas and TV is no different. Newspapers, books, DVDs and downloads of films, TV content and music from the internet are all routinely paid for directly by consumers."