Report on submissions
October 2012
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acma | 1
Contents (Continued)
Executive summary
Meeting the challenge of ever-improving technical standards
Technological innovation issues
Technological migration options
acma | 1Executive summary
This document is a summary of submissions to the Australian Communications and Media Authority (ACMA) in response to its discussion paper Beyond switchover—the future technical evolution of digital terrestrial television in Australia.
The views expressed in the submissions are presented against the set of questions the ACMA posed in the discussion paper. The ACMA believes the summary gives an accurate overview of the submitters’ positions on the issues raised in the ACMA’s questions. While many submissions answered the questions raised directly, some provided opinions.This approach makesit more difficult to identify responses to key issues. The ACMA has analysed those submissions to give what it believes is a fair and accurate representation of responses to the issues raised in each of the questions.
The ACMA recommends that readers refer to original submission documents, using the pages cited in the footnotes, if they wish to access the full context of the quotes provided. The submissions are available on the ACMA’s website.
The ACMA acknowledges that the discussion paper and the feedback provided to questions and issues raised in that paper marks a beginning to its engagement with the prospect of future digital terrestrial television broadcasting (DTTB) technical evolution and transition. Further consultation and analysis will be necessary to any ACMA strategy with regards to new technical standards for the DTTB platform.
Meeting the challenge of ever-improving technical standards
The first section of the discussion paper was concerned with whether the ACMA, as regulator, should do anything to meet the challenge of ever-improving DTTB technology.
The paper requested that submissions address several questions about the ACMA’s activities within the broadcasting technical standards space—both in the sense of specific standards and in a more general sense of what principles the ACMA should apply to introducing any new standard. Submitters were also asked to comment on the discussion paper itself.
Q1. Should the ACMA do anything to meet the challenge of ever-improving technical standards?
Responses largely advocated a more active, ongoing ACMA presence in the standards space. Although, as should be expected, opinions varied as to the nature the ACMA presence should take.
Telstra, FOXTEL, Sony and Consumer Electronics Suppliers Association (CESA) promoted the ACMA facilitating interactions and discussions within industry:
The main focus of the ACMA should be to facilitate and communicate.[1]
(W)e do think that the ACMA should adopt an approach of guiding and supporting industry to develop standards.[2]
ACMA should have a major role in guiding and facilitating standards directions in Australia and the process should not be left to the market.[3]
(W)e would prefer that the ACMA host and participate in the discussions between broadcasters, suppliers and other stakeholders.[4]
In addition to supporting theposition ‘that the ACMA establish an industry working group as a priority’[5], the Ai Group proposed that the ACMA support the August 2012 redevelopment of the receiver standard—‘(t)he ACMA and Government could assist by providing support for that proposal to underscore that the standard has a positive Net Benefit for the Australian community.’[6]FOXTEL submitted that the ACMA consider funding standards development—‘support for Standards Australia from the ACMA could include identifying and encouraging relevant stakeholders to participate in standards development and providing funding for the development of DVB-T2 documentation’.[7]
Media Access Australia (MAA) and Alan Hughes suggested that the ACMA conduct its own research and develop its own standards expertise:
MAA sees value in the ACMA undertaking further research into the advancement of receiver technology, the levels of MPEG-4 capable receivers already in the market and estimates of how this might change over time, based on current consumption patterns and the new generation of receivers being developed.[8]
The Australian Broadcasting Control Board used to inspect broadcasters and monitor the technical quality of transmission. This provided a pool of people who were technically competent on the newest techniques and aware of the issues which reduce quality and cause interference. […] (t)he ACMA […] needs to regain this level of technical expertise. This will mean that they can evaluate new technical standards in the Australian environment.[9]
Alan Hughes, Australian Broadcasting Corporation (ABC) and Australian Communications Consumers Advocacy Network (ACCAN) suggested regulatory intervention and mandating technical standards:
In any future transition to next-generation DTTB technologies, the ABC would welcome the ACMA using its powers under section 130B of the Broadcasting Services Act 1992 to impose well-defined and enforceable minimum receiver standards by way of a legislative instrument.[10]
ACCAN recommends that the ACMA use its regulatory powers to encourage the adoption of next-generation digital terrestrial television broadcast technologies to ensure that all Australia’s FTA broadcasters have the capability to provide essential assistive services to all Australians.[11]
Other responses more generally on ACMA action, called for the provision of adequate (additional) spectrum so that the digital terrestrial television (DTT) platform could develop technically and provide the range of services required by viewers to maintain the viability of the platform:
While it is acknowledged that spectrum allocation is a matter for government, the ACMA’s role in advising the government on spectrum issues means that it is appropriate for it to consult on these issues, develop a position and advise the government accordingly. To facilitate testing of any new platform and service standards, Free TV recommends that the currently unallocated sixth 7MHz DTV channel (Channel A) be immediately reserved to provide space for testing and field trials of new technologies.[12]
Some suggestions, such as the reworking of multiplex licensing to allow shared and managed multiplex, would require legislative change.
Broadcast Australia (BA) suggested that the ACMA undertake its own program of end-user preference research to be informed of the type of DTT platform sought by viewers.[13]
In summary, there was some leaning towards the ACMA using its codes and standards powers and taking an interventionist approach to determining the technology choices made in Australia.This approach would need to meet statutory criteria for the ACMA to exercise its powers.The ACMA’s role includes facilitating the development and deployment of new, innovative technologies that provide consumer benefit.The ACMA does not have a mandate to direct the advancement of a technology merely to safeguard its implementation.
Predominantly, however, the emphasis of respondents was on the importance of the ACMA supporting the development and implementation of industry standards.Respondents noted that the ACMA has a significant role in facilitation and communication and this is expected to ensure that safeguards are inherent in the standards development processes. Early and effective engagement decreases the need for later intervention and allows standards utilisation to meet social policy objectives and decreases implementation costs to industry.
Q2. The approach and scope of this discussion paper.
Those submissions that addressed the question of the paper’s scope suggested that the discussion paper was too narrowly focused on terrestrial television broadcasting and would have benefitted from examining the provision of television content through other platforms such as satellite, cable and on-line (IP):
(W)e are disappointed that the scope of the discussion paper is limited to future technical standards for existing terrestrial broadcasting services. Consideration of digital television technical standards should be informed by broader considerations of future broadcast spectrum use.[…] We acknowledge the need for the ACMA to consider the more immediate issue of the new DTTB standards however we consider that there is scope for the ACMA to consider the longer term implications of IPTV and LTE for broadcast delivery of television.[14]
The ACMA consideration of television standards needs to take a holistic view of the television platform and device ecosystem, noting that consumer demand will be shared across many platforms and devices in the future. It also needs to take account of the NBN and mobile environments, and the reality that viewing devices are becoming more flexible and are no longer necessarily tied to a single platform or service.[15]
BA thought the paper too narrowly focused on the MPEG-4 and DVB-T2 standards:
The scope should be widened to deal with any future technology developments that may warrant consideration for deployment, not only AVC (MPEG4) and DVB-T2 that have been referenced in the paper.[…] Having a framework that is neutral in terms of technology will both make it flexible, future proof, and give certainty in planning for services using new technologies for stakeholders.[16]
Q3. Are there principles that should be codified in regard to regulation of technical migration, within the framework set by the principles for good regulatory process? What factors should these principles consider?
Most responses identified the efficient use of spectrum as an important principle. Spectrum efficiency was understood in two senses. One sense was as allowing spectrum to remain unencumbered and therefore available for allocation for non-incumbent uses:
These principles should be based on the ACMA’s existing spectrum management principles, which focus on efficiency and moving spectrum to its highest value use.[17]
As the switch to digital broadcast has seen a growth in the number of services offered and the resulting near-capacity use of available spectrum, it is important that the management of current available spectrum be used in the most efficient manner.[18]
The growth in demand for mobile and wireless applications has led to a large increase in the demand for spectrum over the last decade and this trend will only increase. This creates pressure on incumbent users, such as broadcasters, to demonstrate that they are using spectrum efficiently and delivering high value services to end users.[19]
Planning for technological migrations should aim to […] (e)ncourage the development and availability of new technologies and services.[20]
The other sense was that incumbents could use their own existing allocations more efficiently through new technical standards, thereby facilitating introduction of their own new and/or innovative services:
For SBS, the availability of new technologies that will allow it to enhance its services and provide them more efficiently and effectively provides a compelling argument for their uptake.[…] It is important that broadcasters have the ability to use their spectrum in the most appropriate and efficient manner. Broadcasters should be able to allocate spectrum dynamically and flexibly according to the content and changing audience preferences.[21]
Policy should be adopted that facilitates the introduction of innovative new services while not compromising principle 2 (above).[22].Milestones for consumer device minimum penetration, minimum time in market and measurement of these should be developed and codified.[23]
Whether the ACMA intervenes in this process or not, we believe it must be proactive in assessing and facilitating opportunities for introducing AD services wherever technical advances provide bandwidth savings.[24]
In order for broadcasters to increase services both mainstream and assistive, efficiencies in the use of current spectrum allocations will need to be found.[25]
Maintenance of present quality of the DTT platform was referred to by BA and Free TV (who also argued for support for the ongoing primacy of the platform).
Existing transmission quality standards should not be compromised—any transition to new technologies should not materially reduce service offerings in terms of range or technical quality to the consumers using a legacy technology during or after technology transition.[26]
The service is free for all Australians, providing valuable public goods such as access to news and current affairs, as well as an investment in the production and distribution of a diverse range of quality Australian content. The maintenance, improvement and future accessibility of these services should be central to the ACMA’s consideration of these issues.[27]
Minimising disruption, either to consumers or to industry, was also a concern in several submissions including the submission from BA.
Consumer disruption must be minimised and consumer investment in reception equipment must, within reason, be protected. The benefits to the consumer, who will have the largest investment in any legacy technology […] private citizens have already spent in excess of $16 billion, and are estimated to spend another $7.5 billion on reception systems and equipment specifically designed to watch and record terrestrially radiated digital free-to-air television.[28]
A light degree of regulation was advocated by Telstra, Ai Group[29] and BA.
Telstra is of the view that industry and market forces should drive technical migration and regulation should only be considered as a last resort. Telstra considers that the principles which the ACMA has already adopted in its Principles for Spectrum Management framework are adequate for dealing with any regulation of technical migration issues.[30]
Mandated consumer devices standards should be ‘light touch’ and should not distort otherwise natural market forces.However, for certainty of all in the industry (including broadcasters and consumers), there should be a clear and defendable evolutionary timetable.[31]
One submission advocated heavier regulation in the form of compulsory standards and the use of simulcasting to encourage consumer take-up of new technologies—followed by cessation of simulcasting to further encourage late adopters to move across.[32]
Harmonisation with international standards was cited by Sony.
(I)nternational standards should be the basis for the development of Australian standards for DTTB. Harmonisation of standards should be a key objective of the standards setting process.[33]
Technological innovation issues
The second section of the discussion paper focused on the issues and challenges the technological evolution raises for Australian free-to-air television and whether there is pressure for change. This section examined the context within which technological change might occur—whether that might be the international development (and therefore the availability locally) of particular standards or whether it be the technological composition of the existing receiver population or the profile of the existing broadcasting chain.
Specific questions that submitters were asked to respond to included:
Q4. What issues technological evolution raises and whether there is pressure for change in Australia.
Consumer demand for new, innovative or additional services was mentioned by a number of submitters.
Consumer demand for innovative and higher quality services will remain an importantdriver of technological evolution.[…] The benefits of policy settings which encourage more efficient use of spectrum by FTA providers include enabling them to return excess spectrum to the market so that it can be allocated for new and innovative services.[34]
It is important that the technical capability to provide assistive services does not interfere with the provision of current services. The adoption of MPEG-4 alongside existing MPEG-2 technology on current multiplexes provides both community and industry benefits, allowing for the provision of new services over MPEG-4 while allowing current services to continue over MPEG-2. […] Therefore, it is ACCAN’s view that adoption of next-generation digital technologies such as MPEG-4 should be implemented in the near future.[35]
Telstra notes that consumers have a growing desire to view content in a non-linear fashion and at locations outside the home environment. Some are also seeking more content, higher definition content, and new services like 3D. These demands are creating pressure to progress the delivery of services over fixed and mobile broadband telecommunications networks and also to improve the capacity of over-the-air networks.[36]
For SBS, the availability of new technologies that will allow it to enhance its services and provide them more efficiently and effectively provides a compelling argument for their uptake. This includes providing more services that respond to the increasing cultural and linguistic complexity of Australian society.[37]
Other submissions placed the demand for new services within the context of the need to compete with other platforms:
In the general public interest it is vital that this delivery platform continues to represent a high value proposition to end users. Hence the platform needs to be able to
- Increase the number of free-to-air television channels it carries as soon as practicable to enhance the entertainment and information utility Australians can derive from their unprecedented investment in digital terrestrial television reception systems and equipment.[38]
Planning for the evolution of these services must recognise the place of free-to-air terrestrial television services in Australia. Although there are a growing number of platforms for the delivery of audio-visual content, free-to-air television is the only service that does not require a paid subscription of some form. […] The service is free for all Australians, providing valuable public goods such as access to news and current affairs, as well as an investment in the production and distribution of a diverse range of quality Australian content. The maintenance, improvement and future accessibility of these services should be central to the ACMA’s consideration of these issues.[39]