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BREMA's Comments on the Radiocommunications Agency Strategy Document, "Mapping the Future of Convergence and Spectrum Management" |
3rd August 2000
Laurence Green
Radiocommunications Agency Strategy Unit
11B/20C Wyndham House
189 Marsh Wall
LONDON
E14 9SX
1. BREMA welcomes the opportunity to comment on the Report commissioned by the Radiocommunications Agency.
2. BREMA represents companies manufacturing consumer electronics products in the UK. Almost a quarter of television production in the European Union is from UK factories. Over half the production is exported. 3.7 million television sets were produced in the UK in 1999 and a positive trade balance of £115 million was achieved.
3. The successful launch and development of digital broadcasting in the UK and the world first in launching digital terrestrial television broadcasting, have given all UK based interests a unique leadership opportunity. The Report illustrates the broader thrust by UK Government to be at the forefront of the exploitation of the Internet and the increasing versatility of mobile telecommunications.
4. BREMA member companies have a direct and immediate interest in the development of digital television, which is clearly seen as a major focal point for the convergence of broadcasting, telecommunications and information technology. A number of BREMA member companies are equally active in the production of TV, VCR, mobile ‘phones, radio and a range of telecommunications and IT products. This response recognises that breadth of interests.
5. The rapid development of digital television (DTV) mobile ‘phones and the Internet, clearly indicates that broadcasting, telecommunications and other services will be provided on a number of platforms and be platform agile. The Report has highlighted how these, and the technologies that support them, will proliferate during the next ten years in ways that are difficult to predict but for which some planning assumptions must be made now.
6. BREMA has already made submissions to the recent consultations by the ITC/OFT/OFTEL on digital television and has responded to the Government development of the Communications Reform White Paper. These responses are enclosed. These documents also deal with content and intellectual property rights, which are referred to on p.21 of the Report.
7. These responses should be seen as essential background to the BREMA comments on "Mapping the Future of Convergence and Spectrum Management". The scope of BREMA’s comments are primarily focused on the spectrum needs which are required to facilitate the changeover from analogue to digital television broadcasting.
8. The initiative of the Radiocommunications Agency to commission "Mapping the Future of Convergence and Spectrum Management" is greatly welcomed. We agree with the comment in the Foreword by David Hendon that the Scenarios cannot be treated as predictions but as insights into potential Scenarios. These can help to narrow down the options of the likely Endstate which may be reached by the end of the decade. It follows that the Government and the regulatory agencies should concentrate on preparing legislation and structuring the regulatory authorities to promote new services and technologies based upon open standards (p.22); and to ensure the appropriate and legitimate exercise of content control and security enforcement.
9. Although it is not possible to forecast the communications environment ten years hence, it is reasonable to assume that the ubiquity of television and radio based upon Public Service Broadcasting (PSB) will continue to be a major factor during the decade, and, whatever the outcome, the current primary reliance upon terrestrial broadcasting will continue as a significant public expectation. Whilst subscription digital services will continue to grow, there will remain at least 40% of UK households who will not wish to subscribe to pay television and will need to be persuaded to move to digital television. This places a heavy responsibility on the Public Service Broadcasters to provide new high quality services available only on digital television. For those reluctant to move on grounds of cost, there is the potential for subsidy (p.36 B5, Appendix III p.32) which could be provided through the sale/auction of spectrum. However, only a limited amount of spectrum might be released after analogue closedown; revenue might have to be diverted from the release of MOD spectrum (p.20, 29 and 30).
10. We would expect that PSB will also be available on other platforms as envisaged in the four 2010 Scenarios i.e: Internet Convergence, Digital Islands, Total Mobility and Broadband Revolution. However, we believe that these Scenarios, possibly in a variety of permutations, will co-exist in a competitive environment during that period.
11. Nevertheless, broadcasting is an inherently efficient means of one-to-many communications and, when judging the scenarios in the context of the more detailed consideration of Annex IV. 6, it is clear that in the decade under consideration the minimum spectrum requirements of Scenario A (Internet Convergence) will need to be supplemented by the significant expansion foreseen in Scenario B (Digital Islands). Our support for this aspect of Scenario B does not imply support for the concept suggested by "Digital Islands". Rather, we envisage terrestrial broadcasting and its extensions such as interactivity, will be dominant during the decade. Other technologies and platforms should co-exist interoperably, as envisaged in the current EU Commission consultations, and the success of commercial offering will determine alternative Endsates.
12. The Report correctly identifies that there will be a demand for additional spectrum for DTV to provide Internet access (p.28 and Appendix IV.6), a radio return channel (p.26, 29) and near video-on-demand (Appendix IV.6.3) which is already available via satellite, to which should be added High Definition TV. We note from Annex IV.I that return paths and mobile use of DTV are options being considered by the ITC.
13. The consumer is concerned with content, cost and convenience. Whichever technology or combination of platforms which provides this, will dominate but this is unlikely to be decided within the decade. Indeed, it is likely that consumer confusion could hinder the development of dominance.
14. The presence of television in almost every UK household should make it the ideal candidate for general access to the Internet, games and interactive services. Although interactive television will become much more prevalent there will remain a separate requirement for purely personal computer applications, which experience has shown have a distinct domestic role/location (p.21 and Annex III, p.12).
15. "Whether current service definitions will make any sense by the end of the decade" (p.7), our current knowledge of existing and emerging technologies enables us to make some short term predictions. It is clear that for the first half of the decade at least, the primary platforms for broadcasting, whether analogue or digital, will utilise the existing allocations. The Government has identified, in essence, that existing viewers should not be deprived by the changeover to digital television broadcasting., BREMA has already made the case to ITC/OFT/OFTEL and DTI/DCMS that provision must be made to allow for the use of set-top aerials. This together with the extension of services such as High Definition Television, may require most, if not all, of the current UHF allocation. A review of spectrum in the 2.4 GHz ISM Band is the subject of a separate RA consultation, to permit local in-building re-distribution, preferably unlicensed, using wireless systems such as Bluetooth, HiperLAN 2 or HomeRF. However, a significant part of the population will find such re-distribution systems to be an expensive imposition merely for them to maintain current services and flexibility.
16. We agree with the conclusions reached by the RA team that spectrum management needs to be more flexible, responsive and give consumers, broadcasters and manufacturers confidence in investment (indents on pages 9 and 31). We also agree the need for international harmonisation on spectrum issues (indents on pages 10 and 35). But we believe that the conclusion given at the top of page 11, that certain broadcasting allocations will not be workable in future, is unlikely to rise during this decade, although we must prepare for this eventuality thereafter. This view is based not least on the assumption that the inertia of the current broadcasting system based upon PSB is unlikely to permit major upheavals in the public acceptance, although government decisions may be required within this time-scale that look beyond it. For this, and reasons stated earlier, we do not consider that the UHF TV bands can be made available for new uses (2nd indent page 11).
17. The proposed measures on assignments and licensing indented at the bottom of page 11 are supported.
18. Turning specifically to Digital Radio and its potential growth, paragraph 1 of Appendix IV.6 states that "The advent of Digital Radio has opened up some flexibility in that area (spectrum) but is not expected to have a significant impact on demand for spectrum". We believe that this considerably under estimates the potential for DAB. The comparatively high cost of product is now being eroded and this will continue, thus opening up the market. In addition to the "radio services" which are expanding rapidly, there is also considerable potential for new services and business applications. These new services will be a significant part of Convergence and will undoubtedly justify an increase in spectrum allocation.
19. BREMA support the comments made by the Radiocommunications Agency in their Annual Report (UK Spectrum Strategy 2000):-
"Industry has expressed concern about the likely coverage of local Digital Radio services that may be possible using the current spectrum allocation in Band III. The Radio Authority and the BBC are currently examining the need for additional spectrum before making a case to the Government for more frequencies".
"Meanwhile, it is premature to consider the possibility of closing analogue sound broadcasting services and retrieving spectrum for other uses, although this remains a long term objective".
20. It is our general view that as an overall response to developments in communications, the questions, conclusions and recommendations reached by the RA are logical and reasonable and that, in reaching these the RA and its contributors, have lucidly explained the difficulties, implications and uncertainties, that we need to face over the next decade. We also agree that predictive means, other than the traditional scenario planning, are necessary and that Scenario Analysis such as Future Mapping appears to provide a potentially flexible and effective technique.
21. As indicated earlier, the BREMA response primarily addresses the requirements that arise in the period up to switchover from analogue to digital television broadcasting. This assumes an Endstate which could be between 2006 and 2010 based on statements made by the Secretary of State for Culture, Media and Sport.
22. Government has identified analogue closedown, and digital television, as central to the communications revolution; and that television is the most feasible way of providing further digital services, such as Internet connection (see Digital TV, Policy Guidelines 25th November 1999). The achievement of this Endstate is therefore crucial to any mapping project and needs to be considered against a TV set market in the UK, currently at record levels of more than 5.5 million analogue units per annum. Such obstacles are raised in the enclosures and need to be addressed if a mapping scenario beyond this Endstate is to have credibility.
23. BREMA welcomes the Report commissioned by the Radiocommunications Agency, which greatly helps to narrow down the options of the likely Endstate, albeit some alternative options are likely to be proposed in response.
24. Our focus is primarily on the development of digital television which has been identified as central to the communications revolution. The Endstate of switchover form analogue to digital television has been provisionally stated as 2006 to 2010. The implications and advantages of establishing a switchover date of say 2010 need to be explored.
25. We do not consider that there can be an assumption that any part of the UHF TV bands can be made available for non-broadcast applications (paras. 12, 16).
Yours sincerely
H Peltor
Director
| Enclosures: | 1. BREMA response to Joint ITC, OFTEL and OFT Consultation. |
| BREMA 3 August 2000 |  |
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