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Digital TV Group's Comments on the Radiocommunications Agency Strategy Document, "Mapping the Future of Convergence and Spectrum Management" |
THE FUTURE OF COMMUNICATIONS AND E-COMMERCE
Comment on the Radiocommunications Agency commissioned report "Mapping the Future of Convergence and Spectrum Management" by the Digital TV Group.
Background
The Digital Television Group (DTG) was established in 1996 to help the industry co-ordinate the introduction of digital terrestrial television services in the UK. Its principal objective was to establish a common set of standards and procedures for the introduction and launch of DTT services. The main output from this work was the publication of the D-Book.
Its membership has since grown to over 100 organisations representing all sections of the digital television industry including manufacturers, broadcasters, network operators and consumer groups. Its scope now includes supporting the development, adoption and promotion of common digital standards across all digital television platforms, as a means of developing a healthy competitive market in consumer goods. It provides a neutral and independent forum where technical issues and other matters of mutual benefit can be resolved.
The work of the Group is now focusing in particular on resolving issues that might impede a smooth and timely transition from analogue to digital terrestrial TV.
We are responding to the paper on behalf of the television industry, whose broadcast constituent is worth at least £6 billion and which consistently provides the exchequer with at least £300 million p.a. in levy payments. Its newly established digital terrestrial pay TV sector is estimated to be worth £2 billion and has over ¾ million subscribers after 18 months of operation, who generate substantial income per subscriber, probably more than that generated by mobile phone subscribers.
Terrestrial television also supports a manufacturing industry that delivers 5 million TVs to the market each year. Viewers watch over 14 hours of terrestrial television each week. We therefore are strongly opposed to any study that assumes as a starting point that better and more profitable use could be made of the uhf spectrum.
THE DTG RESPONSE
Concerns about the use of Scenario Planning
We have serious concerns about the use of scenario planning in that it channels debate along preconceived paths. As stimulus to debate, scenarios can be helpful but there is a danger that they can become "self-fulfilling prophesies." We are concerned that they should not be seen as alternative outcomes by government and other readers.
We also have concerns about the representation of the 25 industry representatives who debated the scenarios and contributed to the report. Who were they and what evidence is there that they were truly representative of the industry. How many represented broadcasting and how many represented the consumer manufacturing industries, for instance? Our evidence is that very few of our members have been aware of the consultation until very recently and have not played an appropriate part in the preparation of the report.
Public Service Broadcasting
There is a strong tradition of public service broadcasting in the UK that is regarded with envy around the world. This applies not only to the BBC but also ITV, Channel 4 and most recently Channel 5, which are bound by the terms of their licences to satisfy ITC requirements for programming.
This public service ethos is synonymous with terrestrial broadcasting. The majority of viewers believe these services are available to them as a right. Many of these channels have strong regional commitments, which are not available on satellite and are available on cable only as a bonus (in the sense that cable services are only available on subscription).
Analogue terrestrial broadcasts, besides being free-to-view, are also available to many consumers with very low capital outlay. A small colour TV may be purchased for well under £100 and, in most cases, may be received on a built-in set-top aerial. It is thus available to young singles in rented accommodation, the elderly and many socially disadvantaged sections of the community.
Reception on portable TVs is also very widespread in second and third TVs in the household, in kitchens, master bedrooms and children’s rooms. Consumers who are accustomed to portable reception will not easily be persuaded to change to any digital platform unless it offers the same freedom and similar prices. That will be a significant challenge for future development; there is a significant risk that digital television could become regarded as a retrograde step by a large segment of the population unless these issues are addressed.
The Speed of Change
It is almost universally true that revolutions in the way we live take much longer than advocates predict. The take-up of most new consumer products follows an initial exponential curve and normally takes about 10 years to achieve 50% penetration. Faster take-up can be achieved in the initial phase by the service-provider heavily subsidising the capital cost of the equipment. The investment is paid for by increased subscription charges.
Whilst such mechanisms have been successfully applied to the early adopter market in digital television, it is by no means certain that it can be universally applied and there are major forces amongst manufacturers that are working to maintain conventional retail markets.
Convergence and the Needs of Broadcasters
Broadcasting, defined as "the distribution of multimedia content on a one-to-many basis" is a cheap and efficient mechanism that will not be supplanted by internet protocols and dedicated two-way channels. Convergence will add to, rather than replace, broadcasting.
Digital terrestrial needs additional spectrum to complete coverage and expand the service proposition, which can be provided by the spectrum released when analogue is switched off. This includes improved coverage to portable TVs (over half of all TVs sold) and new mobile applications. Spectrum planning needs to cater for high definition television, which is likely to become a commercial reality in the second half of the decade. To remove that spectrum to other uses will be vociferously opposed by the broadcasters. The "refarming" of the patchwork of channels for use for non-broadcast purposes will be very, very expensive.
It should also be remembered that the development of digital television has required a massive investment by broadcasters. It is this investment which enables the prospect of "refarming" of analogue spectrum and broadcasters have a legitimate claim that they should be given priority in any re-use of that spectrum.
High Definition
Mention is made in this scenario of a prospect for multiple standards remaining. We are amazed to find that there is no specific mention of high definition television. In Europe in general, a failed early attempt to introduce high definition analogue television has left many companies with polarised views and there is little current interest in developing HDTV services. However, it is a mistake to think that because it was wrong in the late eighties and early nineties, it will be wrong for all time.
The failure of early attempts to introduce high definition TV was caused by the failure of the broadcasters to understand that people do not buy new technology for that technology’s sake, they buy new technology for the expanded benefits it offers. If the technology is perceived to offer little more than what is already available it is bound to fail. The use of a new technology combined with unique new services that only that technology can provide has an infinitely greater chance of success.
High definition broadcasting in the USA has, up till now, been a failure in market terms because the 8VSB modulation system chosen has proved to be inadequate. But sales of high definition displays have been considerable in spite of the broadcast problems and are used by American consumers with programme material originated from DVD players.
High definition will, we believe, come to the fore again as large flat-screen display technology moves into everyday consumer use, probably in the second half of the decade. Provision needs to be made for spectrum to carry high definition broadcast services when the business case for it comes together. Following our own argument of using the most appropriate medium for the task, we believe that satellite transmission offers the best means of conveying high definition services to the home. This will initially be seen, probably within just a year or two, as a specialist sports service to pubs and clubs and this showcase will drive a consumer market forward as prices decrease.
What’s the Hurry?
Finally, we would ask why the RA believes that refarming of spectrum has such urgency? The report has a breathless or even hysterical tone to it, which is dangerous in such an important task as the allocation of a scarce national resource. There is a perceived / implied pressure for early changes which needs justification.
The broadcast industry has been well used to change over many years and there is clearly a need to evaluate convergence technologies at this time. But the future is not clear. We believe that there is a risk of a "knee-jerk" reaction, which proves later to have been premature. We strongly recommend that great care and sufficient time is taken to be sure of future developments before any irrevocable decision on spectrum allocation is taken.
It should also be remembered that the development of digital television has required a massive investment by broadcasters. It is this investment which enables the prospect of "refarming" of analogue spectrum and broadcasters have a legitimate claim that they should be given priority in any re-use of that spectrum.
The DTG Vision
The report sets out four possible scenarios, which we comment on below. However, these scenarios precondition the debate and we do not believe they are representative of the whole spread of opinion. In particular, all the scenarios appear to have been drawn up by enthusiasts and supporters of new technology and the voice of conservatism and consumer lethargy is completely lacking. Therefore we offer our own tongue-in-cheek scenario 5, which we have called "Conservatism Rules OK" to stimulate discussions on the possibilities that the mass population are not so taken by new services as are the contributors to the study.
Scenario 5 is just as right, and just as wrong, of course, as scenarios 1 – 4; it will have an element of truth. The future of home-entertainment systems lies with plurality. Each distribution mechanism has inherent strengths and weaknesses and inherent costs. We must allow systems to develop which trade on the inherent strengths of each platform so as to make best use of scarce bandwidth resources.
The market-place is in many ways the best way to establish the benefits of new technologies and delivery methods. If consumers do not perceive substantial benefits they will not buy them. However, there is a real risk of tried-and-tested methods of delivery being fragmented into a large number of less satisfactory vertical markets, which the consumer pays more for a less satisfactory experience.
DETAILED COMMENTS ON THE REPORT
Section 2
Although Section 2 is intended only as a general introduction to the problems of predicting future spectrum requirements and the methodology employed by the study, it also contains a key statement, which is worth drawing into the conclusions:
"Convergence does not imply that all media will merge into a single, integrated, all-purpose service; instead, each pre-convergence technology will grow and acquire new features and interface more easily with other technologies, but still remain separate and distinct."
Convergence is the application of technology developed in one sphere to another sphere. We agree entirely that it does not imply a single all-encompassing medium as an endgame. Indeed, all past and present evidence suggests that technology development will add to, rather than subtract from, the diversity of products and services.
New products and services impact on existing ones, of course, and may have a significant effect on existing business models but it is rare for a new technology to completely supplant the old.
Comments on Section 3
Scenario 1. Internet Convergence
It is a mistake to think that internet protocol (IP) will become all-pervasive, despite what the protagonists say. Broadcasting (defined as the carrying of content of all sorts to consumers on a one-to-many basis) is a most efficient way to carry the nation’s collective entertainment experiences to the consumer. Multichannel television has offered choice to consumers. Broadband internet and V.O.D. offer the possibility of augmenting this experience but it is an inefficient way of carrying television programmes to large simultaneous audiences. Future home entertainment systems will make use of both techniques, using the most effective and cheapest method to deliver content to the consumer.
Scenario 2. Digital Islands
We fundamentally dispute the assertion that users are "attracted to the security and convenience of proprietary closed networks or ‘walled gardens.’ " Security and convenience are two of a large number of factors that make up a brand proposition. They are not the exclusive domain of closed networks. The use of public (open) standards is a core principle of the DTG and what it stands for.
The most popular brand in entertainment remains the BBC, which is neither closed nor, in the main, proprietary. Proprietary consumer equipment restricts the viewer from changing his mix of entertainment services and is a serious impediment to the CE market. It should be discouraged in legislation.
Many viewers, estimated at between 40 and 60% of the population, will be satisfied with free-to-view television and must be catered for in planning. Television services need to allow for people in rented accommodation, young people and others without permanent homes, the socially disadvantaged and those without credit-worthiness.
"Walled gardens" have their uses in providing a selected and controlled experience, but should not restrict the consumer from venturing out into the wider internet experience if desired. The "walled garden"proposition often involves a degree of fraud, promoting e-mail and interactivity but failing to differentiate the proposition from the open standard internet, which is what most consumers think they are buying. We believe there should be tighter control of advertising to clarify this difference to the customer.
Scenario 3. Total Mobility
The success of mobile phones is undeniable but the use of such techniques for internet access or for high speed data such as television is entirely unproven. 3G networks will clearly have a significant place in future mobile communications but remain an inefficient way of delivering content to fixed locations and are thus a waste of a scarce resource.
Current thinking is that UMTS has a limit of 300 – 400kHz for mobile use, which is ten times insufficient for general television. Logic says that fixed and mobile communications are different and should have different, designed for the purpose, technologies to optimise resources. There are other ways of achieving return cannel communication from fixed home-situations. UMTS could, however, provide the return data path to mobile TV applications in conjunction with a DVB-T forward path for TV content.
There is a need for greater clarity between the home –access network (HAN) and the in-home local network (HLN). The HLN is considered a vital part of future planning amongst CE manufacturers. Home entertainment systems increasingly consist of a large number of set-top boxes accessing different networks, providing storage and distribution to multiple TVs around the home.
The future lies with sharing resources over a HLN. The wiring of the home to carry digital signals, for example using plastic optical fibre, is both difficult and expensive for the consumer and the industry view is that a wireless home network will provide the consumer with the most "user friendly" means of interconnection. Considerable bandwidth is required to enable encoded streams to be distributed to multiple users in a home. Although the powers are relatively low, care must be taken to avoid interference between independent households in flats and apartments.
Scenario 4. Broadband Revolution
This proposal ignores the reality that fibre-optic does not currently extend all the way to the home and would require a massive investment to do so. Neither is the server capacity available to sustain it and it remains to be proven whether customers would in general be prepared to pay for the investment necessary to receive entertainment which they currently can receive for free.
Whilst entertainment habits will undoubtedly change as competition to broadcast entertainment builds, it is folly to think that broadband internet will entirely replace it. Television viewing is predominantly a collective national experience. For each fan to watch "East Enders" by demand from a distant server whenever it was personally convenient would not only be a very expensive way of delivering this content but also ignores the fact that it is a collective experience.
Broadband adds the freedom to view at another time to those unable to watch the broadcast but it should be seen as augmenting rather than replacing the broadcast experience. Broadband adds new entertainment and educational experiences, but it will not replace broadcast services.
A New Scenario - Scenario 5. Conservatism Rules OK
As mentioned in the introduction to this section, we believe the scenarios discussed above appear to have been drawn up by enthusiasts and supporters of new technology. The voice of conservatism and consumer lethargy is completely lacking. Therefore we offer our own tongue-in-cheek scenario 5 to stimulate discussions on the possibilities that the mass population are not so taken by new services as are the contributors to the study:
Consumers prove to be profoundly apathetic to WAP phones, GPRS and UMTS, preferring to stick with gsm for audio conversations and text messaging. There is an adverse reaction against being inundated with messages from shops and services within the cell they are in, the limitations of a "silly little screen" and the extra cost of advanced phone rental.
Penetration rates for subscription TV level off below 50% of households and, whilst idTVs make steady inroads into the market, the number of analogue TVs in use remains stubbornly at 69 million. Analogue TV sales continue to dominate the commodity small screen market because of their lower price and because consumers rapidly discover that they cannot receive digital on a set-top aerial.
Hard disc video recorders are a success and achieve penetration of 50% of households in seven years but analogue VCRs continue to sell at rock-bottom prices and the population increases to 50 million. Stand-alone internet boxes working into analogue TVs become cheap and popular for browsing and email messaging but a significant proportion of the population amongst young people in rented accommodation, single parent families and the elderly, remain stubbornly outside the digital revolution.
Consumers resistance to the switching off of analogue TV develops amongst a significant segment of the population as the reality dawns that their 69 million analogue TVs will shortly cease to work.
Section 3.3 Events and Their Linkage to Endstates
Mention is made in this section of consensus events that are highly likely to be good assumptions on which to base a strategy. Top of those listed is:
"Low-cost terminals (of many types) are available early, to make it easy to subsidise/ give them away to get new subscribers on new services. Government and industry will work together to make them widely available."
Whilst it is undoubtedly true that subsidised consumer equipment can be used to achieve a high level of take-up amongst early adopters, the extent to which this mechanism can be applied to achieve a total changeover needs to be questioned.
In television, the cable operators have traditionally supplied the consumer unit on a rental basis as part of the service subscription. Digital satellite and digital terrestrial operators have also found it beneficial to provide set-top boxes at no capital cost to the consumer in return for an increased subscription level. However, the number of units is relatively small. The greatest number are those supplied to subscribers to the BSkyB platform, some 3 million over two years and this has had a serious impact on the profitability of the companies concerned, albeit within a longer term business plan.
It remains to be seen whether one can extrapolate a technique, which has validity in the early-adopter market, all the way to 100% penetration. Certainly, sales if analogue televisions are currently as high as they have ever been. Figures are not available on how many of these are used with a set-top box but probably no more than 50% and the major CE manufacturers are actively working to develop a market in integrated digital TVs.
Subsidised, low-cost "converter boxes" could also have their place in the final stages of switchover to digital but will be strongly opposed by CE manufacturers in the middle years.
The DTG has carried out a study of the prospects for converter boxes for the DTI, which may provide further insight for RA predictions.
Section 3.4 Interaction of the Scenarios
The report makes an important statement on the distinct advantage of broadcast communication:
"But the Internet is not the only way that communications is organised and provisioned. Wireless networks offer many services that have nothing to do with the Internet. The broadcast TV networks do not go away in this decade; they will surely still be here in 2010; terrestrial and satellite broadcasting are inherently efficient solutions for one-to-many communication. However, there will be a great deal of overlap and reuse in content between the Internet, interactive DTV, and traditional broadcast TV."
Broadcasting is the best way of conveying entertainment to users on a one-to-many basis. Interactivity will undoubtedly develop as a useful added feature of broadcasting but we profoundly believe that the core of people’s entertainment in the future will remain linear viewing of television in a conventional manner.
The future strength of broadcasting lies in it remaining a mass audience entertainment medium but one that provides the jumping off point to multimedia experiences. The key lies in developing programme-related multimedia experiences from the current primitive experimental stage to become a new, sophisticated branch of the industry. That is quite distinct from the development of internet on television, which uses the TV screen but is otherwise unrelated to broadcast media.
We believe that are great advances to be made using broadcast television in conjunction with broadband wired distribution. The objective would be to provide the means of moving seamlessly from broadcast content to on-demand services where the viewer requests additional, individual information. Always-on (xDSL) technology is the key to this. One can see it as a powerful addition to broadcast advertising, for example and a method for the broadcaster to lead the viewer into pay-per-view programming. The broadcast medium thus becomes a showcase for other services delivered by a one-to-one mechanism.
There is an implied assumption that digital terrestrial broadcasting is fully developed, which is far from the case. The present use of "taboo channels" in the uhf spectrum has permitted six-multiplex coverage reaching approx 65% of the population. Plans currently being implemented will raise this to perhaps 80 – 85% but it is not thought possible to extend this to universal coverage without additional spectrum.
It was accepted at the Chester planning conference that field strengths should be raised to 7dB down on analogue to give equivalent field strengths and most other countries that are to start DTT services are planning for field strengths no more than 10dB below analogue. The field strength of digital services in the UK is in most cases 20dB below analogue and is insufficient to be used with portables and set-top aerials. More spectrum will be needed to achieve the Chester criteria.
In addition spectrum is needed to develop the platform to compete effectively with other forms of broadcasting. Not to provide it would condemn terrestrial broadcasters to a second-class existence.
That spectrum is most elegantly provided by channels released from analogue broadcasting. Those channels have been optimised for high power broadcasting and have been coordinated with our close European neighbours.
To redeploy these channels for other non-broadcast purposes is fraught with difficulties. The re-grouping of remaining television services to release a useable block of spectrum would have to be done within existing receive aerial bands, coordination with Europe would be a lengthy and difficult exercise, the cost of regrouping would be high and the cooperation of disenfranchised broadcasters correspondingly low.
The DTG strongly recommends that future use of released spectrum is directed towards applications that can occupy the existing network plan.
Comments on Section 5
One can but agree with the key messages from the scenario analysis that spectrum policies need coherence and flexibility; that reallocation and ‘refarming’ needs to proceed at a faster pace and that there is likely to be increasing demand for spectrum above 2GHz.
However, "reallocation and refarming" implies that existing users are displaced and the report does not offer suggestions on how that would be possible, except to suggest "tradable spectrum licences."
In practice, spectrum usage implies a body of users, who have invested in equipment and operate businesses that are, to a greater or lesser extent, dependent on that spectrum. Where that business involves consumers, as in the case of broadcasting, the public expect continued availability of services on that spectrum to the end of the natural life of their receivers, which may be a very long time indeed.
It is vital for any consumer industry that there is adequate stability. Consumer confidence is a fragile thing and frequent changes, and confusing propositions can be devastating for any manufacturer. The current changes in television, with conflicting information from each of the platforms, has caused great uncertainty and has contributed to the continued high sales of analogue equipment.
We believe that any ‘refarming’ or re-use of spectrum must make provision for the replacement of services using it and must make provision for the costs of replacing obsolete equipment. How this is done is a matter of conjecture – the spectre is raised of consumers saving their old analogue TVs or mobile phones so they can claim a replacement allowance! The point is that there is a natural replacement cycle for equipment. Where such equipment is purchased by members of the general public, that cycle may be long.
We dispute the assertion in section 5.2.1 that "certain allocation categories (in particular fixed, mobile and broadcasting) will not be workable in the future." It is particularly important that spectrum is used for the most appropriate purpose, and not allocated to the licensee with the biggest cheque-book. That is not to say that categories or allocations are fixed for all time – changing technology and demands requires periodic reassessment – but the goal should be improved efficiency in the use of spectrum and not just maximising income from spectrum auctions.
It should also be remembered that the development of digital television has required a massive investment by broadcasters. It is this investment which enables the prospect of "refarming" of analogue spectrum and broadcasters have a legitimate claim that they should be given priority in any re-use of that spectrum.
SUMMARY
The DTG has produced this response on behalf of the television industry, whose broadcast constituent is worth at least £6 billion and which consistently provides the exchequer with at least £300 million p.a. in levy payments. Its newly established digital terrestrial pay TV sector is estimated to be worth £2 billion and has over ¾ million subscribers after 18 months of operation, who generate substantial income per subscriber, probably more than that generated by mobile phone subscribers.
Terrestrial television also supports a manufacturing industry that delivers 5 million TVs to the market each year. Viewers watch over 14 hours of terrestrial television each week. We therefore are strongly opposed to any study that assumes as a starting point that better and more profitable use could be made of the uhf spectrum.
We have serious concerns about the use of scenario planning in that it channels debate along preconceived paths. As stimulus to debate, scenarios can be helpful but there is a danger that they can become "self-fulfilling prophesies." We are concerned that they should not be seen as alternative outcomes by government and other readers.
We also have concerns about the representation of the 25 industry representatives who debated the scenarios and contributed to the report. Who were they and what evidence is there that they were truly representative of the industry. How many represented broadcasting and how many represented the consumer manufacturing industries, for instance? Our evidence is that very few of our members have been aware of the consultation until very recently and have not played an appropriate part in the preparation of the report.
There is a strong tradition of public service broadcasting in the UK that is regarded with envy around the world. This public service ethos is synonymous with terrestrial broadcasting. The majority of viewers believe these services are available to them as a right. Many of these channels have strong regional commitments, which are not available on other platforms.
Analogue terrestrial broadcasts, besides being free-to-view, are also available to many consumers with very low capital outlay and are the only practical means of TV access to low income groups and the socially disadvantaged. Reception on portable TVs is also very widespread in second and third TVs in the household, in kitchens, master bedrooms and children’s rooms. Consumers who are accustomed to portable reception will not easily be persuaded to change to any digital platform unless it offers the same freedom and similar prices.
It is almost universally true that revolutions in the way we live take much longer than advocates predict. The take-up of most new consumer products follows an initial exponential curve and normally takes about 10 years to achieve 50% penetration. Faster take-up can be achieved in the initial phase by the service-provider heavily subsidising the capital cost of the equipment. The investment is paid for by increased subscription charges.
Whilst such mechanisms have been successfully applied to the early adopter market in digital television, it is by no means certain that it can be universally applied and there are major forces amongst manufacturers that are working to maintain conventional retail markets.
Broadcasting, defined as "the distribution of multimedia content on a one-to-many basis" is a cheap and efficient mechanism that will not be supplanted by internet protocols and dedicated two-way channels. Convergence will add to, rather than replace, broadcasting.
Digital terrestrial needs additional spectrum to complete coverage and expand the service proposition, which can be provided by the spectrum released when analogue is switched off. This includes improved coverage to portable TVs (over half of all TVs sold) and new mobile applications. Spectrum planning needs to cater for high definition television, which is likely to become a commercial reality in the second half of the decade. To remove that spectrum to other uses will be vociferously opposed by the broadcasters. The "refarming" of the patchwork of channels for use for non-broadcast purposes will be very, very expensive.
It should also be remembered that the development of digital television has required a massive investment by broadcasters. It is this investment which enables the prospect of "refarming" of analogue spectrum and broadcasters have a legitimate claim that they should be given priority in any re-use of that spectrum.
High definition will, we believe, come to the fore again as large flat-screen display technology moves into everyday consumer use, probably in the second half of the decade. Provision needs to be made for spectrum to carry high definition broadcast services when the business case for it comes together. Following our own argument of using the most appropriate medium for the task, we believe that satellite transmission offers the best means of conveying high definition services to the home. This will initially be seen, probably within just a year or two, as a specialist sports service to pubs and clubs and this showcase will drive a consumer market forward as prices decrease.
Finally, we would ask what the hurry is? The report has a breathless or even hysterical tone to it, which is dangerous in such an important task as the allocation of a scarce national resource. There is a perceived / implied pressure for early changes which needs justification.
The broadcast industry has been well used to change over many years and there is clearly a need to evaluate convergence technologies at this time. But the future is not clear. We believe that there is a risk of a "knee-jerk" reaction, which proves later to have been premature. We strongly recommend that great care and sufficient time is taken to be sure of future developments before any irrevocable decision on spectrum allocation is taken.
The future of home-entertainment systems lies with plurality. Each distribution mechanism has inherent strengths and weaknesses and inherent costs. We must allow systems to develop which trade on the inherent strengths of each platform so as to make best use of scarce bandwidth resources.
The market-place is in many ways the best way to establish the benefits of new technologies and delivery methods. If consumers do not perceive substantial benefits they will not buy them. However, there is a real risk of tried-and-tested methods of delivery being fragmented into a large number of less satisfactory vertical markets, which the consumer pays more for a less satisfactory experience.
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