Sbs submission Digital Television Regulation Consultation Paper
Commercial and national broadcasters should be free to determine the most appropriate mix of services and formats for their audience
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- Commercial and national broadcasters should be increasingly permitted to use spectrum more flexibly
- Multiplex capacity and picture resolution
- Singular transition to spectrum-efficient, next-generation technologies
Commercial and national broadcasters should be free to determine the most appropriate mix of services and formats for their audienceWhat factors will influence the decision to increase or reduce the number of services a broadcaster chooses to provide? The financial viability of each individual service a broadcaster provides lies at the heart of the decision making process. This viability is influenced by, for example, its capacity to generate revenue or increase audience share, and is particularly sensitive to government standards and regulatory burden. Beyond fulfilling basic broadcasting obligations (outlined in the SBS Act and Charter), SBS should be allowed the freedom to reach audiences as the Board determines appropriate to better serve our Charter. Broadly in line with the preliminary Government position, no new regulation limiting the number of services provided by broadcasters should be introduced that would limit SBS (or other broadcasters) to generate a solid return-on-investment or increased audience share from introducing or reducing services. What safeguards, if any, should the Government put in place to make sure that an appropriate balance is maintained between giving broadcasters the freedom to use their spectrum how they see fit, providing audiences with a diverse range of television services and the appropriate and efficient use of spectrum? Transmission cost savings and improved spectrum efficiency could be gained over time from the discontinued use of terrestrial DTTB infrastructure at those facilities where only a minority of FTA broadcasters’ services are provided; for example, DTTB services would cease for singular or minority (that is, less than the full complement of) transmissions from these sites. Historically, the commercial broadcasters have extended their terrestrial networks only as far as it is commercially beneficial to do so. SBS considers the already-available VAST service to be a cost effective means of delivery to small and remote communities. In the longer-term, SBS envisages a further transition from terrestrially-based delivery (DTTB) to satellite and other emerging platforms (e.g. NBN). Determining factors will include the DTTB delivery cost-per-capita, the granularity of local and regional programming (e.g. local ‘break-outs’), and consideration of the additional costs of consumer premises equipment (CPE) and ongoing charges. What consequences, if any, could the removal of ‘service deficient’ declarations have on the content delivered to viewers in smaller regional and remote areas? The current regulatory arrangements surrounding the declaration of ‘service deficient’ areas places the onus on viewers to apply to access the VAST service at their own expense. Any changes made to such arrangements must not negatively impact the quality and reliability of broadcast services in metropolitan and regional blackspot areas. What impact, if any, will the removal of the requirement for the primary channel to be provided in SD have on viewers? SBS supports the removal of the requirement for the primary channel to be provided in SD. The decision on whether to broadcast in HD or higher quality is best left to the discretion of individual broadcasters who are best placed to weigh up the benefits of content and quality considerations to serve their audiences. Distinct HD programming has been available since 2009, and anecdotal information suggests that HD penetration in households has reached approximately 90%. Therefore, it is anticipated that there may be some impact if requirements for primary channels were removed, given the major technological changes that have occurred during the digital switchover. SBS understands that the government has a responsibility to facilitate broadcast services for as much of the Australian population as possible, and minimum safety nets are required during periods of technological changeover. However, SBS believes that consumer expectations have progressed beyond SD content, and consumers are largely aware of any changes that would be necessary to take advantage of newer HD content. A public information campaign, rather than ongoing regulation, may be all that is necessary to ‘groom’ the remaining consumers to ensure they are aware of changes to technology. Furthermore, setting out requirements for ‘primary’ vs. ‘secondary’ (or indeed many other channels) creates artificial distinctions that are representative of a bygone period of broadcasting. The intended objectives of these requirements can more effectively be met through other, non-legislative mechanisms, such as industry codes and education campaigns. The removal of such requirements would ensure consistency across the broadcasting environment and ultimately reduce regulatory burden. As explained further in the section 3 responses below, it will be critical in a future shared-multiplex environment that SBS and ABC have sufficient capacity in order to fulfil delivery of HD content and not be materially disadvantaged compared with the commercial television networks. What factors will influence a television broadcaster’s decision to continue to offer HD content? There is evidence from a number of countries and regions of increased consumer interest in improved quality and HD services. As with implementation Question 1, the ability to increase revenue or audience share will be a substantial driver in influencing a broadcaster to offer HD content. Recently, internationally and locally, FTA and subscription television providers have expanded their HD services in efforts to improve consumer satisfaction. As more spectrally efficient transmission standards are introduced (e.g. DVB-T2), we are also seeing a greater adoption of HD as the 'new entry-level'. DVB-T2 has now been adopted by 68 countries worldwide, with actual deployment in 29 of those countries at December 2014. Informa Telecoms & Media predicts that the number of active HD households will rise to over 600 million globally by 2017, with Asia Pacific emerging as the biggest HD market by that date, followed by North America and Western Europe.1 It said that by 2017 several countries could be approaching the point where almost all viewers would be watching HD content, leading to the possibility of a SD switch-off and the possibility of introducing a new generation of HD technologies. SBS will be strongly influenced by its ability to secure and broadcast sufficient HD content, as well as ongoing consumer demand for high quality content. While costs associated with digital broadcast development and content delivery are steadily increasing with consumer demand, new digital platforms and applications present opportunities for SBS to deliver tailored content to our audiences and develop strong brand relationships with consumers. Rights holder preferences will likely be a factor too; whilst we may not be mandated to carry the FIFA World Cup and other major sporting events in HD our audiences would not appreciate a decision not to include a HD offering. Similarly not having a reasonable number of HD FTA DTTB streams available (or indeed an opportunity for UHD – whether as a DTTB, OTT, DTH or pay TV service) would indicate some misalignment with the Australian retail strategy. SBS is not merely satisfied with following behind the competition on technological development – Australia’s multicultural broadcaster strives for a digital television environment that is world class and future proof. Commercial and national broadcasters should be increasingly permitted to use spectrum more flexiblyWhat form of regulation should there be for services that are indistinguishable to viewers from more regulated services and accessed with common equipment, such as HbbTV? SBS agrees with the preliminary Government position stated in the Consultation Paper that further work should be undertaken on the commercial and regulatory implications of free-to-air television services being delivered using online platforms. This should focus on reducing the regulatory disparity between the broadcasting and internet regimes, and the maintenance of clear public policy objectives (as set out in the Department’s Deregulation in the Communications Portfolio Policy Background Paper No. 1). What arrangements may be required to allow currently established datacasting services provided by commercial broadcasters to continue where necessary after the repeal of the datacasting provisions in the BSA and RadComms Act? In their current forms, arrangements relating to datacasting appear to be limiting the take up and usage of such communication types. If this is in fact the case, opening up the regime may provide more opportunities for media players (including SBS and other operators) to engage in datacasting activities. In turn, such arrangements may more broadly improve the quality of the Australian media environment, by facilitating more voices and greater communication opportunities. This is based on the understanding that any increase in flexibility does not decrease SBS’s ability to control its current spectrum resources. Other than narrowcasting services, are there any other types of services which broadcasters should offer on their television multiplexes? SBS is broadly in favour of any changes to current arrangements that allow us greater flexibility to provide services within our allocated spectrum. As above, this is based on the understanding that any increase in flexibility does not decrease SBS’s ability to control its current spectrum resources. Is it likely that commercial television broadcasters will want to use their multiplexes and hence spectrum to offer third party content that they are not responsible for under the relevant broadcasting legislation? If so, what form of regulation would be appropriate to ensure such content was provided in a manner consistent with commercial broadcaster provided content? SBS is a public broadcaster reliant upon commercial returns for a proportion of our revenue. As such, any future arrangements that might apply to the commercial broadcasters should also apply to SBS. How important is it that broadcasters have the regulatory flexibility to make greater use of new technologies to deliver their television services to viewers? It is absolutely necessary that maximum flexibility be provided to broadcasters to make greater use of new technologies to deliver television services to viewers. SBS is internationally recognised for its technological innovation. After pioneering investment in the online area, SBS is beginning to enjoy scale benefits, in terms of increased audience share and a deeper understanding of those audiences. The social and technological operating environment is changing and this has influenced our strategy, how we operate and how we achieve our purpose. As technology changes, SBS requires the flexibility to change and stay on-pace with cutting edge advancements. Flexibility will allow SBS to deliver the best available content to audiences, and to understand our audiences better. Commercial and national broadcasters should deliver their services through spectrally efficient mechanisms and this can only occur where flexibility allows more efficient means to be explored.
How can the Government support the broadcasting and manufacturing industry in managing a transition to MPEG-4 only television? It is SBS’s view that the next major transition for digital television technologies should be to combine DVB-T2 transmission and HEVC compression. This would put Australia in line with current international developments. SBS does not believe a transition to MPEG-4 only television should be a mandated middle step. SBS supports the principles set out in the Minister’s keynote address to the RadComms 2014 Conference regarding the drive to achieve maximum spectrum efficiency and the eventual spectrum sharing between the national broadcasters. The Australian industry publicly stated in October 2013 that the FTA sector is seeking a migration pathway to more spectrum-efficient DTTB standards, including DVB-T2 and HEVC (high efficiency video coding)2. The national broadcasters could take a lead role in effecting this transition, which will impact a range of stakeholders over the medium-to-long term, including content providers, broadcasters, consumers, retailers and service providers. However, SBS believe this should be to achieve DVB-T2 transmission and HEVC compression. Multiplex capacity and picture resolutionCurrent multiplex capacity in DVB-T, using existing coverage parameters, equates to 23Mbps for ABC services nationwide and SBS services in the metropolitan markets; SBS services are currently operating at 19Mbps in the regional markets as a result of legacy spectrum restrictions in single frequency network (SFN) planning. Analysis undertaken for ABC and SBS by Ericsson reaffirms it is not possible to incorporate the full suite of existing ABC and SBS services utilising MPEG-4 into an existing DVB-T multiplex without a combination of dropped services and some material degradation of picture quality. Even with all services operating in SD mode, there would be a material loss of picture quality. Furthermore, any regression of picture resolution would likely have a negative impact on the retail sector where, currently, significant sales volumes and margins relate to large-screen, high-definition and UHD display devices. Furthermore, the current DVB-T/MPEG-2 Australian receiver standard, first established in 1999/2000, never contemplated a shared multiplex incorporating discretely described network identifiers allocated to each broadcaster (e.g. SBS, ABC). Therefore, it is strongly suspected that all current MPEG-4-capable receivers would not function, or not function in a predictable manner, in a shared-multiplex environment based on MPEG-4 and DVB-T. Our response to implementation Question 14 provides further expansion of this issue.
The MPEG-4 standard was ratified in 2003 and has since been significantly superseded in terms of coding efficiency by HEVC. HEVC coding efficiency will continue to improve for some years to come, without material impact on the design of consumer equipment. The combination of HEVC and DVB-T2 provides five-fold spectrum efficiency for the same suite of content when compared to current MPEG-2/DVB-T technologies; similarly this HEVC/DVB-T2 combination also provides three-fold spectrum efficiency when compared to MPEG-4/DVB-T technologies as proposed in the Consultation Paper. This five-fold spectrum efficiency benefit most closely aligns with the Minister’s drive ‘to achieve maximum spectrum efficiency’. Additionally, it offers material improvement over that obtained from the proposed and more limited MPEG‑4/DVB-T transition. Multiplex sharing in an HEVC and DVB-T2 environment will enable broadcasters to increase the technical quality of their current services as well as augment the number or type of services they provide. Importantly, broadcasters will maintain the capability for flexibility in a spectrally-efficient manner with cost-effective distribution at a time when it is anticipated that audiences will expect HD as the default quality standard. This raising of the expected quality standard and corresponding increased capacity requirements will be offset by the efficiency gains realised through the adoption of these next-generation technologies. These next-generation technologies are already being trialled, planned and implemented in Europe and Asia as outlined at Attachment B - International Developments and Trends.
Should the Government consider any legislative mechanisms such as technical standards for MPEG-4 terrestrial transmitters and/or television receivers? The Australian industry manages the development and ratification of broadcast standards through representations with Standards Australia. An updated digital television receiver standard (AS 4933.1) is currently in the process of being published, which makes references to the emergence of HEVC, IPTV and HbbTV and provides some guidelines, but does not include detailed specifications. For example, there is currently no provision for DVB-T2, 3D or 4K. The transmission standard (AS 4955) was last updated in 2011 and does not include DVB-T2. These standards have not been mandated by the ACMA. SBS does not believe that legislative intervention is warranted at this time for consumer reception equipment standardisation, as the industry is able to set minimum performance specifications as it has done in the past. However, it would be beneficial for Government to mandate that all imports must be fully compliant with these newly-established industry standards. To support industry-led performance, next-generation receivers should be suitably labelled with compliance markers (‘ticks’) at the earliest opportunity to ensure consumers are not misled into purchasing non-compliant imports. A key driver for consumer take-up will be clear messaging from the industry and the retail sector, with the support of Government and its agencies.
By what date does the broadcasting and manufacturing industry consider that MPEG-4-only television could be achieved? SBS advocates a transition directly to the next-generation technologies of HEVC and DVB-T2, bypassing any interim transition to MPEG-4 only. SBS considers that transition to HEVC and DVB-T2 may be possible by 2026; however, there are significant issues that need to be addressed in managing the transition (see response to implementation Question 14 below). What does the industry consider should be the future standard(s) for broadcast television in Australia? Should a pathway to next generation technologies such as DVB-T2 or HEVC also be considered? SBS firmly believes that a pathway to DVB-T2 and HEVC should be the main pathway considered and has outlined the necessary steps to achieve this below. By 2026, 23 years will have elapsed since the ratification of the MPEG-4 standard and, by then, HEVC will have become a very mature global standard with low-cost receiver product pricing. In the same way that in-home picture quality has advanced over the years—from analogue through SD- to HD-digital, largely driven by premium content and live sport—there is global expectation that HEVC/4K/UHD will make similar advances and help create the consumer proposition to upgrade ageing display devices. A further driver will be the new features and applications available in the fast-evolving smart TV/HbbTV environment. Given the lack of evidence or research to quantify the extent of MPEG-4 penetration, not only in terms of households, but also the number of legacy MPEG-2-only devices, SBS considers the timetable to switch to MPEG-4 suggested in the Consultation Paper is not achievable without serious adverse material impact on the audience and the viability of the FTA industry. Directory: sites -> files sites -> Memorandum of agreement files -> Information security policy university administration and services (uas) files -> Chris ham: reforming the nhs lessons from the past and pointers to the future files -> - files -> A guide for parents and carers files -> Ariel M. Sheetrit files -> Chapter Calendar of Events –July 2017 For the benefit of our members and customers please coordinate the scheduling of dates to prevent overlapping events. In the event of conflicting dates it is recommended to personally notify the other chapter of the files -> Collective redress in england & wales files -> County No Treasurer’s Elderly and Disabled property tax credit request affidavit Download 1.6 Mb. Share with your friends:
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