Australian Broadcasting Corporation. Australian Communications and Media Authority

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1 Australian Broadcasting Corporation submission to Australian Communications and Media Authority Digital Television codes and standards February 2008

2 ABC Submission in response to the ACMA discussion paper on digital television codes and standards Introduction The Australian Broadcasting Corporation (ABC) welcomes ACMA s decision to consult with industry on the ways in which it might exercise its powers to create technical standards under Part 9A of the Broadcasting Services Act 1992 ( BSA ) and to seek codes and/or impose industry standards under Part 9B. While, in general, the Corporation does not feel that further regulation of digital terrestrial television broadcasting is currently required, it does believe that it would be appropriate for the existing Australian digital television receiver standard to be mandated. Its experiences with minor alterations to its transmissions with Australian broadcast standards such as switching its high-definition format from 576p to 720p suggest that a number of receivers from smaller manufacturers do not fully comply with current standards. This creates substantial inconvenience for audiences and engenders uncertainty around digital television technologies. In addition, viewers tend to blame broadcasters for such problems, with the result that broadcasters reception advice areas are required to develop solutions to problems not of their making. Mandating the existing receiver standard should alleviate these difficulties. Developing technical standards for digital television The ABC possesses the technical expertise and necessary representation resources to participate in the development of technical standards relevant to digital terrestrial television broadcasting. It is very interested in participating in the development of any technical standards for digital television that ACMA might deem it necessary to determine under Part 9A of the BSA. The ABC itself has been an active member of Standards Australia s CT-002 Committee on Broadcasting and Related Services, as well as its subcommittees. These include CT (Television Broadcasting Transmitting Equipment), which developed the digital transmission standard AS and the digital television receiver standard AS , and CT (Cabled Distribution Systems), which developed the VHF/UHF receiving antenna standard AS and RF cable and fibre-optic distribution standard AS/NZS The ABC supports Standards Australia s existing framework for developing technical standards, which is effective and has delivered standards that accord with international best practice. There is wide industry support and confidence in the work of Standards Australia in developing and maintaining standards relating to digital television. 1

3 ABC Submission on digital television codes and standards 2 Standards Australia employs an approach that is consensus-based, transparent, rigorously defined and open to all industry participants. For example, the membership of the subcommittees that developed Australia s digital television transmitter and receivers standards AS and AS , respectively reflected a cross-section of the broadcasting industry, including the national broadcasters, commercial television broadcasters, subscription television broadcasters, consumer electronics manufacturers, transmission service provider Broadcast Australia and ACMA. The ABC does not believe that there is any need for these processes to be replaced. Instead, ACMA should give consideration to a mechanism whereby it assesses relevant standards developed by Standards Australia for mandating as enforceable technical standards under Part 9A of the BSA. Existing digital television standards The two existing digital television standards developed by Standards Australia AS and AS are very effective and appropriate for Australian free-to-air broadcasters and receiver manufacturers. They reflect by reference the Operational Practices developed by broadcasters in adapting DVB-T to meet Australian requirements. Free-to-air broadcasters fully comply with both the mandatory and optional components of AS Most major-brand receivers comply, to a large extent, with the mandatory components of AS , as well as the optional components when the corresponding functionality is included in the receiver. However, there are a significant number of lesser-brand receivers that do not fully comply with the mandatory components. In particular, a number of receivers do not dynamically respond to PAT, PMT, NIT and SDT updates, as specified in the minimum receiver requirements section of AS , and are thus unable to respond to changes in available services. The ABC has made a small number of changes to its digital television transmissions in recent years. In each case, it has been careful to ensure that the changes to its broadcasts conform to Australian DVB-T standards, but has found that a percentage of non-compliant receivers have been adversely affected by the changes. In March 2005, when the Corporation introduced ABC2, it received more than 200 calls from viewers who initially had no audio on the new channel as the set-top box they were using was unable to automatically detect and adapt to the change. Similarly, in May 2005, the relocation of the ABC s Perth studios to East Perth required a change to its digital distribution. As a result, over a period of approximately two weeks the Corporation received over 600 calls from viewers regarding problems with digital reception on a variety of set-top box makes and models; these had to be resolved through a full factory reset of set-top boxes followed by a channel re-scan. In July 2006, after changing its high-definition format from 576p to 720p, the ABC received over 100 calls from

4 ABC Submission on digital television codes and standards 3 viewers suffering loss of ABC2 or marred programming on the HD channel; again, this problem affected a variety of set-top boxes models and required a factory reset and channel re-scan to resolve. Such circumstances significantly inconvenience viewers and have the capacity, while digital television technologies are poorly understood in the Australian community, to create the perception that, unlike analog television, digital television doesn t simply work. This can only negatively affect community acceptance of digital television and thus potentially slow the take-up of the technology. Moreover, in the ABC s experience, viewers tend to blame these problems on broadcasters transmissions, rather than, as is the case in these circumstances, receiver equipment that does not fully comply with Australian standards. To overcome these difficulties, ACMA should mandate the minimum digital terrestrial television receiver requirements specified in AS in the form of a technical standard under section 130B of the BSA. In a similar vein, ACMA should give consideration to mandating AS/NZS , which sets out requirements in relation to the installation of coaxial cable and optical fibre systems for radiofrequency distribution of analog and digital television and sound signals in single and multiple dwellings. A significant number of Australians live in flats and apartments and, as a consequence, receive television signals through MATV cabling installed in the building. Cabling for analog television is generally inappropriate for receiving digital services and will have to be replaced before analog switch-off occurs if residents are to continue to enjoy access to free-to-air television services. Evidence to date indicates that, as AS/NZS is not mandatory, no provision is being made for receiving digital television in many new multi-unit dwellings. As a result, avoidable inconvenience for residents and future expense for bodies corporate is being created. As with non-compliant receivers, this problem can only negatively affect community perceptions of digital television. It could be avoided by mandating the standard. Developing industry codes and standards As with technical standards, the ABC has the expertise, representation and resources to participate in the development of industry codes relevant to digital terrestrial television broadcasting. It is very interested in participating in the development of any relevant industry codes for digital television that ACMA might request under Part 9B of the BSA. Central to Part 9B is the concept of sections of the industry, which are defined in section 130G as persons carrying on, or proposing to carry on, one or more specified kinds of industry activity (industry activities are defined under section 130F). Parliament s intention, as set out in section 130J, would appear to be that industry codes will be developed by bodies representing sections of industry. This is reinforced by section 130P, which effectively empowers ACMA to invite the formation of such a body to represent a section of industry

5 ABC Submission on digital television codes and standards 4 that does not have a peak body. However, the ABC notes that ACMA is not legislatively obliged to rely upon peak bodies for industry code development. In the case of national broadcasting, which is designated an industry activity under 130F(1)(b), there is no peak body representing the two national broadcasters; nor should there need to be, given that the number of organisations is small and invariant. Should industry codes relating to national broadcasting be required, ACMA should deem the ABC and SBS to represent this section of the industry. In a similar fashion, no overarching body exists that is able to represent digital terrestrial television broadcasters on all issues. For the purposes of Part 9B, such a group would represent an aggregated section of the industry, in accordance subsection 130G(5)(b), consisting of the national and commercial broadcasters. The examples of matters that might be dealt with by industry codes or standards set out in subsection 130K(3) suggest that there may be more call on this aggregated section of the industry to develop codes than on either the national or commercial broadcasters. There may be some scope for the Broadcast Industry Technical Advisory Group (BITAG) to develop codes of a technical nature on behalf of broadcasters. However, in general, the ABC s preference would be for ACMA to deal directly with the broadcasters in developing industry codes relating to digital terrestrial television. Specific issues The discussion paper invites comment on a range of specific issues. The Corporation offers the following observations. Technical receiver standards For the reasons set out above, the ABC believes that ACMA should mandate the minimum digital terrestrial television receiver requirements specified in AS in the form of a technical standard under section 130B of the BSA. Labelling of domestic reception equipment Experience to date suggests that digital television is not well understood by Australian consumers. It is likely that this lack of understanding has adversely affected take-up of digital terrestrial technologies. The process of digital transition can only to be assisted by the provision of more and more accurate information to the public. One approach of this kind that has been applied in the UK with apparent success is the use of a simple, unambiguous labelling scheme that clearly indicates which hardware will work after analog switch-off. Such an approach would almost certainly be of benefit to Australian consumers and, as a result, assist in the process of digital transition. A labelling scheme for domestic digital terrestrial television receivers would be a strong candidate for the

6 ABC Submission on digital television codes and standards 5 development of an industry code, particularly if ACMA was to mandate AS as a technical standard for receiver equipment. A unified labelling scheme will only be effective if it is adequately enforced to ensure that only equipment that does in fact meet minimum requirements will carry the label. The introduction of a unified labelling scheme would be directly enhanced by the presence of a digital testing and conformance centre to assess and certify digital terrestrial television receivers against the requirements of AS Under such a regime, receivers would be required to have received certification from the centre before being permitted to carry the labelling scheme s badging. However, the ABC acknowledges that a number of issues need to be resolved in order to introduce a testing and conformance centre, including where the cost burden lies. It should also be noted that Australia already has one digital television labelling scheme in the form of the voluntary HD tick scheme introduced by the Australian Digital Suppliers Industry Forum (ADSIF). However, this scheme is essentially aimed at assisting consumers interested in purchasing expensive, high-end equipment. What is instead required is a labelling scheme aimed at all consumers from those seeking the cheapest possible way to continue to access television broadcasts after switch-over to those intending to purchase costly, large-format HDTV equipment. Nonetheless, to avoid increasing consumer confusion through the multiplication of labelling schemes, any unified scheme should incorporate HD tick information. Electronic program guides As the number of multichannel services available on free-to-air television grows, electronic program guides (EPGs) will become increasingly important as means a by which viewers can navigate broadcasters schedules. In particular, accurate EPGs that are synchronised with broadcasters transmissions facilitate the use of digital video recorders, which are a replacement technology for the video recorders in Australian homes and are thus likely to enhance the transition to digital television. The ABC seeks to make its services as widely and easily available as possible. Accordingly, it has long provided audiences with extended EPG data, rather than truncated now and next information. The recent decision by commercial broadcasters to provide time-synchronised, seven-day EPG data can only contribute to the take-up of digital television. The ABC does not believe that regulation of EPGs in the form of codes or standards is warranted at this time.

7 ABC Submission on digital television codes and standards 6 Updating of software in domestic reception equipment The ABC is currently in the process of finalising a non-exclusive agreement with a digital receiver testing company, Australian Digital Testing, to provide over-the-air system software updates (OASSU) to digital television receivers. This has the potential to enhance digital television in Australia, as it will allow the software of receivers to be automatically and invisibly updated to correct problems or enhance their functionality. The technology has been delivered in the UK for a number of years by the BBC on behalf of the free-to-air digital industry. OASSU will make a direct contribution to digital television in Australia by removing an element of cost and risk for both viewers and manufacturers associated with introduction of new receivers with enhanced digital capabilities in the market. However, its implementation is currently halted by issues relating to indemnification of OASSU providers. The issue at stake is the possibility of rogue or cloned products from OEM factories illegally using the Organisationally Unique Identifier (OUI) for other suppliers brands, platforms or receiver models. Such circumstances create the very real possibility of a rogue receiver automatically downloading an OASSU that was not designed for it and potentially being rendered inoperable. Clearly, the suppliers of such receivers will not indemnify the OASSU providers against damage to receivers caused in this way. One way to overcome this problem would be for ACMA to determine a technical standard under Part 9A of the BSA that requires all that OASSU-capable digital television products to implement the OUIs allocated to them by the Institute of Electrical and Electronics Engineers (IEEE). Under such a technical standard any product that did not have a correctly-allocated identifier would be a non-conforming product and the supplier or importer of that product could not claim damages against the OASSU providers. In addition, consumers could only take action against the supplier of the non-conforming equipment and not against the OASSU providers. Conclusion The ABC believes that ACMA s regulatory priority in relation to digital television must be mandating the existing Australian digital television receiver standard, AS This will support the timely transition from analog to digital television by reducing consumer uncertainty about the technology and increasing its acceptance. In a similar fashion, there are significant benefits to be gained from the introduction of a unified labelling scheme for domestic digital terrestrial television receivers that clearly indicates which hardware will work after analog switch-off. Such a scheme would be a strong candidate for the development of an industry code.

8 ABC Submission on digital television codes and standards 7 The ABC also believes there is a case for mandating the in-building cabling standard AS/NZS to alleviate avoidable inconvenience and cost to residents of multi-unit dwellings during digital transition.

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