Response summary from B.R.B.Robertson - That terrestrial HDTV is a priority, and an international rethink based on MPEG4/H264 is required.

Consultation: Digital Dividend Review Response summary from B.R.B.Robertson - That terrestrial HDTV is a priority, and an international rethink based on MPEG4/H264 is required. 1 Terrestrial HDTV screen sizes 1.1 It is not in dispute that standard definition digital television (SD) with 576i specification tops out at twenty eight inches widescreen, viewed at average home distances, on either 625 line or 576 line displays. 1.2 It is evident, based on sales of HD-Ready televisions, that consumers are choosing to buy larger than 28 screen televisions. It follows that HDTV is required for a satisfactory TV viewing experience. 1.3 This is happening absent any prospect of free to air HDTV services becoming readily available, across the public service broadcasters (PSBs). HD-Ready is said to be the fastest change in TV sales, ever. 2 Ofcom research about HDTV 2.1 The Ofcom executive summary included: 1.38 Similar issues arise in relation to other services. The research showed people felt that widespread availability of mobile broadband could be of broader value to society, for example in rural areas. More choice on the DTT platform could also be beneficial to society if the content was good the quality of content was seen as critical. 1.39 High definition television, by contrast, was not identified in our research as a major source of broader value to society. A bigger choice of channels was rated more highly, for both citizen and consumer interests, and HD was seen mainly as a premium consumer product, similar to mobile television. 1.40 It is possible, of course, that attitudes to an innovation like HD may change. In time, consumers and citizens may come to expect some HD content to be available to everyone free of charge, just as colour is now. But the evidence that this will happen is not strong right now. 2.2 There has been no authoritative information about HDTV broadcast by the PSBs. The London based terrestrial HDTV trial gave rise to the following report (HDTVUK): A joint statement just released by the BBC, ITV, Channel 4, and Five, has stated that the first trial of high definition TV over digital terrestrial in the London area has been very successful. Not only was it a technical success, but the 450 or so households involved in the trial said they now would expect some HD content to be broadcast via Freeview or equivalent free-to-air digital service. 98% of those who took part said that it was important to have HD services on Freeview in the future, with 86% saying they expected to see it within 3 years. 90% said that the existing public broadcasters should be responsible for HD development. When asked about which programme genres would benefit most from being broadcast in HD, wildlife and sport lead the way with scores of 9.4 and 8.9 out of 10 respectively. Those who took part said they'd like to see at least 6 or 7 channels, and ideally 10, airing over Freeview. 95% said that the HD picture looked as good as or better than they had expected it to. 2.3 With respect to HDTV at Ofcom 1.39 above this is unadulterated hokum. Full HDTV doesn't have a wide appeal because of lack of market penetration (cost of Sky HD service) and lack of consumer knowledge. Failure by broadcasters and miss-selling by retailers, is clearly part of the problem. The BBC seems to have been inhibited by the licence review, before, during and since the Sky-HDTV launch, and had not programmed any significant information about HDTV as a TV programme. Neither has any of the other terrestrial broadcasters. Sales people in the retailers Curry's and Comet, have locally been miss-selling HD-Ready 720p televisions for over a year to my knowledge, by telling people that they will see no difference between these and 1080i/p televisions, although not demonstrating this with side by side working sets. Anyone with good eyesight can see the 1080i/720p difference on a 42 inch display at

nine feet distance - and with 20/20 vision on a 50 inch display. Given experience, by the London trialists quoted at 2.2 above, there is overwhelming support and desire for terrestrial HDTV. 3 Ofcom consumer research about DTT channels 3.1 The main Ofcom report included: 4.110 Respondents were asked to rank a number of digital services in order of importance to them personally. More DTT channels were considered most important, in line with other findings from the research, followed by local TV. The provision of HDTV and mobile broadband were on a par in terms of importance, with mobile TV deemed to be the least important. Figure 4.3 Importance ranking for digital technologies (value to individuals) More DTT channels 63%, Local TV 48%, HDTV 37%, Mobile broadband 33%, Mobile TV 19% 3.2 The Ofcom research flies in the face of the reality, of purchases of HD-ready televisions, and the wishes of people who experienced the terrestrial HDTV trial. Why would anyone buy an HD-Ready TV and prefer more low resolution DTT channels (SD digital) when it is evident that there is not even enough programme content to reasonably occupy the current Freeview bandwidth. The Ofcom research is further qualified: 4.114 The qualitative research highlighted that the broader social value of additional DTT channels was closely related to the content of those channels. It was felt that new DTT services were most likely to have the greatest appeal to most of the country, and that they could show programming that would have the most value to society if they were of high quality. 4.115 Interest in local TV was also qualified to some extent by concern about the cost-effectiveness and quality of local services. Respondents in this research expressed concern that if services were too local they might not be sufficiently interesting to attract audiences. Conjoint analysis suggests that local TV was relatively unimportant in driving consumers preferences for additional DTT services. 3.3 The current realities, include that there is no more programming that would have the most value to society if they were of high quality. Commercial TV advertising revenue is likely to continue falling, as other outlets increase advertising revenues, with a related effect on programme output. The BBC looks likely to be producing as much original programming as the other UK terrestrial broadcasters combined. 3.4 The technologies available have superseded some of the research. 3.4.1 Limited output local TV is more appropriate as streamed/download video on broadband, rather than occupying broadcast bandwidth at the expense of HDTV. This now easy to do. 3.4.2 Mobile broadband suffers no current noticeable constraint except cost, so there is no cost-effectiveness that could be bettered by provision of more bandwidth, except if there was free usage, which is contrary to spectrum pricing. 3.4.3 While mobile phone companies undoubtedly wish to charge for a telephone Mobile TV service that increases their profits, for few rather than many, this does not appear to have been considered in relation to the customer cost-effectiveness of receiving the broadcast DTT TV channels, that should be possible when higher signal strengths are available. 3.5 Conjoint analysis conducted with the London HDTV trialists, people with experience of HDTV, would probably have yielded significantly different Ofcom research results. 3.5.1 Although Freeview was extemporised from the collapse of OnDigitial/ITV-Digital, and some ad hoc allocations might be excused, it cannot be that channels used for half a day (or less) are valued at the same values as BBC and ITV/C4/C5 channels. 3.5.2 More DTT channels with high quality programming are simply not going to happen, when there is already a high proportion of Freeview that deserves to be culled. Look at the schedules, and ask whether repeats of programmes that have already been broadcast and are mainly available on DVD are worthy of bandwidth, at the expense of new HDTV programmes. (There is a technology issue about use of PVRs also, dealt with below.) 3.5.3 The main alternative, providing for some high quality output on an ad hoc basis, absent sufficient content for a broadcasting channel, is the DVD. Again, now very easy to produce. 3.5.4 The subsidiary alternatives of downloadable television programmes, are being offered at sub-standard quality. Shiny new HDTV equipment with degraded pictures compared to the original broadcasts. My computer can record two DVB-T broadcasts simultaneously while watching a previously recorded programme. The monitor will display more than 1920x1080 pixels, so I can readily see 1080i/p downloads, but the services on offer are degraded SD. The limitation for broadband users is that their contracts are not

unlimited, fair use policies limit total bandwidth, and peak usage rates are managed. Without last mile fibre optic cabling, the UK systems are not capable of a reasonable SD service, never mind HDTV, and if you have HD-Ready equipment, why would you watch sub-standard pictures? Only if you had missed an episode of something you must see. I have the Joost trial working, and know how much bandwidth that consumes, so I'm not opining without experience. 3.6 The Ofcom research about lack of support for HDTV and enthusiasm for more DTT channels is clearly out of date. Worse, it is wrong given the experience of the London HDTV trialists, and current expectations for purchasers of HD-ready TVs. This is almost Europe wide, based on HD-Ready sales. 3.7 I believe that it has become axiomatic that Ofcom should revise strategy, based on a public expectation. That a general change to terrestrial HDTV is expected, on a comparable basis to the past changes from 405 to 625 line broadcasting, and from black and white to colour. At analogue switch off points, in the mid and late stages with the majority of people already owning HD-Ready televisions, the additional consumer cost is basically a new MPEG4 STB at about 50. Nothing like past TV changes costs. 4 An HDTV proposal. 4.1 Government argument about spectrum and digital terrestrial high definition television (DVB-T-HD) is a logical fallacy, because technology neutral auctioning proposed for the the analogue TV frequencies, was not applied to the Freeview multiplexes and Top Up TV Anytime. (Summary historical account: http://en.wikipedia.org/wiki/digital_terrestrial_television_in_the_united_kingdom ) Assume that the current DTT multiplexes were freed up for consideration with the analogue TV frequencies. 4.2 Assume ten 1080i terrestrial stations could broadcast in the Freeview, Top Up TV Anytime, and analogue TV bandwidth, assuming that MPEG4 is used and that: 4.2.1 BBC gets 5x 1080i channels, (BBC1, BBC2, BBC3/CBBC, BBC4/Cbeebies, Interactive/sport) The BBC needs almost wholly HDTV output in order to sell programmes overseas and subsidise the licence; while based on their original output, 4.2.2 ITV gets 2x 1080i channels; 4.2.3 Channel 4 & Five get 1x 1080i channel each, and 1x 720i channel each; 4.2.4 plus 2x 576i channels (BBC News24, Parliament) by statistical multiplexing 4.3 HDTV tuner ASICs that are now being made are dual-tuners, as a matter of course. I do not know whether existing Freeview tuners used as STBs for televisions can also be software upgraded to MPEG4, but while I suppose some can, I would suspect that most of the older ones cannot. However, it is no great problem to produce a 50 MPEG4/H.264 dual tuner STB, that is backwardly compatible with MPEG2, which could also downscale 1080i/720p to 576i for people without HD displays (I wouldn't include an analogue modulator). By the time of analogue switch off, the owners of original OnDigital STBs will have had their money's worth, and more recent purchasers also, who bought at average of about 40 and might have had up to ten years use. 4.4 Without BBC TV being all HDTV output, consent for the licence fee will disappear. It will not be acceptable, or affordable to up to half of the population, that an extra fee will be payable to BSkyB/Virgin to watch BBC HDTV programmes. A digital divide would exist. It is in the interests of BSkyB and Virgin Media customers, that they could use HDTV free to air broadcasters without paying extra channel charges to Sky and Virgin. To effectively use, for their own cost-benefit, their PVRs for scheduling clashes. It is not in the interests of Sky and Virgin near monopolies, that they could. 4.5 The principal alternative to the BBC being able to broadcast five channels of terrestrial HDTV, is that they become a satellite HDTV broadcaster. That would require purchase of satellite receivers and installation of aerial dishes, at about 200 per household, because Ofcom and the Government had sold off the terrestrial bandwidth. The BBC would incur costs that otherwise could be spent on programmes. 4.5.1 It is noted that the BBC and ITV have taken appropriate distancing steps from BSkyB, and that Channel4 probably will, but is contractually bound for another year or so to BSkyB. 4.5.2 BSkyB's charging for use of the EPG, makes a freesat service unlikely on their HDTV. 4.5.3 Cost of a planning application for a satellite aerial would be incurred by some viewers. 4.6 I maintain that Freeview DTT channel usage at present, could be decimated, if the public could choose

HDTV channels instead. 4.6.1 There is no need for DTT duplicated broadcasting of radio channels, which are as unsatisfactory as the DAB radio channels where they belong. 4.6.2 There is no need for time-shifted channels with reasonable priced personal video recorders (PVR) now available. 4.6.3 Shopping channels may have a place on subscription satellite channels, but I don't think they should be broadcast as terrestrial channels. Another alternative is surely broadband. 4.6.4 I also don't think a small amount of pay television is a serious contribution to the public good, when it is at the expense of PSB broadcasting, and other carriers are available. 4.7 There is a limit to how much television any person or family can watch. This is only bounded by how much new programming is broadcast, given adequate storage. 4.7.1 Experience of use a personal video recorder (PVR) based on hard disk storage, leaves the user wanting more. Watching only and all the programmes of choice, is at last possible. 4.7.2 The current limitation on PVRs is that they do not have enough tuners, and the future limitation will be that they do not have enough hard disk space for HDTV programmes. 4.7.3 As in normal large scale integrated chip technology progress and cost, the dual tuners for HDTV cost less than the past SD tuner application specific integrated chips (ASICs). So building and selling a two tuner STB where each tuner-asic is dual, now requires one ASIC when in the past it required two. HDTV STBs can be priced at today's 40 SD dual-tuner. 4.7.4 But more relevant is that quad-tuner HDTV PVRs should have a ready market in the UK at prices that people have readily paid for dual-tuner SD PVRs within the last year. Six or even eight tuner PVRs are reasonable too, where the disk heads and platters can accommodate eight read-write channels on a 500GB hard disk (that currently retails separately at 80). 4.7.5 With adequate PVRs, repeat and time-shifted broadcasts are a redundant use of bandwidth. Repeats have their place in all broadcasters' schedules, but only providently. A well endowed PVR viewer hardly ever needs any repeats. 5 More Technologies 5.1 There is a general lack of public perception, about personal computers used as media centres. This fails to get any mention at all on the BBC web-sites, in the digital reception advice. If a suitable computer is available it is a small step to convert it to PVR use, in excess of anything on sale as a standalone PVR. 5.1.1 The last generation of Pentium-4 class computers, are eminently suitable for use as dual-tuner standard definition DVB-T PVRs. Rather than being discarded, this is an option and good reason for keeping them.(dvb-t SD PC-receivers are HDTV capable with 3.4GHz P4) 5.1.2 The new generation of dual-core/core-duo desktop computers are suitable for HDTV PVR use. A PC-receiver, dual DVB-S and DVD-S2 card, currently costs about 80. A terabyte of hard disk storage is obtainable for 160. If free to air HDTV was available, PVR use would be an appropriate use of such a computer, even for Virgin+BSkyB receiver/pvr subscribers. 5.2 I would go further than Ofcom has outlined and optionally include AAC decoders too in MPEG4 STBs, at a time when people would be buying their new DVB-T-HD STB, to solve another problem by enabling DRM at the same time. 5.2.1 My working assumption is that RadioScape would licence their RS500 module, which provides reception for DAB (Band-III & L-Band), DRM (LW, MW & SW), FM-RDS AM (LW, MW & SW) including AMSS, automatic alternative frequency switching (AFS), EPG (DAB), SDCARD Recording (DAB/DRM) and playback of MP3/WMA files. 5.2.2 This would enable a switch to Digital Radio Mondiale, as opportunity arose, preferably at a higher quality than DAB - that has suffered from the never mind the quality feel the width approach of, forget sound quality and be amazed at the number of radio stations. 5.2.3 Creating an additional reason and value, for the change in technology, goes hand in hand in this case with using a 5:1 sound system that has been bought to date mainly for DVD player use. The module would enable a 5:1 system as the principal all bands radio receiver.

6 Disagreements with Ofcom 6.1 The most fundamental disagreement, is that I would not be starting from here. Spectrum management is only a matter for Ofcom because of Government Acts and Regulations. When considering the proposed cessation of terrestrial analogue TV broadcasting ("switchover"), Ofcom are in the "jobsworth" position of low level officials in public service. They have no authority for change, with respect to the words of the legislation, except to know the rules backwards, although even if they know that there is flexibility they can choose not to use it. It is only the Government that can change an Act and Regulations that they were wrong about. 6.2 The four channel analogue band plan was created around groups of ten contiguous channels band span. Recommended aerials matured into three main types, channels 21-37 A, 35-53 B, 48-68 C/D, and two later groups of channels 35-68 E, 21-48 K. A wideband channels 21-68 W aerial is used for a few transmitters, mainly relay, but with an amplifier would be the most appropriate DTT replacement, providing for all possible changes. Old original aerials with different channel spans have likely all been replaced with these groups. If the existing transmitter analogue band plans were used for ten contiguous HDTV multiplexes, then hardly anybody would have to change their aerial. 6.3 The benefit of HDTV, which for a majority of people will only require purchase of MPEG4 STBs, supposes acceptance that this is a significant benefit for everyone, and MPEG4 becomes the norm commensurate with past TV broadcasting changes. But the main Ofcom document includes: 4.27 For as long as the majority of households could not decode HDTV signals, it might be necessary to simulcast services in both HD and SD. This would likely be the case for PSB services, which are intended to be available to 98.5% of the population after DSO. The benefits of HD services would initially be felt as enhanced viewing quality for viewers with HD equipment, but not necessarily as additional content choice, as the HDTV services would probably be duplicates of existing SD services. If the multiplexes switch to MPEG4 at switchoff, there is no need for any SD simulcasting, as the MPEG4 STB can downsize any HD picture to the required output of SD if required. 6.4 The Ofcom main document also includes: 4.28 A new national multiplex carrying HDTV would use the same amount of spectrum as a standard definition multiplex but would carry fewer services, because the data requirements of HDTV are higher. It is currently forecast that one multiplex could carry up to three HDTV services using the MPEG4 encoding standard. Absent any numeric values, I doubt this statement. It seems more likely to me that one 1080i HDTV service could be carried per channel, with perhaps room also for one SD service, but with qualifications. For example STBs are capable of using dynamic rate changes, and because older cinema colour film stock is lower than 720i resolution, first there is no point at all in transmitting such films at 1080i, but even at 720i it could be appropriate to use compression techniques to lower the bandwidth required compared to highly detailed pictures that make use of the detail available at 720i. 6.5 Dynamic reconfiguration of allocated channels is best done using contiguous channels. Envisaged, is that a PSBR broadcaster could choose to split a 1080i service into two 720i services, or even into four 576i services at times. There are uses of eight simultaneous SD broadcasts that come to mind, sports tournaments, the BBC broadcasting Wimbledon, and the Olympics. 6.6 The use of broadcast spectrum as a scarce resource, requires that equitable conditions apply. Ofcom includes: 3.33 From digital switchover, the three digital multiplexes carrying public service channels will operate from a similar number of sites as used by analogue broadcasting today (at least 1,154). The PSB multiplexes should consequently be available to the vast majority of UK households (98.5%). The three commercial multiplexes have decided to operate from 81 sites serving around 90% of UK households. I cannot agree that half the Ofcom proposed multiplexes, the commercial ones, are allowed to cherry pick while ignoring a significant part of the population, six million people. This makes nonsense of a significant part of the Ofcom arguments about extra choice of DTT channels, and segregates the uses to which spectrum within the commercial multiplexes can be used for the public good, other possible future beneficial uses for consumers and suppliers. Either all the channels have the same value, or if there is no universality of service then this discount of service coverage should carry a premium for the benefit of the PSBRs commensurate with, and proportionate to, the privilege granted. The current Ofcom proposal principles were not tested under market conditions for the existing Freeview allocations. 6.7 My proposed use of the existing analogue band plan at main transmitters, for switchover to ten HDTV

multiplexes on contiguous channels supposes that co-channel interference is better managed in digital transmission. The thresholds of interference requirements, favour using less powerful main transmitters, rather than maximising their output. So as not to interfere so much with interleaved relay stations operating within an area, generally using lower power main transmitters and higher gain directional aerials is a primary objective. Using a 1,000,000 watt transmitter when 10,000 watts would do, is not very Green and the difference is easily within the scope of aerial gain. The reasons for very high power analogue transmitters, to overcome all interference, do not apply to digital transmission based on threshold levels. In essence this requires going back to the drawing board and reconvening a WRC, when more effective decisions about cross-border interference could also be made. Nobody will die as a result of delay in the analogue shut down, and the overall picture of consumer purchases of HD-Ready televisions and availability of MPEG4 has radically changed the parameters since Ofcom's perceptions of, and agreement to, the The Regional Radio Conference RRC-06. The same applies to our neighbour countries and co-signatories. Brian Reid Beetson Robertson - 20 March 2007