Channel 4 response to DMOL s consultation on proposed changes to the Logical Channel Number (LCN) list Channel 4 welcomes the opportunity to respond to DMOL s consultation on proposed changes to the DTT logical channel number ( LCN ) list. Channel 4 believes there are opportunities to rationalise and simplify the current LCN list which would have substantial benefits to viewers improving clarity, organisation and the usefulness of the list. In responding to the questions in the consultation we have approached our answers with the following objectives in mind: 1. to put the consumer at the heart of the policy and to think through what they would expect to see; 2. to think about the scale of the channels on offer in terms of broadcast hours, breadth of interest and reach and to suggest rankings which are intuitively consistent with that scale ; and 3. to ensure that any changes proposed act to future proof the platform as far as possible. As a result of these objectives we believe that the most appropriate and intuitive grouping of services is as follows: 1. General entertainment 2. HD services 3. children s services 4. shopping (if created) 5. news 6. local television 7. text, interactive and IP delivered services 8. adult services 9. Radio Our responses to the specific questions posed by DMOL are set out below and reference this ordering. In addition to this we believe that any services with restricted hours should be grouped after the relevant genre classification. So for example, in this consultation general entertainment channels with restricted transmission hours would be listed after the main general entertainment services. 1. DMOL would like to consult on the proposal that one of the guiding principles for maintaining the LCN map should be that services on the platform should be sequenced in the following order: a. TV services b. Text and interactive services c. Radio services >> Consultation Question 1: Do you agree with this principle? Channel 4 agrees that these are appropriate principles to apply when allocating numbers as they are likely to reflect the way viewers would expect services to be grouped on what is principally regarded as a television platform. However, in the era of convergence we think it is appropriate to extend the definition of text and interactive services to also include those delivered by IP. In addition, we do have a concern in relation to adult services which we believe should be appropriately
segregated from other services whatever their means of delivery and in our suggested ordering would come after text, interactive and IP delivered services. 2. DMOL currently allocates TV channels according to the Classifications set out below. DMOL would like to consult on the following Classification definitions which may be adopted in a future version of the LCN Allocation Policy. a. Adult channels that are carrying content of a sexual nature aimed at adults b. Children s channels whose output (as measured by non-repeated output) is more than 80% dedicated to school-age and pre-school children c. High Definition channels delivered compliant with the D-Book HD specification d. Local channels broadcast to a geography within, but less than, the whole of one of the countries of the UK e. News channels whose output in hours is more than 80% dedicated to carrying news and current affairs f. General Entertainment channels offering at least 21 hours of output each week that do not qualify for one of the other Classifications above >> Consultation Question 2: Do you agree with these definitions? Channel 4 agrees that these definitions are broadly appropriate. As a guiding principle we would like to see those channels with greater scale in each area being represented to viewers before those of a narrower or more focussed interest. Applying this broad philosophy gives a rationale to the proposals to, for example, show local services, which by definition are available to only a minority of viewers, after national services and those channels which are available for limited numbers of hours later than those which are generally available when the majority of the audience are watching television. We believe that geographic availability would be a more important determinant than genre so for example in the event that a shopping genre were created, a local shopping channel should still appear under local services rather than shopping. Our specific comments on these proposals are that: the adult definition should be tightened up to reflect the proportion of adult material carried on the channel (similar to how the children s definition sets a threshold for children s content). This could be done by altering the definition to read: channels that are predominantly carrying content of a sexual nature aimed at adults We are particularly keen that DMOL reacts to the clear intent of the regulator in grouping and highlighting these services in a specifically demarked area; we support the idea that channels with limited broadcasting hours should appear after those that are generally available in primetime as this minimises viewer irritation over apparently blank LCNs; and we believe that, although the local TV debate is fluid, a distinction can be drawn between separately listed local channels and/or local multiplexes, such as Channel M in Manchester, which are available in restricted geographic areas and, for example, the Government s proposed national backbone to support local services which by definition would be available UK-wide. On this basis we believe it is perfectly reasonable to group local channels and multiplexes
together in some part of the LCN list and separately from the proposed national backbone. 3. DMOL would like to consult on proposed definitions for UK, National and Local TV services: a. UK services are those who are broadcast to Scotland, Wales, Northern Ireland and England b. National services are those who are broadcast to Scotland or Wales or Northern Ireland or England c. Local services are those who are broadcast to a geography within but less than the whole of one of the countries of the UK >> Consultation Question 3: Do you agree with these definitions? As noted above as a general principle Channel 4 believes that service availability can be used as a guiding principle when allocated positions in the LCN list. This methodology allows listings to be organised dependent on the geographic coverage of a service with those services available to all viewers allocated places in the listing higher up than those available to specific groups of viewers. It will be important to ensure that appropriate prominence for PSB services is maintained and the relative position of these categories relative to other groupings will also be important. Since most of these services will be broadly based they ought to appear before more targeted services such as children s, news or shopping (were it be created). There will remain an issue of determining the relative ranking of UK-wide services available only for limited hours versus national or local services. We are not in favour of services such as S4C being pushed into a new national ranking as we see no clear requirement for change here. 4. DMOL would like to consult on the proposal to introduce a new Restricted Hours mixed genre classification for any services that are on air for less than 21 hours each week. >> Consultation Question 4: Do you agree with this proposal? Channel 4 is supportive of this proposal as it follows on logically from the principle of availability discussed above. It seems odd to us that channels which broadcast for only a very few hours and are, therefore, not available to the majority of viewers would achieve precedence and prominence over channels which are generally available to all viewers merely for historical reasons. As this current proposal applies to general entertainment services we believe they should be listed after the main general entertainment genre. 5. DMOL would like to consult on the proposals for positioning Local TV channels within the LCN map. Below are a number of options for consideration: a. DMOL moves the current Local TV classification to LCN60 b. DMOL moves the current Local TV classification LCN100 c. DMOL dissolves the Local TV classification and allocate channels to the next most appropriate classification regardless of geographical target d. DMOL retains the current Local TV classification at LCN200 e. Other (please specify) >> Consultation Question 5: Which is your preferred option? We believe that a distinction needs to be drawn between services available in defined localities and those available nationally. In order to allow for the potential for local multiplexes (of the type running in Manchester) and the resulting possible
variety of channels, DMOL needs to allocate a range of numbers which allow for expansion for up to 10 or even 12 services. This expansion is not easily accommodated in the generally congested numbering from 1-100. Dissolving the local TV classification does not appear appropriate as research shows that viewers dislike gaps in the LCN listing and given the restricted availability of local TV channels only a minority of viewers will ever be able to receive them, therefore most people scanning a list containing a series of local services would see nothing. The current sequence at LCN 200 is in reality only a few places below 110 because boxes and sets do not show unused LCNs, however the appearance of adult services above 200 is unfortunate and we understand the concerns of local TV providers who do not wish to be associated with adult services. This issue could be resolved by moving adult services well away from other channels. In terms of ordering we believe local TV should appear at lower numbers (ie closer to the top of the LCN list) than both adult and text services. This implies a listing at numbers lower than 100. The exact positioning would depend on the eventual ranges allocated to other services but we would prefer the order to be as shown at the beginning of our response. 6. DMOL would like to consult on the proposals for positioning of Text and interactive services within the LCN map: a. DMOL retains the current 100-119 range for Text services b. DMOL repositions the existing text services after all broadcast TV services c. DMOL repositions the existing text services after all broadcast and IP TV services d. Other (please specify) >> Consultation Question 6: Which is your preferred option? Given the expansion of TV services Channel 4 does not believe that the current positioning of text services at 100-119 is sustainable or desirable. It makes more sense to place these services after the existing broadcasting TV services and placing them in a new category of text, interactive and IP delivered services. Our main concern is the positioning of adult services. There is merit in placing text services at lower numbers (ie closer to the top of the LCN list) than adult services allowing a safe segregation of adult services away from other services (as shown in our schematic at the beginning of this response). However, given that many of the text services are themselves partly adult in nature this is a difficult judgement to make and we do not believe it makes sense to divide text services into different genres themselves. On balance however, we favour putting text services before adult services so that adult services can be safely segregated from other services on the platform. 7. DMOL would like to consult on the proposal that where there are five or more channels that share an editorial genre within General Entertainment that normally DMOL will consult on the creation a new Classification. >> Consultation Question 7: Do you agree with this proposal? This seems a sensible suggestion as it would allow channels to be grouped into logical areas which would assist viewer navigation. In order to do this it may be useful at this stage to pre-determine what those genre classifications could be so that channel providers are readily aware of the impact of launching further services and any future consultation exercise could be expedited.
8. DMOL would like to consult on the proposal that a new teleshopping classification is created at LCN 60. The classification is proposed to be defined as channels that are licensed as teleshopping services that do not contain adult content. >> Consultation Question 8: Do you agree with this proposal? Channel 4 supports setting up a new shopping genre which could also include channels offering other transactional services (but not adult services). We believe it should be part of the main television listing ie grouped between channel numbers 1-100. Whether channel 60 is the correct starting point depends on the decisions made about other proposals such as moving HD, local and adult. It would be useful in this context to know whether viewers would prefer or expect to see shopping services before or after news and children s services which may be a useful topic for further research and investigation. Our instinct, as shown in our opening comments, is that shopping should come after children s but before news channels. 9. DMOL would like to consult on the proposal to create a new classification within the range LCN 400-499 for live TV channels delivered via IP. IP Classification definition to be: channels delivered via internet protocol rather than via DVB broadcast (not including on demand or virtual channels) >> Consultation Question 9: Do you agree with this proposal? We understand that this proposal is partly designed to accommodate services launched on new connected TV devices including those of YouView. In order to avoid confusion and an overlap or duplication between numbers allocated by DMOL and those used by connected TV devices there is clear merit in a co-ordinated approach. It is also sensible that at this point in time IP delivered services are kept clear of broadcast channels on the basis that they will not be receivable by the majority of viewers as new equipment will be required to access them, nor will they by definition be delivered by DTT. In addition, many of these services will be pay rather than free to air channels which further reduces the potential availability to viewers. In order to future proof the platform and to prepare it for connected TV devices and IP delivered services we believe there is merit in creating a broader grouping of services encompassing text, interactive and IP delivered services. If this proposal (creating an area for IP delivered services) is accepted a critical issue is to ensure that any numbering system is not specific to one product/provider but has general applicability and/or a variety of equipment providers can use the numbering system. Therefore, we believe that very careful thought must be given to how numbers are allocated and who allocates them. It would be possible for DMOL to either agree to leave a range of numbers blank in the LCN listing for a variety of providers to use; or alternatively for DMOL to allocate these numbers to specific channel providers which would require the creation of direct relationships between DMOL and those channel providers who will not be using DTT to deliver services. Therefore, on the face of it this latter option looks odd as DMOL s role is to manage the DTT platform. In addition, at this stage DMOL does not, in our view, have the resource to do the latter nor the funding to do it so there will be a question of how the costs of this allocation are borne. Balanced against this however, in a more converged era, this option has the merit of providing an existing fair, reasonable and non-discriminatory policy and mechanism for allocating channel numbers which would be open and transparent.
10. The Adult channels, including the Bookends required by OFCOM, are currently placed at LCN92-99 with an overflow section recently created at LCN 189-199. DMOL would like to consult on alternatives: a. to extend the current range from 92-99 to 92-110. b. to form a new and continuous block for Adult channels after News, but starting at LCN100 c. to form a new and continuous block for Adult channels to join up with the existing overflow at 189. d. to form a new and continuous block for Adult channels at the end of broadcast TV channel list e. to form a new and continuous block for all Adult channels (including any delivered via IPTV), at the end of the all TV channels list f. Other (please specify) >> Consultation Question 10: Which is your preferred option? Channel 4 agrees that adult television services ought to be separately listed and segregated from other channels. We believe this is what viewers would like to see and is clearly the intent of Ofcom who have requested that bookends are broadcast and that channel names are prefaced with Adult. Of the options suggested we do not believe that either a. or b. are viable given the congestion in the main list and the issues with allocating a range of numbers to local TV so there will be insufficient space to fully segregate the channels. We also believe options c and d fail to adequately segregate the services by placing them relatively close to the main TV LCN listings. We therefore favour either option e or f and believe that our schematic suggesting a listing beyond text, interactive and IP services would fall in category f. To be effective this categorisation would probably need to group DTT delivered and IP delivered channels together as suggested in option e, otherwise our approach might result in adult delivered IP services being listed above DTT delivered adult services which is not our intention. 11. DMOL would like to consult on the proposal to move the HD classification from the LCN 50 range to the LCN 100 range. >> Consultation Question 11: Do you agree with this proposal? Channel 4 is not in favour of this proposal. Given the consumer demand for HD services and the significant investment made by broadcasters in providing HD services we believe the 100 sequence places HD too far down the LCN list. Our strong preference is for HD services to be listed immediately after existing SD general entertainment services. Other issues Channel 4 as an indirect shareholder in DMOL is familiar with the issues DMOL has encountered with trying to get all channel providers to sign LCN agreements and the limited sanctions available to DMOL for those refusing to sign. We believe it is critically important that DMOL has a direct relationship with channel providers so that it can adequately manage the DTT platform and LCN lists. We therefore believe that the LCN policy should be updated to include an explicit statement specifically requiring channel providers to sign an LCN agreement in order to be covered by and benefit from the provisions of the LCN policy. We believe the inclusion of an explicit statement to that effect will strengthen DMOL s position when dealing with those providers refusing to enter into agreements. Such a change will also help to ensure
that DMOL does have a direct relationship with each channel listed on the platform and can legitimately apply sanctions against those who don t.