Australian Broadcasting Corporation submission to The Department of Communications, Information Technology and the Arts Meeting the Digital Challenge Discussion Paper on Media Reform Options April 2006
Australian Broadcasting Corporation Submission to the Department of Communications, Information Technology and the Arts on the Discussion Paper on Media Reform Options Executive Summary The ABC has a key role in ensuring that audiences have access to a diversity of programming, particularly in regional areas. The ABC is well placed to develop enhanced regional services across its digital platforms. The ABC supports the development of a Digital Action Plan to guide the transition from analog to digital television in Australia and the introduction of a fixed deadline for the switch-off of analog television services. The ABC believes that the Digital Action Plan should be overseen by an independent body with responsibility for ensuring a timely switch-over to digital television. To improve consumer confidence in digital television, the Digital Action Plan should make allowance for the creation of a Digital Test and Conformance Centre and the use of software updates via Over-the-Air Downloads. Unallocated spectrum set aside for datacasting services should first be used to address existing problems affecting digital television in Australia before consideration is given to new services. Should this spectrum be used for new services, the ABC would be potentially interested in providing content for mobile television or interactive digital services. The ABC welcomes the lifting of the genre restrictions on national broadcaster multichannels, as this will allow the Corporation to better contribute to encouraging digital take-up in Australia. The proposed restriction of sport content on national broadcaster multichannel services inhibits an opportunity to increase the public benefit provided by the anti-siphoning list. Broadcasters should be allowed to choose whether to use their spectrum for high definition television (HDTV) or for additional services. As the number of households capable of receiving HDTV services remains very small, the proposed capacity for broadcasters to provide an HDTV multichannel seems likely to have limited appeal. 1
ABC SUBMISSION ON MEDIA REFORM OPTIONS 2 Introduction The ABC welcomes this opportunity to provide comments on the Government s proposed changes to Australia s digital television and media ownership regimes. As many of the proposed changes, particularly those in relation to media ownership, relate primarily to commercial media services, the Corporation will confine its comments to aspects of the proposals that relate to its services. First, the ABC believes that any discussion of diversity in the Australian media must acknowledge the importance of sectoral diversity. As a national broadcaster, the Corporation has an important role to play in increasing the diversity of programming available to the Australian public, particularly in regional and rural Australia. Further, as the ABC has argued in numerous past submissions on aspects of digital television in Australia, the delivery of new and exciting content to audiences remains the key to the transition to digital broadcasting. Accordingly, the Corporation is pleased to see the inclusion of proposals to substantially lift the current restrictions on the genres of content on its multichannel services. However, the ABC believes that the proposed restrictions on the carriage of sporting events on the anti-siphoning list on its multichannel services represents a wasted opportunity to extend the public benefit created by the list. The ABC has also previously indicated its belief that the determination of a fixed, realistic date for the switch-off of analog television transmissions will act as a significant driver of the transition to digital television in Australia. To ensure the smoothest possible transition to digital, the Corporation supports the development of a formalised Digital Action Plan that will support consumers and allow the industry to plan with certainty. Diversity and Regional Services The ABC notes that one of the objectives of the Government s proposed approach to media ownership regulation is to ensure media diversity through clear protection against excessive ownership concentration among traditional media outlets, combined with market entry opportunities and regulatory barriers that allow for new platforms and services, that will assist in delivering a competitive sector providing diversity and choice for consumers. 1 The ABC believes that, in addition to such mechanisms, the current diversity of Australia s media is preserved and enhanced by the balance of complementary national, community, 1 Australian Government, Meeting the Digital Challenge: Reforming Australia s Media in the Digital Age. Discussion Paper on Media Reform Options, March 2006, p.4.
ABC SUBMISSION ON MEDIA REFORM OPTIONS 3 commercial and subscription broadcasting sectors. As a national broadcaster, the ABC plays an important role in guaranteeing that audiences have access to a diversity of sources of news and information, and a variety of programs oriented towards local communities. This is particularly true in regional Australia where the Corporation provides a wide array of localised services and is an active participant in regional communities. The ABC operates 60 ABC Local Radio stations around the country to provide news, information and other programming of direct relevance to local communities. Each station is supported online by a complementary website within The Backyard gateway on ABC Online. A recent report by the Communications Law Centre on media in regional Australia found that local communities generally value ABC Local Radio as a credible alternative to the journalism of local newspapers. 2 Since 2001, ABC Radio has applied National Interest Initiatives funding to maintain 25 Radio Online producer positions across Australia. These Radio Online producers gather, source and prepare content from regional Australia to increase the level of community-specific information on ABC Local Radio, The Backyard and other ABC platforms. The ABC also produces Australia Wide, a daily regional news and magazine program delivered via ABC2 and the ABC On Demand broadband service. The half-hour program features regional news from around the country coupled with a magazine-style segment that focuses on a different aspect of regional and rural Australia each day of the week. Magazine segment themes include youth, the environment and the arts. ABC Local Radio has become a primary source of emergency information during natural and other disasters affecting local communities. Most recently, ABC Local Radio Far North established a bureau in the devastated region of Innisfail to ensure that the local community received accurate and up-to-date news and information. This emergency broadcasting role is widely acknowledged and in 2003, the ABC entered into a Memorandum of Understanding with Emergency Services Australia as the primary disseminator of emergency information at the national level. Since then, the Corporation has entered into a similar agreements and local partnerships with relevant authorities in all states and territories, with the exception of New South Wales, where it has a signed interim agreement with the New South Wales Rural Fire Service and is pursuing agreements with other emergency services bodies. The ABC believes its unmatched network of Local Radio and Digital services can provide the basis for increased digital content creation in regional areas in the future. The ABC is well placed to develop enhanced regional services across its digital platforms and to develop each 2 See, for example, Tim Dwyer, Derek Wilding, Helen Wilson and Simon Curtis. Content, Consolidation and Clout: How Will Regional Australia by Affected by Media Ownership Changes? 2006. Melbourne: Communications Law Centre, p.xiii and passim.
ABC SUBMISSION ON MEDIA REFORM OPTIONS 4 Local Radio station into a hub for the creation of digital content that can be adapted for delivery on broadband, radio, digital television, and other emerging platforms. In this way, the ABC will continue to be a powerful safeguard of media diversity in coming years. Digital Switchover The ABC supports the development of a Digital Action Plan to guide the process and timing of the cessation of analog television services in Australia, as well as to further promote and encourage take-up of digital television. As previously indicated in its submission to the Department s December 2005 Review of the Duration of the Analog/Digital Television Simulcast Period, the ABC is willing to actively participate in the development of the Government s Digital Action Plan. The development of the Digital Action Plan must involve all relevant stakeholders and will require firm leadership from government to ensure that milestones are met in its development. The Plan should establish clear responsibilities for implementation. It may be necessary for the Digital Action Plan to provide financial incentives for broadcasters to develop new content in order to drive take-up of digital receivers. The ABC also supports the introduction of a fixed deadline for the switch-off of analog television services and believes that a strong commitment led by government is necessary to drive take-up of digital television services and encourage digital receiver sales. The ABC does not support the use of take-up rates of digital television as a trigger for the switch-off of analog television services. The ABC notes that the Discussion Paper identifies the date for analog television switch-off as being between 2010 and 2012. While the Corporation acknowledges the clear intention to specify a fixed date, it considers the imprecision of the stipulated span to be a cause of uncertainty. Broadcasters and transmission service providers require certainty to enable appropriate decisions to be made in relation to the replacement or refurbishment of ageing equipment. The ABC looks forward with interest to seeing the final form of the Government s Digital Action Plan. The Need for a Separate National Body to Implement the Digital Action Plan The ABC notes that the Minister has recently canvassed the possibility of the creation of new processes or organisations for the coordination of the switchover process and
ABC SUBMISSION ON MEDIA REFORM OPTIONS 5 acknowledged that it may well be that existing structures are not best placed to undertake the important task of coordinating and implementing switchover. 3 The ABC continues to believe that the establishment of an independent national body to oversee digital switch-over is an important element of any Digital Action Plan, and notes the successful work of SwitchCo, which plays this role in the United Kingdom. The proposed new body should be required to plan and coordinate the efforts of the Australian Government, the regulator (Australian Communications and Media Authority), the free-toair broadcasters, the receiver industry, retailers and installers and others including consumer groups to meet the milestones established by the Digital Action Plan. The proposed body would need to be clearly focused on the single objective of co-ordinating the digital conversion. While it would need to engage with existing organisations, including Digital Broadcasting Australia (DBA), the body should be set up to deliver one specific outcome the timely completion of the migration from analog to digital television broadcasting and should not become a forum for further debate. Improving the Consumer Experience of Digital television The speed and ease of the transition from analog to digital television is likely to be affected by consumer confidence in the reliability of digital television receivers. As the Corporation has previously argued in its submission to the House of Representatives Standing Committee on Communications, Information Technology and the Arts May 2005 Inquiry into the Uptake of Digital Television in Australia, anecdotal evidence suggests that the retail industry has many digital receivers returned due to difficulties with reception, use of unsuitable antennas and other issues. The ABC thus believes that the Digital Action Plan should include the establishment of a Digital Test and Conformance Centre to establish consistent standards and ensure all receivers work as intended in the Australian market. The establishment of a Test and Conformance Centre would allow the introduction of an Australian digital television compliance tick which would assist in supporting consumer confidence and encourage broadcasters to expand their creative thinking about the potential that digital only services offer for new business models. The Centre would also allow broadcasters to test new digital broadcast streams before commencing transmission to the public. Similarly, the Digital Action Plan should seek to improve the consumer experience of digital television by utilising digital receivers capacity to be provided with updated software via Over-the-Air Downloads (OADs). OADs are recommended for ensuring continuity of digital 3 Senator the Hon. Helen Coonan. A Digital Action Plan for Australia, Address to the Australian Broadcasting Summit, Sydney, 4 April 2006. Online: <http://www.minister.dcita.gov.au/media/speeches/a_digital_action_plan_for_australia>.
ABC SUBMISSION ON MEDIA REFORM OPTIONS 6 service, as well as minimising consumer disruption and cost. This technology has been successfully demonstrated in Australia and has been delivered in the United Kingdom for a number of years by the BBC on behalf of the free-to-air digital industry. The delivery of OADs would be a direct contribution to the development of digital television because it removes an element of cost and risk for both viewers and manufacturers associated with the introduction of new receivers with enhanced digital capabilities into the market. Completing Digital Roll-out Once the Digital Action Plan establishes a firm date for analog switch-off, the ACMA should begin actively planning spectrum arrangements for that event. The full planning for digital services after the closure of analog services needs to be completed as soon as possible. This should include planning for the digitisation of self-help services, which to date continue to be planned in analog. In accordance with the principle of universal coverage, the ABC plans and expects to offer the full range of its digital services in self-help areas, including ABC2, an electronic program guide, interactive programming elements, high definition television (HDTV) broadcasts required under legislation and radio services, such as dig. Additionally, it might include the planning of further spectrum for the ABC if the number or minimum technical standards applying to the services that it is required to provide are increased. New services on spare spectrum and other platforms The Discussion Paper proposes that the two unallocated channels set aside in most licence areas by the then Australian Broadcasting Authority (ABA) for datacasting services be used for new, non-free-to-air-television services, such as subscription, narrowcasting, data and mobile television services. In the ABC s opinion, this unallocated spectrum should first be used to address existing problems affecting digital television in Australia before consideration is given to new services. Correcting existing spectrum problems As the Corporation has argued in its submission to the Department s January 2005 Review of the Broadcasting Services Band Spectrum: Identification and Structural Efficiency, the first use for unallocated spectrum, including spectrum reserved for datacasting services, should be the elimination of any existing shortfalls in coverage of digital terrestrial television. Such coverage shortfalls can arise when digital services are introduced using UHF spectrum in areas where the corresponding analog services are carried on VHF channels. The principle needs to be recognised that achieving equivalent coverage for an analog service may require a number of digital transmitters or services. The ABC has previously highlighted these issues with a discussion of the move from analog on VHF to digital on UHF in the Bega/Cooma
ABC SUBMISSION ON MEDIA REFORM OPTIONS 7 region and sought government leadership in the resolution of these issues in a way that does not disadvantage viewers or demand excessive expenditure by broadcasters. The second use for unallocated channels should be addressing problems created by Single Frequency Networks (SFNs) in some areas. As the ABC has previously indicated, it does not consider SFNs to have been successful, as they cannot achieve equivalent coverage to analog services and have given rise to a high level of transmission-related complaints in certain areas where they are used. Accordingly, the Corporation is opposed to the planning of SFNs. As previously argued in its submission to the Departmental review of broadcasting services band (BSB) spectrum, the ABC believes this is particularly true of the two unallocated channels set aside for datacasting, the reservation of which was one of the key reasons for the adoption of SFNs in areas such as the Central Coast of New South Wales and the Gold Coast and the Sunshine Coast in Queensland. As described in detail in the ABC s BSB spectrum submission, digital television audiences in those areas have suffered from mush area interference problems as a result. Thirdly, the ABC believes that, where spare VHF Band III spectrum is available, it should be used to ensure adequate spectrum is made available for Digital Audio Broadcasting digital radio services. Thus, the ABC would strongly argue that the priority order for the use of unallocated television channels would be to firstly provide multiple transmitter services to meet known reception shortfalls between digital and analog services, secondly to eliminate or reduce the need for SFNs in areas with highly congested spectrum, and, thirdly, where possible, to provide Band III spectrum for digital radio services. New Digital Services While the ABC believes that the channels currently reserved for datacasting services should be used to address existing problems with digital television in Australia, it acknowledges that this is not the approach taken in the Discussion Paper. The Corporation thus offers the following comments on possible new uses for the spectrum. The Paper indicates that the national broadcasters are to be precluded from controlling datacasting transmitter licences. The ABC questions whether this restriction is desirable in light of the Government s broader objective of removing cross-media and other regulatory barriers. Further, if the intent of this restriction is to ensure the emergence of new services using this spectrum, the ABC points to its record as an innovator and enabler of new digital services. Notwithstanding this, there is nothing in this restriction to prevent the ABC from providing content to operators of datacasting transmitter licences, including for datacasting and mobile television services.
ABC SUBMISSION ON MEDIA REFORM OPTIONS 8 Mobile Television In the case of future mobile television services, the ABC believes that there is likely to be a case for mandating access to a certain percentage of the spectrum for the national broadcaster to ensure that quality Australian content is able to be accessed by Australians through these new services. Like all broadcasting services, there should be sectoral diversity in the selection of content made available to viewers over mobile television services. Similarly, the ABC would expect that this new form of broadcasting service would be subject to the same end-to-end planning processes as other services operated in BSB spectrum. The ABC is currently involved in providing content for both the datacasting and the mobile television trials and notes that most content providers for the mobile television trials are subscription television channels that carry minimal Australian content. Access could be mandated for the ABC to provide a channel of short-form Australian information and other local video content suitable for this new portable broadcasting platform. Datacasting Services The ABC believes that there are a number of possible new, interactive digital-only services that would provide rich viewer experiences and would further assist with the uptake of digital television in this country. The ABC has explored a number of ideas for datacasting services of this kind, including education and regional news and information services, that it is unable to mount as inadequate space remains on its existing 7MHz broadcasting spectrum allocation. The Corporation would be potentially interested in offering such services if further spectrum became available, either on a datacasting multiplex operated by the holder of a datacasting transmitter licence or if the Corporation was itself able to secure control of such a licence. Multichannelling The Discussion Paper proposes the removal of the current genre restrictions applying to national broadcaster multichannel services under subclauses 5A(2) and (3) of Schedule 4 of the Broadcasting Services Act 1992 ( BSA ), subject to the restriction that the channels not carry sporting events listed in the Broadcasting Services (Events) Notice (No. 1) 2004 more generally known as the anti-siphoning list. The ABC welcomes the lifting of the genre restrictions. However, the Corporation is concerned that the proposed restriction of sport content on its multichannel services inhibits an opportunity to increase the public benefit provided by the anti-siphoning list. Removal of the Genre Restrictions on National Broadcaster Multichannels With the exception of the launch of ABC2, which has been successfully used by retailers as an enticement to consumers to purchase digital receivers, there has been relatively little
ABC SUBMISSION ON MEDIA REFORM OPTIONS 9 incentive for viewers to adopt digital television, a fact reflected in the slow adoption of the technology. Evidence from the UK suggests that in markets where there is limited consumer choice in free-to-air broadcasting, free-to-air multichannel services have been an important driver of widespread adoption of digital television and the development of a strong free-to-view multichannel market alongside subscription television. The ABC submits that a similar appetite for greater viewer choice in the free-to-air market exists in Australia. Of particular interest is the experience of smaller markets which have experienced the introduction of new, digital-only channels. In all cases, the take-up rate for digital television has been significantly higher than elsewhere in the country. For example, in Hobart, the estimated number of viewers with digital receivers grew to 26.4% between the introduction of the digital-only service in January 2004 and the first quarter of 2005. 4 When the same service was introduced in Launceston, the proportion of digital-capable viewers rose from 4.8% when the service launched in August 2004 to 11.1% in the first quarter of 2005. Similarly, in Mildura, Victoria, retailers reported a substantial increase in sales of digital receiver equipment after a new, digital-only television channel was introduced in January 2006, with one retailer reporting sales of 1,300 set-top boxes in the two months surrounding the launch, as opposed to 250 set-top boxes in the preceding eleven months. 5 The ABC welcomes the proposal to lift the existing genre restrictions on national broadcasters multichannel services. Broadening the scope of additional services made possible through digital national multichannels will help to further differentiate digital from analog television, and increase its value in the eyes of potential audiences. Lifting the genre restrictions will allow public broadcasters to provide the Australian public with greater access to the full range of publicly-funded programs, including making full use of archival material as rights and funds permit. This would enable the Corporation to rebroadcast older, landmark Australian drama and comedy programs, allowing Australians to once again see these programs and give the Corporation the ability to make more effective use of the vast resource that is the ABC archives. The removal of these genre restrictions would allow the ABC to offer further services that reflect its Charter obligations and programming strengths in a form convenient to audiences. The ABC has already foreshadowed in the media that, should the genre restrictions be lifted and subject to rights clearance, it may broadcast programs from its archives, such as the acclaimed drama series GP, Brides of Christ, Grass Roots, Police Rescue and Blue Murder and 4 Prime Television. Prime Television Ltd submission to Review of HDTV Quota Arrangements, June 2005, p.2. 5 Retailers report sales are hectic as new digital TV service commences in Mildura, Digital Broadcasting Australia Information Bulletin, February March 2006. Accessed 13 April 2006: <http://www.dba.org.au/newsletter/ib-febmar06-full.asp#reception2>.
ABC SUBMISSION ON MEDIA REFORM OPTIONS 10 comedies including Aunty Jack, The D Generation and Mother and Son. Similarly, it proposes to extend the range of programs from the ABC main channel that are carried on a time-shift basis on ABC2, including entertainment, comedy and drama, and national news and current affairs. The lifting of the genre restrictions will also extend the scope of programming that can be included on the ABC2 schedule from the ABC new media productions currently available as video-on-demand from ABC On Demand on ABC Online, including short-form comedy and other entertainment programs. Restrictions on Anti-Siphoning List Events on National Broadcaster Multichannels The ABC supports the principle underlying the anti-siphoning list, which seeks to ensure that the most significant sporting events are made available to Australian audiences on freeto-air television. Moreover, the Corporation believes that the possibility of listed events being carried on its multichannels presents an opportunity to increase the public benefit of the anti-siphoning regime by increasing the chances that audiences will be able to freely view major sporting events. However, this opportunity would be frustrated if the proposed restriction on the carriage of listed sports on national broadcaster multichannels was enacted. As a public broadcaster, the ABC is in the position to ensure that the viewing public is able to freely access a greater number of sporting matches on the anti-siphoning list, in partnership with the rest of the industry. The ABC broadcasts a range of Australian sporting events that have devoted followings but attract insufficient audiences to be of interest to commercial broadcasters, and have not even been of interest to the subscription television sector. These include competitions on the current anti-siphoning list, such as international Test matches involving the Australian netball team. This complements the ABC s extensive coverage of a range of regional and, in particular, national women s sport. For example from May 2006, the ABC will be broadcasting matches from the regional and state-based netball competition live on ABC2 on Friday nights and then replaying them on Saturday afternoons on its main television channel. The ABC believes it would be appropriate if it was in a position to similarly broadcast the international netball Test matches live on ABC2 prior their re-broadcast on the ABC main channel. However, the proposed anti-siphoning restrictions on its multichannel services would prevent this. Similarly, in recent years the ABC has been offered the free-to-air rights to a number of sports matches from the anti-siphoning list, including the on-sale by commercial broadcasters of the rights to carry listed sporting events outside of their immediate region of interest and events that have made available as a result of the anti-hoarding provisions of the BSA. However, due to pre-existing programming commitments, it has not always been possible for free-to-air coverage of such events to be offered on analog services. The ability to offer such events on multichannel services would allow the ABC to broadcast these key
ABC SUBMISSION ON MEDIA REFORM OPTIONS 11 sporting matches live on ABC2, particularly in prime time, as well as on its main television channel at a time that allows the Corporation to keep faith with its loyal audiences for longstanding programs. The important result is that more Australian viewers would get the opportunity to see their sport live in a free-to-air environment. Providing the national broadcasters with the capacity to air listed sporting events on multichannels would also enhance the effectiveness of the anti-hoarding provisions set out in Part 10A of the BSA. The purpose of the anti-hoarding provisions is to prevent commercial broadcasters from making strategic acquisitions of rights to overlapping sporting events to deny those events to their competitors, a consequence of which is that the public is also denied access to events. Commercial broadcasters only need to offer these events to the national broadcasters to avoid sanction under the anti-hoarding provisions. However, past experience shows that in order to meet the expectations of loyal audiences for its regular programming, the ABC is unlikely to have the capacity to accommodate such events on its main channel television service. However, if the national broadcasters were permitted to carry these events on multichannels, they would be more likely to accept the offered events for live or prime-time broadcast and rebroadcast at a suitable opportunity on the main-channel service, increasing the effectiveness of the anti-hoarding provisions. The resulting public benefit of greater access to significant sporting events free-to-air would grow as digital take-up increases. Allowing the flexibility to broadcast sporting matches on the anti-siphoning list across both free-to-air analog and digital channels would also assist in the take-up of digital television receivers. The one-off expenditure of less than $100 for a standard definition (SD) set-top box would allow viewers to access a broad range of programming and assist with the free-to-air broadcasters meeting the anti-hoarding provisions of the legislation. High Definition Television High Definition Television Quotas The ABC notes that the Government proposes to retain the High Definition Television (HDTV) quotas until the introduction of multichannelling by commercial broadcasters. The Corporation believes that broadcasters should be allowed to choose whether to use their spectrum for HDTV or for additional services. Since 1 July 2003, the ABC has transmitted an HDTV version of a proportion of its programming on digital logical channel 20. In each reporting period since that date, it has met or exceeded the requirement set out in clause 4 of Schedule 2 of the Broadcasting Services (Digital Television Standards) Regulations 2000 that it transmit 1,040 hours of HDTV content each year.
ABC SUBMISSION ON MEDIA REFORM OPTIONS 12 However, evidence to date continues to indicate that HDTV will not be a major driver in the uptake of digital television in Australia in the near or medium term. Currently, the number of HDTV receivers in the market is in the order of 400,000, meaning that around 30% of the small number of Australian households able to receive digital terrestrial television are able to receive HDTV signals. Moreover, none of the households that receive digital television via subscription services are able to view high definition programming (HD). However, the Corporation acknowledges that in the longer term consumer interest in the format is likely to grow, as is the saleability of rights to HD content on international markets. Accordingly, the ABC is in the process of developing the capacity for HDTV production. The ABC believes that the development of digital television in Australia would be better served by allowing broadcasters to make their own judgements about the uses of their spectrum allocation that will be most attractive to Australian audiences. However, if the existing quota-based approach is to be retained, the Government should revisit the standards for digital receivers to require that all boxes be able to decode both SD and HD signals to free up bandwidth by eliminating the need for wasteful HD SD simulcasting in the longer term. In its submission the Department s June 2005 Review of High Definition Television Quota Arrangements, the ABC has argued for both this change to the Australian standard and also for the adoption of the MPEG-4 Part 10 HDTV encoding standard 6 in its submission to the review of high definition television quota arrangements. Both changes would free up valuable spectrum to allow it to provide an additional multichannel service, interactive enhancements or to increase the resolution of its HD output from 576p to either 720p or 1080i format. Removal of the HDTV Simulcasting Requirements The Discussion Paper suggests that the Government could remove the HD SD simulcast requirement so that broadcasters HDTV services can be different from the SDTV simulcasts of their analog services. Given the very small number of HDTV receivers currently in use, an HD multichannel of this kind may have limited appeal. However, if the standards for digital receivers were to be changed to require that all boxes be able to decode both SD and HD signals, as argued above and previously by the ABC, the potential for an HD multichannel would become more attractive and could contribute to digital takeup. Conclusion The ABC has focused its comments in this submission on those proposals within the Discussion Paper that are directly relevant to ABC services. The key points made in the submission are: 6 MPEG-4 Part 10 is also known as Advanced Video Coding (AVC) or ITU-T Rec. H.264.
ABC SUBMISSION ON MEDIA REFORM OPTIONS 13 As a national broadcaster, the ABC is well placed to contribute strongly to ensuring that audiences have access to a diversity of programming, particularly in regional areas. The ABC s unmatched network of Local Radio and Digital services provides the capacity to develop each Local Radio station into a hub for the creation of digital content that can be adapted for delivery on a range of platforms. The ABC supports the development of a Digital Action Plan to guide the transition from analog to digital television in Australia and the introduction of a fixed deadline for the switch-off of analog television services. The ABC believes that the Digital Action Plan should be overseen by an independent body with responsibility for ensuring a timely switch-over to digital television. The ABC welcomes the lifting of the genre restrictions on national broadcaster multichannels, as this will allow the Corporation to better contribute to encouraging digital take-up in Australia. However, the proposed restriction on sport content that can be shown on national broadcaster multichannel services inhibits an opportunity to increase the public benefit provided by the anti-siphoning list. The ABC believes that unallocated spectrum set aside for datacasting services should first be used to address existing problems affecting digital television in Australia before consideration is given to new services. However, should this spectrum be used for new services, the ABC would be potentially interested in providing content for mobile television or interactive digital services.