RESPONSE FROM BRITISH TELECOMMUNICATIONS PLC ( BT ) TO DMOL S CONSULTATION ON PROPOSED CHANGES TO THE LOGICAL CHANNEL NUMBERS (LCN) LIST Introduction BT Vision is BT s digital TV service that combines digital terrestrial television (DTT) delivered Freeview channels with a digital video recorder and a comprehensive selection of On Demand (VoD) programming and interactive delivered over the customer s BT Broadband line. BT is also a shareholder in YouView and intends to be an affiliate ISP for YouView and a YouView content provider through BT Vision. BT s main concerns in responding to this consultation are to ensure that: 1. Sufficient opportunities are made available to make use of IP channel functionality and the corresponding LCNs made available by Freeview; and 2. Channels are presented, and LCN s are allocated, in a manner which meets viewer convenience and expectation. As such, BT has proposed that DMOL follow the same approach to the ordering of IP delivered channels in the EPG as it has taken to the ordering of DTT channels in the EPG. This approach recognises the importance of grouping channels by content type genre in accordance with viewer expectation rather than according to the means of delivery of the channel. BT has specific customer research that demonstrates that customers have very little understanding of the difference between a Freeview channel and a Pay TV channel. This research also shows that customers group channels by genre. Therefore, the same logical channel ordering that DMOL has applied to DTT channels should be applied to IP delivered channels. This can be achieved by reserving 5 discrete number blocks within or immediately after each of the General Entertainment, HD, Children s, News and Adult genres for IP delivered channels. It is important to highlight that BT s proposal is not that the IP delivered / channels are fully interspersed throughout the EPG but kept in discrete sub-sections of the 5 content type genres listed above. So while our recommendation meets viewer expectation, it avoids the complexities presented by having the IP delivered fully interspersed in the EPG. It also has no material impact for Freeview only viewers, but substantially benefits viewers who can receive Freeview and IP delivered. BT believes that its proposal to include IP delivered in each content type genre will have no material impact on viewers who only receive Freeview but will substantially benefit viewers who received both Freeview and IP delivered. Consultation question 1: Do you agree that the revised LCN listings must at a minimum address the issues of the genres which have overflowed and ensure there are no further overflows in the next two to four years? Yes, BT Vision s view is that viewers will benefit more from the grouping of all channels in the same genre together. 24 th May 2012 1 P a g e
Consultation question 4: Do you agree with the proposal to position the HD genre at LCN 101? Do you agree with the proposal to reorder the HD channels in the same order as their standard definition equivalents? Do you agree with the proposal to support LCN swaps of SD for identical simulcast HD channels if proposed by the channel provider? Yes, BT agrees with the proposal to re-position the HD genre at LCN 101 and use the same order as the SD equivalents. Viewers are currently familiar with the positioning of HD channels separately from SD channels and using the order of the SD equivalents is logical to viewers. BT will support the proposal to swap LCNs of SD channels with those of identical simulcast HD channels provided that there are technological mechanisms in place to ensure that customers without HD are not disadvantaged, for example, where customers cannot received HD channels, BT would expect the SD channels to remain in their current locations. Consultation question 5: Do you agree with the proposal to position the Children s genre after HD at LCN 110? BT agrees that the Children s genre should be positioned after HD. The exact number range for this genre should depend on other suggestions made by BT in this response.. Consultation question 6: Do you agree with the proposal to position the News genre after the Children s genre at LCN 120? BT agrees that the News genre should be positioned after the Children s genre. The exact number range for this genre should depend on other suggestions made by BT in this response. Consultation question 7a: If the outcome of the parallel and targeted consultation is that the Adult genre is reunited as an interim solution do stakeholders agree that there should continue to be only one Adult section in future? Yes, BT s view is that viewers will benefit more from, and be more appropriately protected by the grouping of all channels in the same genre together in a single location in the LCN listings. BT agrees there should only be one adult section in the future to minimise the risk of children finding them or being required to scroll past them in order to reach their genre channels. This should include all adult, whether TV channels, adult related text and MHEG and any adult IP delivered. Consultation question 7b: If the outcome of the parallel and targeted consultation does not result in the interim reunification of the Adult genre, should the two Adult sections be reunited, particularly given the requirements of the BCAP code? Yes, BT s view is that viewers will benefit more from, and be more appropriately protected by the grouping of all channels in the same genre together in a single location in the LCN listings. By reunifying the adult genre this will minimise the risk of children finding them or being required to scroll past them in order to reach their genre channels. 24 th May 2012 2 P a g e
This should include all adult, whether TV channels, adult related text and MHEG and any adult IP delivered. Consultation question 7c: Do you agree with the proposal to position the Adult genre after all of the television and the Text and MHEG genre? If not, please provide evidence based reasons and an alternative proposal. BT agrees that the Adult genre should be placed after all of the television and that the Adult genre should include all adult related, whether this is text and MHEG or IP delivered. BT believes that the LCN listing as proposed by DMOL does not take into account IP delivered that belong within the Adult genre. BT s preference is for LCNs across television (including IP delivered television channels) to be grouped by genre. As such, any IP delivered that belong in the Adult genre should also be positioned within the Adult genre number range. This approach also offers the most consumer protection by keeping all adult related in one single number range that can then be buffered appropriately in the listings. According to DMOL s current LCN listing proposal, the Adult genre is positioned above the IP delivered number range. If DMOL maintains that IP delivered should be kept in a single discrete number range, then BT does not agree that the Adult genre should be placed above IP delivered, or within proximity to IP delivered without a suitable buffer genre between the IP delivered and the Adult genre. This is particularly important because IP delivered will include general entertainment and children's /channels. IP delivered /channels will form a core part of a viewer's TV experience and the same logic as applies to DTT delivered should apply to IP delivered. With the exception of the five main public service broadcaster channels, we see no evidence to suggest that LNCs are less likely to be used to locate IP delivered than DTT delivered television. However BT agrees that scrolling through the Adult genre to reach the IP delivered should be minimised. Yet the positioning of the Adult next to, and especially above, IP delivered increases the likelihood that the Adult genre will be discoverable by children and young people, who could easily have to scroll through the Adult genre to reach a favourite children s or general entertainment channel that sits within the IP delivered genre. Equally, without a sufficient buffer beneath the IP delivered, children could easily scroll down into the Adult genre. In both instances, DMOL s proposed positioning of the Adult genre fails to address the regulatory and consumer protection issues that DMOL has identified in the consultation document and the need to move the Adult genre away from television that are frequently accessed by children and young people. This suggests that the range of channels likely to feature within the IP delivered has not been fully understood by viewer's taking part in DMOL's viewer research. As IP delivered /channels increase, this will become an increasing concern for viewers and DMOL unless the positioning of the Adult genre is reconsidered. DMOL has also identified in the consultation that qualitative research showed that some viewers felt the text were clearly targeted at adults and some were somewhat 24 th May 2012 3 P a g e
adult-like in their content (for example 1-2-1 Dating, Rabbit and Gay Rabbit 1. As such, BT believes that the progression from the Children s genre to the IP delivered genre should not require scrolling through the Text and MHEG genre. It is also arguable that there should also be a further buffer between IP delivered and Text and Adult. To conclude, it is BT s preference that the IP delivered are allocated on a purely genre basis and that there is a discrete block of LCNs reserved in each genre range for IP delivered as further explained in Part A of Appendix 1 as BT s IP Channel Proposal. On this basis, the positioning of the Adult genre would not need to be changed. However, if DMOL intends to keep IP delivered in one single, discrete number range, BT would propose placing the IP delivered ahead of the Adult genre and the Text and MHEG genre. Consultation question 8: Do you agree with the proposal to position the Text and MHEG genre after all the television with the exception of adult, at LCN 200? Do you agree with the proposal to split the genre into two sub-genres, Text Services and MHEG Services at LCNs 200 to 225 and 226 to 299 respectively? If not, please provide evidence based reasons and an alternative proposal. BT agrees that Text and MHEG should be placed after all the television except the Adult genre. Furthermore, BT proposes adult related Text and MHEG be relocated in the Adult genre. BT does not agree with the proposal to place a single discrete number range for IP delivered after this genre. Due to the reasons outlined in 7C. Consultation question 9: Do you agree with the proposal to abolish the Local genre and to classify local within genres by their content? BT agrees with this proposal. Consultation question 10: Do you agree with the proposal to allocate LCN 8 now to the channels with public service status licensed under section 244 CA in England and Northern Ireland, and similarly to allocate LCN 45 (or the lowest available LCN) in Wales and Scotland, and that this is an appropriate way to meet the appropriate prominence requirements of the EPG code? BT agrees with this proposal. Consultation question 11: Do you agree with the proposal to position the Interactive genre at LCN 350? BT agrees with the proposal to position the Interactive after the Adult genre. The Interactive and the Radio genre provide a buffer should younger viewers scroll up the LCN listings from BBC One. The exact number range for this genre should depend on other suggestions made by BT in this response. Consultation question 12: Do you agree with the proposal to reserve 100 LCNs, starting at LCN 400, for IP delivered? Please provide reasons and an alternative proposal if not. 1 DMOL Consultation on proposals for the reorganisation of the DTT LCN listing and on changes to DMOL s LCN policy, section 5.10, p.70. 24 th May 2012 4 P a g e
BT does not agree with the proposal to reserve 100 LCNs for IP delivered on the grounds that this is not an adequate number range and also for the reasons explained below. As a TV service that will make third-party IP delivered content and channels available via its User Interface EPG, BT would propose that DMOL reserve 5 blocks of LCNs for use by IP delivered at the end of each genre (See Part A of Appendix 1). It is BT s view that, irrespective of the delivery mechanism and technology used, TV and which are similar to TV should be positioned together in the listings. For viewers who do not receive IP delivered, such a proposal would have no material impact. Their channels would remain in logical genre order and contiguous on the EPG. For viewers who do receive IP delivered, it would be more intuitive and logical to find all TV channels together by genre. BT s view is that the viewer will not expect to have to consider whether a channel is delivered using broadcast DTT or IP technologies when using their EPG and therefore locating IP delivered at LCN 400 will be counter-intuitive to the viewer and render DMOL s genre proposal (with which we agree) incomplete. This view is supported by the research DMOL conducted which states that the majority of viewers expect to see channels grouped together by content type. In this regard, content type clearly means genre (i.e. general entertainment, children s, news, etc.) enabling the viewer to exercise editorial discretion / selection as opposed to meaning the method of technological delivery (which is not a factor typically considered when selecting what service to view at any particular time). BT is proposing to use IP delivered to deliver TV channels which will include high quality children s and general entertainment channels that perform consistently well on BARB. These channels will form a core part of a viewer s TV experience. Allocating a single, discrete LCN range of IP delivered next to the Adult genre and away from the other TV channels blurs genres, SD, HD, 3D as well as premium and basic content and would not be appropriate for these reasons. BT believes that the research conducted by DMOL did not highlight to participants what these channels would be used for and the importance of IP delivered in the future. With more and channels being delivered via this mechanism, a LCN listing next to the relevant TV genre would be more logical for customers. If DMOL decides to progress with an IP delivered service LCN range, BT proposes that this should be located as close as possible to the TV and a sufficient distance away from the Text and MHEG and, crucially, the Adult genre at LCN 150/200 (See Appendix 1). LCNs for genres following this would be moved to start from 300 and follow the LCN guideline proposed. BT also proposes reserving more than 100 channels for IP delivered. This will allow for future growth and development in this area. Out of approximately 700 television and radio channels licensed by Ofcom in the UK only 80 DTT channels are available on Freeview despite a complete range of 999 LCNs. In these circumstances, 100 LCNs is unnecessarily limited. BT s view is that the developing technologies around the delivery of TV using IP will significantly benefit the viewer and Freeview. Given that DTT capacity remains a finite resource IP channels will be able to provide a full and increasing range of channels, across a variety of editorial genres to viewers. By locating IP delivered within existing TV genres this will promote the use of IP delivered channels/ and augment and complement Freeview without impacting Freeview only viewers. 24 th May 2012 5 P a g e
Consultation question 13: What are your views on DMOL s overall proposal for the LCN listings? Please provide reasons for your views, and where appropriate, suggest alternatives where you disagree with the proposal. BT is in agreement with the majority of the DMOL proposals as outlined in previous responses. BT agrees with the DMOL proposal to locate the Adult genre away from other TV including Children's. However, BT would propose that DMOL also consider moving some Text and MHEG which also included adult content as part of the reunification. BT agrees with the proposal to position the HD genre at LCN 101 and the swapping of HD and SD channels if the potential negative impact on SD customers is removed. For IP delivered BT proposes that LCNs are reserved at the end of, or immediately after each genre (see Part A of Appendix 1). This would allow IP and DTT channels of the same genre to be located next to each other. If DMOL proceeds with a single, discrete LCN range for IP delivered, BT would propose that this range was positioned closer to the other TV at 150/200 (see Part A of Appendix 1). Viewers will expect TV channels to be located together, and be a sufficient distance from the Adult genre, irrespective of delivery mechanism. Consultation question 14: Do you agree that DMOL s proposals make adequate provision for the number of new in particular genres that are likely to be launched on the DTT platform over a 2 to 4 year time horizon. If not, please provide reasons for your view. We do not believe that 100 LCNs is sufficient for the reasons explained in our response to Q12. As an indication, BT believes a more appropriate number of LCNs would be in the region of 200-300. Consultation question 15: Do you agree that DMOL should seek to improve the navigability of the DTT platform? What are your views on the proposal to create information pages as bookends for genres after General Entertainment? BT would prefer to see the detailed proposals for the bookends and customer research before commenting on this proposal. There are many impacts and questions on such a proposal, for example: Would there be a bookend proposed for general entertainment? What would be the impact on the LCN for BBC1? What would the genres be called? Who will be able to customise the bookends? Will anyone other than DMOL have discretion to name the bookends? Consultation question 16: Do you agree that DMOL should not propose a reorganisation of the General Entertainment genre by channel family at this stage? BT agrees with the proposal not to reorganise the General Entertainment genre by channels family at this stage. 24 th May 2012 6 P a g e
Consultation question 17: Do you agree that a reorganisation of the General Entertainment genre into channel families is an issue to which DMOL should return in a future review of the LCN listings? What principles might such a reorganisation be based on? Yes, to improve the logical sequence of channels in the listings BT would agree that further investigation and review is required here. BT will provide further comments once this consultation process has started. Consultation question 18: We would welcome stakeholders views on the proposed timing of any changes. BT proposes that changes take place at times of least viewer activity. The changes should take place after the Paralympics and should be regionalised in the same way as DSO to allow control of operational impacts. Consultation question 19: We would welcome stakeholders views on the proposed communications plan to support any LCN listing changes. BT proposes that changes are clearly and timely communicated to viewers and interested parties. Subject to the budget that is available to DMOL for the communications plan for the LCN listing changes, BT believes that the methods used as part of the DSO were a good example of EPG based viewer communication. 24 th May 2012 7 P a g e
Appendix 1 BT LCN listing proposal: Part A: BT proposes reserving LCNs at the end of each TV genre. This will allow IP channels to be located next to DTT channels of the same genre. The table below gives an indicative number range. DMOL proposal Genre General Entertainment (inc Local) BT IP channel proposal First Last Genre LCN LCN 1 99 General Entertainment (inc Local) First Last LCN LCN 1 99 HD 101 109 General Entertainment 100 179 IP delivered Children s 110 119 HD 181 189 News 120 139 HD IP delivered 190 249 Text and MHEG 200 299 Children s 250 259 Adult 300 349 Children s IP delivered 260 279 Interactive 350 399 News 280 299 IP delivered 400 499 News IP delivered 300 319 Radio 700 750 Text and MHEG 320 369 Adult 370 409 Adult IP delivered 410 429 Interactive 430 529 Radio 700 750 Part B: If DMOL insist on maintaining a single, discrete number range for IP delivered, BT proposed the following re-ordering of LCNs: DMOL proposal Genre General Entertainment (inc Local) BT IP range proposal First Last Genre LCN LCN 1 99 General Entertainment (inc Local) First Last LCN LCN 1 99 HD 101 109 HD 101 109 Children s 110 119 Children s 110 119 News 120 139 News 120 139 Text and MHEG 200 299 IP delivered 150/ 399 200 Adult 300 349 Text and MHEG 400 499 Interactive 350 399 Adult 500 549 IP delivered 400 499 Interactive 550 599 Radio 700 750 Radio 700 750 24 th May 2012 8 P a g e