Australian Broadcasting Corporation Submission Digital Conversion of Self-Help Television Retransmission Sites (Department of Communications, Information and the Arts) August 2007
Australian Broadcasting Corporation Comments on the DCITA Discussion Paper on Digital Conversion of Self-Help Television Retransmission Sites Introduction The ABC welcomes this opportunity to comment on the needs of Australians living in areas served by self-help television retransmission sites. The Corporation recognises the important role played by both community groups and the Government in providing self-help television retransmissions that provide broadcasting services for all free-to-air broadcasters to small communities unable to access the available free-to-air terrestrial services for geographic and topology-based reasons. In this submission, the ABC seeks to provide comments both on the specific issues raised in the Department s June 2007 discussion paper, Digital conversion of self-help television retransmission sites, and on a small number of related issues. ABC Approach to Audience Delivery As the national broadcaster, the ABC has a long-standing policy of ensuring that its broadcast services are available as a free-to-air terrestrial service to all Australians. In this regard, the ABC makes no distinction between regional and remote areas in planning its analog and digital television coverage. In practice, this has been reflected in the standing ABC policy that terrestrial television services should be made available to all communities of at least 200 persons. The ABC is currently implementing its rollout of digital television transmitters to replicate its existing analog network. As planned, this rollout will be concluded before 2011. At the end of July 2007, the ABC had 237 transmitters delivering digital terrestrial television services to approximately 97% of the population. Remote Areas with Populations of Less Than 500 The ABC currently provides its analog television coverage to 78 sites with a population of 500 or less. Of these sites, 63% are located in the remote areas. Since 2001, the ABC has extended its digital television coverage to 11 of these sites and plans to roll out the remaining 67 sites before 2011. This reflects the Corporation s policy of converting all of its analog television transmission services into digital mode, so that all Australians currently receiving ABC services continue to do so in addition to receiving the full benefits of digital television. In view of pending Government decisions on digital conversion in remote areas, the ABC would be happy to adjust its digital television rollout program to avoid pre-empting any Government decisions in respect of the smaller remote communities. 1
ABC Submission: Digital Conversion of Self-Help Television Retransmission Sites 2 Defining the Services to be Retransmitted The ABC defines its digital service as all services available within the 7MHz bandwidth of its standard free-to-air channel allocation. This currently includes its primary channel, ABC2, a high definition television (HDTV) service to meet legislative requirements, radio services such as the dig service and the carriage of an electronic program guide and interactive programming elements. Any additional services that the Corporation mounts within the spectrum available to it will also be regarded as part of its digital service. For example, the ABC has submitted proposals to government for an additional standard definition channel, which should be regarded as part of the ABC digital television service if it proceeds. The Corporation believes that all Australians should have access to its complete digital service, whether from ABC-funded terrestrial transmitters or self-help services provided by community groups. In relation to proposals to replace existing self-help retransmission arrangements with multiplexed or other delivery means, the ABC would be concerned about any proposal for self-help retransmission of its services that did not carry the complete ABC digital service. Reliability of Retransmission Services Viewers frequently regard self-help retransmission services as the responsibility of the respective network. As a consequence, the ABC is concerned about the quality of service from self-help retransmission services. As digital reception suffers from the cliff effect in which the ability to decode signals ceases abruptly below a threshold signal strength, it is less forgiving than its analog counterpart, which degrades gradually as signal strength decreases. The ABC notes that digital retransmission facilities will thus need to be adequately designed and implemented to ensure a reliable service. In addition, a publicity campaign is also essential in ensuring viewers understand their receive equipment (antenna, set-top-box/receiver and cable) also plays an important role to ensure reliable reception. There is an important role for Digital Australia to play in the planning of publicity campaigns for the self-help services and their conversion to digital. Consideration of the Need for Specific Digital Self-Help Retransmission Services In examining the question of self-help arrangements, it may be useful to consider whether all areas currently requiring analog retransmission facilities will not to convert to digital equipment. Analog self-help retransmission services are established in locations where signals from the broadcaster-funded service are inadequate. However, those inadequate signals may be the result of either reduced signal strength or ghosting, which is a common problem with analog television.
ABC Submission: Digital Conversion of Self-Help Television Retransmission Sites 3 As digital transmissions provide a ghost-free signal, it is possible that some sites may not need to migrate to digital if their analog services have been introduced as a result of severe ghosting problems. The ABC understands that some field surveys have been conducted under the Government s Television Black Spots Program prior to the introduction of the analog television self-help services. These measurement results may be useful to identify if any of these services have been established due to severe ghosting problems from the main service, which may negate the need of such services to convert to digital. Timing of Conversion to Digital for Self-Help Retransmission Sites for ABC Television The majority of the self-help retransmission sites for ABC services derive their program feed via satellite and hence the ABC s digital television service is available for retransmission. However, some sites rely on an off-air feed from an ABC service. The timing of these services migration to digital would depend on the completion of ABC s rollout program for the availability of the parent ABC digital television service. Self-Help Retransmission Services As Non-Commercial Activities The ABC regards the provision of self-help retransmission services as important and suggests that this activity be recognised by governments as a non-commercial activity. The ABC is aware of instances where public utilities, for example, have attempted to charge commercially-based access fees to local councils seeking to provide improved or additional broadcasting services such as the ABC national triple j radio network to local communities. Providers of self-help transmission services, primarily local governments, should only be charged reasonable access fees to public infrastructure. Planning for Conversion to Digital Once the Government s 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. Such planning should include the digitisation of self-help retransmission services. In view of the financial burden to local councils or other groups who operates self-help facilities on behalf of communities, the ABC would suggest that the direct conversion from analog to digital of these self-help services without any simulcast requirements should be considered. This would allow for the reuse of spectrum currently allocated to analog selfhelp services, particularly in areas where the population is comparatively small. This has the advantage that no new channels are required and cost of the conversion may be significantly minimised.
ABC Submission: Digital Conversion of Self-Help Television Retransmission Sites 4 The communication of dates and the implications for viewers in terms of purchasing receivers for conversion to digital for self-help services should be readily achievable in small communities.