APPENDIX 2
Supplementary memorandum submitted by
ASTRA Marketing Limited
COMMUNICATIONS POLICY AND THE ROLE OF SATELLITE
In light of the Culture, Media and Sport Select
Committee's inquiry into communications, ahead of the draft Bill
this year, I am writing briefly to outline the role of satellite
and to highlight some issues that may be of interest to you.
As you may know, ASTRA is Europe's leading satellite
system. As well as transmitting over 1,000 TV and radio channels
to over 89 million homes across Europe, ASTRA offers fast, secure
transmission of Internet Protocol based video, audio and data
applications direct to homes and businesses. The ASTRA Broadband
Interactive (BBI) service, now commercially available, provides
two-way broadband connectivity via satellite giving users both
receive and transmit capabilities.
IMPORTANCE OF
GOVERNMENT COMMUNICATIONS
POLICY
ASTRA welcomes the general direction of the
Government's policy development process from the Communications
White Paper, through to the current OFCOM Bill and the forthcoming
draft Communications Bill. We believe that, together, these present
significant opportunities to simplify and enhance the UK regulatory
regime, to promote rapid take-up of new digital services and advances
in technology and to put the UK in a very strong position, internationally.
BENEFITS OF
SATELLITE
Satellite technology addresses several key policy
objectives simultaneously. ASTRA provides comprehensive geographic
coverage in the UK, with virtually 100 per cent of the population
able to access digital satellite television services. With the
arrival of ITV on digital satellite in November 2001, alongside
the existing services of BBC1, BBC2, Channel 4 and Channel 5,
digital satellite now delivers the full range of free-to-view
services, without the need for a subscription. With ASTRA's nation-wide
coverage, the satellite platform will therefore be a vital element
in delivering the digital switchover timetable.
Satellite will also help close the "digital
divide" between urban and rural areas by providing access
to services in areas where traditional cable or terrestrial services
(such as ADSL) are unlikely to be available in the medium term.
Furthermore, the flexibility of satellite services are such that
a very wide variety of local, community and specialist channels
(including, for example, minority language, regionally-relevant
and ethnic interest programming) can be delivered to audiences
anywhere in the UK. Newer, broadband, services which are now becoming
available will further enhance this offering and will help UK
businesses improve their local and worldwide competitiveness through
access to fast, efficient communications networks within organisations,
between businesses and in relationships with customers and suppliers.
CREATING THE
RIGHT CLIMATE
However, while satellite has a key role to play
in assisting the UK to develop its communications networks and
services, it is important that the Government understands and
supports moves to improve the regulatory regime we face. The policy
development process described above does not exist in isolation
and "joined-up" government means that departments should
seek to address the communications agenda in its entirety when
developing new policies and refining existing ones.
PLANNING ISSUES
For many years, satellite dishes have been subject
to an anomalous planning regime which is the product of regulation
not keeping pace with technological development. For example,
it is permitted to erect on a dwelling a very large terrestrial
aerial atop a five-metre pole. Yet, in certain circumstances (eg
in conservation areas or on listed properties) planning consent
is required to erect a satellite dish measuring only 65cm in diameter
at its widest point.
The DTLR recently announced that it would begin
a review into this anomaly. ASTRA welcomes this, but is concerned
that such a review may take several years to produce a change
in the law on general permitted development. This will hinder
the take up of digital services delivered by satellite and does
not represent a "level playing field". We would urge
a speedy resolution and simplification of the rules to improve
access to new technologies in the UK.
EQUIPMENT LICENSING
Two-way services to and from satellites are
increasing in sophistication and relevance to businesses and consumers.
For many, these will provide the possibility of secure and rapid
transfer of large amounts of data. For others, they will enable
new ways of working and new ways of delivering services and entertainment,
cheaply and efficiently across wide areas to targeted audiences.
In remote and rural regions, satellite will be the only infrastructure
that can offer true broadband connectivity.
To encourage early adoption of these innovative
opportunities progress must be made on equipment licensing. Currently,
the Radiocommunications Agency operates a system which requires
individual consents to be granted for the installation of two-way
satellite receiving and transmitting equipment (known variously
as VSATs, SITs or SUTs). Because there have, to date, been relatively
few license applications for this new technology applicants have
been able to spend a great deal of time ensuring all license applications
have been fully understood and progressed smoothly. As the take-up
of interactive services expands rapidly, however, this bespoke
approach to licensing will be unsustainable; it will discourage
adoption of new technology and place the UK at a competitive disadvantage.
Indeed, it is with the higher capacity transmission equipment,
where commercial interest amongst potential users is highest,
that the longest delays on licencing will occur. Equipment licensing
must therefore match current technology as delays for licencing
on these transmitters could run into weeks.
Many European Governments have already recognised
that individual licensing regimes are a barrier to innovation.
End user terminals comply with Digital Broadcasting Video Group
(DVB)/European Telecommunications Standards Institute (ETSI) standards
and they operate in spectrum bands exclusively allocated by the
International Telecommunications Union (ITU). Best practice in
the rest of Europe is for a simpler, more streamlined and less
bureaucratic licensing system. Holland recently became the fifth
EU country to implement the European Radio-communications Committee
(ERC) decision on exemption from individual licensing, following
the lead of Italy, Denmark, Austria and Luxembourg. The other
three Scandinavian countries are expected to follow suit.
In the Communications White Paper the Government
proposed to roll back regulation and to "reduce the regulatory
burden upon communications operators by using general authorisations
rather than individual licences wherever possible". ASTRA
believes that, if the UK is to lead in digital communications,
and maintain a competitive edge, early progress on licensing must
be made.
SUPPORT FOR
SWITCHOVER
The technology exists today to transform large
parts of the country from analogue to digital technology simply
and efficiently, and in a way which offers platform neutrality.
For those in communal housing, whether public or private, this
technology—the Integrated Reception System (IRS)—offers
low unit cost conversion, which would benefit some 4.5 million
households across the UK. IRS offers residents in communal homes
a full choice of access to both analogue and digital terrestrial
services, digital satellite, FM and digital radio.
As well as being an issue of consumer choice,
delivery of digital services into communal housing would significantly
improve the proportion of households with access to digital services
and contribute greatly to ensuring that the switchover target
date is met. By promoting choice of platforms and broadcasters
amongst their tenants, social and communal landlords can also
play a part in combating the risk of creating a digital divide.
The Department for Culture, Media and Sport
has worked closely with industry to produce an informative leaflet
on IRS for communal housing. Clearly, the implementation of IRS
communal reception systems will require resource from landlords
across the UK and ASTRA would encourage government to go further
in supporting these initiatives. With almost one in five UK householders
living in communal housing, access to digital services for these
residents will be critical if the 2006-10 timeframe for switchover
is to be met.
ACCESS TO
SPECIALIST PROGRAMMING
ASTRA currently carries around 40 smaller TV
and radio services from specialist broadcasters to audiences throughout
the UK. These comprise both pay-tv and free-to-air channels and
are part of the multi-channel attraction of the satellite platform.
We continue to support and encourage our customers providing such
services. In any future policy developments on communications,
especially as regards access charges or licensing fees, ASTRA
believes that it is particularly important to take account of
the effect on specialist channels.
SPECTRUM MANAGEMENT
Last year, the Treasury and the Department of
Trade and Industry undertook a consultation on radio spectrum
management, headed by Professor Martin Cave. The "Cave Review"
is due to report shortly and, from our discussions with the Review
team, it is possible that a form of "greater autonomy"
for the UK may be recommended, possibly including less adherence
to international agreements on spectrum use.
This presents very serious policy and practical
problems for satellite operators, since our services are not broadcast
solely to the UK. ASTRA's fleet, for example, covers most of Europe,
currently from three orbital positions. Once designed to take
account of existing transnational agreements, spacecraft cannot
be reconfigured or adapted. It is doubtful that the economics
of satellite operation would be sustainable in countries not supporting
these transnational agreements.
Satellite companies have invested billions of
pounds over decades to bring leading-edge high technology services
to UK and European consumers and businesses. Such an investment
of time, money, research, manufacture, design and innovation has
been made possible in part by a clear recognition by national
governments that there is a unique case for international co-operation
in allocating spectrum to satellite use.
ASTRA believes that a decision by the UK to
alter or attempt to alter the core transnational agreements on
spectrum allocation for satellite within Europe would do serious
damage to the industry in this country, in Europe and globally.
Specifically, any move towards market testing, auctioning or otherwise
redefining the small band of spectrum frequencies currently assigned
to satellite across Europe could have a potentially disastrous
effect on the economics of the industry and the continued delivery
of services and innovation
I would urge you to consider carefully how the
UK can successfully pursue "joined up government" on
communications issues, especially in relation to satellite technology
which, with its nation-wide coverage, offers the best way forward
for delivering a digital Britain.
Finally, I hope that this note has been informative.
If I can be of any further assistance, please do not hesitate
to contact me.
24 January 2002
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