Select Committee on Culture, Media and Sport Appendices to the Minutes of Evidence


Memorandum submitted by the Consumers' Association


  Consumers' Association (CA) has three key concerns about the draft Digital Action Plan (DAP):

    —  The draft DAP identifies a range of important issues but CA is concerned that it does not set out a practical timescale or an adequate critical path. A lot of the processes in the plan rely on co-operation between competitors to resolve problems, and experience has demonstrated how difficult this is to achieve, even with Government facilitation (eg initiatives to provide information to consumers). There is very little "slack" in the timetable, even if the groups work well. A number of the latter stages rely on earlier strategic decisions and successful outcomes, such as the impact of spectrum decisions, the quality of the new BBC services and the availability of an affordable free-to-view decoder on DTT. CA is concerned that Government is rushing switch-over and trying to "shoehorn" these processes into its original unrealistic timetable. This is likely to result in short-term decision-making which may restrict future benefits to consumers and the UK economy.

    —  The draft DAP does not amount to a high level statement of why and how Government intends to deliver digital switch-over, and the public and private benefits of the policy remain unclear and contested. There is a need to both add value to digital television and ensure that certain key benefits are available to all. This means establishing a notion of universal service for television after switch-off and improving on commitments to merely provide parity with analogue service in key aspects such as coverage. There is also a need to clarify the role of digital television in achieving other public policy objectives such as universal internet access. Government should not leave industry to both define and deliver the benefits of digital, and has been unhelpful in suggesting that digital television will necessarily provide all consumers with benefits such as better pictures or internet access. It must now play a key role in ensuring that the actual—not just potential—benefits of digital are clarified, improved, relevant and available to all.

    —  It is essential that consumers should be involved if the switch to digital is to be legitimate and successful. CA looks forward to being closely involved in a number of the processes outlined in the DAP.

  Detailed comments on a number of sections are included below. We would welcome the opportunity to discuss these comments in detail.


  Effective consumer representation is vital to both the success and the legitimacy of the Government's switch-over strategy. The Department of Culture, Media and Sport Viewers' Panel has provided a useful "reality check" for Government policy, and CA believes that there is a need for ongoing consumer consultation and research to ensure that viewers' interests are protected. Organisations such as CA also have a key role in both representing consumers and acting as a "trusted source" of information and we would welcome the opportunity to be involved in a Stakeholders Group which oversees the other elements of the DAP.

  CA has extensive experience of product testing, human factors, consumer research, technical committees and policy work, as well as more traditional "soft" consumer issues. We would also therefore welcome the opportunity to be involved in a number of the working groups proposed in the draft DAP. However attention needs to be paid to the limited staff resources which consumer representatives can devote to these initiatives. It may be that certain working groups, such as those concerned with technical issues, would not require consumer involvement as long as there was adequate scrutiny of their outputs. For this reason we recommend that the Stakeholders Group should oversee the work of all the other groups.

  CA is disappointed that the Cabinet Office Code of Practice has not been followed during this consultation. The period allowed for comments has been insufficient to allow us to comment on the broad range of issues which the plan addresses and which affect consumers. Although the draft has been published on the new DTI/DCMS digital television website, it is not publicly accessible through the main UK Online portal. The DAP places a heavy burden on consumer organisations to respond to consultations, and we are concerned that these problems should not be repeated during its implementation.


  CA is concerned that the draft DAP is not set in the context of a high level set of objectives for switch-over. Government has a vital strategic role to play, and until it clarifies the public and private goods which digital television will deliver to individuals and the UK as a whole, both the feasibility and the legitimacy of the Government's intention to switch-off the analogue signal remain in doubt.

  Digital television is central to a broad range of public policy goals including access to Government and other public services, better public service broadcasting and a competitive economy, and we are pleased that the DAP is intended to co-ordinate the actions of a number of Government departments in this area. However an number of unresolved issues, such as the role of digital television in achieving universal internet access, means that the public goods associated with the switch to digital remain unclear and contested. Even the benefits of raising revenue from spectrum sales need to be offset against the costs of switching, and in the current economic climate, these sales are unlikely to realise the full value of spectrum in any case.

  For many consumers, the private goods of the switch to digital are equally unclear. Many consumers remain confused by what digital TV offers them personally, and it is unhelpful to suggest that digital TV will necessarily provide better pictures or internet access for all. This is not just an issue of informing and persuading consumers, since our research has demonstrated that many are simply not convinced by the existing digital commercial digital television offering. CA believes that the supposed "killer application" for digital television—multi-channel pay television— is unlikely to drive take-up to levels which will allow the analogue signal to be switched off. It is therefore essential that Government should establish a notion of universal service for digital broadcasting, setting out the minimum features, levels of interactivity and access to signals, and clarifying the key benefits of digital which all consumers can expect to receive at switch-off.

  Although CA would be strongly against switch-off before the three key tests of availability, affordability and take-up are met, we recognise that Government has to consider the costs of broadcasting both analogue and digital signals and being unable to release spectrum for other uses. As we have argued in the context of the Viewers' Panel, it is vital that Government should clarify this balance when the 70 per cent take-up target is achieved, and ensure that any revenue from spectrum sales is offset against the costs of improving coverage and providing digital equipment for those consumers who would otherwise be unable to switch. It is also essential that the Government ensures transparency when balancing these public and private goods. The three key tests should not be abandoned on economic grounds, but if they are, the costs of an early switch-over should not be met by consumers.

  CA believes that Government should not rely on industry to both define and deliver the public/private benefits of digital television. The commercial offering has persuaded one third of consumers to switch to digital, but take-up is slowing, and the lack of strategic leadership has resulted in problems with inter-operability and doubts about the future of terrestrial broadcasting. Consumers and industry need to have confidence if they are to invest in digital equipment and services, and although we agree that "the market should bear the lion's share of the work", Government has a key strategic role to play in determining the objectives of switch-over and the benefits it will deliver. Once Government has decided where we are going, it is possible for industry and consumer groups to join in the task of getting there.


  CA's key concern is that spectrum planning should protect analogue viewers before switch-over and ensure that spectrum sales do not restrict future benefits after switch-off. Although CA does not wish to be involved in the proposed Spectrum Planning Group, it is essential that the Stakeholders Group should agree its terms of reference and have oversight of its work. CA is concerned that this work should be based on active research and signal monitoring, given the unrealistic assumptions about aerial quality which are currently used in coverage modelling.

  During transition, digital signal boosts should not interfere with analogue signals, and the phasing of switch-over should take account of regional variations in take-up. The existing complaints process should also be improved, and there should be no transfer of spectrum to other uses until switch-over has been successfully completed. CA is also concerned that adequate spectrum capacity should be retained for future terrestrial broadcasting, both new services (eg local/regional channels) and higher-bandwidth services (eg a seven-day EPG)

  CA recognises the planning and economic constraints on providing universal digital terrestrial coverage prior to switch-over, but we question the wisdom of permanently abandoning existing analogue levels of terrestrial coverage. In areas where there is currently no planned DTT coverage, consumers should be informed and a free-to-air satellite solution needs to be provided.


  CA welcomes the proposals contained in the DAP to improve information, support and awareness of digital TV among consumers and retailers. This is a worthwhile objective in itself, but this alone will not necessarily drive take-up among those consumers who are not attracted by the existing digital television offering. General information about digital television should avoid misleading consumers about the availability, nature and cost of services—such as internet access—which may not be available on all platforms. It should also be regionally targeted to ensure that consumers not misled about the choices available.

  CA is concerned that the Market Preparation Group should involve consumer groups and other "trusted sources". Although we welcome initiatives by the DTG and CAI to improve the standard of information provided by retail, support and engineering staff, we do have concerns about whether competitors will co-operate to deliver solutions rapidly in the way envisaged in the MARCOM proposal. Consumer involvement would also ensure that the proposed research into viewers' needs and expectations informs the agenda of this group. CA considers that the work of this group should focus both on raising awareness of the benefits that digital television provides now, but also on delivering potential future benefits across all platforms. CA is keen to play a role in the Market Preparation Group.


  CA has extensive experience of both "hard" (STB power consumption, PDC protocols) and soft (human factors, functionality) equipment issues. Staff from our testing lab are involved in the UK Market Transformation programme and the Easy TV initiative, and we would welcome further discussions about the potential for CA to be involved in the Technology and Equipment Group.


  CA was disappointed to have been unable to participate in the initial digital television pilot projects, as we believe our expertise in product testing and research into consumer behaviour would enhance transparency and avoid over-dependence on industry inputs. It is vital that the lessons learnt in these pilots inform the debate surrounding digital switch-over, so the results of all the pilot projects should be made public. CA would again welcome further discussion about these issues and the potential for CA involvement.


  CA welcomes the proposal to appoint a digital "project leader" to co-ordinate Government's approach to digital television. This person's key role should be ensuing that research and consultation with viewers and consumers is reflected across the range of processes which make up the DAP.

20 November 2001

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