APPENDIX 3
Memorandum submitted by the Consumers'
Association
SUMMARY
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.
STAKEHOLDERS
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.
GOVERNMENT POLICY
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.
SPECTRUM PLANNING
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.
MARKET PREPARATION
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.
TECHNOLOGY AND
EQUIPMENT
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.
PILOT PROJECTS
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.
PROJECT CO-ORDINATION
AND MANAGEMENT
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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