Memorandum submitted by HDforAll
THE OFCOM
DIGITAL DIVIDEND
REVIEW
The HDforAlI campaign
The HDforAll campaign seeks to pave the way
for High Definition (HD) television to be made available on all
platforms, including free-to-air digital terrestrial television
(DTT), commonly known as Freeview.
HD is the new global standard for television
and such services are already available to subscribers via cable
and satellite in the UK.
The HDforAll campaign is urging Ofcom to ensure
that, as an outcome of the Digital Dividend Review (DDR), adequate
spectrum is reserved for public service broadcasting in HD to
ensure that the social value of universal digital terrestrial
television is not lost and the public interest is protected.
The campaign is supported by the Public Service
Broadcasters (PSBs)—BBC, TV, Channel 4 and Five—manufacturers
and retailers of "HD Ready" televisions including Sony,
Samsung, Toshiba, Comet and DSGI (the high street electricals
group behind Dixons, Currys and PC World).
The Digital Dividend Review (DDR)
Ofcom is currently consulting on proposals for
the use of the "digital dividend"—the radio (analogue)
spectrum released by digital switchover.
In relation to the potential uses of the spectrum,
Ofcom has concluded:
1. That the "market" can best
decide the most valuable and efficient uses for the spectrum.
2. That little demand exists for HD television
services on DTT (Freeview).
3. That HD television services have low
social value.
4. That facilitating HD television services
on the DTT platform merits no intervention.
As a result Ofcom has indicated that it plans
an open auction to sell off parcels of spectrum to the highest
bidder(s). The potential outcome is that DTT will be the only
major UK television platform unable to offer viewers HD television.
The case for intervention
— PSBs and consumers have and
will invest heavily in the digital terrestrial platform, to give
everyone the option of free-to-air television through an aerial,
when analogue services are removed at switchover.
— In the past, the free-to-air
broadcasting that so many UK viewers value has always been allowed
to develop in line with technological advances like colour, widescreen
and stereo sound—making these features universally available
to all. HD television is the next such advance.
— The costs of transmitting television
channels in HD are substantial and will require high levels of
investment by the PSBs. At the same time, free-to-air transmission
offers no corresponding revenue stream to pay for that investment.
This will put PSBs at an economic disadvantage when bidding in
a competitive auction against commercial operators of subscription
services.
— Without intervention there is
the risk that a viable PS8 HD offering on DTT will not be possible
for the next generation of consumers, resulting in a second class
television service for millions of viewers who have already invested
in both the digital terrestrial platform and "HD Ready"
TVs in time for digital switchover.
— Ofcom asserts that the PSBs
could broadcast up to five HD channels, without sacrificing other
services, within their existing capacity. This is simply not possible—it
cannot be achieved without either removing substantial numbers
of existing Standard Definition services, and/or adversely affecting
their quality.
— Even taking account of improvements
in compression technologies and other technical developments,
HD within the current capacity restraints would be unlikely to
offer a viable number of channels.
— Without the intervention, the
move to a more spectrum efficient technology (MPEG4) is unlikely
to happen. An allocation of spectrum now to HD will allow very
significant spectrum efficiency gains in the future and is therefore
a "spend now to save later" strategy.
April 2007
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