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DTG Response to Ofcom Consultation: Licensing Local Television – How Ofcom Would Exercise Its New Powers and Duties Being Proposed by Government 16Th March 2012

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DTG Response to Ofcom Consultation: Licensing Local Television – How Ofcom Would Exercise Its New Powers and Duties Being Proposed by Government 16Th March 2012 DTG Response to Ofcom Consultation: Licensing Local Television – How Ofcom would exercise its new powers and duties being proposed by Government 16th March 2012 The Digital TV Group’s (DTG) response to this consultation principally relates to the questions in 4.104, “Do you agree with our approach to technical standards? Do you have any views on the choice of transmission mode or encoding standards?” and to the paragraphs on technical standards, (4.98 to 4.103). In making its response, the DTG recognises that local TV will benefit viewers and may well strengthen the attractiveness of the digital terrestrial TV offering. It recognises that placing technical requirements for interoperability on the channel and multiplex operators could be seen as adding cost that might adversely affect those businesses. The DTG has therefore kept its recommendations to what it believes is the minimum required for interoperability. The Group believes that this level of interoperability will make local TV service accessible to the widest range of viewers and will therefore strengthen rather than weaken the business proposition. The DTG has also made some more general observations, and has identified which comments are firm recommendations for interoperability and which are observations. The DTG’s detailed comments and recommendations are as follows:- Ref Digital TV Group comment Supporting rationale for DTG Supporting evidence for DTG comment comment - how it benefits industry and/or viewers 1 Broadcast Technical Requirements: The To maximise the compatibility of The D-book provide the UK profiles of the international and European new services should comply with the the new TV services with the standards including ETSI EN 300 744. UK profiles of international standards existing platform and with the UK embodied in the DTG D-Book (firm base of DTT receivers. This will The D-Book is constantly reviewed by industry and therefore always recommendation for ensure that the consumer current – it is the reference used by the industry so it is appropriate for interoperability). experience is as good as possible, licences to refer directly to it. There is a strong rationale for all that the new services are accessible aspects of the local TV broadcast and existing services are not signals to be compliant and the disrupted. This benefits viewers. following components of service Industry will experience fewer This document has been written using feedback from the DTG’s membership but does not necessarily represent the views of all DTG members organisations. information should be broadcast:- costly enquiries and product returns. 1a • Use of UK Logical Channel Number Compliance with the UK method of The Ofcom technical reference parameters, as currently worded, are signalling (firm recommendation signalling of the Logical Channel insufficient as a reference in the service and multiplex licence for interoperability) Number is required to ensure that requirements to ensure that the local TV services appear in the intended the services appear in the expected place on receiver channel listings and the Electronic Programme Guide. place in viewers’ (on screen) channel lists and Electronic Research submitted to Ofcom in response to an earlier consultation by a Programme Guides. This will third party suggests that there is some evidence of a correlation between benefit viewers who will find it channel number and viewing figures (see1 footnote). So correct display on easier to find their local channel receivers of a well understood channel number for local TV is likely to and will in-turn benefit local TV give a worthwhile commercial advantage to the operator. operators by driving higher viewing figures. 1b • Use of Target Region Descriptors Compliance with the UK’s Target All Freeview HD and current and recent Freeview branded receivers are for the appropriate TV region (firm Region Descriptors is required to required to be able to interpret broadcast Target Region Descriptor data, recommendation for ensure that viewers’ receivers offer and offer viewers the choice of region where more than one is available. interoperability) the correct regional choice in cases This may be important for overlapping local TV services. where two or more local TV During the early stages of switchover, viewers experienced difficulty in services were receivable. getting the correct regional TV services. The Target Region Descriptor was Viewers will benefit by getting the introduced to overcome the problems experienced. intended local service on the appropriate channel number. 1c • Guidance Descriptor (observation) The guidance descriptor is used to Many broadcasters do use the Guidance Descriptors, so there may be an label events with guidance for the expectation among viewers that they will get similar information for viewer. The descriptor contains a services carried on the local multiplex. text field which contains the guidance text for the event e.g. "contains strong language and 1 http://stakeholders.ofcom.org.uk/binaries/consultations/psb2_phase2/responses/DiscoveryNetworksUKAnnex2.pdf This document has been written using feedback from the DTG’s membership but does not necessarily represent the views of all DTG members organisations. scenes which some may find upsetting". 2 Broadcast signal testing: The DTG This is to minimise the possibility of To address problems experienced with receivers due to changes to strongly recommends a regime of problems in viewers’ TV sets and broadcast signals during switchover at Ferryside, then at the Selkirk and broadcast signal testing against the receivers caused by the launch of Beacon Hill transmitters, the government (DCMS) funds scenario testing UK’s DTT receiver ‘zoo’, hosted by the the new services. Viewers benefit of broadcast streams for each switchover region against the DTG receiver DTG, prior to service launches (firm by improved reliability of receivers, ‘zoo’. recommendation for and the industry benefits from The receiver problems experienced ranged from complete loss of service interoperability). fewer enquiries and product to loss of a few channels. Receiver manufacturers report that, as receivers returns. Ofcom should ensure that and the broadcast signals become more complex, there is an increase in there is funding provision for this. “no fault found” product returns. Testing of changes to broadcast signals against the receiver zoo help to alleviate this. 3 Cooperation with other multiplex While DTG standards anticipate the A detailed white paper covering these issues, “UK DTT features for operators: The DTG further technical needs of prospective local support of Local TV services” is available on the DTG recommends a requirement for TV services where possible, it website: http://www.dtg.org.uk/publications/books.html ongoing cooperation by the local TV seems likely that new technical multiplex licensee with the other requirements for local services may multiplex operators and with the DTG emerge. to ensure continued interoperability. The local TV operator will benefit Licensees should be required to by offering its viewers the same cooperate with industry via the DTG on platform improvements as they standardising any new aspects of their experience on other channels. The services that are not covered by wider industry and viewers benefit existing standards, such as additional from consistency of experience languages (the current specifications across the whole platform. cover only English, Welsh, Gaelic, and Irish) (firm recommendation for interoperability). 4 Choice of exact radio-frequency Viewers will benefit by being more transmission mode(s): The transmission likely to receive the services on This document has been written using feedback from the DTG’s membership but does not necessarily represent the views of all DTG members organisations. mode(s) should be specified by Ofcom existing receivers and being and should be either: an existing D- assured of receiving the services on Book mode with receiver performance new receivers. specified; or a new mode to be chosen If there are strong technical or in discussion with the DTG Radio commercial reasons to use Frequency (RF) Group with the different modes at different intention that it should be compatible transmitters then Ofcom should with as great a proportion of existing take steps to limit the number of receivers as practical, and with the modes in use so that receivers can intention that the transmission mode be optimised and tested for a low selected be assimilated into the D- number of standardised modes. Book, including performance Even an addition of one or two requirement. Ofcom should take steps modes would be a significant to avoid the proliferation of modes. burden for manufacturers. (firm recommendations for interoperability). 5 Cross carriage of full service The user experience for viewers of The new recording features have been developed to keep pace with information: The DTG agrees that Freeview and Freeview+ is heavily developments mostly on satellite and cable platforms and are seen as there should be a requirement to cross dependent on full cross-carriage of desirable for attracting and retaining viewers. carry full service-information, including specific service information (DVB the Event Information Table which SI) signalling. provides information for the Electronic Programme Guide (firm This will ensure that viewers of the recommendation for local TV service continue to have a interoperability). consistent experience such as with accurate recordings.
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