Cover sheet for response to an Ofcom consultation BASIC DETAILS Consultation title: Draft Annual Plan 2014/15 To (Ofcom contact): Puja Kalaria Name of respondent: Richard Lindsay-Davies Representing (self or organisation/s): Digital TV Group Address (if not received by email): CONFIDENTIALITY Please tick below what part of your response you consider is confidential, giving your reasons why X Nothing Name/contact details/job title Whole response Organisation Part of the response If there is no separate annex, which parts? If you want part of your response, your name or your organisation not to be published, can Ofcom still publish a reference to the contents of your response (including, for any confidential parts, a general summary that does not disclose the specific information or enable you to be identified)? DECLARATION I confirm that the correspondence supplied with this cover sheet is a formal consultation response that Ofcom can publish. However, in supplying this response, I understand that Ofcom may need to publish all responses, including those which are marked as confidential, in order to meet legal obligations. If I have sent my response by email, Ofcom can disregard any standard e-mail text about not disclosing email contents and attachments. Ofcom seeks to publish responses on receipt. If your response is non-confidential (in whole or in part), and you would prefer us to publish your response only once the consultation has ended, please tick here. Name Richard Lindsay-Davies Signed (if hard copy) DTG response to: Ofcom “Draft Annual Plan 2014/15 Friday 14 February 2014 Ofcom: Draft Annual Plan 2014/15 The Digital TV Group (DTG) welcomes the opportunity to respond to the above consultation regarding Ofcom’s draft proposals for their priorities and work areas in the financial year 2014/15. In responding to this consultation, the DTG will be referring where appropriate, on a paragraph by paragraph basis to relevant issues, concerns or opportunities arising from the consultation document. Related to the discussion at 2.38-2.42 regarding the increasing popularity of data services leading to quality of service issues; there may be a benefit to the industry, regulators, government and consumers in clarifying the differences between over-the-top (OTT) and internet protocol television (IPTV) in relation to a ‘broadcast quality experience.’ Both methods of delivering content should invoke a different expectation about the quality of service received; the former being delivered over the ‘open internet’ and the latter over a managed internet service provider (ISP) network - see Figure 1 for details. OTT IPTV Content Delivery Open ecosystem ‘Walled garden’ ecosystem Network Type Open Internet Managed network Network Open Internet. Content hosted at CDN. Service provider own and/or Ownership manages the delivery network Quality of None Video traffic delivered in bandwidth Service allocated separately from other traffic Examples YouTube, Netflix, BBC iPlayer, ITV Player, BT Vision, Virgin Media, BT TV and 4OD, Demand 5, VuTV TalkTalk proprietary parts of YouView Protocol HTTP Raw UDP, RTP (UDP.TCP), Multicast Challenges Variable quality, often no premium content Expensive, competitive & big investment Benefits Low cost, flexible consumption across Interactive, QoS & UX guaranteed devices Figure 1: The differences between OTT and IPTV The majority of UK consumers now watch OTT and Informa predict that OTT will have eight times as many viewers by 2015 (27m) compared to just 3.6m IPTV subscriptions.1 With the quality of service varying between OTT and IPTV, this distinction becomes even more important as suggested at 2.40 with “people switch[ing] seamlessly between DTT broadcast and IP multicast channels, they will have high expectations for equivalent quality of service between them.” From a policy perspective it is worth noting this expectation and the continued relevance of DTT broadcasting in meeting consumer demand as the only technology that can currently reliably deliver content universally and for free; particularly when considering the availability of public service broadcasting - currently 98.7 per cent versus standard broadband (95.3 per cent) and superfast broadband (67.9 per cent).2 As “broadband networks are also being called upon to deliver data-rich broadcast quality content”, the DTG are well placed to assist the industry in finding technical solutions to potential quality of service issues. 1 http://www.informa.com/Media-centre/Press-releases--news/Latest-News/OTT-TV-viewers-to-outnumber-IPTV-viewers-in-2013-/ [accessed 09-Jan-2014] 2 Ofcom | Availability of communications services in the UK, May 2013 [accessed 09-Jan-2014] Page 1 of 4 This document has been written using feedback from the DTG’s membership but does not necessarily represent the views of all DTG members organisations. Please note that the DTG is made up of member companies who may also be submitting an individual response to this OFCOM consultation. DTG response to: Ofcom “Draft Annual Plan 2014/15 Friday 14 February 2014 Related to Section 7 of your consultation, in particular 7.5 - 7.6 and other “emerging issues that might inform future Annual Plans”, the DTG encourages Ofcom to consult its Future of Innovation in Television Technology (FITT) Taskforce report, published on 20 May 2014. The FITT Taskforce is a 2025 horizon-scan of the UK audio- visual industry aimed at providing recommendations for government, regulators, industry and academia from both a supply and demand-side perspective. In exploring the potential to reduce the detailed technical regulations which affect broadcasters at 9.14 - 9.16, the DTG look forward to engaging with Ofcom constructively on this. We welcome Ofcom’s commitment at 9.16 to consult upon your proposals as a result of your review of the detailed provisions in the technical code; such as bit-rate requirements on radio and picture quality requirements on television. [Q1.] What are your views on Ofcom’s proposed priorities for 2014/15? 3.53 - 3.54 The DTG are able to assist Ofcom with their white space work, particularly TV white space and and coexistence testing (3.57) with experience of LTE coexistence testing and 4G filter conformance testing for at800. 3.78 In addressing the challenges of regulating IP-delivered linear services on EPGs, the DTG can work with industry to introduce a technical solution to the digital terrestrial television specification (D-Book). This could, for example, recognise services in relation to their IP address to determine where it is originating from - either outside the UK or European Union and hence outside of the jurisdiction of the AVMS Directive. It could then provide the viewer with an adequate warning thus adhering to the principle of ‘active choice’ to maintain audience confidence in broadcast content. [Q2.] What are your views on Ofcom’s proposed work areas for 2014/15? 4.34 - 4.39 The DTG agrees with the statement at 4.35 that “in principle, many coexistence issues could be mitigated or avoided entirely if the performance of transmitters and receivers in devices operating in the same or adjacent bands could be better coordinated.” Although, this section of the consultation refers primarily to the growing demand for wireless and mobile data - the same can be said for television receivers which will need to operate effectively and be better coordinated with mobile and wireless receivers. The DTG support the study mentioned at 4.38 to assess options for improving the potential impact of 4G transmissions on DTT receivers. Further to offering any assistance required by Ofcom - the DTG encourages all stakeholders to liaise with us in order to understand and replicate our successful method of industry collaboration used in developing and maintaining receiver standards for UK DTT. It is in the interest of all industry stakeholders (whether they are incumbent or new entrants) and ‘UK Plc’ in the broadest possible sense that the radio spectrum is used most efficiently and kept free from interference (5.17 - 5.18). 4.42 - 4.43 DTG Testing would like to access the new UK planning model (UKPM) to look at the DTT signal strength in geographical areas, in order to better understand the potential impact of results taken from coexistence studies. Whilst the DTG currently work with the cooperation of Arqiva Page 2 of 4 This document has been written using feedback from the DTG’s membership but does not necessarily represent the views of all DTG members organisations. Please note that the DTG is made up of member companies who may also be submitting an individual response to this OFCOM consultation. DTG response to: Ofcom “Draft Annual Plan 2014/15 Friday 14 February 2014 and the BBC to understand impacts, we believe an open model would be the best way to add further value to our analyses. These would be used to build up a picture of areas where DTT reception could be effected by interference from other technologies - specifically results from those technologies that have been derived from testing carried out on DTT receivers. The data provided could be in the form of coordinates that can be exported to modelling tools such as MapInfo.1 and would be used as part of reports for projects carried out by DTG Testing. External access to the UKPM should be made freely and easily available i.e. online, so as to encourage the contribution of work carried out by industry when investigating future and current spectrum usage. Further to this an option to increase the precision of modelling the impact of technologies such as 4G and white space devices have on DTT should be included in any future versions of the UKPM. For example, data obtained from the LTE 800 pilots carried out by DMSL ran into difficulty when adapting the UKPM to predict potential interference during trials.