ADSIF response to DST discussion paper on legislative framework for DTV switchover timetable
Australian Digital Suppliers Industry Forum
Response to Digital Switchover Taskforce discussion paper: Legislative framework for implementing a digital television switchover timetable
Introduction The Australian Digital Suppliers Industry Forum (ADSIF) of the Australian Industry Group (Ai Group) was established in response to demands from the suppliers of digital television and radio product for a coordinated approach to planning and implementation issues related to digital television and radio in Australia. Membership ranges from the major global manufacturers to small Australian based suppliers of digital broadcasting products and services. A list of ADSIF members is attached at Annexure A. The Ai Group welcomes the opportunity to provide the views of ADSIF members in response to the Digital Switchover Taskforce’s discussion paper on the legislative framework for implementing a digital television switchover timetable. Summary of responses to discussion paper ADSIF agrees with the following proposals set out in the discussion paper: 1. The legislation should be amended to allow for the simulcast period for one or more licence areas to be shortened; and 2. The legislation should be amended to allow for a switchover timetable based on regions that are smaller than and within existing licence areas, while keeping in place the policy of achieving equivalent coverage. In regard to the key issues requiring a response, ADSIF submits that: 1. The final timetable should be set in the Broadcasting Services Act, providing certainty to industry and consumers; 2. Captions should be available on all commercial television multi-channel services from 1 January 2009; and 3. The quota of 1040 hours of high definition programming each year be maintained in legislation. Mechanism for setting a digital switchover timetable The discussion paper sets out the following options for legislative and administrative mechanisms that could be used to implement a digital switchover timetable: a. By legislation – setting the final switchover timetable in the Broadcast Services Act
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ADSIF response to DST discussion paper on legislative framework for DTV switchover timetable
b. By legislative instrument – allowing the setting of the switchover timetable by one of the following: i. Regulation made by the Governor-General on advice from the Minister; ii. Written determination of the Minister, possibly delegated to an official of the Department of Broadband Communications and Digital Economy; or iii. Written determination by ACMA, possibly giving the Minister the power to give general directions. ADSIF submits that certainty to industry and consumers is paramount in implementing a timetable. As the discussion paper notes, setting out the switchover timetable in legislation as in (a) above ‘would be the most definitive statement of intent regarding digital switchover, providing certainty to industry and consumers’. A commitment to a firm timetable by government in legislation will ensure all necessary resources are allocated by all stakeholders to achieve the switchover timetable. ACMA research1 has confirmed that analog switch off is a key driver for uptake. That research showed that a third of all respondents to the survey undertaken in late 2007 were still not aware of analog switch off. The same research listed ‘need it eventually/changeover/long term decision’ as the fourth, (with 13.5%) in order of priority, of the seventeen specified reasons for consumers showing an interest in digital television. The reasons given by non-adopters of digital television were summarised as a ‘lack of interest in watching TV, perceived cost and lack of any awareness of any compelling need to change’. ADSIF considers analog switch off would provide the most compelling reason for non-adopters to switchover. The Government is solely responsible for setting this key switchover driver, so it is critical that Government sends a message to consumers that it is serious in its intent to switch off analog transmissions by setting the switchover timetable in legislation, specifically in the Broadcasting Services Act. A timetable set by legislative instrument will allow for more flexibility. This may appear attractive, but it will lead to continual negotiation with those parties over the switchover timetable, resulting in a loss of confidence in the ability to meet the final deadline. With the first markets possibly being switched over as early as 2010, it is critical that the timetable is set as soon as possible. We understand that the Digital Switchover Taskforce will provide a recommendation to the Minister by September 2008, with the Minister announcing a timetable in March 2009. If the timetable is set by legislative instrument the discussion paper forewarns that a further period of consultation may then be required as there would be a direct or indirect effect on business. Even though the switchover to digital television is in the national interest, ADSIF has concerns that particular sectional or regional interests may have undue influence over the implementation of a timetable. A timetable set by legislative instrument would allow these interests a greater opportunity to make changes to the timetable and postpone the national switchover date.
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‘Digital television in Australian homes – 2007’ by Eureka Strategic Research February 2008
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ADSIF response to DST discussion paper on legislative framework for DTV switchover timetable
With the Department of Broadband Communications and Digital Economy and ACMA being responsible for ensuring resources are available within their respective budgets to achieve the switchover timetable, delegating responsibility for setting the timetable to either the Department or ACMA would not be good policy. ADSIF is strongly of the view that the final timetable should be set in the Broadcasting Services Act, providing certainty to industry and consumers. Captioning on commercial television multi-channels The lifting of the prohibition on commercial broadcasters delivering a standard definition multi-channel from 1 January 2009 will provide another key content driver for switchover. However, this might disadvantage hearing-impaired viewers due to the exemption from captioning requirements on commercial multichannel services until the end of the simulcast period. Confusion will be created while commercial broadcasters are required to deliver captions with the main channel services, and not with multi-channel. It will also complicate the message to be provided by retailers to customers. This confusion may lead the consumer to believe that their reception equipment is deficient in not displaying captions on multi-channel services. Therefore, ADSIF submits that captions should be available on all commercial television multi-channel services from 1 January 2009. Children’s content requirements on commercial television multi-channels Any decision taken regarding children’s content requirements must take into account the key objective of encouraging digital take-up, not creating possible obstacles that will confuse customers. End of high definition quota The requirement in legislation for commercial broadcasters to transmit 1040 hours annually of native high definition programs has provided broadcasters with a key justification to invest in high definition production and encoding equipment, and for suppliers to invest in the development of high definition reception and display equipment. While Australia may be a leader in its adoption of high definition, ADSIF submits that there is still a need for the high definition quotas to remain in legislation. ACMA’s research2 rates picture quality as the number one reason for interest in digital television. For consumers, high definition is synonymous with improved picture quality and digital television. Removing the high definition quotas after simulcast may send a confusing message to consumers about the government’s commitment to the delivery of high definition on free to air digital television. From 2009 there will be additional pressures on the capacity of broadcasters to deliver high definition and standard definition multi-channels and additional ancillary services within the allocated 7 MHz bandwidth. Without the high definition quota, commercial television broadcasters could sacrifice their high definition service for additional standard definition multi-channels at the end of
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‘Digital television in Australian homes – 2007’ by Eureka Strategic Research February 2008
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ADSIF response to DST discussion paper on legislative framework for DTV switchover timetable
the simulcast period in a particular market. It is likely that some regional markets will be switched over earlier than metropolitan markets. Under the current legislation, high definition would be available on free to air television in metropolitan markets but may not be available in those regional markets that have been switched over. This would not only create confusion, but would disadvantage regional viewers. It would also put into doubt the delivery of one of the key consumer drivers, disenfranchising millions of consumers who have specifically purchased a high definition television or set top box to receive and view high definition programs. ADSIF strongly urges that the quota of 1040 hours of high definition programming each year should be maintained beyond the date that switchover is completed in 2013.
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ADSIF response to DST discussion paper on legislative framework for DTV switchover timetable
ANNEXURE A:
About Australian Industry Group (Ai Group) The Australian Industry Group (Ai Group) is Australia’s leading industry organisation representing 10,000 employers across a broad and expanding range of sectors, including manufacturing, construction, automotive, telecommunications, food & beverages, IT & call centres, transport, labour hire and other industries.
Australian Digital Suppliers Industry Forum (ADSIF) Membership Major CE suppliers: LG Electronics, Motorola Australia, NEC Australia, Nokia Australia, Panasonic Australia, Philips Consumer Electronics, Pioneer Electronics, Samsung Electronics, Sharp, Sony Australia, TCL Electronics Australia, Toshiba Australia Specialist digital TV receiver suppliers: DGTEC, Digital Products Group, Control Dynamics (Digitalview), Interactive TV, Thomson Suppliers of antennas, cabling and distribution systems Clipsal Australia, Downer-EDI, Ikusi Australia/NZ, Matchmaster Communications, Hills Industries, GPC Electronics, Kordz, Richardson Electronics, Pacific Satellite, Peregrine Semiconductors, Standard Communications Digital TV technical service providers: AV Link Australia, Australian Digital Testing, IceTV, Radio Frequency Systems, Rohde & Schwarz ADSIF Steering Committee Members: Ross Henderson Steve Rust Carl Rose David Brand Kurt Jovias Denis Kerr Tony Grasso Ken Joyner Robert Waterford Managing Director, AV Link Australia – Chair Managing Director, Panasonic Australia Managing Director, Sony Australia Marketing Director, LG Australia Marketing Director, Samsung Australia Deputy Managing Director, Sharp Corporation Australia Managing Director, Rohde & Schwarz Australia Director Global EME Strategy, Motorola Australia Chief Executive Officer, Matchmaster Communications
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