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To: The General Manager, Digital Broadcasting and Spectrum Management email@example.com From: David, Central Coast NSW firstname.lastname@example.org Submission to the Department of Communication, Information Technology and the Arts in regards to the issues paper “Provision of Services other than Simulcasting by Free-to-air Broadcasters on Digital Spectrum.” General concerns in regards to future DTV policy formation Initially, digital television was promoted to provide a variety of new services and features; not just high definition. I believe that Free-to-air digital television should be a flexible mix of SD multichannelling and high definition. My family and I purchased our SD set-top-box to receive the Australian Broadcasting Corporation‟s SD multichannels ABC Kids and Fly, and we were very disappointed when shortly afterwards they were shut off. Fundamentally, issues such as realistic funding of services promoted, a definite analog switch-off date, mandatory requirements for manufacturers to include SD digital tuners in all new integrated TV sets, permission for commercial FTA multichannelling, and removal of genre restrictions on national broadcaster multichannelling are all crucial steps in increasing the uptake of DTV. DVB-T technology has the ability to offer new innovative services, such as the dual – simulcast- broadcasting of both houses of federal parliament, at considerable less cost, especially in regards to infrastructure. For instance, SD multichannelling of parliamentary broadcasts through the national broadcaster, the ABC, would allow greater coverage of parliament, leading to greater transparency of government and the strengthening of the democratic process. DTV has potential to offer an inexpensive service, which provides immense social benefit and is in the national interest. Such a service through DVB-T is inexpensive compared to establishing a separate network and allocating two separate frequencies. SD multichannelling provides efficient use of the spectrum for services such parliamentary broadcasts. Most people would agree that parliamentary broadcasts need not be in high definition [Maybe only ceremonial events]. For example, technically, this service would be possible if after the analog transmission ceases; the ABC is given that spectrum for SD multichannelling of services beneficial to the community, such as parliamentary broadcasts. Attached to the national broadcaster‟s digital network, the service would have greater coverage. There are many instances where FTA SD multichannelling would provide a valuable asset to the whole community. I have used the dual parliamentary broadcasts proposal to illustrate the merits of SD multichannelling and it is crucial to note that SD multichannelling has as much merit as high definition in the sphere of DTV. It is crucial that DTV in Australia remains a flexible system of SD multichannelling and high definition. This type of service, parliamentary SD multichannelling, would not impinge on subscription multichannelling. Also, this service needs to be universal. The current subscription DTV access structure would not allow this. SD multichannelling is a crucial component of DTV just as crucial as high definition is. Responses to questions proposed in issues paper 1. Whether broadcasters should continue to be required to transmit a simulcast of their analog services in SDTV or whether there should be any relaxation to these requirements. The simulcast rules currently in place should remain to ensure a similar level of high quality programming after transition. 2. Whether broadcasters should be allowed to provide HDTV programming that is not a simulcast of their SDTV/analog programming and have that count towards the HDTV quota. At this time, HDTV should remain a simulcast of SDTV/analog programming. If alternate HD programming was permitted, the material would have to be native not upconverted. When analog ceases, the commercial FTA broadcasters should be allowed to offer subscription HD services via their redundant analog spectrum, especially when current pay-TV operators are reluctant to offer HD programming. 3. Whether different rules should apply to regional and metropolitan broadcasters. There should be no changes to simulcast requirements in regional areas. 4. Whether commercial FTA broadcasters should be allowed to provide digital program channels [SD multichannelling] in addition to the SDTV simulcast of their analog service, and their HDTV requirements, and whether there should be restrictions on the number of channels. Commercial FTA SD multichannelling should be permitted if the services do not diminish [reduce] the quality of the „main‟ channel [ie. The analog simulcast channel] programming. The additional services should only “enhance” the main service. Such as, for example, the broadcasting of various courts during the Australian Tennis Open, or in the case of the Olympics or the Commonwealth Games, the telecast of various events which occur at the same time. Also, „time-shifting,‟ for example, programs starting an hour two later on a separate channel. It should up to the individual network if they feel it‟s commercially viable to offer these “enhanced” additional services. Technically, the quality of the SD signal should not be degraded. I gather its possible to broadcast the main channel [analog simulcast channel] and three other SD services at the same time. The 7 MHz bandwidth offers 30 Mb/sec throughput – each SD service requires 6 Mb/sec for video and 256 Kb/sec for MPEG stereo audio. If not already in place, minimum picture and audio quality standards should be set in regards to any SD multichannelling. 5. Whether the genre restrictions on SD multichannelling by national broadcasters should be modified. Current genre restrictions are too narrow and must be modified. The restrictions do not allow for creative, constructive nor innovative use of SD multichannelling by the national broadcasters in the public interest. 6.The impact of FTA SD multichannelling on digital subscription television. It appears that the government‟s indirect commercial interest [through Telstra] in Foxtel has influenced the current legislation. FTA broadcasters have been disadvantaged by this legislation, which aims to promote greater uptake of pay-TV. As for commercial FTA SD multichannelling, it would be restricted to outside HD broadcast times and if the additional programming was only an enhancement or „extension‟ of the main service, I do not believe it would have a serious impact on digital subscription television. FTA SD multichannelling is very different compared to pay-TV, which has over a hundred channels of very different nature operating 24/7. FTA SD multichannelling is of little or no comparison. As for national broadcaster SD multichannelling, there are services, which are of a high cultural or of high community benefit that can be delivered by SD multichannelling. These services should be universal and this cannot be achieved through the current pay- TV structure. Furthermore, SD multichannelling was one of many facets promoted initially for the uptake of FTA digital television.
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