Wednesday, 5 March 2008



Avanti Communications
Q1: Access to the BBC's digital SDTV services on a free to air basis is reasonable by virtue of the service using capacity on the Sky platform which fills in Freeview gaps.
Q2: Universal access for licence fee payers to subscription-free means of access to digital services should be available: This inevitably means that some fee payers will have one option, others will have more depending upon their geography or the nature of their abode.
Q3: If the BBC is to continue to draw public money to fund itself, it is our belief that its services should be made as attractive as possible to fee payers. A small selection of channels and an inadequate availability of HDTV content will become a major barrier to the success of Freeview in the future, consigning fee payers to a markedly second class service. It should also be possible for consumers to chose free to air services whilst having the option to upgrade to paid for content in order to make the service competitive and attractive to the widest group of customers.
If this can be achieved by continuing to make BBC services (with advances in HDTV and premium content) available through the Sky electronic programme guide, he consumer will be well served. However, we believe it is possible that there may be insufficient satellite capacity to enable the BBC to fully compete with a full range of innovative HDTV and interactive services at the 28.2°E position used by Sky. Furthermore, it is in the best interests of the consumer that all free to air programming is provided with the latest available technological enhancements (HDTV is the new “colour” TV and all consumers should have access to it).
Q4: Yes, furthermore the technology is now available to the BBC to deliver Freesat in IPTV format with a satellite return path, facilitating a far wider range of interactive services than are currently available in other European satellite TV offerings. Future proofing also means, at a minimum the capability to grow a large HDTV offering. HDTV will be ubiquitous on competing platforms in the medium term. If the BBC chooses a Freesat technical solution that does not have sufficient capacity (as is the case with Freeview) to offer a full HDV suite, it will have failed in its objective. The BBC has a proud heritage of technical innovation and should remain at the forefront.
The BBC’s Public Service Remit. The BBC has a number of public service duties. These include the Public Purposes form the BBC of “helping to deliver to the public the benefit of emerging communications technologies and services and, in addition, taking a leading role in switchover to digital television”, and a requirement that the “BBC must do all that is reasonably practicable to ensure that viewers, listeners and other users (as the case may be) are able to access the UK Public Services that are intended for them”.
Q5: Improving access to digital services is not the only stipulation that is made by this paragraph, but yes, Freesat will do that. The Public Service Remit also compels the BBC “to deliver to the public the benefit of emerging communications technologies”. If Freesat does not include at minimum, a large range of HDTV services and an expanded suite of free to air content, and preferably IPTV and interactivity, it will fail in this key objective. 12
Competitive impact. The Trust has taken into account the market impact of the proposition. In particular, we should welcome your views on the following issues and will take them into account when our final decision is made.
Q6: No. The markets not mentioned are the distribution mechanisms. The choice of which satellite operator’s capacity Freesat may use will have a dramatic impact on the future proofing of the Freesat service (because of capacity constraints at existing orbital positions). Choosing a new, innovative supply of satellite capacity will grow competition in a market which is less competitive than many.
Q7: It depends on the scope of Freesat, and whether a full service multi channel offering with high HDTV content and interactive services are offered. If this is the case, the answer is YES. Also, if Freesat is offered at 28.2°E, it does not offer any additional choice at all, and is a pointless exercise since BBC content is already free to air at that position. The concept of choice should include the BBC leading in quality of innovation and breadth of free to air and premium content availability.
Q8: No to the second part. If the BBC simply elects to maintain a small suite of channels from the orbital position 28.2° East, it is possible that there will be insufficient satellite capacity available to enable the BBC to innovate well a full range of “emerging communications technologies”. In the USA it is reported that some 1500 HDTV channels are being launched this year, in Europe there are apparently fewer than 100. If the BBC fails to innovate, it is likely that the rest of the market will follow, creating a barrier to innovation.
Q9: In part. However, see answers to questions 6,7 and 8 above.
Q10: No. The BBC uses licence fee payers’ money to benefit the producers of independent content, and to benefit the supplier of Digital Terrestrial Transmission facilities, so why should Freesat Joint Venture Partners not benefit accordingly if essential costs need to be covered to facilitate success?
Q11: Other comments. In addition to seeking views on the specific questions detailed above, we are interested in your views on other aspects of the proposals.
Q12: Genuine choice requires that the BBC collaborates with the other providers of free to air content to produce the largest bouquet of content available using the most advanced technology. Anything less will consign large sections of the population to using second class services.

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