Wednesday, 5 March 2008



An existing satellite broadcaster (name withheld) 3
We are a broadcaster already operating, “Free to Air” on the digital
satellite platform (and on the BSkyB EPG).
We support the intention of the BBC to embark on a “FreeSat” proposition…with some caveats. Our comments relate less to the consumer (viewer) aspects of access to BBC services, but focus on the wider implications of competition on the provision of digital TV, via in particular, digital satellite (DSat). Other broadcasters, and their viewers, are also licence-fee payers!
Even above all the viewer considerations, a fundamental (and positive) implication of the BBC proposition is that for the first time there will be an alternative to BSkyB in the supply of satellite TV services. In the UK (uniquely), there is a perception that satellite TV is only available via BSkyB, and that a subscription is involved.
It is somewhat surprising that the studies which the BBC has received make no mention of the implications of what would be the first competitor to BSkyB in the provision of satellite-delivered digital TV. Licence payers are not just “BBC fans” – they include all who receive any television, including those who may feel no particular loyalty to the BBC. As licence payers, their requirements should be considered in any review of the provision of BBC services. All TV viewers have to pay the licence fee, even if their preferred viewing is non-BBC.
We would make the following points (we talk about the “BBC Offering”, but assume it would be the one mentioned in the documentation, being operated by a consortium of broadcasters or another service intermediary):
However it is portrayed, the BBC satellite offering will be perceived as one competitive with BSkyB. Given that there is no current competitor in satellite delivery of digital TV, this is to be welcomed.
By virtue of being on satellite, the BBC DSat proposition presents the opportunity of offering a much more efficient means of distribution of BBC HD broadcasts, for which DTT/Freeview is clearly not suitable (unless the BBC alone is given a privileged position re Freeview, which will not be acceptable).
The Technology utilised will presumably be such that the BBC “FreeSat” will include provision of EPG services, capable of providing access to any digital FTA channels on the Astra 2D/Eurobird platform. As such, the BBC service will be subject to the same FRND regime as is BSkyB. Any FTA channels will be able to seek (on appropriate terms) to be listed in the BBC “FreeSat” platform.
Ofcom is about to undertake a review of the wholesale platform markets for digital television. This should embrace in full the BBC’s proposals. The BBC proposal clearly could have significant impact on competition on the wider market for ALL digital TV services
It would be unfortunate if the “free” element of BBC FreeSat was emphasised to the exclusion of possible subscription extensions. Indeed, the fact that the BBC services might 4
not remain forever “free” has to be taken into account. The debate over the charter and licence fee has widely discussed the possibility that some (or ultimately all) services from the BBC might become subject to a direct subscription – whether or not as a replacement for the licence fee.
As a competitor to BSkyB, the BBC service should surely provide the potential for paid-for services, whether from the BBC or third parties. The market would be severely distorted if consumers had to (artificially) choose between a “free” satellite platform and one which permitted paid-for services. The precedent already exists – Freeview sits alongside “Top-Up TV”.
There are many potential subscription or conditional access services which BSkyB does not permit. It would be a significant stimulus to innovation if the BBC service were to provide mechanisms (which are technically easy to provide) to allow such services to develop. These could be free or paid-for services
The set top boxes to be used as part of the BBC services must be of “open” architecture. Only this would allow proper development of competitive DSat offerings – and at the same time would allow the BBC to continue to offer a truly “free” version, while permitting variants with (encrypted) paid-for conditional access services.
In summary, we support the BBC proposition, with the caveat that it should NOT be restricted to only satellite TV channels which are entirely Free to Air.

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