The BBC responded to Ofcom on the DDR earlier this week. Click here (go to the bottom of the page) for a copy from the BBC’s website — as of today, Ofcom had not posted a copy on its website. Not including the associated Indepen report, the beeb’s response is 75 pages, so maybe Ofcom’s scanning machine could not handle it! The BBC’s response is well-written and well-argued. It’s so large, it’s not really easy to summarise, so I thought I would explore a few of the themes and issues that surface in the document:
Regret. Ah, you might think, regret is a word rarely mentioned in policy circles. You’re correct. Policy-makers are rarely in their jobs long enough to be confronted with regret, right? Ofcom’s former CEO Stephen Carter has moved on and isn’t answering questions about the low level of telecoms infrastructure investment following the BT Settlement. So, the BBC is asking Ofcom to think about regret now, writing:
It is therefore necessary to consider the potential for “regret”, i.e. whether a decision that is costly to reverse may turn out, with hindsight, to be wrong, and to include, when this is the case, the costs of regret and/or reversing the initial decision in the impact analysis. There are a number of reasons why it may be costly to reverse a decision not to reserve spectrum for HD PSB services.
HD take-up / future demand. Here — as everyone expected — the BBC demolishes Ofcom on the evidence about HD television. This is mainly in response to Ofcom’s question no. 5 about choosing between a market-led approach and an interventionist approach. After summarising the evidence supporting the HD lifestyle, the BBC write:
All the evidence, summarised in this section, from market data and audience research, shows that HD on DTT is not a “premium” offer, but rather a standard service, which has substantial social value, beyond its private value, and hence, needs to be available universally at reasonable cost. Indeed, it is likely that if Ofcom (had it been in existence at the time) had undertaken several decades ago similar analysis to that used now in the DDR, it would have concluded that there was little social value associated with moving from black-and-white to colour television.
– and the horse you rode-in on!
A managed approach. The BBC uses interesting wording to describe a potential Ofcom intervention to allocate part of the digital dividend for HD on DTT. The BBC calls this a ‘managed strategy’. Nobody likes an interventionist, but everyone believes in management. I think this is not only brilliant writing but also correct from a regulatory perspective. Managers take calculated risks based on evidence — we see Ed Richards willing to take such a risk with the proposed Public Service Publisher (PSP) — and I think the BBC is here subtly challeging Ofcom to put some of its intellectual firepower to the task instead of hiding behind the concept of uncertainty.
‘Spend to save’ strategy. Genius phrase and one that will undoubtedly become prominent in U.K. government press briefings. Tesco is probably kicking themselves they did not think of this one. Unfortunately someone else already did — always the lawyer, I searched a trademarks database and it is registered to a financial services firm. Anyway, for the BBC spending to save has to do with the efficient MPEG4 transmission standard:
HD can also contribute to increased spectrum efficiency in the medium term. Whilst in the short term HD requires more bandwidth than SD, because its delivery requires the adoption of the more spectrum efficient technology called MPEG411, it will drive a gradual adoption of receivers coping with this MPEG4 technology. Just as in order to release 112 MHz of valuable UHF spectrum by 2012, it was first necessary to use extra capacity to simulcast digital and analogue services from 1998, the launch of an attractive HDTV offer, using both existing and new capacity, will drive a managed migration to MPEG4. It will then become possible to migrate some or all of the SD services to MPEG4. This will therefore open up the prospect of greatly increased efficiency across the whole DTT platform, for HD as well as for SD services. If Ofcom allocates part of the released spectrum now to HDTV and MPEG4 broadcasting, it will greatly increase spectrum efficiency across the whole platform, and will be able to get back at least as much spectrum as allocated, in the mid-term (a 12 year licence period).
That’s it for now, but I might turn back to this document in the future…
