Release the Green Flag

The Department of Culture Media and Sport, of the UK Government, finally released the Green Paper on the Future of Television in the UK - which was interestingly called ‘Watch This Space: A new strategic direction for UK media’.

I have spent spare moments this week reading the Green Paper in the context of the earlier OFCOM and DCMS reports, as well as those from Sky and others.

You can take your own time having a deep read of all of these documents, all referred to below.

However you might want to read my breakdown of the Green Paper and what is proposes, and what I believe it means.

There was a degree of belief that it would have been out earlier this year, but it took a little while longer. Exactly why, we can guess but cannot know. But looking at the paper I can believe that it was a lot more than IP transition was embedded into the Green Paper.

It was understood that a key part of the IP transition was going to be about ensuring that nothing was lost in the transition as it relates to Public Service Media. Indeed much of the green paper discusses the need to ensure that we have trust in news sources, and that future television distribution must ensure that trustworthy news based on rigorous standards are delivered over the future television infrastructure.

It also talks at length about the importance of content provenance, and expanding partnerships between public service media and with commercial platforms, particularly those that make use of a distribution capability of the Internet - such as YouTube. It stresses the need for that collaboration particularly with regard to ensuring that the public receive the benefits of a wholesale shift to the expanded capabilities of full Internet delivery can bring, without any of the possible impacts.

The key benefit that needed to be present in such as transition was the continued universal access to trusted and high-quality television content which benefits our modern digital society more broadly.

It picks out events that have occurred in recent times as examples where untrustworthy sources of media have challenged the foundations of society, and that the future TV infrastructure must work to create trustworthy sources that deal with the speed and negative aspects of social media. We can all understand those issues that we have seen over the last few months.

The paper then expands into the key options that are to be consulted on. This is the main purpose of a green paper. The goverment uses a green paper to propose options and solicit for feedback that may then be used to formulate actual change and legislation.

In other words, it portrays the direction of travel that government wish to go in for open comment from relevant parties in the UK.

With respect to the Future of Television Distribution, there are three options presented. These are different to the three options laid out in the OFCOM Future of Television Distribution report. The original three options were:

• Invest in a more efficient DTT service

• Reduce DTT down to a core service (known as nightlight)

• Move towards DTT switch-off over the 2030s

Looking now at the new options, you can see an immediate change of tone.

• Option 0 - Allow the market to determine outcomes - which is NOT being considered

• Option 1 - Managed transition to IPTV by 2034 - which is considered

• Option 2 - Managed transition to IPTV by 2044 - which is considered

All of the new three options described in the report result in full IP transition. There is no other destination. It is all about how and when.

They have dropped the options that focused on deploying a more efficient broadcast based solution (such as deploying DVB-T2 combined with HEVC or another advanced codec as they have done in other countries).

They have also dropped the standalone option of the ‘lighthouse’ basic service (taking 3 multiplexes of content forward on a reduced spectrum range. However that aspect is still present as part of one the new options.

A key takeaway, is that NONE of them results in any Broadcast services being in the future of TV in the UK. All that they fully kept was a transition to full IP based services, but they have expanded upon it that single original option.

Another point to make is that even though there are three options presented, one (Option 0) is ONLY there for comparison purposes.

Option 0 is a key tell with regard to the Future of Television Distribution. It tells you very clearly that transition is happening as a consumer led change, this was also a main point of the OFCOM Future of Television Distribution Report. This is very important from the perspective of nay sayers/Broadcast holdouts to this process. Several of the opposing reports produced focus on a seeming reluctance or desire for viewers to change from broadcast based or hybrid services to full IP based services. This reluctance is not there, as seen in the viewer led transformation that is the move to Internet delivery. It is important also in assessing views that try to say that the transition will take longer than estimated because of some reluctance, or natural resistance to change from the consumer. In other words, the direction of travel is most likely to be faster than expected.

The two main options are therefore very much pitched based on either taking 8 years to transition or taking 18 years to transition. I know my response is the same as many others, 18 years is a very long time indeed.

Other than the two different durations, the nature of the transitions are actually not really different. The longer transition includes some identified mitigations, without sharing much belief that it would really be needed. However it is on the table for discussion. The reasons why? I believe that they are somewhat arbitrary, but aligned with longer planning windows for things such as spectrum management, as well as reflective of a small lack of confidence in the estimates of the amount of acceleration towards IP, and away from Broadcast based services.

The clear message about the transition is that running Broadcast based infrastructure as a separate platform is costly and that as the number of users of that broadcast infrastructure reduces that the cost per viewer will significantly increase. This is the key challenge about broadcast, the cost of running the service is commensurate with the size of the coverage and the number of services, not the number of viewers. IP on the other hand, costs are generally in proportion to the number of viewers (General because there are some key aspects that don’t increase significantly in cost when traffic increases).

This is the key reason for managing the transition to IP and why Option 0 is presented for comparison. Public Service Media and Commercial Companies will be making decisions on where to spend their budgets during this consumer led transition and will follow the viewers.

If left to the Option 0 approach, that means each company would exit from Broadcast according to individual decisions when their cost limits are hit for each of the broadcast companies. In other words, shifting the impact of cost of operating the broadcast infrastructure to the companies that are left still broadcasting. That creates a dangerous environment for operating a commercial platform, where you would be second guessing the others on the platform. This has already been seen in other countries, most notably with the exit of Canal+ from the French DTT platform because they did not see a future business in it.

The implication also is that for many of those companies, that will actually want to exit from DTT BEFORE 2034. In other words, there is a strong possibility that Option 0 would reduce broadcast service provision even before 2034, leaving the other companies with the cost risk of paying for a rapidly accelerating infrastructure cost per viewer. The viewer is one the most critical parameters in Public Service Media business models which (other than BBC) are based on advertising.

Option 1 (exit by 2034) is not presented as a favoured option per se by the Government. However reading the green paper you see all the supporting evidence that Option 1 is the one most likely to be picked based on the information to hand. This is because Option 1 is the LOWEST COST option. It is very much presented as it is Option 1 unless there are key reasons that are demonstrable that show that we need to take Option 2, with its associated higher costs. Those costs are also to be born by Government in all likelihood, as commercial companies will be under pressure to make commercial only decisions. In other words, they need to avoid any aspect of Option 0 when following Options 1 or 2.

The government is very clear though that these are not the only selection criteria, as it is of great importance that the quality of public service television services are maintained.

It also should be said the green paper does portray many of the challenges such as Broadband capacity, Broadband universal access, and Education are seen as solved challenges that just need resourcing, or at least they are challenges that with the right effort are all achievable.

The point is also made that these key items are needing attention anyway, because they are part the common shared infrastructure that Broadband Internet provides. Broadband is seen as being critical for the current and future of UK society with many benefits across many areas. This includes providing a huge amount of our entertainment services away from video, education, telephony (from January 2027) to the delivery of all government services. It seems that the addition of television and meeting the need of a highly trusted, high standard news media is incremental to that.

In other words, providing cost effective and universal access to broadband is a focus of this government (and the last one for that matter) and that adding Television to that is a bonus extra to the costs that are already being spent to ensure we have high performance broadband for everyone (well 99%+). It is important to note that this is already in target for before 2034. By the time the earliest date comes around, the plan is very much to be mopping up only a few hundred thousand people in disadvantaged (economically or connectivity) areas of the UK by then.

Many of the dissenting reports focus on the additional cost of broadband to the viewer, which is not applicable to 97%+ of the population. Even then those reports ignore the benefits that lower cost social tariffs have in ensuring that broadband is available to all because everyone benefits of that access beyond entertainment.

The government is very much taking education, social connectivity, NHS, Government, and Retail use cases into account. Broadband is the 4th utility service, as important as electricity, gas and water to most people, and the government is invested in ensuring that even the poorest have access to it. That evolution of attitude is accelerating as we move forward. In other words, Broadband expansion to everyone is absolutely critical and will be complete before the Option 1 date.

Some government help is indicated as being needed for a small percentage of the population, the percentage of which depends upon the execution of the required option. That is definitely not stated in full cost terms, but you can bet that these have already been calculated, and the government will be looking at fine tuning those figures during the consultation feedback.

Looking at Option 2 (2044) again, the main difference apart from date is that this option would introduce a transition phase of dual operation based on a lighthouse service. This lighthouse service of basic channels would ensure access for any person not transitioned to IP delivered television. It is also designed in the shear knowledge that the commercial bulk of media will have already made the jump to IP based delivery, thus it would only be the most basic prime channels. All the commercially sensitive channels would already have made the jump, even before 2034 as we have indicated in the thinking behind Option 0.

The period of dual operation between 2034 and 2044 is all about ensuring that a basic service is available that does not cost too much both for commercial aspects of TV companies and for the government. This dual operation has all the advantages of a 2034 transition, with all of the disadvantages of having to continue to operate the broadcast service for a reducing number of viewers. In other words the worst aspects of a low service provision, high fixed cost, low viewer platform.

One facet of transition that the paper is also sure of, is that this is only focused on the transition of DTT to IP based delivery. It sees satellite delivery being something that is in the commercial only side of television distribution, and there is an assumption that satellite delivery would continue during the time of transition, with the support of the commercial companies that provide satellite service.

The reality is that the primary driver of Satellite TV in the UK is Sky. The satellite constellations in use over the UK are primarily used for that service, and services like FreeSat piggy back on those satellites because they are available. Sky have not explicitly said it, but they are already clearly planning for a 2030-2034 turn off of their satellite services driven by the fact that they do not wish to be commercially involved in the funding of new satellite capacity that has to come on line in that timescale for the continuance of satellite TV provision across the UK.

If they have no intention of funding that capacity, or they wish to only plan for satellite service extension where they can as part of a transition that they plan, then there will be no Satellite based delivery by the date of Option 1, nevertheless Option 2. This could be seen as an issue, but from Sky’s perspective they are focused on ensuring that the vast majority of its user base will be IP connected. Sky will already be IP only by that point based on public statements and positioning. Virgin Media O2 are already well on their way to full IP only delivery as well, but that is a matter for them as far as the government is concerned.

Annex B of the Green paper are very clear about the identified challenges that need to be solved for either option. The difference and selection approach between the options is very much based on whether the Green Paper solicits new input that mandates a larger transition that is longer than 8 years, and that leads towards a grudging selection of Option 2. The government is very clear though that since quality of transition and that there is a deep need to transition to a public television service market that is trusted and fair, Option 2 is there to be selected. There is also an option in the feedback for identifying a different 3rd option, if you can justify it.

In their recently published report, Christy Sword (a consultant who works with Arqiva, core organiser of the Broadcast 2040 campaign) has made much of the belief that the transition facing us now is unjustified, undesirable and not in the consumers best interest, and it should be delayed as long as possible. He also makes it clear that he sees the original 2007-2012 DSO as being entirely different to the Broadcast to IP transition. Much of his argument is based on the view that there are few benefits to the transition for consumers.

This argues in the face of the reality that this is a consumer led change, driven by the benefits of TV everywhere, removal of cabling/antenna requirements allowing consumers to have seamless content consumption anywhere in their house and in the outside world, and also with new services coming to improve the experience. In addition a key improvement for IP transition which is not referred to as the obvious benefit, is that current DTT infrastructure provides limited HD services to consumers (I think I count 9 for most regions). Most of the services are distributed in Standard Definition - quality wise little different from the services that were available in the 2000s. They have stuck at those quality levels because of the restrictions on spectrum that DTT actually has - which means DTT is limited by a hard limit in the number of channels. It is certainly very very limited when it comes to only having 9 or so HD only channels. Certainly the UK also has not been one of the countries that has been able to launch more advanced higher quality services on DTT, like in other countries. So no 4K HDR services on DTT, only on BBC iPlayer. Even then spectrum limitations mean only a limited number of channels can be broadcast that are 4K in resolution, even with more advanced codecs.

IP based Television delivery is not limited by spectrum. It is limited by capacity of the Internet, but the scaling of that capacity is not something that is a physical restriction. There are cost restrictions, but not physical restrictions. What it means though when you look at existing full streaming platforms like Freely, the IP transition provides HD by default. By HD, we do mean many at the lower grade of 720p and not 1080p, but this is still significant quality improvement compared to SD which is the default on DTT.

This is also without taking into account how moving to IP will allow the expansion of the existing linearly delivered 4K HDR services of BBC iPlayer to the default channel and possibly allow others to launch high quality services based on new formats. This is without taking into account the availability of interactive services/information services in parallel with video, or even multi-view possibilities that are not possible on DTT. You just need to look at the trials of new services for the World Cup, where we have seen services delivered using new services such as personalised views of the game rendered in real time. This is only possible over IP, not over Broadcast.

The key part of a Green Paper is to consult, to solicit informed and justified feedback on the options presented and on the approach that the government wish to take with future evolution of TV distribution. In that vein, you should spend some time looking at the nature of the specific questions raised that the Government is looking for direct answers to (‘Watch this Space - a new Strategy a New Strategic Direction for UK Media’). They inform you of the attitude and stance that the government has in respect to this work.

• The initial questions are focused at grounding the response in terms of the UK TV market, after an open question for each and every responding organisation to say what they think in a freeform manner.

• The next group of questions are focused on the ‘bonus content’ in the report - regarding news and media literacy, provenance and the beliefs around the important of a strong, trustworthy news environment.

• It also requests the views of the consulted party with regards to the role of public service media in the future.

• It is not until question 13 to 20, do we start with the feedback on the approach and the options for the future of TV distribution. And this covers standard questions as to preference, rationales, additional timeframes, and commitment of the consulted party to being involved in supporting the transition.

• And then the rest of the questions to 29 are about regulation, prominence, facets of public service media, and finally a question to ensure that the impact to all parties are considered from an equality perspective as question 30.

In other words, out of 30 questions, only 8 are actually directly about Broadcast to IP transition itself.

There is enough there in the questions though for proper feedback from any party, but it is important to set this Green Paper in context. We thought it would be about TV transition but the vast majority of the questions are not directly about that.

• The UK government is taking the bull by the horns for an IP transition that is happening anyway (as Option 0 is described)

• The problems are not really in the infrastructure, it is in terms of institutional readiness and consumer readiness. By consumer readiness I do include the experiences, devices and services provided to consumers as well as the consumer themselves. By institutions, I do include all of the companies involved in supporting consumers in their consumption of services.

• In other words, making the experience of IP based TV delivery more seamless than the current hybrid world (which is a well defined requirement)

• The government is cogniscent that an unmanaged, market led (i.e. consumer led) only approach could be a costly problem for public service media companies and the UK as a whole, primarily from the costs of having broadcast infrastructure running when viewers of that infrastructure rapidly dwindle in an uncontrolled way.

• The government want to provide the way forward for public service media to prosper and to thrive during and after the transition has completed. We are also already in the transition.

• It also wants the UK media to be kept as strong and viable as possible, to provide trusted news and media to the public at large, whilst minimising costs to the population either through taxation or through bills.

• It sees that the way to do that is to minimise the period of uneconomic use of broadcast infrastructure, and the devil’s detail is in when that point starts and when can they end it.

• Option 1 makes clear financial sense, but there needs to be focus on the industry now with support to ensure that Option 1 is the right option, and to have Option 2 as the backup plan that grudgingly the UK government would look to support if they have to.

• The comparison between the Option 1 transition of 2026 to 2034 and the original DSO path of 2007 to 2012 is not made by the government, but is by the proponents of those who believe Option 2 is the better option. However the belief that the transitions are different enough to justify making it a 2026 to 2044 path does not hold much weight in reality, and the real answer to whether it should be Option 1 or Option 2 is actually in my view an Option 1a.

• Option 1a is to target 2034 but to have flexibility to extend a short period in the event that some of the key challenges take longer to resolve, thus limit the transition period to as short a period as possible.

• This already has precendence with the current transition of Telephony to IP based operation, that started in 2017 and was originally targeted to end in 2025, but was extended to January 2027. This was extended because some of the safety aspects of telephony were not dealt with as rapidly as they could have by service operators, and the extension was prudent in the face of that assured readiness. It should be noted that telephony transition is on track now, but it should be watched by anyone who has an interest in the Broadcast to IP transition.

Epilogue
I have not covered all the aspects of IP transition here in this article. I have discussed it before in one or two of my posts so please have a look at those. I am though sure that I will talk about it again, so do subscribe if this interests you.