Thanks for posting - to me this looks to be good forward-thinking, opening a path to a broadcast environment where DVB has surrendered to fibre/pair and 5G based IP delivery and certainly points to where regulation should be required.
(Apologies for ranting a bit.......)
I wonder if consideration should go further?
The consultation document suggests that non-PSB content could be SD/HD substituted where it is essentially (not exactly) the same, but PSBs should remain as simulcasts. This seems a bit harsh on commercial PSBs. Channel 4, for instance, should be able to swap DVB-T2 HS C4 for the SD version on LCN 4, where the set provides for this, and despite the "LEMNUS" macro-region not being respected.
Also, it may be possible for PSB and non-PSB commercial channels to develop "Adsmart" type applications, or to deliver localised or interest group content. Clearly, this goes beyond the functionality of even smart TVs with Channel List Management (CLM), requiring the development of application layer components making deep calls into firmware, so it isn't what this consultation is about. But, such future development shouldn't be proscribed by only allowing PSB HD substitution to be an absolute mimic of the SD, whether the HD version is off-air or IP delivered.
1.
Do you agree with Digital UK’s proposed amendments to the LCN Policy, to enable HD/SD substitution for devices that support CLM?
Yes, this is a sensible future-proofing measure, it allows the Freeview
EPG to maintain a look and feel comparable to commercial EPGs.
Simul-cast requirements for PSBs could, however, be relaxed to enable (for instance) Channel 4 to offer HD versions in areas that do not conform to their SD advertising macro-regions.
2.
Do you agree with Digital UK’s proposed amendments to the LCN Policy, to enable IP fallback channels for devices that support CLM?
Yes, this is a sensible future-proofing measure, it allows the Freeview EPG to maintain a look and feel comparable to commercial EPGs.
The proposals include a requirement that that this feature should be readily inhibitable by easy to access user setting. This is necessary to protect households that have data capping or per bulk tariffs applied to their broadband provision.
Channels that wish to include localised content outside of the broadcast environment should be allowed to substitute elements of their broadcast programme stream with separately delivered IP content if this were to become a practical feature of a significant part of the smart TV population.
Channels should be encouraged to engage with manufacturers of smart TVs to establish the possibility of both localised programme content, and the substitution of commercial spots.
In the above case, regulation should apply to the content of any sustaining service that would be available to viewers of consumer equipment that does not support temporary substitution.
3.
Do you agree with Digital UK’s proposed amendments to the LCN Policy, to enable IP-delivered channels for devices that support CLM?
Yes, as above, this is a sensible future-proofing measure, it allows the Freeview EPG to maintain a look and feel comparable to commercial EPGs.
This feature should only be available to non-PSB channels unless a specific case is made for an additional IP only PSB service with a cherished LCN, for instance, “red-button” type streams, or specific interest or timed content.
4
.
Do you agree with Digital UK’s proposed amendments to the LCN Policy, to remove restrictions on the number of times channel providers may reorder their LCNs or change the names of their channels?
Yes. There should be a restriction that protects the integrity of viewer familiarity with the list, but this would persist if changes were limited to two per year.
Further change control measures may be required to guard against significant bulk changes changing the nature of the list. These change controls could describe the triggering of communications requirements including marketing and on-screen messaging.
5.
Do you agree with Digital UK’s proposed amendments to the LCN Policy, to remove rules that prohibit LCN trading between channel providers?
Yes, but any significant change, as a result, should conform to a change control policy (see 4 above).
Privileged single-digit LCN (as applied to the BBC and commercial PSBs) should not be tradable, but an element of the PSB’s OfCom broadcast licence or undert
aking pursuant to the BBC’s charter.
6
.
Do you agree with Digital UK’s proposed amendments to the LCN Policy, to increase the minimum broadcast hour requirement for new channels?
Yes, the allocation of an LCN should be only made to a channel that is substantively available.
However, consideration should be undertaken on the possibility of relaxing the restriction that IP versions of a programme stream are direct replicas of the broadcast version. It should be possible for a channel that has a time-limited broadcast allocation, but a unique LCN could augment their broadcast hours by IP substitution. In this case, the minimum broadcast hours restriction should apply to the broadcast version, and not the sum of broadcast and IP deliveries.