Dear OfCom

It seems to me that the job of OFCOM is generally to work in the publics interest in making sure the communications industry, provide a high quality service to the general public, whos spectrum they pay a licence to use, but to some extent ofcom’s role should also be to make sure that we are being offered the best quality of services those providers can offer ?

The current situation in which we are going to have to wait several years for analogue switch because of some time schedule set previously, seems archaic before HD freeview services can be offered in the uk. It seems to me the lack of flexibility set out by the original timetable is stifling the possibility of HD freeview now, which is fully technically possible.

1. The main generator of Hd broadcast content/programs paid for by the licence fee is obviously the BBC, they currently are offering this improved quality HD content generated by the licence fee, through other peoples commercial services namely SKY’s services and other cable providers etc, these customers who pay for these services get this HD content for free I imagine. Yet this HD content is not equally available to the majority of BBC customers who pay the licence fee, this situation is not in the publics interest ? And needs to be remedied ?

2. The argument that analogue services need to be turned off completely before any HD services can be offered is also weak. In the sense that trials of HD freeview in london were very successful ? And did not interfere greatly with current broadcasting ? Why these trials cannot be extended and widened i’m not sure. Its not as if the turnoff of country wide, of analogue television transmissions will occur simultaneously anyway ? Nor will the general public receive HD freeview rollout simultaneously either ? The parity of quality of service for various tv-licence payers has rarely been equal ? Ie the number of areas even now that have low quality freeview reception has not even yet been properly tackled ? Television transmission operating licences should be offered not just on a purely commercial basis of how much someone will pay for it. but also on the basis of what percentage of the customer base will they will promise to provide to, perhaps like the post office, that all addresses shall be offered the same service ? From a practical point of view simultaneous countrywide rollout of any service will delay its implementation, in my opinion it is in the best interest of the public, to make the provision of HD services available as soon as possible and if that means that some areas get HD first, then this will enduce competition for other areas to provide it sooner.

3. Even without analogue television turnoff, the bandwidth within the available currently allocated digital freeview spectrum is such, that some low quality mpeg2 encoded tv channel licences could be revoked in the public interest(say the removal of 6 of the worst channels), this could free up enough channel bandwidth within the current freeview setup to provide at least 2 HD mpeg4/H264 channels on freeview right now ? Depending on the quality of the HD channel and the fact that Mpeg4 H264 encoding is so efficient in comparison to the original freeview video format mpeg2, it might only take up 2 to 3 ordinary freeview channels, to offer 1 full quality HD one, dependant on quality,

4. Also I have a question as regards the HD compression quality trials that were conducted toward the end of the BBC HD freeview trial, was it made sure that the 410 trialists who were asked theyre opinion on the quality of the viewable HD signals were doing so on a fully HD capable television, as most of the public has been duped into buying televisions not fully 1920x1080p or even 1080i compatible in terms of their native resolution ie the top quality and best candidate for true HD? As such theyre opinions which will be deciding what quality of compression we get in the future on Hd freeview channels may be made on a very poor basis ? And from a providers point of view the harder the HD mpeg4 is compressed the more channels they can fit into a transport stream theyrefore more advertising and more potential profit for them, theyre are many issues at the moment with the current mpeg2 freeview setup where people were/are over compressing channels, lowering the quality of the broadcast, to some extent ofcom should provide rules about the the supposed resolution of the content but also rules about bitrate and compression within the HD standard to make sure we are actually receiving HD quality standards when theyre are offered or even for that matter pal quality with the current freeview standard, Quite a few people have complained at the quality standard of some of the HD content offered by sky for instance as it is possible to over compress HD to such an extent that you lower the visible viewable spatial resolution of the video on the television viewed, below that of the supposed actual resolution of the HD standard. And this can be further compounded as mentioned earlier by televisions that don’t support true HD (1920x1080p) or worse another old broadcasting anachronism that should be dealt a final death blow in any new HD standard : interlacing ?

5. I personally certainly think it is the remit of ofcom to try and obtain on the publics behalf the best possible freeview broadcasting it can ?, and if possible why not insist that UK broadcasters lead the world in HD freeview broadcasting ? This would certainly show that ofcom really are working in public interests, to encourage the technological excellence of broadcasting offered to the UK public. Instead of lagging behind the rest of the world.

6. The sale and marketing of mpeg4 H264 compatible HD capable freeview receivers needs a period of time to become established in the publics imagination, the sale of these devices needs to start now if the quantity is to be available for the supposed official launch of these HD freeview services sometime after analogue switch off process in the future. At the moment sky and cable providers are making a killing by getting people to pay for HD services, which are own spectrum is perfectly capable of providing, right now. The public in general may not understand the technicalities of the situation, but this should not be used as a reason for them to be duped into paying extra money for HD services above and beyond the licence fee cost. The environmental impact of late HD freeview rollout, will be a further spurt in growth of satelite dishes adorning buildings across the land, and a further dimunution in the relevance of public sponsored broadcasting, versus private commercial services SKY et al.

The spectrum available for transmission upon, is something the public still own, and through licensing the use of spectrum we should negotiate the best services via it, and at the moment there is too much lag occuring in the provision of the best quality services.

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