The Multiplexing Option for Digital Television

Summary

This submission calls on the Canadian government to expedite the process of Canada's digital television transition by requiring broadcasters who are unable to convert to digital by August 31, 2011 to employ multiplexing transmission until such a time as they are capable of completing a full switch to digital high definition broadcasting.

Multiplexing is the use of one digital transmitter by one or more broadcasters to transmit several programs at the same time. It significantly reduces the spectrum use of each broadcaster. It is technologically feasible under a digital paradigm but thus far the industry has demonstrated no interest in multiplexing because Canada's digital standard (ATSC) cannot support high definition signals via this method.

The approach I recommend would allow Canada to move forward with use of spectrum White Space and explore further uses of the digital dividend on the schedule which the CRTC announced in 2007. The Canadian broadcasting industry has thus far shown very little urgency in its approach to the digital transition, despite repeated warnings from the CRTC and a clear statement from Industry Canada earlier this year that the 2011 analogue–shut–off date is firm. Earlier this year, major private broadcasters such as CTV and Global announced at public CRTC hearings that they expect to be years late in completing their transition. The government must clearly demonstrate that this is unacceptable.

The industry has made it clear there are not sufficient resources in Canada to update all transmitters to digital by August, 2011. Multiplexing greatly reduces the number of transmitters in question and allows broadcasters to proceed at their own pace to full high definition. Standard definition digital signals are still superior to their analogue counterparts and have proven quite popular in Europe. Its lower costs may also encourage new broadcasters and potentially reduce problems associated with ownership concentration.

Simply put, the market is not delivering the desired result in Canada's digital television transition. Canada stands alone among western developed nations in having a government largely disengaged from the digital television transition. As a result Canada is falling behind many countries that are already thinking beyond the digital transition and exploring spectrum development. By demanding multiplexing as a minimum requirement, the government can ensure all Canadians are capable of receiving the benefits of digital television and help spur on further economic growth.

Submission

First, I would like to thank Industry Canada for this public initiative. I hope these submissions are given serous consideration; for Canada's digital future is not simply an industrial issue, but is of relevance to all Canadians.

My 2009 PhD dissertation at McGill University was entitled Canadian Broadcasting Regulation and the Digital Television Transition. I continue to research and write about this broadcasting juncture because I feel its implications go far beyond what programs we are watching. Free–to–air television broadcasting uses the public airwaves to ensure no citizen is excluded from a basic television service. The digital transition provides an opportunity to enhance this service while allowing growth within established broadcasting sectors and encouraging further technological innovation. I am convinced Canada has not sufficiently explored this new technology and further development has been restricted by the effects of incumbent broadcasters protecting their financial interests.

This submission calls for the government to take a leadership role in requiring broadcasters to multiplex their signals in standard definition (SD) if they are not otherwise prepared for the August, 2011 analogue–shut–off (ASO). This rule would apply is all the markets specified in CRTC 2010–167. I believe my submission addresses three questions in three of the areas of expressed interest in the Industry Canada consultation paper.

In a 2008 speech, CRTC Chair Konrad von Finckenstein expressed his concern that industry had been "dragging its heels" and he was greatly concerned "that the industry will not be ready" for the 2011 OTA shut–off. His apprehensions have proven well–founded.

The market–led television transition in Canada has proven incapable of the task at hand and it is time for the government to assume a more prominent role. In 2009, the CRTC asked a group of industry experts to draft a report on the progress of digital television in Canada. They could reach no conclusions on the key OTA sector:

It is not sensationalizing to say OTA television broadcasting in Canada is facing a crisis, one which was entirely avoidable. Let there be no mistake: Canada has already fallen behind global leaders like the U.S., Brazil, Japan, Korea and the UK in digital broadcasting and the situation appears to be getting worse.

The Industry Canada consultation paper, Improving Canada's Digital Advantage, states the following:

This submission fully agrees with that statement. What my work thus far has shown is that the role of government has been undervalued in the Canadian digital television transition. Despite calls from the CRTC (as recently as this spring) and from digital television specialist Michael McEwen in his 2007 report to the CRTC successive governments have refused to take direct responsibility for the digital television transition.1 Industry Canada and Canadian Heritage need to set clear parameters for broadcasters for Canada to have any chance of meeting the 2011 deadline.

Many experts now believe we are past the point of achieving full transition by the deadline. The use of multiplexing signals may prove to be a viable compromise, and will still provide incentive for broadcasters to move toward full HD over–the–air programming.

Other Canadians are saying similar things. The town of Kamloops has been a site of lively citizen participation in the digital television transition. A group called Save Our CBC Kamloops (SOCK, Save Our CBC Kamloops) has been active in recent years, trying to restore the CBC television broadcasts which were cut from the community in 2006. What is particularly noteworthy of this citizen effort is the way the group is taking advantage of the opportunities offered by the technology of digital transition to further their cause. S.O.C.K. is appealing to the broadcasters and regulators to establish a digital television multiplex broadcast in the region that would allow for multiple channels, not just the CBC.

At a hearing before the CRTC in 2009, Pam Astbury of Kamloops presented on behalf of the group. She spoke of the promise of OTA digital television: "We believe that the future of television will be constructed upon a digital foundation and that digital technology is the answer to both large and small market areas across Canada". The group also notes the affordability of multiplexing signals:

In the same hearings, CRTC Chair Konrad von Finckenstein asked "And what is stopping the local broadcaster from multiplexing right now? As far as I know there is no regulatory impediment". This was indirectly answered by CTV president Ivan Fecan who said "First, it is important to understand that a multiplexed channel while digital, is not HD. … And given CTVgm's proposal… to continue operating analog transmitters in markets where digital over–the–air service is not available, it is unclear what this will achieve."² In other words, the private sector is only interested in investing if it will allow for high definition broadcasts. There is no private sector will to explore the possibilities of multiplexing. This is why a strong position from the Canadian government is required.

The March 2010 CRTC policy announcement on digital television (CRTC 2010–167) which followed these hearings offered only the following tepid support of multiplexing: "Broadcasters should continue to explore opportunities such as multiplexing to ensure that Canadians continue to have access to free (over–the–air) conventional television services". There is no regulatory teeth behind this statement — the broadcasters are free to do as they wish and they have made it clear they have no interest in SD. Thus, a key element of the promise of digital television (freeing spectrum) remains underdeveloped and a segment of the population is near losing its OTA signal.

The CRTC has emphasized the expansion of the high definition format because it is suited to the ATSC standard and it places Canada in a stronger international position in the media marketplace. This position stands in contrast to many European systems which have placed little emphasis upon HD and much more upon multiple free over–the–air digital channels. Freeview was launched in the UK at the end of 2002 and offered free OTA services via digital multiplexes, providing 30 TV channels in standard definition.

Some public broadcasting stations in the U.S. have manipulated this new ability to multicast in digital by running simultaneous multiple SD broadcasts on their allotted spectrum space during the day (i.e. children's shows, educational programming and political information), while converting to one HD broadcast for the evening schedule.³ The ability to multiplex signals is a key advantage of the digital system.

Thus, in answer to the questions in the call for comments, this submission addresses the barriers to implementation in the section Innovation Using Digital Technologies: the digital television transition has been hindered by broadcasters who are unprepared for the switch but will not consider the advantages of multiplexing. In the section entitled Digital Infrastructure, Industry Canada asks: What steps should be taken to ensure there is sufficient radio spectrum available to support advanced infrastructure development? This submission advances the position that the current plan will not free the required spectrum unless we allow many broadcasters to simply go off the air — an option certainly unacceptable to many Canadians. Multiplexing keeps stations on the air and allows the spectrum to be used for other development. In Canada's Digital Content, the call for comments asks: What kinds of 'hard' and/or 'soft' infrastructure investments do you foresee in the future? HD broadcasting is certainly the future of television — no program can be widely sold on the international market otherwise. The OTA signal is of a higher quality than the cable or satellite counterparts and is to be encouraged by OTA broadcasters. This submission sees multiplexing as a temporary measure in most markets until the broadcasters are able to make a full HD conversion.

Industry Canada has made the potential use of white space technologies a key pillar of Canada's digital strategy. This is the correct approach; however, Canada will not truly benefit from new spectrum uses until the broadcasters have completed their transition to digital. Requiring unprepared broadcasters to multiplex their signals keeps stations on the air, maintains citizen access to signals, and frees up spectrum space for further development.

I appreciate your consideration of this submission.

Gregory Taylor

¹ DTV Working Group Report. Issues Raised By Going Digital. April 2009.
A Report to the CRTC on Digital Transition Strategies in a Number of Different Countries.

² All of the included Kamloops and multiplex comments are available in the transcripts to 16 November 2009 Policy proceeding on a group–based approach to the licensing of television services and on certain issues relating to conventional television. Notice of Consultation CRTC 2009–411.

³ Book, Constance Ledoux. (2004). Digital Television: DTV and the Consumer. Media Technology Series. Alan Albarran, Series editor. Oxford: Blackwell Publishing 2004.