Opinion of November 25, 2008 on the draft plan for the end of analog diffusion and the shift to digital.

The French Superior Audiovisual Council (Conseil supérieur de l'audiovisuel) has been asked by the French government to give its opinion on the draft national plan for the switch-off of analog broadcasting and the shift to digital. After deliberating at its plenary meeting on November 25, 2008, it issued the following opinion.

The Conseil welcomes the forthcoming publication of the national plan for the cessation of analog diffusion and the shift to digital, which, under the provisions of the law, is a necessary condition for any large-scale switch-off operation. The existence of the plan is a prerequisite for the Conseil's first switch-off decisions, which can only be implemented at least nine months later.

However, the late publication of this plan is a particularly strong constraint on the shift process in France: analog diffusion in the first zone with more than 100,000 inhabitants cannot be stopped before October 2009. However, the last region in mainland France must switch over to digital diffusion before November 30, 2011. The switchover will therefore take less than 26 months, at the rate of almost one region per month.

1° - Freeing up a sub-band for very high-speed mobile Internet

The Conseil confirms that it has taken steps to avoid, as far as possible, the use of frequencies above channel 60 (790 MHz).

However, in order to successfully complete the process of shutting down analog diffusion, the Board reiterates that it is essential to have access to the entire UHF band (470 - 830 MHz) until November 30, 2011. In particular, in regions where it would not be possible to immediately apply the definitive frequency plan ("target plan"), it must retain the option of maintaining certain existing digital diffusions in this part of the spectrum without any specific formalities.

In other cases, the Board demands that the authorization proceedings envisaged in the draft plan be spelled out very rapidly, and that they guarantee a response to the Board's requests within a period not exceeding one month. If the November 30, 2011 deadline is to be met, frequency plans for more than half of France's regions will have to be published by the end of 2009.

The Conseil emphasizes that this direction calls into question the planning model previously adopted for the transition to digital diffusion, which was based on the frequencies negotiated by France at the 2006 Regional Radiocommunication Conference. Given the imminence of decisions to stop analog diffusion in the first regions, a major project will have to be carried out very quickly.

It is imperative that the Board has the necessary financial means to carry out this accelerated reconstruction of the target plan in all areas where analog diffusion is to be stopped.

2° - Enhancing DTT and radio service supplies

The Conseil is delighted that it now has the possibility of allocating Band III to digital terrestrial radio broadcasting, in line with its recommendations and operators' expectations.

It regrets that the draft plan does not supply such favorable prospects for digital television services. The use of several channels for high-speed Internet services creates major uncertainty as to whether it will be possible to meet the needs identified for the audiovisual industry, as transmitted by the Conseil in its contribution to the consultation on the digital dividend. The Conseil notes that the studies, which concluded that it would be possible for the entire audiovisuel supply to coexist with a sub-band of nine channels allocated to other services, could not be the subject of contradictory analyses, as they have not yet been published.

Pending the completion of this essential work, the Conseil has doubts about the possibility of offering, outside the sub-band and under conditions compatible with the economics of the sector, ten multiplexes with national coverage for DTT (coverage of at least 95% of the population in mainland France), two multiplexes for personal mobile TV (coverage of at least 60% of the population) and one multiplex for local TV.

Once it has this information, the Conseil will assess the resources actually available, taking into account the needs of the audiovisual industry, the requirements of its economic equilibrium and the competitive balance on the diffusion market.

For the time being, the Conseil emphasizes that a successful shift to all-digital broadcasting means that the target plan must guarantee each of the multiplexes shown at least the same coverage as at present, particularly in border regions. It would be inconceivable that households currently receiving DTT over the air would be deprived of it when analog diffusion ceases. Consequently, the Conseil considers that it will only be possible to identify additional channels once continuity of digital terrestrial coverage is guaranteed.

3° - Digital switchover procedures

The Conseil is delighted that the viewer has been placed at the heart of the government's concerns in the preparation of this operation, in particular with the reminder of the principle of service continuity.

With regard to the modalities of the digital switchover, it is pleased to see several of its notices approved by the Government.

It takes note of the mission entrusted to it to publish a complete timetable for the digital switchover, specifying the various stages of this large-scale operation.

The expiry of Canal+'s analog diffusion authorization on December 6, 2010 will enable the rapid deployment of digital radio in band III throughout France. Nevertheless, the Conseil emphasizes that the end of Canal+'s analog diffusion, which is not synchronized with that of the other channels, will deprive a proportion of viewers who do not subscribe to the service's free-to-air channels. The France Télé Numérique public interest group will therefore have to monitor the Canal+ switch-off closely.

In this respect, the Conseil considers it essential that the GIP's missions explicitly include the three transitions made necessary by the digital switchover: the early cessation of Canal+'s analog diffusion in certain regions; the cessation of analog diffusion for other channels; and the possible reorganization of certain digital frequencies towards the target plan. In this respect, it would be advisable to specify the players who will be involved and the related financing.

With this in mind, the Board would like to see the GIP's existence extended beyond November 30, 2011, to support the transition of the last regions to the target plan. It would also like to see its membership expanded, but never reduced. Lastly, its funding needs to be adjusted accordingly.

4° - On the precise timetable for digital switchover

The Conseil is delighted with the announced timetable for the first phases and the simultaneous start of the switchover to all-digital in two regions, the first in the east and the other in the west of mainland France, which is a prerequisite for the total shutdown of analog diffusion by November 30, 2011.

There has already been a significant delay in the switchover process: the law made provision for the first regional switch-offs to begin as early as March 2008; they will begin 18 months later. Knowledge of the overall timetable is now an essential asset for the success of the project. It will help mobilize the many players involved in the switchover to "all digital", starting with the France Télé Numérique public interest group, local authorities, broadcasters, industrialists, antenna installers, technical broadcasters, building managers and retailers. Indeed, this is a key expectation of many partners in the digital switchover. A clear understanding of the timetable is also essential if we are to publish, by the end of 2008 in accordance with the law, the list of sites destined to receive DTT and their provisional commissioning date. The Conseil will do everything in its power to ensure the rollout of DTT before the dates set for the end of analog diffusion.

For this reason, a complete timetable is attached.

It hopes that this shutdown and shift timetable will be included in the national plan as soon as possible, so as not to delay the operational rollout of the operation.

The Board summons the Government's attention to the fact that this large-scale plan is still largely financed by the audiovisual industry. With just one year to go before the first region switches over to all-digital broadcasting, the release of a sub-band for other spectrum users adds a further layer of complexity to the execution of this operation.

This additional complexity will translate into costs that will need to be highlighted. The Board proposes to evaluate the amount of funding required to free up the sub-band. This financing should be based on the resources generated by the allocation of the sub-band to electronic communication services. In spectrum management, it is standard practice for beneficiaries of the release of a frequency band to bear the costs associated with this release.

In conclusion, the Board stresses that the release of a sub-band now requires substantial additional work, both in terms of national planning models and international coordination. This adds to the burden of preparing for the switch-off of analog diffusion. This new constraint, combined with the late publication of the analog broadcasting switch-off plan, makes the transition to "all-digital" much more complex in France than in other European countries.

It is therefore imperative that additional means be allocated to the players involved, in particular the Conseil and GIP France Télé numérique, so that this ambitious operation can be successfully completed within the timeframe laid down by law.

The Conseil will be vigilant to ensure that this change in government policy on frequency management does not prejudice audiovisuel operators already authorized, and preserves the quality of terrestrial hertzian diffusion to which our fellow citizens are so attached.

For the French Superior Audiovisual Council :
The Chairman,
M. Boyon

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Appendix: Provisional timetable for the digital switchover of France 3's opting-out areas (12 Kb).

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