On 19 December 2019, France’s National Broadcasting Authority (CSA) solicited Arcep’s opinion on upgrading the digital terrestrial television (DTT) broadcasting platform. This request for an opinion was part of the public consultation that CSA launched on 16 December of last year , whose purpose was to take stock of the work that had been done since 2017, to prepare for the future development of DTT in Metropolitan France. Arcep welcomes the invitation from CSA to be part of this work, and to have the opportunity to set out some of the general points of inquiry surrounding this DTT platform upgrade endeavour.
Today, CSA is publishing a summary of the contributions received to its public consultation, and Arcep is taking the opportunity to publish its opinion on the matter.
Arcep adopted this Opinion on 25 February 2020, before the public health crisis caused by the Covid-19 epidemic. The opinion therefore makes no reference to this unusual situation. During the lockdown, while DTT enabled millions of people to continue to access television services, consumption of non-linear services, and video on demand (VoD) in particular, rose significantly.
Planned upgrades to the DTT platform will affect the other broadcasting platforms
If the DTT platform plays a prominent role in the audiovisual media sector and the distribution of its content, it operates alongside other, by now well established technological broadcasting platforms, such as wireline telecoms (ADSL and fibre), cable and satellite networks, and over-the-top (OTT) services delivered via the internet, which are found in most homes today.
As a result, any discussions over the future shape of DTT must take its inclusion in a broader context into consideration. This is especially true when it comes to any changes to technical standards (codecs, etc.), as all of the players that may be affected by the consequences of these developments must be given the opportunity to be associated with them. In addition, any data-related issues (e.g. regarding targeted advertising) need to be addressed by taking their use on all of the different platforms, media and devices into account. By the same token, to have a detailed overall view of the market, it is vital to consider the relationships between all of the players on these different platforms, beyond just the relationship between ISPs and content providers.
The project to upgrade DTT is set against the dramatic change in the way people view audiovisual content, which means placing it in a broader economic context for the different stakeholders.
These major changes enable content providers to broadcast their programmes on new technological platforms, and now endow them with real power when negotiating with DTT broadcasters. It is with these elements in particular in mind that Arcep concluded that competition regulation that applies only to digital terrestrial TV broadcasting , which it has been enforcing since 2006, must come to an end. An extension of the fourth round of Arcep regulation, combined with commitments from TDF, was thus designed as a useful transitional period before this regulation is phased out at the end of this year.
The opportunity afforded by this upgrade project should also be addressed through the lens of a cost-benefit analysis for all of the players concerned, taking into account the uncertainties over how long the operational benefits gained from the platform’s upgrade will last. Here, Arcep welcomes CSA’s questions over the costs tied to this work.
Another point that could be explored is the possibility of giving content providers greater flexibility in how heavily they use the DTT platform. The freedom given to content providers by releasing them from some of their current obligations could have an influence over the audiovisual regulation model as a whole. This is why it cannot be granted without strict oversight by CSA, to ensure both economic equilibrium and a level of coverage that is as ambitious as the one currently provided by DTT alone.
Closer collaboration between Arcep and CSA on digital issues, through a new joint division
Lastly, TV channels will become increasingly dependent on a vaster ecosystem that includes, for instance, ISPs and device suppliers. The developments affecting the audiovisual sector – and by extension the telecoms sector – that are currently underway will bring CSA and Arcep to work more closely together on digital issues. The joint division they created not long ago will be a useful channel for undertaking this work.
 A summary of all of the contributions received, as well as the complete non-confidential contributions received from stakeholders and Arcep’s opinion are being published together, and are available on the CSA website
 Referred to as Europe’s “market 18”