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Digital Terrestrial Broadcasting in Hong Kong Consultation Paper

19 February 2001

Information Technology and Broadcasting Bureau
1/F-2/F
Murray Building
Garden Road
Hong Kong

Dear Sirs,

We are pleased to have the opportunity to comment on the Digital Terrestrial Broadcasting in Hong Kong Consultation Paper.

We do not propose to comment on the recommendations proposed in the Consultation Paper on an item by item basis, but where we have made no response to any recommendation proposed in the paper, you may assume that the Hong Kong Democratic Foundation is in agreement.

Before we set out our responses on specific issues raised in the Consultation Paper, we would like to make some brief comments on the implications of the future potential availability of broadcasting services. These are of relevance to some of the views we have formed on the Consultation Paper’s recommendations.

With a potential of the availability of over 200 and up to more than 260 channels, we have concerns whether these could be sustained on a viable economic basis by a population of the size of Hong Kong’s of which well over 90% are Cantonese speakers.

These concerns have been further reinforced by the decision of HKDTV Ltd not to take up the domestic pay television programme service license recently granted to it. Our concern is further heightened by the fact that the ultimate parent company of HKDTV Ltd is one of the largest multinational media groups with considerable experience world-wide in TV broadcasting. It is also the second time within the last couple of years that this group has failed to proceed with a broadcast license granted to it for Hong Kong, the previous occasion being in respect of a VOD broadcast license.

Furthermore, we note the Government’s failure to call for applicants for programme licenses for the Broadcast Satellite Channels allocated to Hong Kong by the end of 2000, as originally indicated. We therefore wonder whether this is an indication that the Government might also be concerned of possible over-supply of broadcasting services.

Choice of DTT Standard 4.12
We would suggest that it might be prudent for the Government to wait to review the DTT standard to be issued by the Mainland before reaching any final conclusion on the standard to be adopted in Hong Kong. We believe such a delay can be tolerated in view of the large increase in broadcasting service provision during the next eighteen months that will result from the recently awarded four domestic pay television programme service licenses.

Separate Licensing 5.7
We agree with the Consultation Paper’s recommendations that the "separate licensing" approach be adopted.

1. Based on our concerns on possible over-supply of broadcasting services, we would

Recommend that a minimum of three multiplex licenses be issued initially and that they all be Multiple Frequency Network. Further more two of these licenses should carry the obligation to provide up to 50% of the channel capacity for each of the existing terrestrial broadcasters. However, should there be a good response in terms of the number of applicants for licenses, then the number to be offered could be increased from the proposed three to up to as many as the maximum six available at this time.

2. In view of our recommendation in paragraph (a), we would propose that applications in this round be limited to one multiplex license only.

Restrictions on Television Programme Service License Categories 6.7
Since there will be a very significant increase in broadcasting service provision during the next eighteen months, we do not see any reason to limit the licensees to the provision of services in just the "domestic free television programme service" and "domestic pay television service" categories.

Allocation of Capacity for Telecommunications 6.12
While the 25% of multiplex capacity ceiling for additional services seems reasonable, we would suggest that the relevant licensing authority reserve discretion to allow license holders to increase this to 50% of multiplex capacity should circumstances justify in due time. We make this proposal as it is our view that, with advances in technology and given the seeming very adequate availability of alternative broadcast delivery technologies, it may well be desirable to enable greater use of multiplex capacity for additional services.

Digital Audio Broadcasting
We are in agreement with the recommendation that introduction of digital audio broadcasting should be delayed until cost and other market considerations become more favourable.

Yours faithfully,
Hong Kong Democratic Foundation

George Cautherley
Vice Chairman