No. 312 (October 2007)
Technological neutrality and service neutrality
The terms “technological neutrality” and “service neutrality” are frequently used by regulators and particularly by the European Commission. In the real world, “neutrality” is often perceived to be a good idea: indeed, some countries, such as Switzerland, have historically followed the principle of neutrality. As no regulator would want to be accused of being biased, most regulators try very hard to be “neutral”. But what do people mean by “technological neutrality” and “service neutrality”?
The policy of “technological neutrality” is simple to explain: regulators should let the market decide which technology should be used for a particular purpose.
Surprisingly, this policy is relatively new in Europe! In the 1950s and 1960s, the development of TV in Europe was hampered by arguments over technical standards. Each country felt that it was their sovereign right to choose technical standards that were different from their neighbours, thus resulting in a confused mixture of incompatible TV standards (e.g. 405, 819 and 625 lines, PAL and SECAM, analogue stereo and digital stereo).
Were the decision-makers aware that “national standards” would act as barriers to trade – or, at least, make it difficult to watch TV services from other countries? Regrettably, the answers are “yes” and “yes”! Some national Governments selected colour TV systems that were subtly different from their neighbours (e.g. variants of the PAL system with different frequency separations between vision and sound carriers). Why did they do this? One very simple reason was that they wanted to favour their indigenous electronics manufacturers by erecting barriers to trade. Eventually, manufacturers in various European countries came to the conclusion that the multiplicity of national standards had failed to protect them against the severe competition from foreign manufacturers (mainly from Japan). Furthermore, they realised that the multiplicity of national standards made it difficult for them to export to other countries. In fact, they decided that the previous policy was actually harmful to their interests!
Despite this experience, industrial objectives have long dominated European thinking about technical standards for TV. In the mid-1980s, there was a strong push for a single European standard for satellite TV – to gain broad acceptance, it had to be different from all of the existing standards. The chosen standard, called MAC, gained support from the EC and from many national governments. Although MAC was listed in the 1986 TV Standards Directive (86/529/EEC) as the mandatory standard for broadcasting satellites, it has now disappeared from view.
Things got even more confused in 1986, when it seemed that the USA would adopt the HDTV standard developed in Japan. This prospect was a source of great concern to many Europeans, who felt that Europe must have its own standard for HDTV – so as to avoid becoming dependent on foreign technology. Their solution was HD-MAC, which was ingeniously based on the MAC system. In essence, HD-MAC transmissions provided two inter-twined versions of the broadcast programme: a standard definition version for MAC receivers and a high-definition version for HD-MAC receivers. In practice, the presence of the HDTV information degraded the quality of the standard definition signal. This was a fatal flaw because, initially, most consumers would watch the standard definition version of the HD-MAC signal and it was obviously unreasonable to expect them to watch poorer quality pictures simply so that a few viewers could watch HDTV. Even worse, although the HDTV pictures were very attractive, HDTV receivers and displays would be so expensive that there would be little or no consumer demand for HDTV. Nevertheless, HD-MAC was heavily promoted by the EC (e.g. Directive 92/38/EEC) – until it became obvious that much better technology (i.e. digital TV) was on the horizon. In reality, HD-MAC never left the laboratory.
Digital TV offered a real opportunity for Europe to avoid multiple standards. There was no need to worry about offending those countries using their own national standards – because nobody was using digital TV. As everybody seemed to agree that harmonised standards provided real benefits for all players in the broadcasting value chain (including consumers), the European Digital Video Broadcasting (DVB) Project was established in 1993. Today, this consortium has more than 300 members, including broadcasters, manufacturers, network operators, software developers and regulatory bodies. DVB standards for satellite, cable and terrestrial TV services have been adopted throughout the world. During the mid-1990s, regulators began to recognise the benefits of being technologically neutral: in practice, regulators did not need to impose standards for digital TV because the cross-industry membership of the DVB Project meant that industry could choose its own standards – without regulators or politicians having to pick winners!
Nevertheless, Governments were still concerned about the possible emergence of multiple broadcasting standards – which would clearly not be in the interests of consumers. As a result of such concerns, in 1995, the EC issued Directive 95/47/EC which stated “All television services transmitted to viewers in the Community whether by cable, satellite or terrestrial means shall . . . . . if they are fully digital, use a transmission system which has been standardized by a recognized European standardization body.” Note that, from the EC’s perspective, there are only “three recognised European standardization bodies”: CEN, CENELEC and ETSI. The inherent assumption was that the relevant standardization body (ETSI in the case of transmission systems) would avoid multiple standards for the same application. Unfortunately, this assumption was undermined by the fact that, during the 1990s, the standardization bodies also recognised the benefits of technological neutrality. If there are several competing technologies for a given application, it is much easier for the standards-setting bodies to standardize all of the candidate systems. Some might argue that standardization is all about making difficult choices – but the conventional wisdom is now that choice of standards should be left to the market (and, hence, not determined by standards bodies).
By the late 1990s, technological neutrality had become a central feature of the EC’s policy on regulation of telecommunications services, including broadcasting – and this was confirmed by the 2002 Framework Directive (2002/21/EC) which repealed the 1995 Directive that required digital TV transmission systems to conform to European standards.
Given the strength of the EC’s commitment to technological neutrality, it was surprising to hear Commissioner Viviane Reding’s announcement at CEBIT in March 2007 supporting DVB-H as the preferred standard for mobile TV in Europe. Even more surprising was her statement in a press conference that, if European industry failed to reach agreement by July 2007 on a single standard for mobile TV, she intended to mandate the use of DVB-H. In July 2007, the EC issued a Communication (COM(2007)409) entitled “Strengthening the Internal Market for Mobile TV” which confirmed the EC’s preference for DVB-H by stating “DVB-H appears to be the strongest contender for future terrestrial Mobile TV deployment in Europe”. Although the prospect of mandating a single technology is no longer imminent, it still remains an option for mid-2008 – as can be seen in the following extract:
The Commission will:
This breach by the EC of its long-standing policy of technological neutrality (and its willingness to mandate a single technology) is astonishing because, just a few months earlier on 4 December 2006, Commissioner Reding gave a speech at the ITU Telecom Conference in Hong Kong which included the following passage:
“If we look at Mobile TV standards, there are already a number of accepted alternatives vying for position. Which one is best? . . . . I believe it should be up to businesses to define attractive business models that will entice consumers to opt for the standard they like best. Governments are not usually best placed to decide between competing technologies. We know that the choice of the wrong standard can lock our economies into long periods of economic underperformance, while market led solutions have consistently provided a much better environment for technology selection.”
Are we now moving back into era in which politicians will pick winners? Time will tell, but I sincerely hope that technological neutrality will remain as a fundamental principle of regulation of telecommunications services.
"Service neutrality" is a more recent concept than technological neutrality – and slightly more difficult to define. In essence, it implies that regulators should encourage more flexible use of spectrum by allowing ANY frequency band to be used for ANY type of service. Imagine that you are the exclusive licensee of a particular frequency band in a given area and that your business requirements have changed and thus you have more spectrum than you require. In the past, you would probably have simply relinquished the excess spectrum to the regulator – who would then charge you lower licence fees in subsequent years. In the future, you might be able to sub-license your excess spectrum to another user – possibility generating more income than the licence fee charged by the regulator. Such spectrum trading would be encouraged by the concept of service neutrality – and, ideally, spectrum usage would automatically migrate towards the applications that have the highest economic value.
At present, most spectrum usage is defined by frequency tables, such as those published in the ITU Radio Regulations, which allocate frequency bands to specific types of service, such as broadcasting, fixed, land mobile, maritime mobile, aeronautical services, radionavigation, fixed satellite (space-earth), fixed satellite (earth-space), etc. Taken to its logical extreme, service neutrality implies that such frequency tables are old-fashioned and unnecessary. I have heard various economists state that there is no scarcity of spectrum and that the real problem is that there are too many engineers involved in spectrum management!
Obviously, economists are very clever people – but, before accepting such arguments, we should ask “Why do we have frequency tables?” The answer is very clear: interference issues are generally much more manageable if similar services are grouped in specific frequency bands. Some services, such as aeronautical services or radio astronomy, require very high levels of protection against interference. On the other hand, some services (such as radar) can tolerate fairly high levels of interference – but the high peak powers used by radar transmitters means that other services cannot readily share spectrum with radar services. In recent months, there has been much discussion about the potential use of the digital dividend (i.e. the spectrum that can be released when analogue TV services are closed down). For example, it has been widely suggested that mobile phone services could be accommodated within UHF Bands IV & V (470 – 862 MHz). The CEPT is currently studying the problems of interference between TV services and mobile phones: the work is not yet complete, but it is clear that interference would be minimised by having different types of services in different sub-bands – in effect, exactly the opposite of service neutrality!
Economists often try to dismiss interference as a trivial issue. It is important to recognise that the transition to digital TV dramatically changes the impact of interference. Interference to analogue TV was easily identified by non-technical members of the public because it caused visible patterning on the screen or audible interference to the sound. Digital TV receivers usually operate very close to the threshold of failure, unlike analogue TV receivers which typically operate at 30 dB above the failure point. Consequently, interference is often catastrophic on digital TV services. Furthermore, interference to digital TV generally causes the screen to freeze or go blank – unfortunately, these symptoms are identical to those caused by failure of the transmitter, faults on the receiving aerial or cable down-lead or, more usually, by software crashes within the digital TV receiver!
If your digital TV reception fails frequently due to interference from a nearby mobile phone, you may be able to diagnose the problem if the mobile phone is being used by someone else in your home. But how would you solve the problem if the interference is being caused by somebody in your neighbour’s home? Those lucky enough to have a spectrum analyser at home might be able to spot the problem – but, to my knowledge, very few members of the public have the appropriate equipment or technical ability (even if they are highly-qualified economists).
In summary, "technological neutrality" should be strongly encouraged, but my concern is that interference could kill the superficially elegant concept of "service neutrality".
Philip Laven
ex-Director
EBU Technical Department
18 October 2007
Footnote
Philip Laven decided to "retire" from his post as Director of the EBU Technical Department at the end of August 2007 and return to the UK. Nevertheless he is still very much involved in EBU and EBU-related work (DVB, WorldDMB, ETSI ...).
He has been succeeded by Lieven Vermaele, formerly with VRT in Belgium.
The Technical Review would like to thank Phil Laven for his excellent Editorials and support over the last ten years. At the same time, the Technical Review welcomes Lieven Vermaele to the fold. He will be taking over the Editorial slot from the next edition onwards ... and like Phil Laven before him, has become Editeur Responsable of the Technical Review.
Mike Meyer
Editor
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