Media Monitoring Africa (MMA) and the SOS: Support Public Broadcasting Coalition (SOS) note the announcement made at yesterday’s cabinet briefing concerning the long-awaited broadcasting digital migration.
MMA and SOS wish to commend the commitment made by cabinet to provide FREE Set-Top-Boxes (STBs) to 5 million TV-owning households in South Africa. We welcome this decision and consider it a victory for the public. MMA and SOS have been among a small handful calling for free STBs to encourage take-up of the new technology, particularly for economically vulnerable households, and speed up our migration process. We, however, need further details on who will be prioritized for these free STBs, and what process people will have to go through to access them.
We are mindful of the draft subsidy scheme proposed by the Universal Access Agency of South Africa (USAASA) and the fundamental changes cabinet’s announcement of free STBs, yesterday, makes to it. We also note the deficiencies of the proposed subsidy scheme which include:
• The definition of poor households was set too low at households earning R3200 pm. We believe it should minimally be expanded to the upper-bound poverty line of R4500 pm and even further expanded to cover emerging middle class households earning up to R12000pm.
• In their proposals, USAASA and the Minister of Communications referred to a prescribed means test in order to access STBs. We remind both that the people of South Africa must not be subjected to complicated, expensive and humiliating processes of proving that they are poor. We have outlined in great detail ways in which government must streamline the process of accessing STBs by providing for automatic qualification criteria as well as close cooperation between the Department of Home Affairs, the Social Assistance Agency of South Africa, the SABC’s TV Licenses Division and the South African Post Office.
While MMA and SOS welcome government’s inclusion of STB control, we remind government that the control mechanism cannot and must not be used to cut people who, for any reason, do not pay their TV licenses as this would be unconstitutional in its restriction of their right to access to information. Further, we maintain that STB control alone is not enough, but must be complemented by encryption and conditional access in order to promote meaningful universal access and media diversity .
Certainly, STB control will help protect the STBs from theft and unlawful sale, thereby securing public investment into their manufacture and distribution. However, we remind government protecting public investment into the STBs is not limited to protection from theft alone, but also protecting the market from being flooded by “grey import” STBs.
Without signal encryption, there is no in-built mechanism to prevent non-conformant “grey-import” STBs from working in South Africa. As was evidenced in Mauritius’s own digital migration, signal encryption is crucial for ensuring that end-users are guaranteed uniformity of service. Let us eschew arrogance and exceptionalism and learn from the mistakes of those who have come before us.
Encryption will also have the effect of giving free-to-air broadcasters the opportunity to access international high-quality premium content that will attract the viewing public and keep free-to-air broadcasters viable in the digital age.
Moreover, without conditional access, there will be no STB interoperability, and end-users will be forced to buy decoder after decoder at prohibitive costs if they want to access broadcasting services additional to free-to-air. Further, “no conditional accesss presents a barrier to entry for new players, and maintains Multichoice’s market dominance in the broadcasting sector as well as its de facto monopoly in the pay-TV space.
Free set-top boxes is only half the victory, and while we await further detail from the draft policy yet to be gazetted, there remain a number of key battles to secure meaningful access to broadcasting services in the digital age. To this end, we call on the Minister of Communications to give evidence-based answers to the following questions at Tuesday’s DTT readiness briefing to Parliament as well as to the television viewing public who will be directly affected by this decision:
• What framing principles informed cabinet’s turn-around on its 2013 position on STB control, conditional access and encryption?
• What evidence did Cabinet consider in the cost-benefit analysis behind its decision, and when will that evidence be made available to the public who deserve full transparency in one of the most significant infrastructure projects South Africa has ever undertaken?
• Without encryption, how will public investment and uniformity and quality of service be protected from non-conformant “grey imports” that already exist in the market?
• Without conditional access, how will barriers to entry for new broadcasters in the digital environment be overcome and interoperability be achieved?
At the heart of our concern is that without conditional access and encryption, South Africa is headed on a course wherein like the two nations precipitated by our colonial and apartheid past and the prevailing gross inequalities we see in South Africa today, even broadcasting services on which the majority of our people rely will be divided into a free and inferior service for the poor and a high quality service accessible only to the rich who can afford it.
For further information please contact
Coordinator: SOS Coalition
076 084 8077
Director: Media Monitoring Africa
082 887 1370