BBC Executive response to BBC Trust request for clarification Project Canvas Executive Summary 1. Overview The BBC submitted its proposals for Project Canvas to the BBC Trust in November 2008 and the proposals were put forward for public consultation by the BBC Trust in February 2009. A number of issues were raised by stakeholders, and further to this the BBC Trust has requested further information from the BBC and its partners. We welcome the opportunity to directly address and resolve specific questions and are confident that this submission tackles the key points raised. We believe that there is strong and growing endorsement for the vision and strategy set out in February 2009 and that, if implemented correctly, a broadband connected TV platform, open to all content and service providers and application developers, is essential for UK consumers, UK PSBs, the wider creative industries, the horizontal market for consumer electronics equipment and the future growth of broadband in the UK. Canvas will set a new benchmark in UK media. The core principles that made Freeview and Freesat a success a simple consumer proposition, free at the point of use - are becoming more, not less important. But to protect these principles in a broadband environment requires a fundamental re-assessment of the concept of open platforms. The cornerstones of the Canvas proposal - a neutral venture, offering a common user experience - are intended to lower the barriers for content and service providers and application developers, democratising access to the television set and creating a simple, accessible environment to deliver value to the broadest possible range of UK consumers. In this response we address each of the areas where stakeholders have requested further information. In particular we set out: 1. Our support for pay services, including specific proposals on conditional access and DRM 2. The wide range of monetisation strategies enabled by Canvas, including internet based advertising, micropayments and subscription 3. Our detailed plan for industry engagement, building on proposals made by the DTG and including working with other bodies including the EBU and the OIPF 4. Details on the proposals for a common user experience, with detail as to how this enables flexibility for content and service providers, ISPs, platform operators and manufacturers 5. Specific proposals on access and business rules and how pay models will be enabled without compromising Canvas as a neutral venture 6. The BBC s commitment to a standards based approach for broadband connected television devices, including support for the development of a common technical specification with or without a Canvas user experience 7. Our developed thinking on the Canvas venture, including remit, eligibility criteria and governance framework
8. Limits to the remit of the Canvas venture that it will not own or aggregate content, set price points for devices or offer prominence to its members 9. The BBC s continuing commitment to its Syndication Policy to provide BBC iplayer beyond Canvas, including via non-canvas branded devices developed via the Canvas hardware specification 10. Articulation of the fit between Canvas and the planned launch of Freeview HD and BBC iplayer on Freesat We believe that these proposals will help enable creativity and business innovation, not least by releasing content creators from the high fixed costs of broadcasting including for example, truly local services across the whole of the UK. Our approach to the BBC Trust s request for more information has been to be as complete and direct as possible, to enable informed decision making by the Trust and to provide clarity on the detail of the application for stakeholders. The further clarification does not, in our view, reflect any change to the vision and strategy as set out in the initial application. We should however recognise that the Project Canvas proposal itself was expressed in terms of a request to engage with industry, therefore some of the information requested is subject to ongoing debate and discussion. We have highlighted areas where differing options are under consideration, indicating our best assessment of the route most likely to preserve the principles and objectives of the proposal. We are confident that with the further information published here, the consensus needed to unlock the future potential of the UK s existing free to air platforms can be achieved. Since the time of the application, the UK television market has evolved in a manner broadly consistent with the forecasts made at the time 1 : a burgeoning interest in the benefits of connected television; an expanding range of approaches to technology solutions, and the growing market share of UK ISPs who are also pay TV platform providers. The free to air market has not been dormant either, with HD on DTT on track for late 2009 and a range of providers, including Freesat, ready to offer single-servicebased on demand content to the set top box. In our view, these factors serve to underline not only the consumer value but also the timeliness of the Canvas proposals. With 2010 such an important year for switchover and HD, we welcome the BBC Trust s acknowledgement that the Canvas proposals require a timely response and we hope that the information collected here will enable the early publication of initial conclusions that mark the start of the next stage of the approval process. We have structured our response into five main sections, broadly consistent with the structure of the information request. These are: 1. Approach to the proposed venture 2. EPG and enabling access for content and service providers 3. Industry engagement and technical standards 1 See counterfactual put forward in the preliminary market impact assessment
4. Distribution 5. Fit with wider BBC strategy In each of the five sections, we reprise the original submission and the relevant stakeholder feedback and then provide an overview of how we see the proposals developing in line with the original vision and strategy, before turning to responses to the specific questions in each section. 2. Summary of further information by section Venture proposal The initial application sought to explain the rationale for a new Free to Air (FTA) platform venture and its importance in ensuring the future development of the existing platforms (especially Freeview). It explained that this venture would follow the principles of Freeview and Freesat in its incorporation, that the venture would not own or aggregate content rights and that it would exist largely to promote the agreed standard to consumers and industry. We also explained the ambition (beyond the scope of this proposal), to include Freesat within any new venture. In this response, we explore the specific roles and functions of the venture and contrast these with other parts of the value chain such as content providers and ISPs. We explain how the role of the Canvas venture extends to the management and updating of a device user environment in an evolution of the approach Freesat takes to the EPG today. We also offer more detail on how the venture will be governed, how its articles will ensure the delivery of the BBC s desired public purpose outcomes and set out the proposed criteria for membership, which potentially extends to PSBs, ISPs and TV platform providers. EPG and enabling access for content and service providers In the initial application we set out the importance of a consistent interface to reduce the barriers to entry for content and service providers and application developers and to deliver the proposed consumer proposition. We suggest that this is critical to protecting scale in the horizontal market for device manufacturers and advertisers and integrating broadcast and broadband services. This interface will be a key element of the overall Canvas consumer proposition and will ensure that content and services are easily discoverable to users. We also set out our ambition for a high level of compliance with best practice for accessibility and the intention that this interface will be customisable by users. This response clarifies the limits of the ambition of the Canvas user experience, explains options for device manufacturers and the potential flexibility for pay platform providers, ISPs and other parties who may seek to retail Canvas devices directly. This includes the proposed common approach to DBook 7, making the deployment of a Canvas UX (linked to the trade-mark) an option for device manufacturers and platform providers. The response goes on to describe how Canvas devices will support a wide range of monetisation options, including targeted advertising, micropayments and subscription and how these will be supported, including the approach to conditional
access, DRM, data management and billing. In each case the response reflects the intended openness and consistency of the platform and user interface - and the objective that the venture becomes neither a gatekeeper nor a competitive bottleneck. The response also sets out the likely relationship between the Canvas venture and content and service providers, describing in detail how Canvas business rules will seek to maintain an open environment, including transparent rules for prominence of content where appropriate. Industry engagement and technical standards The Canvas proposal is in part a request that the BBC engages with industry to help develop a technical specification for broadband connected television devices. The BBC has a long history of sharing its research and development with the industry and of developing and standardising approaches to broadcast technology issues. This proposal differs from the BBC s usual approach in that it formalises the request for further engagement, recognising the range of stakeholder interests and the complexity of the technologies involved. In this response, the BBC sets out the areas of technical development to date, the work completed with partners, the engagements with national and international standards bodies and the ambition to share all such work with the wider industry in a programme of staged engagement. It sets proposals for industry engagement following discussions with the DTG Executive and a proposed workplan for 2009/10 alongside work with a range of bodies including OIPF and EBU to bring a globally scalable specification to market in the UK in 2010. Distribution The Canvas application includes a range of proposals to mitigate the potential load of rich video traffic on the UK s networks and to enable business opportunities for ISPs that support the Canvas standards. These include device mitigation solutions such as local storage, and the proposal that the Canvas trade-mark is made available to any ISP able to offer a minimum level of quality delivery to customers. These proposals have been developed further in conjunction with UK ISPs and this response offers more details, setting out the principles behind a Canvas quality standard and how this will be managed and accredited, including via both managed and over the top routes. The responses also set out the partners response to questions arising from the involvement of BT in the proposals and a commitment to ensuring plurality of supply. Fit with wider BBC strategy The Canvas proposal is a core part of the BBC s wider digital strategy, including its commitment to support the take-up of broadband and the evolution of the UK s free to air TV platforms. The initial proposal described the ambition to link the launch of Canvas with the arrival of HD on DTT, ideally by synchronising consumer marketing in early 2010.
This document updates on BBC strategy in this area, in particular the BBC s ambition, shared with ITV, to ensure that Canvas is aligned with plans for the launch of Freeview HD, by ensuring clear consumer messaging and promoting transparency in planning for manufacturer partners. We also reassert the BBC s commitment to its syndication strategy 2 and describe how Canvas relates to the planned launch of BBC iplayer on Freesat. The response also sets out how the Canvas proposals build on the return path specification being evolved from that included in the DVB-T2 standard, to unlock more value for consumers, content and service providers and manufacturers. 2 http://www.bbc.co.uk/bbctrust/assets/files/pdf/consult/ondemand_syndication/policy.pdf