Industry perspective on proposed amendment of BDM Policy


The South African Communications Forum (SACF) has released the following
statement regarding its recent submission on the proposed amendment of the
Broadcasting Digital Migration Policy (“New BDM Policy’).

The statement reads: “The SACF fully supports the continued mandatory
inclusion of a control system in all set top boxes to be sold in South Africa as
outlined in the policy. The SACF believes there may be some misunderstanding of
what was actually decided by Cabinet as set out in the New BDM Policy.

Although the use of the control system by broadcasters is not mandatory, all Set
Top Boxes (STB) sold in South Africa will have to comply with the South African
Bureau of Standards (SABS) standard which includes a requirement for a control
system – both in the retail and subsidised market.

SACF believes that the inclusion of a control system in the STB will promote
industrial development, consumer protection, job creation, access to information
and Black Economic Empowerment.

Currently SACF represents six Set Top Box Manufacturers in its Industrial
Development Working Group, all of which have significant black ownership and
have been certified at level 2 or 3 for Broad Based Black Economic

SACF formed an Industrial Development Working Group as we recognise the
importance of building a sustainable Electronic Industry Manufacturing base in
South Africa. We believe that this is one of the strongest reasons why the South
African Cabinet decided to maintain the requirement for a control system as
outlined in the New BDM Policy.

Inclusion of a control system will support all local STB Manufacturers (including
members of the Industrial Development Working Group) and prevent dumping by
foreign vendors of products that would have negative impact on consumers’
experience of digital migration.

The STB industry is expected to create 23,500 direct and indirect jobs. From a
long-term perspective, without a control system, South African electronic industry
manufacturers would not be able to use Digital Migration to create sustainable
growth and ultimately thousands of jobs will be lost.

Currently South African STB manufacturers are operating at less than 40%
capacity and to open the South African market to a flood of imports will be
detrimental. With the five-year delay in the commercial launch of Digital
Migration, the STB manufacturing industry has taken a serious financial knock.
They estimate their collective losses to be in excess of R50m while they waited
for the commercial launch

The continued inclusion of a control system in the New BDM Policy also means
faster access to the Digital Dividend – the primary goal of digital migration. Only
once digital migration has been successfully launched and concluded will this
important spectrum be released to boost internet access and penetration in
South Africa.

If the Government had decided to drop the control system altogether then the
SABS standard would have to be changed – at minimum this would further delay
the launch of Digital Terrestrial Television migration by six months to a year. STB
control is mandatory under SANS 862. Recently this standard was amended –
however the language relating to the control system remains as previously

Inclusion of a control system as outlined in the New BDM Policy will also better
protect the interest of consumers. First and foremost, stolen or misused STBs,
which were purchased by the Government, can be remotely disabled. On its
own, this will eliminate major potential losses, as well as protect the consumer
by reducing the value of a stolen STB to zero.

Importantly this New BDM Policy will also protect consumers from grey goods
which have caused enormous audio, video and other problems experienced by
consumers in other countries in which they have been allowed, such as in
Mauritius. Consumers will be protected since manufacturers will only be
authorised if their offerings fully conform to local standards.

The inclusion of a control system will also support the provision of internet
access on the STB that was, itself, a subject of debate and controversy. The
strong motivation for the inclusion of the so-called “return path’ for internet
access is that various departments of Government will be able to communicate
their services and messages to TV households.

The control system, as a broadcast operator’s management tool, completes the
efficacy of the e-Government services to be offered. Once implemented, the
operator would be able to send “targeted messages’ to which a connected
household would be able to respond accordingly.

Broadcasters have a choice as to whether or not to use the system – either now
or at a later stage in the future. In our view it might have been better to keep
the previous policy in place so that the use of a control system in the STBs be
required across the board.

However we have appreciation for the difficulties that Cabinet faced in trying to
balance competing interests in changing the policy. Competing interests have
been intransigent in trying to resolve their differences and the delay in launching
digital migration has had tremendous negative impact across the Information
and Communications Technologies (ICT) industry, including delaying the use of
the digital dividend in South Africa. The approach taken will however enable the
Government to recoup the cost of inclusion of the control system from those
broadcasters who use it.

The SACF fully considered the Broad-Based Black Economic Empowerment
(“BBBEE’) implications of implementing the control system and has been an
advocate for lowering the bar, so that the control system implementation does
not become a hindrance to emerging and new entrant manufacturers gaining
experience in manufacturing STB in South Africa. Government’s approach caters
for emerging entrepreneurs in ways that are consistent with government’s
BBBEE policies, legislation and regulations.’


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