GSA rules out Conditional Access for Free-To-Air Television, GIBA welcomes the New Standard

Press Statement On The Revised Minimum Specification On DTT And DTH Receivers Which Rules Out Mandatory Encryption Of Free-To-Air Television Through A Conditional Access System

The Ghana Standards Authority (GSA) has published a revised standard on Digital Terrestrial Television (DTT) and Direct-To-Home (DTH) Receivers which makes Conditional Access System (CAS) non-mandatory for Free-To-Air Receivers. This will mean television broadcasters who have been authorised by the National Communications Authority (NCA) to operate in the Free-To-Air (FTA) category can continue to reach the general public without viewership restriction as required by the terms of their authorisation, which is consistent with the provisions of the 1992 Constitution of the Republic of Ghana, regarding media freedoms, human rights and the individual rights to information.

In the earlier press statement published in the Daily Graphic of 28^th May 2019, GIBA raised concerns about the Ministry of Communications (MoC)’s move to introduce a mandatory encryption of Free-To-Air television by means of a conditional access module for the purpose of collecting TV licence fees. This was a departure from the original draft policy which did not include a CAS. The concerns stemmed from the revision of the draft policy to the effect that the existing Ghana Standard on digital television receivers for Free-To-Air would be revised to include conditional access among other new features. For example, paragraph 5.4 of the policy indicated that even digital television sets already in Ghanaian homes and receiving digital channels cannot continue to receive signals from the DTT platform unless a Conditional Access (CA) embedded Set-Top-Box (STB) prescribed by the Ministry of Communications is acquired in addition.

The MoC did not countenance the legitimate concerns of the main industry stakeholder – GIBA, but proceeded to request the amendment of the previous standard (GS1099: 2014) to include a mandatory CA feature by its communication to the Ghana Standards Authority (GSA) which was referred to the GSA Technical Committee on Telecommunications and ICT Equipment Standards (TC 24) for consideration. It would be recalled that the MoC through the NCA published a notice in the Daily Graphic of 1^st and 2^nd April 2019 suspending the DTT conformance certification process to make way for the modification of the minimum specification (Conformance Regime) which was withdrawn by the same publication. The publication also placed a ban on the manufacture, sale, purchase and promotion of DTT Receivers already certified in conformity with the withdrawn specification. This publication which caused an uproar in the television industries amidst some legal challenges was eventually modified by means of an addendum allowing existing DTT operations to continue until another specification was adopted.

After several weeks of deliberation by the Technical Committee, the GSA globally published its report for public comments and indicated that some of the proposed amendments from the MoC were incorporated into the updated standard but the proposal to include a mandatory Conditional Access System (CAS) could not be incorporated because, among other reasons, the Committee did not find it appropriate to include that in a standard specification document for Free-To-Air television receivers. Following receipt of comments from industry stakeholders, dealers and world renowned manufacturers, the GSA proceeded to publish the final standard which has now been gazetted and is available for sale at the Ghana Standards Authority.

GIBA considers the exclusion of a mandatory CAS as a major victory for indigenous Ghanaian businesses which dominate the FTA sector. The proposal from the MoC to encrypt FTA content had attracted considerable anger from the sector as the proposal would mean a tacit conversion of their Free-To-Air broadcast services into a Pay-TV model, controlled by a third party CA vendor and or the platform owner, allowing for the monetization of their contents, as proposed by the Ministry of Communications. As FTA broadcasting service providers, the Pay TV model will only project dwindling advertising revenues, as the blocking of contents would result in the reduction of viewers accessing the FTA service.

This culminated in the airing of a public service campaign by GIBA informing the public of the unholy obstinacy on the part of the MoC and the latter’s resolve to go ahead with the destructive policy which would also deprive the poor Ghanaian of access to information. GIBA maintained that the public service campaign which sought to show the policy shift of the MoC was necessitated by the MoC’s refusal to engage with the major stakeholder in the industry and to take account of its input. The campaign was subsequently suspended through the intervention of the Parliamentary Select Committee on Communication upon the promise of facilitating engagement with the MoC to ensure that GIBA’s concerns were addressed.

As was revealed in GIBA’s Press Statement of 28^th May 2019, there are official correspondence confirming that the policy shift to introduce CAS was predicated on conversations between the MoC and a media business interest called Inview Technologies, known for partnering African government officials to make money off existing media establishments to their disadvantage, and tactfully making the government of unsuspecting African states to cough up huge sums of tax payers funds for the purchase of Set-Top-Boxes (STBs) with CA keys, in their control by default, for the trading of their numerous advertising services, without any investment in infrastructure nor acquisition of authorization from authorities such as the NCA. The said correspondence showed that the Minister of Communications, Mrs. Ursula Owusu-Ekuful handpicked Inview Technologies, and had discussions with them about their launch of “FreeTv Ghana” which ironically would require Ghanaians to pay for reception of Free-To-Air channels such as TV3, GhOne, TV Africa, Crystal TV, Adom TV, UTV, JoyNews, JoyPrime, etc., all of which Ghanaians (more than ninety five percent) have always relied on for information and broadcasting services for free. Inview Technologies is a UK company, registered locally in some African countries and Mr. Andy Townend was introduced by the Hon. Minister of Communications as the local representative of Inview Technologies, from the mother company.

GIBA has made well researched proposals on alternatives to raise revenue to fund public broadcasting and the DTT platform, that eliminated the need to encrypt FTA television and which entailed no administrative cost for the collection, in sharp contrast to the proposed use of a CA model, for the collection of TV licence fees but the Ministry of Communications has paid no heed.

With the publication of the Revised Standard GS1099: 2019 by the Ghana Standards Authority, GIBA is confident that the previous Conformance Regime for the Certification of Receivers of Free-To-Air Digital Terrestrial Television would be revised by the NCA to reflect the tenets of the new standard. The MoC would also be expected to commence a process to revise the DTT Policy to align with GS1099: 2019 and to engage the television industry about the digital migration which has long been stalled because of the efforts to introduce a CAS.

What is new about GS1099?

The revised GS1099: 2019 published in August 2019 has expanded its scope to now cater for Direct-To-Home (DTH) digital satellite television in addition to DTT which was the sole subject matter of the earlier standard. This also allows combo decoders (a hybrid of DTT and DTH digital television receivers) to be covered. Until now digital receivers for DTH satellite television in Ghana had been largely unregulated. Operators in this category did not have to apply for equipment type approval and certification because there were no published minimum specifications to guide such a process. The National Communications Authority (NCA) will now be expected to put in place appropriate processes for the implementation of a type approval regime for both DTT and DTH Receivers.

The revised standard also introduces a new minimum requirement of HEVC (High Efficiency Video Coding) for HD (High Definition) digital receivers. HEVC, also known as H.265 and MPEG-H Part 2, is a video compression standard, designed as a successor to the widely used Advanced Video Coding (AVC, H.264, or MPEG-4 Part 10). In comparison to AVC, HEVC offers from 25% to 50% better data compression at the same level of video quality, or substantially improved video quality at the same bit rate.

Other changes made to the standard include an upgrade of the flash memory, a revision of the frequencies for Ku band and C-band, an addition of L-band frequencies and a revision of DTT modulation and transmission parameters.