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IPO submission on digital migration strategy
13 April 2007 at 11h08

Indra de Lanerolle and Mark Rosen made a submission to the Department of Communications on behalf of the IPO on the Draft Broadcasting Digital Migration Strategy  and Implementation Plan for South Africa

The following points were made:

1.

The IPO is of the view that while intellectual property rights need to be protected, the DOC is requested to take into account, both the income and expenditure streams in relation to stakeholders in the production industry.  In that regard, the DOC should be cautious not to implement any strategy which would have any negative effects on the earning capacity of producers and growth of the local content production industry during digital migration.

2.

The IPO agrees that digital broadcasting is dependent on a restructuring of the market and the industry.  In this regard, the DOC is requested to take into account the role of the independent production sector as key stakeholders in relation to the income streams which will be open to producers once the "making available" rights become part of our legal framework. 

3.

The IPO wishes to debate openly, matters relating to quotas of South African content on South African television.  This is important as growth in the industry is dependent in part upon commissioning, purchasing and licensing of content, but also upon the requirements that those commissioners are required to fulfil.  In that regard the IPO believes that the role of ICASA in determining these quotas should be emphasised.

4. Finally, the IPO wishes to discourage any delays in the licensing of new subscription television services.  A number of potential entrants to the market who submitted applications in terms of ICASA's invitation to apply have committed significant resources in new local content and building capacity should they be licensed.  Delays to the end of 2008 and beyond would have the effect of stunting growth in the industry which had been identified as one of the key growth areas of the Accelerated and Shared Growth Initiative - South Africa (AsgiSA).  The IPO believes in a free and fair competitive environment and government needs to carefully interrogate any advantage which may be given to one broadcaster over any other potential broadcasters in relation to subscription services which would limit the growth and development of the industry.  Again, the IPO believes that ICASA should be charged with fast tracking the issue of new subscription licences which will encourage competition, ensure growth in the industry and create stakeholder value.



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