02. 12. 2010

ANEM participation in public debate on bylaw for the implementation of the digitalization process

Public Consultation on Draft Regulations on the transition from analogue to digital broadcasting of radio and TV programs and access to multiplex

The process of digitalization is a very important transition process for the electronic media. The Strategy of transition to digital broadcasting of RTV programs in the Republic of Serbia envisaged April 4, 2012 as the date of the transition of the TV programs while the Action Plan sets out the activities of all relevant authorities and institutions in this process. One of the important preconditions for successful implementation of digitalization is to create appropriate legal framework, and within it the passing of relevant bylaws envisaged by the Action Plan. The Regulations on the transition from analogue to digital television broadcasting and access to multiplex in terrestrial digital broadcasting is one of the most important documents. Therefore ANEM, representing the interests of its members, participated in Public Consultations on the Draft Regulations, which was conducted by the Ministry of Telecommunications and Information Society (MTIS).

ANEM submitted to the said Ministry its suggestions and comments on the Draft regulations on December 2, 2010. General suggestions are the following: it is necessary to clarify who is authorized for the preparation of the Draft Regulations - MTIS or the Agency for Electronic Communications (RATEL), as well as to inform the public about whose this Draft Regulations actually is; it is unacceptable to reduce the guaranteed minimum of the flow from 3 Mbps to at least 2 Mbps on a single television program as well as the failure to establish the principle of distribution of potential additional available space in the multiplex is also unacceptable; the solution, where RATEL prescribes the conditions and procedures for issuing broadcasting licenses after the transition to digital broadcasting with its regulating act is unacceptable, since the license issuing is in the competence of the RBA and is regulated by the Broadcasting Act; it is unacceptable to impose the obligation to all broadcasters to participate without compensation in the promotion of the process of transition from analogue to digital TV program broadcasting.

In its letter, ANEM suggested to the Ministry that was necessary to harmonize the Draft Regulations with other set of rules and conduct additional consultations with other interested parties, in order to avoid the adoption of the Regulations that would be inapplicable.

ANEM letter (available only in Serbian) to the MTIS is available here