Written evidence submitted by Arqiva (CISDC0007)

Arqiva Consultation Response – Scottish Affairs Committee

Connectivity in Scotland: Digital Connectivity

About Arqiva

Arqiva is a leading UK communications infrastructure provider operating at the heart of the UK broadcast industry, enabling universal access to free-to-air television and radio services, reaching over 98.5% of the population.

Our transmission network delivers Digital Terrestrial Television (DTT) and radio, ensuring resilience, reliability, and choice for audiences across the country. Arqiva holds two of the three national commercial DTT multiplex licences, operates two national commercial digital radio multiplexes, and manages multiple local DAB licences. These services remain essential for cultural cohesion, emergency messaging, and universal access - regardless of age, income, or technical ability.

Beyond broadcast, Arqiva connects over 10 million smart meters in the water and energy sectors and has a long-standing commitment to delivering and maintaining Critical National Infrastructure (CNI), hosting multiple government, mobile, emergency services, transport, and telecoms contracts operated via third parties. It also operates a range of ground satellite dishes supporting Direct-to-Home (DTH) TV and are a leading independent reseller of satellite capacity, with a growing presence in Low Earth Orbit (LEO) up-linking.

Executive Summary

Arqiva welcomes the opportunity to respond to the Committee’s ‘Connectivity in Scotland: Digital Connectivity’ inquiry. As the UK’s leading provider of universal broadcast DTT and AM/FM/DAB radio services to over 98.5% of the UK, our response is primarily focused on Question 3: ‘What are the knock-on impacts to transitioning to digital services for those in Scotland’s rural communities – particularly the debate and shift towards online-only television (IPTV)?’

The DTT service is currently only guaranteed until 2034, and the future of the platform is currently being considered by the Department of Culture, Media and Sports (DCMS) Future of TV Distribution Stakeholder Forum which is expected to set out options to Government on whether DTT should continue beyond that date.[1] Scotland would be disproportionately affected by any decision to turn-off DTT because of its geography, lower broadband availability and uptake, and its high reliance on free-to-air terrestrial broadcast services. We are concerned that Scotland - along with Wales and Northern Ireland – risk not being sufficiently taken into consideration within the current decision-making process.

Scotland’s rural connectivity remains materially behind the UK average, with lower full-fibre and gigabit availability and many communities still unable to rely on stable, affordable high-speed broadband. These disparities mean broadband cannot yet serve as a universal or resilient alternative to DTT, particularly across rural mainland Scotland and the Highlands and Islands, where 26% of households in Scotland depend on terrestrial television on their main television without access to cable or satellite, with only 4% of Scottish households relying solely on IPTV.[2]

The removal of DTT would therefore carry heightened consequences for Scotland, weakening national resilience, reducing access to public service broadcasting, and risking disconnection for households with limited or unreliable broadband. Arqiva’s tall tower network often provides the only coverage across vast areas of the country, and a premature move to IPTV could jeopardise the continuity of essential broadcast, radio and resilience services on which millions depend in Scotland.

This issue was discussed by the Scottish Affairs Select Committee in 2023 and, given the risks to the network’s future, we believe the Committee should reaffirm its previous recommendation to Government that it should maintain Freeview beyond 2034.

DTT Network Overview

The UK’s DTT network represents one of the UK’s largest communication infrastructure assets, consisting of 80 main sites and over a 1,000 relay sites nationwide, and remains the UK’s only universal TV platform, supporting equitable access regardless of geography, income, or age and reaching over 98.5% of UK households.[3]

Over 10 million homes watch terrestrial television on their primary TV set with around 3 million UK households relying exclusively on terrestrial TV without access to other services.[4] Despite this, service is only guaranteed until 2034.

Whilst Arqiva recognises that viewing habits are evolving, we - alongside more than 37 charities, broadcasters and industry groups in the Broadcast 2040+ coalition - are calling for an extension of the life of the platform, with Arqiva calling for a commitment to extend it to 2045. This would provide a more realistic and responsible timeline to explore an eventual move to all-IPTV viewing.

DTT in Scotland

Across Scotland, 226 sites provide universal DTT access, including some of the UK’s tallest structures such as Black Hill (310m) and Durris (307m) transmitters. DTT is hugely popular in Scotland, with citizens spending an average of 2 hours 48 minutes per day watching broadcast television on a TV set in 2024 – the most of any UK nation – rising to 5 hours 44 minutes for individuals aged 65+. An estimated 26% of homes in Scotland depend on DTT on their main television without access to cable or satellite, with only 4% of Scottish households relying solely on IPTV, a figure which has remained broadly static year-on-year due to Scotland’s challenging geography and access to reliable and affordable broadband.[5]

Scottish Affairs Select Committee, 2023

The critical role of DTT in Scotland was subject to a Scottish Affairs Select Committee inquiry during the previous Parliament. The Fifth Report of Session 2022-23 on Public Broadcasting in Scotland made the following recommendation:

“While we acknowledge the UK Government has made a commitment to maintain Freeview for a significant number of years yet, we see no reason why the forthcoming Ofcom review should prevent the UK Government from giving certainty of continued coverage beyond 2034 to households in Scotland reliant on Freeview at the earliest opportunity. We recommend that the UK Government signal that it will maintain Freeview beyond 2034”. [6]

Due to Scotland’s topography, many households continue to struggle to access reliable high-speed broadband, and any move towards an online-only future would have consequences far beyond those experienced in more digitally advantaged parts of the UK.

The timing of this inquiry coincides with the conclusion of the DCMS-led stakeholder forum on the Future of TV Distribution – initially launched by then-Media Minister Stephanie Peacock MP and now under the remit of Minister Ian Murray MP – which we anticipate will set out its policy position in early-to-mid 2026 on the future of the DTT network. This inquiry also follows a recent a Westminster Hall debate on the Future of Terrestrial TV – led by David Mundell MP – during which the risks of a premature DTT switch off for Scotland and the wider UK were discussed.[7]

Risks to Scotland

The interests of people living in Scotland, Wales and Northern Ireland risk being overlooked in the national debate. We are concerned that the evidence base being used to guide DCMS thinking does not adequately reflect the needs of the nations. For example, the DCMS-commissioned study by Revealing Reality included only 4 Scottish, 6 Welsh and 1 Northern Irish participant, compared with 28 Londoners.[8] This London-centric and digitally enabled sample risks producing conclusions that do not reflect the realities of digital connectivity in Scotland.

Our view is that 2034 is not a realistic timeframe for assuming Scotland could rely primarily on high-speed fixed broadband for television. Coverage is not the same as take-up, and millions of UK households will still not subscribe to high-speed broadband by the 2030s due to affordability, digital literacy and reliability issues. Around 1.9 million UK households already struggle to pay their broadband bill[9], more than 1 million have been disconnected,[10] and many more are cancelling or downgrading to save money because of the ongoing cost-of-living crisis. Older and disabled citizens also often lack confidence online, while rural and coastal households face unreliable service. 21% of over-65s have no internet access at home,[11] and 26% of UK households already struggle to afford communications services.[12]

DTT Forecasts

Estimates of the likely ongoing use of DTT beyond 2034 vary given the high degree of uncertainty on trends amongst different age and income groups and the affordability of high-speed fixed broadband to support IPTV. However, all forecasts agree that use will continue to be significant for millions of households over the next two decades, with Enders Analysis estimating 16 billion hours of viewing by 2039, down from 21 billion hours in 2024,[13] and industry analyst Mathew Horsman projecting c.2.9m UK households will still rely on DTT as their chosen means of watching linear TV by 2045.[14]

Public Concern

The DTT platform remains central to the delivery and protection of universality within Public Service Broadcasting. An end to DTT could put this at risk. A recent poll of over 26,000 people found that DTT is regarded not merely as a media platform but as a vital public service, with 76% wanting it to continue beyond 2034, 75% viewing it as a critical safety net even among streaming users, and 74% saying that switching it off would feel like a “betrayal.” Opposition was strongest among older, disabled, lower-income and digitally excluded groups.

Given the scale of reliance on DTT and the limits of broadband uptake, Arqiva takes the view that the continuation of the DTT network is one of the most consequential UK Government policy decisions affecting digital connectivity, resilience, social inclusion and national equity in Scotland over the next decade.

Arqiva Proposal: DTT beyond 2034

Arqiva has proposed to the UK Government a viable, cost-effective and future-proofed plan that would maintain DTT until at least 2045. Extending DTT beyond 2034 is not an anti-digital position; rather, it is a pragmatic and enabling approach that protects universal access to broadcast services while supporting the UK’s thriving hybrid TV ecosystem. By maintaining a resilient broadcast backbone through to at least 2045, the UK can support a transition to IPTV over the longer term, while simultaneously unlocking spectrum, efficiency and innovation benefits across the network.

The UK’s DTT network currently comprises six core multiplexes – three licensed to the PSBs (two by the BBC and one, D3&4, shared by ITV and Channel 4), three licensed to commercial operators (two by Arqiva and one, SDN, by ITV). This is in addition to the nationwide Comux multiplex which carries commercial services and Local TV, and the smaller NI Mux serving Northern Ireland. However, much of the existing DVB-T infrastructure installed during Digital Switchover (2008–2012) will have reached the end of its operating life and must be replaced with modern equipment (known as DVB T2). As part of a future DTT network, Arqiva proposes transitioning from the current six core multiplexes to three DVB-T2 multiplexes after 2034.

Benefits of Upgrading to DVB-T2

This streamlining would provide the same universal coverage through a more efficient architecture, reduce collective costs for the BBC and other PSBs by over 40% in real terms, and unlock the 600 MHz band for Government auction and mobile use. Crucially, it would also permit a similar range of services to continue to be offered to viewers.

Modernising the DTT network would also deliver significant environmental gains, with engineering assessments indicating that renewal and migration to modern DVB-T2 equipment would reduce power consumption by over 40%, supporting the Government’s Net Zero objectives. For the BBC specifically, it is estimated that the cost of retaining DTT could amount to just 2% of current licence fee income or around 1% if other costs which are likely to increase if DTT is turned off are taken into consideration (e.g. radio and internet delivery costs).[15]

This credible plan to retain DTT alongside IP-based streaming services supports the UK’s £124 billion creative industries and guarantees universal access to terrestrial broadcast services at no recurring cost to taxpayers.[16] It protects choice and access for the vulnerable groups who rely on DTT to stay connected, while also supporting the UK’s Critical National Infrastructure (CNI).

Transitioning the DTT network to DVB-T2 and integrating any associated spectrum clearance would require a multi-year, regionally phased programme between 2031–2034, drawing on known approaches from the successful DSO and 700 MHz clearance programmes. However, this transition depends on a timely Government decision on the future of TV distribution given the significant operational and financial resource required to upgrade the network.

Risks to full reliance on high-speed fixed broadband for TV

By contrast, there is currently no plan that would maintain universal and free access to television in the event of a DTT switch-off. As previously outlined, broadband availability is not the same as uptake, and despite the success of Project Gigabit and other targeted interventions, rollout timeframes have slipped from 2030 to 2032 due to nationwide deployment complexities. Further delays are possible, potentially overlapping with any proposed DTT switch-off and leaving millions isolated from TV access.

Rural connectivity still lags behind urban. Ofcom found that full-fibre broadband was available to 71% of urban premises but only 52% of rural premises. Scotland trends lower in terms of rural residential gigabit capability at 43% whereas England trends at 54% gigabit connectivity.[17]

To replicate DTT’s universal reach, a high-speed fixed broadband connection of at least 30 Mbps would need to be effectively guaranteed to 98.5% of households. This would require a huge and ongoing subsidy to support those who could not afford it, which would almost certainly fall on taxpayers. Estimates are likely to vary but research by EY suggests an estimated cost of £218 per household per year for broadband and potentially an overall cost of £1bn per year in Government subsidies could be required.[18]

CNI and Other Users

Radio in Scotland

Radio remains a cornerstone of UK media consumption: 87% of people aged 15+ in Scotland listen to radio each week, with total listening rising from 79.2 million hours per week in Q1 2024 to 81.1 million hours in Q1 2025.[19] Large parts of the DTT network shares infrastructure with broadcast radio services and removing DTT from Arqiva’s towers would increase radio distribution costs, estimated to be around a 30% average increase - or considerably more for some operators – potentially threatening the viability of services.

Critical National Infrastructure

Beyond terrestrial broadcast services, Arqiva operates one of the UK’s most resilient communications networks, engineered to withstand extreme weather, power outages, and cyber-attacks. Its tall tower infrastructure underpins a wide range of critical services, including emergency communications, utilities, transport, government departments, mobile operators, and national security functions. It also enables emergency broadcast messaging - a vital safeguard during times of national crisis. The removal of DTT could significantly weaken this infrastructure and reduce national resilience, particularly across mainland Scotland and the Highlands and Islands, where Arqiva’s towers often provide the only coverage for vast areas.

Recommendation

The outcome of the DCMS Future of TV Distribution review represents one of the most consequential digital infrastructure decisions of the decade. Our view is that a long-term commitment to the UK’s hybrid model - where terrestrial TV provides a universal foundation and internet streaming offers additional choice and functionality - remains the best approach for the United Kingdom and for Scotland into the 2040s. This approach can be secured without additional recurring public funding, and Arqiva urges the Committee to give this issue careful consideration and reaffirm its 2023 recommendation that government commit to the long-term future of DTT beyond 2034. We would also welcome the opportunity to present further detail to the Committee.

A clear and timely decision from Government on the future of TV distribution and the continuation of the DTT platform will allow Arqiva to make the necessary investments to upgrade the network by 2034. It will also protect universal access to broadcast services in Scotland, safeguard CNI, and unlock wider investment in the network.

Providing certainty for DTT until 2045 would ensure a gradual and realistic transition to fixed broadband delivery over the longer term while preserving consumer choice - allowing people to watch TV in a way that suits them, regardless of age, income, technical ability or where they live. Delaying risks undermining resilience, increasing costs for other services, and eroding the principle of universal access that underpins UK broadcasting.

December 2025

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