I do not agree with the proposals relating to High Definition Television (HDTV).
OFCOM's identification of HDTV as a premium consumer product, in my opinion, fails to take into account the ever-changing world of consumer electronics. Particularly in recent years, prices for panel-based (LCD/Plasma) HDTV sets have been plummeting. As technology becomes more cost-efficient and refined, it is hard to imagine that this will stop.
In addition, screen sizes are growing larger and larger - with the knowledge that 40", 50" and even 60" sets are available (although currently at a premium), the majority of people would probably agree that a 32-inch television set is no longer a large screen size.
Similarly, the resolution of today's panel-based TVs is growing, to the extent that a "Full HD" 1920x1080 resolution panel is already affordable to many and will almost certainly become the standard for all but the smallest screen sizes in the future. The 720x576 resolution of current Standard Definition Television can be hard to endure on the large, high-resolution screens of the future - particularly when the high bandwidth to number of channels ratio is taken into account (too many channels are compressed into too small a space, with the picture quality suffering greatly as a result).
These two points relating to resolution and screen size, in my opinion, make your comparison of HDTV as a “premium consumer product” similar to mobile television, a poorly thought out one. My understanding is that video-capable mobile telephones have a low screen resolution as well as the obviously small screen. By comparison, HDTV is close to a necessity on large, high-resolution screens. The decisions made by OFCOM regarding frequency allocation must surely be future-proofed, which makes your analysis of HDTV as a “premium consumer product” less important, as in the technology world, today's premium products are often affordable to all in a matter of years. I find it astonishing that OFCOM could be this short-sighted.
My second point relates to the fact that OFCOM have decided that a larger selection of channels would be more highly regarded than higher picture quality. It is my opinion that, particularly in the United Kingdom, consumers very much have a "quality rather than quantity" attitude to television services. It is also arguably difficult to justify the existence of many of the additional channels that currently consume space on the Freeview platform - especially in the age of internet shopping, how can OFCOM *possibly* justify making room for potentially more shopping/"bid up" channels rather than offering consumers the greater picture quality they will expect from their new displays?
Lastly, the proposal document claims that the evidence for customers expecting free-to-air HDTV services to be delivered into their homes is “not strong right now”. This is particularly interesting, as the results of the consumer HDTV tests carried out in London by the BBC, ITV, Channel Four and Five, have come to a much different conclusion. If I recall correctly, over 90% of the respondents explicitly stated that they expected HDTV to be available over the air. Granted, the people taking place in this survey already had HDTVs so could probably be described as a mix of enthusiasts, early adopters, and people who had bought HD because it is already the standard for new displays. This, however, still does not explain the differences in your findings with theirs and I suggest that you re-evaluate.
Limiting the natural progression of television pictures would, in my opinion, be a tremendous mistake and will only disadvantage the UK and its consumers. In the United States, their new ATSC television standard already delivers HD channels over the air. This is despite the fact that most consumers there rely on Cable television for their TV signal. In a country such as the UK, where roof-top aerials are favoured, it would in my opinion make no sense not to accommodate at least some HD programming.