[cma-l] Digital Radio Working Group - we need your views!

[Two Lochs Radio]

Some off-the-cuff comments on your discussion points...

<< • FM cannot perform rewind, storage and interaction >>

That's not true at all in a technical sense - it's just that manufacturers 
generally choose not to offer or market it in mainstream radios. There have 
been small MP3 players around that have been able to do this for years (I 
have an old one in my shirt pocket right now). Any MP3 player/recorder or 
mobile phone with a built in tuner has all the electronic blocks inside 
needed to offer this, they just don't impelment it in most cases. Any DAB/FM 
radio design needs at most an extra A/D convertor chip inside to be able to 
do it as well, and most will have a signal processor already capable of 
this. It's a marketing choice not to offer it, not any inherent limitation.

And there is no good reason why DAB/FM receivers should integrate FM 
services into the same menu as DAB pretty well seamlessly. They can pick up 
station names through RDS, and there is no technical reason why sufficient 
other EPG and 'now playing' info shouldn't be carried by RDS (or even DAB 
multiplexes could feed receivers with additional text/EPG information about 
FM stations operating in their region).

So to make a perhaps radical proposal, I would suggest that the best way to 
achieve near universal availability of DAB/FM receivers by natural growth of 
the market would be to make them provide pretty much the same facilities in 
FM as they do when used in DAB (record/rewind, EPG, now playing, selection 
by name etc). This is not a technical issue - the infrastructure and data 
paths are all there already - it is purely a market issue.

2 What might switchover mean? Would it drive digital growth? How can we
achieve a form of switchover? What          conditions/criteria are
needed?

<<  • What is your vision of a “hybrid” or mixed solution?
<<  • How do we provide enough digital capacity for all local and community
stations? Should we?
<<  • Should we boost individual station quality before extending choice?
<<  • How do we persuade car manufacturers to put FM/digital receivers in
their cars? Do we need a European      standard? If so, what might it be?

You haven't mentioned satellite radio, which is really taking off in the US. 
This is in generally an excellent proposition for cars, and in particular 
provides near 100% geographic coverage, needing FM or other fill-in only in 
the most dense of high-rise city centres or tunnels.

You also haven't mentioned DRM, which is looking increasingly interesting as 
a low-cost, long range digital radio platform.

So one vision of a hybrid solution could be satellite radio for general 
digital coverage, with FM or DRM fill-in coverage for city centres and for 
very localized/community radio services. DAB has little to bring to this 
party, but could be used instead of DRM for fill-in of national services.



<<• One s/o proposal –
- a clear majority of people (in listening hours) are using digital
- a majority of homes have digital receiver(s)
- a majority of new cars have digital receiver
- 90% of population are covered by digital
- 80% of country (geographically) is covered
- Analogue commercial revenues are less than transmission costs
This might be achieved (without further intervention) by 2015/17: at
that point Govt could announce a five year switchoff (?) of AM and FM
for national services.
What is your view of this scenario?
• What is the cost of extending coverage to most of the other 20% of
country? How is this to be funded? What are implications for Scotland
and Wales?>>

This would be a very dangerous proposal as it stands. For a start, 'a 
majority' could mean just 51%, and at best is likely to be interpreted by 
most people as two-thirds. However, unless the idea of persuading car 
manufacturers to put digital receivers in as standard were achieved, the 
above set of criteria is never likely to be fulfilled!

80% geographic coverage is an ambiguous criterion - is it to be measured on 
a UK-wide basis, or a 'nations' basis? Done on a UK basis it would be 
disastrous for all those of us working in the north and west of Scotland, 
since you can be pretty sure that most of the unserved 20% would be in our 
region. At present we have zero DAB coverage in the north-west, and no 
indication of anyone proposing to install any at all, but we have 
half-a-dozen community-based FM stations (operating under ILR licenses, and 
typically covering areas the geographic size of Birmingham).

It seems to me there should be no general switch over/switch off until the 
alternative system (be it DAB, DRM, satellite, whatever) has achieved at 
least the same, and preferably greater geographic and population coverage 
than the system that it is proposed to switch off.. That is the situation 
that has been accepted for TV switchover, and I can't see any unique aspect 
of radio that suggests it should follow the same principle (though I can see 
reasons why it should be required to achieve greater coverage before 
switchover).

Another absolute precondition of a switchover should be that any digital 
carrier becoming exclusive to an area should be obliged to provide carriage 
for any existing local analogue services. Even the market-driven US accepted 
that a similar arrangement was necessary when satellite-fed cable TV systems 
started becoming prevalent in the US - I understand.they are obliged to 
carry all local radio and TV services along with whatever national 
programming they wish to distribute.




<<3. How do we encourage a migration to digital? What public or private
initiatives are needed?
• a plan for fitting cars with digital receivers
• exclusive digital content
• co-ordinated marketing and promotion
• upgrading of networks/ improve listening quality
• affordable smart receivers
• reorganisation of commercial licences and muxes
• consolidation of ownership
• subsidise receivers and/or transmission (eg the Ofgem analogy in energy)
• subsidise a revised DRDB

What is your view of any/all of these suggestions?>>

As outlined above, I think the best chance of encouraging a migration to 
digital is, ironically,  to make the FM side of DAB/FM radios provide the 
same facilities to FM channels as they do to DAB channels. That would give 
many FM listeners an incentive to get the new DAB/FM radios, and before you 
know it, there would be a much greater level of DAB radio penetration. OR, 
if those extra facilties (record/rewind/EPG/now paying etc) aren;t 
sufficient incentive to persuade someone to buy a radio, perhaps we have a 
large part of the answer to the question of why DAB take-up has been slow.

Why would we need an initiative for "consolidation of ownership"? Hasn't 
this happened already (GCap, Bauer...) to a massve extent under existing 
framework.

Otherwise, the market and the regulators just need to be patient, and not 
expect  in search of a quick buck to herd the public unnaturally rapidly to 
a new platform. After all, no special incentives were needed to get us to 
switch the majority of radio listening to FM, or all TV viewing to 
UHF/satellite. If the new system offers clear advantage in terms of quality 
and choice then the public will get there fast enough. Ah, maybe there's a 
clue in the first part of the previous sentence!

Alex
Two Lochs Radio

PS I can still clearly remember the time around 20 years when working in the 
BBC as the first mentions of DAB (Eureka 147 as was) were made, and early 
trials about to be started, one potential benefit to the BBC being touted 
was that it was inherently unsuitable for local radio!