Committee Secretary Senate Standing Committees on Environment and Communications PO Box 6100 Parliament House Canberra ACT 2600

Re: Australian Broadcasting Corporation Amendment (Restoring Shortwave Radio) Bill 2017

Dear Secretary,

I live in Alice Springs and in the course of my work I travel all around Central Australia. Beyond about 70km from Alice Springs and in several select communities I can receive no radio broadcasts, and my only contact with the outside world is the occasional mobile phone reception area or wifi hotspot surrounding a roadhouse or station homestead or similar.

I also have a satellite phone which I try to leave turned on when travelling. This way, if someone (e.g. my family) hears of a fire, flood or road closure in the area I am travelling in, they can try to get through to me and warn me. However, the disadvantages of this setup are 1) someone on the outside needs to have up-to-date information on emergencies which are unfolding, 2) they then need to know my whereabouts and understand that I may be in danger and need contacting and 3) They need to be able to get through to me on my satellite phone at the appropriate time. On point #3, there have already been times when I have been travelling with my satellite phone turned on and I have not received incoming calls. This is despite being connected to what is regarded as the most reliable satellite network. It is also possible that I will not have my satphone on at the appropriate time and there are any number of other inhibitions which might prevent me receiving an emergency call or update. The satellite phone has also proven unreliable when trying to stay in touch with family.

In the course of my work as a travelling minister/chaplain I visit people who are the most affected by the termination of the ABC shortwave service: people on the move. This includes grey nomads and other tourists on the roads, hikers and campers, truckies, stock agents and others who travel for work, and station workers who work away from the homestead. I am concerned for both their physical and mental wellbeing. In an emergency like a fire, flood, or road closure they have very limited connection with the outside world. Many live or work in isolated areas, with many hours spent outside of mobile phone/internet and now radio connectivity. They need mental stimulation and connection. The companionship of shortwave radio in the past has been a great benefit in this area. It not only gives them access to what is happening around them and further abroad, it also gives them something to chat about when they are able to connect with fellow humans at the end of the day or the end of the trip.

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The termination of ABC shortwave services has certainly left a hole in communication and connection in Central Australia. I am, however, concerned about the aims and wording of the bill under consideration.

As the ABC has pointed out, analogue shortwave is an old technology. Everything else is moving to digital, and digital is the way of the future. It would be a shame to lock the ABC into delivering an old, analogue service instead of transitioning to a state-of-the-art digital service. Such a service is available in the form of DRM30 digital shortwave radio, as you are probably aware from other submissions (in particular, the DRM consortium submission #13 and Alan Hughes submission #31). DRM30 seems to be the solution to many of the issues with the old shortwave services

Advantages of DRM30:

1) It is a new, digital service which fits nicely into the ABC’s stated aims of updating its technology and providing digital radio to all Australians no matter where they live (and I would add work and travel).

2) At least one of the Central Australian transmitters (Tennant Creek) is already DRM30- capable, meaning it’s a matter of basically flicking a switch to start a digital transmission trial. Other transmitters (e.g. the international ones) may also be DRM30-capable, and if they are not it is not a big expense to retro-fit them to transmit the digital signal using a simple piece of rack-mounted equipment.

3) All the transmitters (when they are converted to be DRM30-capable if necessary) can transmit BOTH an analogue signal AND a digital signal at the same time, facilitating the eventual transition to all-digital. People with the old shortwave receivers can immediately have their radio station back while they source a new DRM-capable receiver.

4) Being a digital service, it offers audio quality comparable to FM, with other perks of digital radio like ease of tuning, ability to record programs, information on what’s playing, and even graphics able to be received. This means there will be an immediate turn-around in the audience numbers. The number of analogue listeners is not likely to increase dramatically. With a digital service the number of listeners would only grow as people found out the many advantages over other forms of radio and podcasts/online listening.

5) The advantage of the old analogue shortwave radio was its broad reach. DRM30 has the same broad reach, but with better listenability because it offers FM-quality audio. This means people travelling from place to place would not lose their station. Furthermore, they would not need to re-tune their radio as they entered each town. A single DRM30 transmitter could cover the whole of Australia with a strong signal, meaning that a national ABC program could be heard everywhere without dropouts! This has huge implications on potential listener numbers and desirability of tuning in.

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6) One of the significant costs associated with analogue shortwave transmission was electricity costs. DRM30 uses at least 40% less electricity, while being able to transmit two digital broadcasts simultaneously (e.g. English and another language for Radio Australia broadcasts).

7) DRM30 offers impressive Emergency Broadcast Services, including the ability to turn the radio on and select the appropriate frequency to deliver an emergency warning. It can also transmit weather maps and text which are displayed on a small screen on the radio to supplement the oral warning.

8) Because of their vast reach, DRM30 transmitters can be located outside cyclone areas, meaning they can reliably transmit emergency information without being at risk of being weather-affected.

9) Because it is a broadcast, DRM30 Emergency updates don’t get bogged down by how many people tune in to hear them. This is an advantage over, say, internet or mobile phone- based services, which the ABC themselves have already discovered the limitations of during emergencies.

9) It is easy to make radios (both car and portable) that can receive both the existing DAB+ digital radio stations (already in use in the bigger population centres) and DRM30. Selecting the channels would be a matter of choosing the name of the station and it wouldn’t matter to the user whether they were listening to DAB+ or DRM30 because either could offer pretty much the same listening quality and additional services.

10) Radios can also be made which support “legacy” shortwave, AM and FM as well as the DAB+ and DRM30 digital standards, to be backward compatible. There are already chips available that can be used in such radios.

11) The DRM standard can also be used for local radio: approximately equivalent to the old AM radio in coverage, but much better audio quality and energy efficiency. This can be utilised alongside DAB+ all over Australia, and broadcasters can choose which digital standard suits their needs better.

Shortcomings of DRM30:

With so many advantages to DRM30 radio, and the ease and cost-effectiveness of transitioning to it, why haven’t the ABC already taken it up? Surely there must be some significant downsides?

The only downside to DRM30 is that everyone will have to go out and buy a new DRM30- capable radio to listen to it. Manufacturer PantronX is currently fulfilling pre-orders for its Titus II DRM-capable portable radio (which also receives DAB+, FM and AM). It costs under

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$USD100. Mike from PantronX said in June 2017: “We are first fulfilling large orders from international broadcasters. Individual orders most likely are late fall. If you preordered someone will contact you when the order comes up. Sorry for the delays but demand has been almost overwhelming.”1

There aren’t many radios available to buy globally off-the-shelf yet, but that is about to change. India have just rolled out a nation-wide DRM network. That is over 1 billion potential listeners. Other countries such as Indonesia are doing DRM trials. International broadcasters such as the BBC, Radio Russia, Radio France Internationale, and even Radio New Zealand all have DRM transmissions.

DRM is on the cusp of taking off globally, so the radio shortage will not be an issue for long. As mentioned above, chip-makers have already produced chips which are capable of AM, FM, DRM and DAB in a single chip, making it very easy for manufacturers to design and build DRM-capable radios. Many manufacturers have already experimented with building DRM into their products, with some having prototypes. They are just waiting for demand to put them into production.

Car manufacturer Hyundai is already selling it i10 model in India with a DRM-capable infotainment system. Other car manufacturer are following suit.

Australia prides itself in its innovation. It was the first nation to commence 24 hour digital radio broadcasts using the DAB standard. We have started turning on digital radio stations in capital cities around the country, but they rely on short-distance standards called DAB and DAB+. In their submissions to government agencies the ABC and other pertinent parties have regularly and consistently admitted that DAB is not appropriate to cover the broad tracts of remote Australia. Despite this, they have done very little to push for a more appropriate digital technology for wide area coverage. Their bias toward covering the major population centres with new digital technology is unmistakable. Essentially, they are abandoning isolated Australians around the country. Australia is sadly lagging behind with digital radio because of this failure to roll out DRM.

The ABC’s excuse that there are not enough receivers available is lame at best. The ABC should take a page from Telstra’s book. Over a decade ago Telstra was looking at the best technologies to service the vast tracts of Australia and came up with Next G, operating on the 850MHz band. To this day as far as I am aware, Telstra is the only telco who utilises the 850MHz band. Initially they had to work with manufacturers to produce mobile phones which could work on their new network. Phones had to be made specifically for the Australian market. I have recently bought a Samsung Galaxy S7, and every S7 sold globally is Next G capable!

1 http://swling.com/blog/2017/06/pantronx-titus-ii-drm-receiver-june-2017-update/

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When the ABC and other broadcasters in Australia first turned on DAB digital radio in Australia the handset situation was similar. Australia was the first in the world to commence 24/7 DAB transmissions. There were few DAB-capable receivers available at the time, but that didn’t stop them from introducing and promoting it.

The ABC says that other broadcasters are not interested in the DRM standard, and this makes it too hard for the ABC to introduce it by itself. That might be the case if it weren’t a matter of just flicking a switch to turn DRM30 on and halve electricity costs in the process!

What the ABC also seems to fail to realise is that the higher population centres that benefit from DAB+ radio now will also benefit from DRM radio in the future. DRM radio does not exclusively benefit those in remote, sparsely populated places. It has immediate benefit to travellers on the roads no matter where they are in Australia, and it also has potential to benefit even the most densely-populated areas. Once the DRM standard is introduced to Australia other broadcasters will jump on the bandwagon when they see the advantages over DAB+.

ABC Rebuttal:

I am still concerned that in its submission to this bill the ABC is still only going on listener figures based on where people live. When the ABC does this they are leaving out a significant chunk of listeners who have no access to ABC radio or online when they travel or where they work. This is especially the case in regional and remote areas. Sure, station homesteads might have the ABC via SkyMuster or VAST, but as soon as workers leave home in the morning to work they lose all their access for the duration of their time away from the homestead. This is an extreme example, but there are many people in regional areas throughout Australia who would lose their connection to the ABC as they travel or work outside the town they live in.

On page 5 of their submission, the ABC states:

“In May 2000, the National Association of Shortwave Broadcasters reported that shortwave usage in Australia was less than 1% of the population. This represents fewer than 1,500 active shortwave users in the Northern Territory at that time. The significant growth in internet usage, access to streamed radio and the increasingly limited amount of content available via shortwave since 2000 has led to a further decline in shortwave listenership, and ABC Radio estimate that in 2016 there were approximately 500 regular domestic shortwave listeners (approximately 0.7 per cent of the Northern Territory population).”

The maths here is flawed as it assumes that the shortwave listeners in Australia are distributed evenly throughout Australia. Where there are other methods of listening to the ABC the shortwave listening would decrease. Considering the anecdotal evidence suggesting that the Northern Territory transmitters actually provided a signal through much of the

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Australian inland and even into territorial waters, it would be realistic to estimate that nearly 100% of Australian shortwave listeners would have been tuning in to the NT transmitters. Even if the ABC is correct that the percentage had dropped from 1% to 0.7% between the years 2000 and 2016, that is still 0.7% of Australia’s population were shortwave listeners, or approximately 168,000. If we assume that only 80% of Australian shortwave listeners were tuning into NT transmitters and the other 20% were listening to Radio National or overseas broadcasts, that is still 134,000 shortwave listeners in Australia. This 134,000 would have been focussed in areas which had little or no other listening options – for example, the Northern Territory! I would hazard a guess, too, that for most of the 70,000 people in the Northern Territory who have the VAST service on their houses that they wouldn’t have to walk far from their houses to lose all ABC reception! All of these calculations are estimates and guestimates, but they illustrate the point that the ABC has manipulated the figures to make them fit the picture they want to paint.

On page 6 of its submission the ABC mentioned that other International shortwave broadcasters have been abandoning shortwave technology in the past two decades. This is only partly true, as some broadcasters are switching to DRM30 which is still a shortwave technology. Other international broadcasters like China National Radio and All India Radio and are actually commencing DRM30 broadcasts as well.

The ABC states on page 8 of its submission: “Complaints have been received from industry and interest groups as well as from politicians and members of the public. Of these, however, the number of contacts from people within the intended coverage areas for the services was 20. The ABC has provided each of these listeners with advice about alternative ways to listen to NT Local Radio and Radio Australia respectively.”

I find these numbers very hard to believe, considering how many people I have heard talking about it in person and complaining about it on the Alice Springs ABC talkback radio. And I for one have yet to receive my advice about alternative ways to receive the ABC’s emergency warnings as I travel around Central Australia.

On page 9 of its submission the ABC states that should the bill go through it would require “The re-establishment of defunct transmission infrastructure.” The transmission infrastructure is not in fact defunct, but simply lying unused at the moment. However, if the ABC does not soon re-negotiate contracts with Broadcast Australia, the sites may be dismantled and properties sold. Then the cost of re-establishing transmission would be far higher.

On page 10 of its submission the ABC states: “The ABC, rather than the legislature, is expert in the field of broadcasting, and should be free to determine the best methods of transmitting its services and to be responsive to technological and audience changes, in accordance with its powers under the Act.”

If the ABC is indeed an expert in the field of broadcasting, and if it is attempting to be responsive to technological changes, why was DRM30 not considered, and why is it still not being considered? The last mention of DRM in an ABC submission to the government was

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probably in 2010, when it admitted that DRM was the most viable technological solution for covering the vast expanses of land between large population centres in Australia.

Again on page 10 of its submission: “To reinstate these shortwave services to the NT, PNG and the Pacific, when there this limited and diminishing audience demand and the respective networks are provided for by other means, would cost the ABC approximately $4 million per annum.”

As mentioned above, moving to a digital transmission would immediately reverse this trend of diminishing audience demand. Additionally, the digital transmission would cut the power cost by almost half. I would estimate the effect would be to reduce the cost to the ABC to under $3 million per annum straight away.

In Questions on Notice from the ABC, page 12, the ABC says: “Digital Radio Mondiale technology is not currently utilised as an industry standard transmission technology in Australia. The ABC trialled this technology from 2007 to 2015 but due to the extremely low numbers of receivers available in the market and the expense of the ones that could be purchased, the trial was discontinued.”

I would be interested in knowing about these trials, as the only ones I have been able to pull up easily on the internet were a test by the ABC in 2005, tests by the SBS and a trial by 2ME in 2007. Did the ABC actually do trials (publically-informed, long-running), or only field tests? If they did trials, were they ongoing throughout the period 2007 to 2015? It surprises me that I cannot find any information on these supposed trials, and I cannot help but think this is the ABC trying cover up the fact that they did not take this new technology seriously enough. It seems they are trying to mislead the government and the Australian people again with this answer.

The ABC does not mention DRM30 anywhere in its submission, though it is certainly aware of it. Why is this? Is it that they are not considering DRM as an alternative? Is it that they don’t want to give DRM breathing space because they are afraid that if the public become aware of it that they will be held accountable as to why they did not implement it sooner?

Other considerations:

As early as 2010 the ABC has admitted in government submissions that their preferred digital radio standard (DAB) is unsuitable for full coverage of regional and remote areas and the connecting roads of Australia. SBS and Broadcast Australia have made similar admissions in their submissions. All of these organisations and others suggest in their submissions that DRM30 (DRM broadcast in the bands under 30 MHz for long-range transmission) is the best technology for Australia’s vast landmass. The resultant federal report, “Review of technologies for digital radio in regional Australia” (7 October, 2011) also concludes that DAB is not suitable for all regional areas, and that DRM is the preferred technology to supplement DAB+ in regional areas.

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The ABC has expressed concern that the shortwave band is too congested for the introduction of DRM. However, with the cessation of AM broadcasts in Central Australia there should be at least six frequencies available for its implementation. There may be a bit of red tape to cut through with the Australian Communications and Media Authority (ACMA) in terms of the allocation of frequencies to DRM trials, but the ACMA have already set embargoes on frequencies in the 5-20MHz and 26MHz ranges, for the explicit purpose of exploring digital radio possibilities.

Conclusion:

I have intentionally left out footnotes and references in this submission for brevity and readability. I am more than happy to supply you with the links and sources of all the information I have provided in my submission. Please contact me if this is required.

The longer we take to introduce DRM in Australia, the longer Australians will miss out for. And not just Australians in the far-flung places, but all Australians – especially those who live in smaller population centres or work or travel distances on our road networks.

I believe the shortwave service was important, especially to those in remote areas and those on the move. This service must be re-introduced for their physical and emotional safety.

I am concerned that the Bill as it stands may restrict the ABC to the old analogy shortwave, when DRM30 digital shortwave is the future. Because DRM30 can be transmitted alongside analogue shortwave in a trial/transition period, I would like to see this implemented immediately.

It is sad that the ABC is not doing something about this of their own accord, without the need for the government to intervene. Especially when such a simple solution is at hand. I was at an ABC community forum in Alice Springs the other week, with ABC board members in attendance. At each of the 8-10 table groups shortwave radio was a distinct concern and was presented among the top 3 issues of concern from each table. However, when I received the email summary from the ABC of what they had “heard” on the evening, they had lumped shortwave along with broadband and digital services and labelled it “accessibility issues”. I hate to sound pessimistic, but it seemed like a placating and publicity campaign rather than a genuine attempt to hear, understand and do something about the concerns of local people.

The ABC’s submission to this inquiry has been shown to be misleading. It also presents verifiably false information. The ABC should be reprimanded and called to account for what it has done and written. Additionally, the ABC’s submission calls into question their technical expertise in the field of broadcasting. Is the ABC capable of making independent decisions which “ensure that the functions of the Corporation are performed efficiently and to the

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2 ABC submission to the inquiry at hand, page 3.

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