SBS SUBMISSION TO THE AUSTRALIAN COMMUNICATIONS AND MEDIA AUTHORTY THE FUTURE DELIVERY OF SERVICES IN AUSTRALIA JULY 2019

KEY POINTS

 Terrestrial radio is extremely important to SBS audiences and will remain so for the foreseeable future—it provides wide-area coverage at no cost to Australian audiences.  Currently, SBS relies heavily on AM radio. By virtue of the spectrum it uses, AM has the best reach across Australia given the geographical scale of the country and the dispersed Australian population. However, the audio quality of AM radio is sub-optimal, and it is susceptible to more interference than other technologies.  A successor technology will need to have similar reach and provide better audio quality. High speed internet access does not currently have sufficient reach across Australia to make online-only audio delivery practicable on a national basis, nor is this likely in the short-medium term.  While there is no obvious successor technology available to be immediately deployed, SBS recommends further consideration be given to a number of options to replace AM, with a focus on: o Mondiale (DRM); and o emerging satellite technologies.  Until a few years ago, there had been no wide-area or large-population adoption of DRM internationally to drive mass produced, low price-point DRM receivers for domestic listening. This has changed since the adoption of DRM30 by All India Radio for nationwide broadcasting in the MF Band and the increasing integration of software defined receivers (SDR) by the automotive industry in India and Europe.1 2 3  SBS therefore recommends that the ACMA further consider DRM as a successor to analogue radio broadcasting in Australia in the medium- to long-term. Field trials should be conducted in Australia to develop an Australian base of knowledge and establish suitability to the Australian environment, which can also be augmented by overseas industry expertise.

1 https://www.drm.org/drm-digital-radio-broadcasting-in-india/ 2 https://www.nxp.com/docs/en/supporting-information/Radio-IC-FNL-PR.pdf 3 https://www.nxp.com/products/media-and-audio:MEDIA-AND-AUDIO-PROCESSING

 SBS acknowledges that the introduction of DRM technology would have cost implications for reception equipment and network upgrades. Government funding would be required.  In our broad continent, satellite delivery is likely to be cost-prohibitive in the current environment for mass audience consumption, but is worthy of review if emerging satellite technologies reduce cost. In particular, SBS recommends the ACMA monitor opportunities using Low Earth Orbiting satellites.  To promote migration to new digital radio technologies, SBS recommends consideration of a government mandate for manufacturers to include relevant technology in new-build cars.  In considering replacement technologies for AM, the following considerations are relevant: o The impact of Australia’s geographical position on the introduction of additional digital signals; o Assessment of the potential for, and impact of, allocating LF Band spectrum for broadcast purposes; o The energy efficiency of digital radio delivery; and o Opportunities to mandate future receiver capability.

SBS RECOMMENDATIONS

Digital Radio Mondiale DRM30 should be investigated as the preferred replacement technology for wide- area AM radio coverage. Industry and the ACMA should conduct field trials (and associated desktop studies) for each of the DRM30 and DRM+ technologies—to develop an Australian base of knowledge, establish suitability for the Australian environment (both regarding spectrum and topography), and augment this with research of overseas expertise. The ACMA should investigate the introduction of additional digital signals (notably DRM30) into spectrum already coordinated for AM services. The ACMA and industry should evaluate the potential application of DRM30 in the LF Band in the Australian environment to provide long-range coverage. The ACMA should develop a plan for the introduction of an all-digital radio broadcasting solution taking to account factors including digital radio capability and penetration in consumer and in-car devices, consumer education requirements, and energy efficiency. Low Earth Orbiting satellite With the increasing utilisation of Low Earth Orbiting (LEO) satellites deployed in satellite constellations, the ACMA should conduct a business case assessment of the viability of LEO technologies to provide broadcast illumination across the Australian continent capable of providing direct delivery of radio broadcast services to in-car and portable devices.

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INTRODUCTION The Special Broadcasting Service Corporation (SBS) welcomes the opportunity to comment on the Australian Communications and Media Authority’s (ACMA) Consultation paper on The future delivery of radio services in Australia (the Consultation Paper). SBS appreciates and values the ACMA’s ongoing consultation with industry. SBS is unique in the Australian media environment, providing multilingual, multicultural and Indigenous radio, television and digital media services that inform, educate and entertain all Australians and, in doing so, reflect Australia's multicultural society. SBS reaches almost 100 per cent of the population through its six free-to-air TV channels (SBS SD, SBS HD, SBS VICELAND HD, SBS World Movies, SBS Food and National Indigenous Television (NITV)) and seven radio stations (SBS Radio 1, 2 and 3, SBS Arabic24, SBS PopDesi, SBS Chill and SBS PopAsia). Servicing 68 languages including SBS Arabic24, SBS Radio is dedicated to the nearly five million Australians who speak a language other than English at home, while the three music channels (SBS PopAsia, SBS PopDesi and SBS Chill) engage all Australians through music and pop culture from around the world. SBS’s reach is being significantly extended through SBS’s digital services, including SBS On Demand, the SBS Radio App and portals which make online audio programming and information available to audiences at a time and place of their choosing. SBS Radio services SBS produces radio services and online content in 68 languages other than English, providing essential news and information about life in Australia. This service includes important settlement material, as well as information on things such as surf safety, enrolling to vote, accessing mental health services, or finding a playgroup. These essential services support social cohesion by enabling participation in all aspects of Australian life for people speaking a language other than English. SBS broadcasts language programs on both the AM and FM frequencies nationally across Australia. SBS Radio 1 and SBS Radio 2 are broadcast on both the AM and FM frequencies in Melbourne, Sydney, Canberra and Wollongong. SBS Radio also broadcasts nationally on either the AM or FM frequencies in other major centres around Australia. Additional local area radio infill services are provided in 143 areas under ‘self- help’ arrangements, for example by a local council or community group. The first phase of DAB digital radio expansion has now been completed in regional markets—Canberra, Hobart and Darwin, in addition to existing coverage in Sydney, Melbourne, Brisbane, Adelaide and Perth. The assets utilised for the transmission of SBS Radio’s services are not owned or operated by SBS. Transmission services in the 10 major markets are fully outsourced to Broadcast Australia (BA) under a long-term service level agreement. Current Australian position Although over-the-air (OTA) radio in Australia is predominantly delivered in an analogue format, the future of radio delivery is expected to progressively become digital. However, there are challenges in reaching this ‘digital future’. These include: determination of best-suited platforms; international coordination and technical standards; management of the implementation timeframe; and, availability and price- point of next-generation receivers.

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Currently, OTA radio in Australia is provided by means of two analogue technologies— AM and FM—and in digital mode using DAB; all of which can be consumed in-home, in- car and using hand-held portable devices. The coverage of each of the technologies and transmitter summary details are provided at Attachment A. Two additional digital delivery methods supplement the traditional OTA platforms— delivery via the terrestrial DTV multiplex and delivery via the Viewer Access (VAST) service. However, these methods are only suited to in-home listening, and provide a more limited suite of radio services compared with traditional OTA platforms (they provide most national broadcaster services but no commercial radio services). The evolution of delivery technologies is depicted in Figure 1 below.

Figure 1: Technology lifecycles4

To assist comparison of current and future delivery options for radio, SBS has undertaken research, which is set out at: Attachment B which provides an overview of the major technologies currently deployed around the world for the delivery of broadcast radio services. Attachment C which provides a high-level summary of the international adoption of the broadcast technologies by lead countries.

AUDIENCE TRENDS The majority of listeners still tune in to terrestrial radio Terrestrial radio broadcasting remains extremely important to SBS audiences and will do so for the foreseeable future. While some SBS Radio services are now digital-first, others remain focused on crafting entertaining and informative radio programs for older audiences, and are delivered on a linear basis through terrestrial platforms. According to the 2019 Infinite Dial Australia Study5:  83% of Australians surveyed noted that they had used AM/FM or DAB+ in the last week

4 SBS developed chart; information sourced from various company and government agency publications. 5 https://radioinfo.com.au/news/radio-stays-strong-podcast-listening-and-smart-speaker-use-grows- infinite-dial

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 Radio dominates in the car, with 85% of those who had driven or ridden in a car in the last month listening to radio, while 38% listened to a CD player, 26% to online audio streaming services, 21% to owned digital music and 12% to podcasts  22% of Australians listened to a podcast in the last month (compared with 32% in the US)  52% of Australians who have ever listened to a podcast have listened to a radio show catch-up podcast  Awareness of the Australian radio industry’s free mobile app Radioapp has increased to 19%, and is now nearly on par with the long-established international TuneIn app (awareness of which was measured at 20%) Turnover of terrestrial radio reception equipment is much slower than turnover of mobiles, with technology take-up heavily influenced by the car industry According to Statista, the worldwide average lifespan of a smartphone is approximately 33 months.6 Mobile communication devices—phones (and associated peripherals)— continue to evolve at a rapid rate, both in terms of device features and in terms of the technology; i.e. the ‘long-term evolution’ (LTE) communications standards. Conversely, the average replacement cycle for a new car in Australia is approximately 10 years and with it the installed in-car radio base. The replacement lifecycle for in-home receivers is not known but likely to be of a similar order. Without new features, there is a very limited consumer proposition to replace a functioning radio receiver. That is, there is considerably greater inertia to change for traditional broadcast devices compared to mobile communications handsets. Historically, the advancement of audience take-up of emerging broadcast radio technologies has been greatly influenced by in-car listening; the tipping point is largely triggered by the availability of the technology as a standard factory-fit in vehicles. Past examples include the transition from predominantly AM listening to FM in both Australia and the UK and, more recently, in substantially influencing the transition to DAB.7 In Australia, in 2019, over 60% of new cars are fitted with DAB+ as standard;8 ABS data cites the average life of a car at 10.1 years.9 In the UK, 91% of new cars are fitted with DAB/DAB+ receivers and the average age of a car is circa 14 years.10 In India, digital radio receivers are fitted in the majority of cars without surcharge.11 While SBS notes the growing importance of digital audio listening, including podcasts and streaming, terrestrial radio broadcasting will continue to be a major platform for Australian audiences in the medium term. The reach of high speed internet access is not sufficient to replace terrestrial delivery High speed internet access does not currently have sufficient reach across Australia to make online-only audio delivery practicable on a national basis. Access issues relating to broadband or mobile connectivity would also need to be considered under any online- only scenario. Regarding the uptake of digital media services in regional areas, in 2018, SBS submitted to the Review of the VAST service. In that submission, SBS noted:

6 https://www.statista.com/statistics/786876/replacement-cycle-length-of-smartphones-worldwide/ 7 http://www.digitalradioplus.com.au/latest-news/2016/cars-drive-up-dab-digital-radio-listening 8 http://www.digitalradioplus.com.au/dab-in-vehicles 9 https://www.abs.gov.au/ausstats/[email protected]/mf/9309.0 10 WorldDAB – November 2018: https://www.worlddab.org/public_document/file/1077/WorldDAB_Infographic_Q2_2018_A4_with_source s_FINAL_updated_28_11_2018.pdf?1543396898 11 https://www.drm.org/drm-digital-radio-broadcasting-in-india/

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…while broadband technologies are increasingly reaching greater population numbers, they are not yet achieving the reach and capacity which terrestrial and VAST services already have – near-universal access. Whilst internet-enabled delivery technologies and platforms are developing, there are capacity issues which are likely to lead to a significant time lag before they reach the same proportion of the population at requisite speeds, particularly in remote areas… Despite the growth in online content delivery mechanisms, therefore, broadcast (both terrestrial and satellite) remains the most robust and reliable one-to-many content delivery mechanism.12 While the submission related to television access, the same issues exist for radio broadcast access. SBS strongly supports the further development of broadband and high-speed wireless internet technologies in regional areas. However, until this is achieved, digital media services cannot sufficiently serve these audiences. Additionally, there are equity issues in relation to internet access, whereby this is not yet a technology that is financially available to all households.13

FUTURE SCENARIOS Overview It is SBS’s view that the future delivery of radio will be provided by a mixture of technologies, dependent on location (e.g. rural versus urban; in-car/portable versus in- home); progressively evolving and transitioning over time. There is no single technology to suit all environments. DRM While the audio quality of AM radio is sub-optimal, and AM is susceptible to more interference than other technologies, by virtue of the spectrum used it provides the best contiguous reach across Australia to match the sparsity of population over wide areas. DRM30 is an open standard which overcomes the shortcomings of AM, and which has been adopted as part of the regulatory standard for Medium Frequency (MF) Band broadcasting in other geographically-large countries (e.g. India and the Russian Federation). The recent widespread adoption of DRM30 in India has prompted large-scale production of low price-point DRM reception equipment, predominantly based on silicon chipset technology to develop a receiver based on software rather than a hardware realisation. This is software-defined radio (SDR). The automotive industry in India and elsewhere is increasingly integrating SDR technology into factory-line car production. Attachment C provides a summary of radio developments in the automotive environment and Attachment D provides an overview of SDR devices, including by reference to the productions of two global manufacturers.

12 SBS submission to the Review of the Viewer Access Satellite Television (VAST) service – issues paper (2018) https://www.communications.gov.au/sites/g/files/net301/f/submissions/sbs.pdf 13 Australian Bureau of Statistics, ‘As in previous years, the greater the household income the more likely there is internet access at home. In 2012–13, 98% of households with household income of $120,000 or more had internet access, compared to 57% of households with household income of less than $40,000’. https://www.abs.gov.au/ausstats/[email protected]/Lookup/8146.0Chapter12012-13

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Ostensibly, DRM30 can be operated on the same frequency as the AM service and therefore utilise the same antenna system as the current AM service, albeit with some technical adjustment. Mainstream contemporary AM transmitters are likely to be DRM30 capable with straightforward upgrade or enablement to DRM30 modes of operation; older models of transmitter will need material upgrade or to be replaced. SBS recommends further trialling of these technologies in Australia. The results would also help inform decision making in the choice of digital technology for the delivery of more localised services. Furthermore, this would position Australia to contribute to the International Union Radiocommunication Sector (ITU-R) update of recommendations and standards.14 The FM transmitter network utilised by the national broadcasters provides high fidelity audio services to the vast majority of the Australian population. Another DRM standard, DRM+, is suited to provide digital transmission in VHF spectrum that may prove to be a suitable future replacement technology although, unlike AM, SBS does not see the need for transition in the immediate future. Low Earth Orbit satellite The increasing deployment of Low Earth Orbit (LEO) satellite technologies for other wide-area distribution applications warrant further investigation as a potentially suitable technology for nationwide, or wide-area broadcast. Although, the spectrum utilised would not be suited to in-building penetration, products are available to provide extension in-building distribution. Other technologies SBS does not favour utilisation of the proprietary standards for future broadcast delivery, such as ‘In Band, On Channel’ (IBOC) as approved for use in the United States since 2002. This is because proprietary standards do not provide confidence in future structured development and compatibility evolution. ACMA SCENARIOS AND QUESTIONS The following sections respond to the scenarios and questions set out by the ACMA in the Consultation Paper. ACMA scenario 1: radio makes greater use of FM technology ACMA question 1: What are the current infrastructure and cost challenges facing AM radio? SBS has entered into a long-term fully outsourced service contract with BA for the provision of radio transmission services. SBS’s long-term cost base for ongoing AM, FM and DAB services is predictable subject to CPI variation. The ‘core’ SBS radio network is comprised of six MF services and nine FM services (i.e. excluding self-help infill services). Although small compared to the vast network of ABC AM and FM services, SBS seeks to increase energy efficiency where practical. Electrical efficiency improvements have recently been achieved through recent transmission asset replacements:

14 The ITU-R Recommendations constitute a set of international technical standards developed by the Radiocommunication Sector: http://www.itu.int/pub/R-REC/en

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 two MF transmitters at Craigieburn (Melbourne) and Bicentennial Park (Sydney) respectively; and  two FM transmitters at Black Mountain Tower (Canberra) and Gore Hill (Sydney). ACMA question 2: What are viable options to supplement or replace AM radio over the next 5–10 years? SBS considers there is limited opportunity to supplement AM radio in the short-term. SBS considers the timeframe for completion of a full digital transition of AM services to DRM30 is beyond a 10-year timeframe. However, it is recommended that work commence at an early opportunity to determine the appropriate technical standards and modes of operation to establish the strategies for transition and optimisation of operational parameters. SBS sets out a more detailed response to the digital transition options in its response to ACMA question 6 below. ACMA question 3: What are the benefits and impacts of an extension to the FM band? SBS does not support an extension of the 87.5–108 MHz spectrum block for broadcast purposes; any such utilisation would require the import (or manufacture) of new receivers by the consumer. Any scenario requiring replacement receivers (other than for incremental service enhancements such as RadioDNS functionality) should be to incorporate digital functionality. ACMA question 4: What specific spectrum planning changes should the ACMA consider? SBS encourages ACMA to continue to explore further opportunities for AM-to-FM conversion, although SBS sees very limited opportunity to apply the conversions where needed most—in the large urban and electrically noisy environments. Furthermore, the number of MF stations seeking conversion would severely exceed the extent of any available FM spectrum. In markets adjacent to the metropolitan capitals and other areas of major urban development, it is expected that spectrum congestion is such that there is unlikely to be much, if any, opportunity to be gained from a change in the channel raster spacing between services (i.e. ‘repacking’). Strategic spectrum planning should give priority to the AM replacement adopting DRM30 technology within a reasonable timeframe. In some geographic areas, there may be a number of technology options (e.g. a mixture of digital broadcast technologies and wireless broadband), but in the more rural and remote areas the solution will be more limited. The introduction of digital modulation transmission technologies in the MF Band will need to include an assessment of interleaved spectrum sharing impacts, mitigation strategies against interference, and a review of protection ratios in order to optimise future network planning opportunities. The juxtaposition of Australia and its limited number of ‘RF neighbours’—principally New Zealand and Papua New Guinea—provides potential degrees of freedom that may not feasible in other parts of the world. In the first instance, these opportunities should be explored in a technical context. ITU-R coordination methods such as Recommendation

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BS.1615-1 (2011) and Circular Letter CCRR/20 (2002) do not incorporate the full range of DRM30 modes of operation.15 16 Furthermore, the ITU rules for the introduction of additional digital signals (sidebands) into MF spectrum already allocated and coordinated for AM services appear to be potentially restrictive and overly conservative in their approach. The potential for the introduction of additional digital signals may be particularly pertinent to parts of the Asia-Pacific region. Preliminary investigation by SBS suggests the current methods are likely to take a conservative approach to protection ratios from the context of subjective degradation in a contemporary DRM30 environment. These methods need to be refreshed to incorporate DRM modes which may prove efficacious in the Australian environment ACMA scenario 2: AM and FM radio progressively migrates to DAB+ digital radio ACMA question 5: How could local geographic area community broadcasters and narrowcasters, (not currently eligible for DAB+) be accommodated in such a scenario? Currently, there is very limited availability of spectrum in the DAB sub-band (TV channels 9 and 9A), which accommodates eight DAB ensembles (8A to 8D and 9A to 9D). However, there is potential for some opportunistic allocation of additional Band III spectrum in those areas far removed from Band III DTV services (e.g. parts of WA). Considerable work was undertaken in 2015–16 by the ACMA and industry to optimise the planning parameters for future DAB allocations throughout regional markets. The planning outcomes resulted in some degree of compromise in terms of range and acceptable interference between markets to facilitate DAB multiplexes in all potential markets.17 There will be some markets sufficiently distant from Band III DTV services where it may be technically feasible to accommodate community and narrowcasters services in a low-power local multiplex. Alternatively, DRM30 technology could be used in MF spectrum to provide up to four program services as a means of providing a small-scale multiplex across a local area. Commercial viability in DRM mode for the services in question would be dependent on the availability of DRM receivers, and such transition would likely parallel a wide-scale conversion of national broadcaster and commercial broadcaster services. SBS’s response to the ACMA question 6 below provides detail of issues relating to DRM30 migration.

15 ITU-R Recommendation 1615-1—Planning parameters for digital sound broadcasting at frequencies below 30 MHz (May 2011): https://www.drm.org/wp-content/uploads/2012/10/Recommendation-ITU-R-BS.1615- 1-201105-IPDF-E.pdf 16 ITU-R Circular Letter CCRR/20 dated 6 September 2002: https://www.itu.int/md/R00-CCRR-CIR- 0020/en 17 Digital Radio Planning Committee (Technical Sub-Committee) DAB+ Regional Planning Technical Report (Document DRPC-TSC-2016-72) dated 25 August 2016

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ACMA question 6: Could wide coverage national AM services be economically and technically matched in DAB+? Is DRM a viable alternative transmission technology? Are there other technology, market or conversion options (e.g. some markets only)? The availability of AM-capable receivers is in the early stage of decline with an increasing number of brands only providing for FM and DAB modes.18 As frequency of operation increases, greater transmitter network density is required to provide equivalent coverage due to the changing propagation characteristics with frequency (for example topographical screening / line-of sight requirements). Although potentially viable in small countries within Europe, it would be cost prohibitive to replicate AM coverage with a DAB+ network in a vast territory such as Australia. SBS considers DRM30 to be the best option for the ultimate replacement technology for AM radio. The digitisation of AM radio through the adoption of DRM30 provides a hybrid mode of transmission which facilitates the transition from analogue ‘AM’ listening, through a period to a future all-digital state without the need for a specific time limit or barrier driving the need for consumers to immediately procure a new receiver. In 2006, SBS and BA conducted a field trial of DRM technology at the Gungahlin MF site (Canberra) over a three-month period to assess the feasibility of using DRM as a future modulation scheme, and the feasibility of achieving same coverage when operating in an AM-DRM simulcast mode. A high-level summary of the trial configuration, tests and results is provided at Attachment E. The trial equipment was mostly ‘first generation’ and DRM products and modes have materially advanced since that time. The choice of DRM configuration would be key in the mitigation of AM receiver limitations (digital cross-talk) and in facilitating the operation of the DRM component at a higher power level with respect to the AM carrier, so extending the coverage of the DRM signal. An in-depth Australian study is essential to determine how the boundary of AM coverage be determined and to assess and optimise field parameter variables. ACMA question 7: What role might a decision mandating the eventual switch-off of analogue transmitters play, either in providing a business case for investment in digital radio transmission or in encouraging uptake of digital ? What are the risks associated with such a decision? Unlike the transition to , there is no direct financial dividend to be secured through an auction and re-use of the traditional radio broadcast spectrum (MF Band and FM Band). Both of these spectrum blocks have been internationally adopted as broadcast services bands in virtually all countries. The MF Band is ideally suited to providing wide-area coverage. The Band II spectrum is not attractive to mobile/portable applications because the wavelength at these frequencies would result in a grossly inefficient internal antenna. Broadcasting is globally considered to be the ‘best use’ application for these frequency blocks.

18 The BMW i3, Tesla Model S and Model X electric cars do not feature AM receivers (due to the electrical noise generated by the car); access to AM broadcasters is available through the internet (subject to the availability of mobile broadband). Of the range of portable and digital radios featured by two major electrical retailers, AM functionality was available for only 24% and 32% respectively of the products on sale; the majority of DAB receivers also feature FM.

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It is SBS’s view that a coherent strategic plan is necessary to drive the transition to an all- digital radio broadcasting solution in order to maintain widespread coverage that broadly parallels the reach of analogue radio today. The plan should contain a timetable for the introduction of a minimum level of digital radio capability in consumer and in-car devices, aligning with the broad principles adopted in the European Union under the EECC directive.19 It should also consider the energy efficiency opportunities of new technologies. Without such a plan, the existing digital divide, between an increasingly multi-platform environment available in the metropolitan and urban markets, and the retention of an AM-only reach into the rural and more remote areas, will be even more pronounced, where the availability of a reliable 3G and 4G cellular communications network is unreliable or non-existent. The global market reliance on AM broadcasting is reducing and over time. AM broadcasters and AM listeners in Australia will become increasingly disconnected. The wide-area AM networks are the source of critical information during times of emergency. The AM facilities owned and operated by BA are critical infrastructure, with high levels of service resilience, redundant program input feed arrangements and significant generator-support autonomy (many days’ supply of fuel with emergency contingency refuel arrangements in place). A cogent policy commitment to the advancement of digital radio is essential and will strongly encourage the SDR chips set manufacturers and product developers to direct digital radio products (including functionality to retain AM reception) to the Australian market and accelerate the ultimate transition. ACMA question 8: What specific spectrum planning changes should the ACMA consider? Refer SBS responses to ACMA question 4 above. ACMA scenario 3: FTA terrestrial radio progressively migrates to online streaming ACMA questions 9–12 In urban and suburban environments, listeners will benefit from a pluralist delivery environment and be able to consume radio/audio/ data services via a broad range of technology platforms:

 traditional radio via AM, FM and DAB+ technologies;  streaming via 3G, 4G and progressively 5G cellular networks;  municipal wireless networks (e.g. city-wide Wi-Fi); and  small Wi-Fi networks (e.g. cafes, bars, shopping malls). In comparison to the virtually contiguous coverage provided by the AM and FM radio networks there are many areas where cellular coverage is not reliable for streaming services, even with a network density of over 10,000 Telstra 3G/4G base stations. Some of these streaming blackspots include suburban areas of Sydney, barely 25 km from the CBD—for example the Sydney Northern Beaches. Attachment G provides coverage

19 European Electronic Communications Code (EECC) mandates that all radios in new cars across the EU must be capable of receiving and reproducing digital terrestrial radio (e.g. DAB/DAB+) by the end of 2020.

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information for the Telstra mobile cellular networks and comparison to the wide coverage of AM radio. Access to services via mobile cellular networks necessitates a subscription to the network service provider / retailer; charges will be dependent on the data plan selected. Other than through support from government initiatives such as the Mobile Black Spot Program, as has been the case for the 3G and 4G network expansion, or a future imposition of universal service obligations, the capital investment required to provide a terrestrial network of sufficient density and broadly equivalent coverage to that of the existing national broadcaster networks at frequencies of 700 MHz and above would be commercially unviable. Overall, SBS sees wireless broadband technology as a supplementary platform operating alongside broadcast networks to provide an alternative source of services in urbanised environments, and in providing augmentation of traditional radio through functions such as RadioDNS and as part of an integrated infotainment system—the ‘connected car/home’. RadioDNS is an open standard, which can facilitate seamless migration between entertainment and radio platforms—for example: integration of TPEG information with the navigation system to provide details of road-traffic issues and broadcast network ‘Service Following’. For more information refer to ‘The automotive environment’ section of Attachment C. Next-generation developments such as 5G-Xcast—a European project focussed on broadcast and multimedia enablers for the fifth-generation wireless systems—are expected to provide a seamless integration and handover between delivery platforms.20 SBS SCENARIOS SBS scenario A: LF band macro-area DRM30 services Short-term DRM trials have been undertaken in Europe using existing Low Frequency (LF) Band infrastructure (e.g. Republic of Ireland, Russian Federation),21 and research papers have been published by Moscow Technical University of Communications and Informatics that indicate this spectrum block is capable of providing very wide-area coverage, particularly through the adoption of SFN clusters.22 A body of research has been conducted, notably in the Russian Federation, to model and promote the benefits to be obtained from the adoption of DRM30 in the LF Band to provide wide-area coverage with a small number of moderately powered transmitters. From the limited review by SBS to date, and constrained access to English language translations of other referenced papers, these studies appear to have been mostly theoretically based. Whilst there are many ITU-R publications which reference the technical parameters and provide guidelines for the transition of radio to digital platforms, with the exception of DAB/DAB+ technologies, to a material extent a number of these publications are

20 http://5g-xcast.eu/about/ 21 The LF Band (frequency range 148.5 to 283.5 kHz) is allocated to broadcasting in ITU Region 1 and is specifically excluded for broadcasting in ITU Region 2 (the Americas); the LF Band is not utilised for broadcasting in ITU Region 3. 22 Digital Radio Broadcasting Network in the Arctic Region (April 2019): https://www.researchgate.net/publication/333072839_Digital_Radio_Broadcasting_Network_in_the_Arctic _Region

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predicated on desktop analysis, laboratory tests and limited field experience of DRM30 and DRM+. It would appear there is a limited body of field evidence that has directed the optimisation of these standards for application in the field which are particularly pertinent to the Australian environment; for example, the 18 kHz channel bandwidth (in the MF Band) and the influences of propagation in tropical environments.23 SBS recommends the ACMA undertake a study and review of published material to assess the potential application of DRM30 in the LF Band in the Australian environment, which may subsequently lead to an assessment of the feasibility of, and impediments to, allocating LF Band spectrum for broadcast purposes. SBS scenario B: satellite radio Satellite technology could be utilised to provide a national, or wide-area footprint of radio services across virtually the whole of Australia as is already utilised for the delivery of VAST and Foxtel services. Although all SBS radio services are carried on the VAST platform (which utilises the Optus 10 and Optus D3 satellites), the downlink is specific to Direct to Home (DTH) services requiring a small receiver dish (circa 90cm diameter) and does not provide direct delivery to a mobile or handheld/portable receiver. The Sirius-XM platform (operating in S-Band spectrum at nominally 2320 MHz) provides subscription radio services to vehicles (and homes) across the mainland US and parts of Canada and Central America, noting the service footprint is supplemented by an estimated 500+ low-power terrestrial repeaters. S-Band allocations for satellite broadcasting in the spectrum block 2520–2670 MHz are listed in the Australian radiofrequency spectrum plan as published by the ACMA.24 There is no S-Band capability on the current fleet of Optus satellites, and none is forecast at this time for Optus replacement satellites that are currently in the planning stages. SBS is aware of anecdotal evidence that satellite delivery of radio would be prohibitively expensive, however further investigation of costs should be undertaken. The reception of geostationary satellites would suffer from topographical screening in southern states and in areas of urban high-rise buildings. However, the increasing global adoption of LEO satellites to provide wide-area services suggests that the business case viability for LEO satellite application for wide-area IP-delivery of broadcast services should be assessed, together with an assessment of the technical implications. CONCLUSIONS Given the vastness of the Australian continent and the dispersion of its population, there is no single technology solution to the digitisation of radio delivery. However, without a strategy to adopt digital technologies in the MF Band and an accompanying industry specification to define digital receiver functionality, there is the potential for a growing digital divide between metropolitan and regional/rural markets.25

23 Examples include: the subjective AM audio quality impacts arising from adjacent channel 18 kHz bandwidth DRM interfering signal and the impacts of ionospheric noise in tropical environments on network planning. 24 https://www.acma.gov.au/theacma/australian-radiofrequency-spectrum-plan-spectrum-planning-acma 25 An increasingly multi-platform environment is available in the metropolitan and urban markets while Australia sees the retention of an AM-only reach into the rural and remoter areas, where the availability of a reliable 3G and 4G cellular communications network is unreliable or non-existent. Comparative coverage of AM and 3G and 4G network reach is provided at Attachment G.

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The broadcast services bands are internationally coordinated for broadcasting through the ITU. Radio broadcasting is considered ‘best use’ for the MF and FM Band spectrum blocks. There is no alternative demand for the MF Band spectrum. There is very limited demand for the FM Band spectrum for other applications such as mobile broadband and M2M applications due to the wavelength and the low efficiency of compacted antennas at these frequencies. The propagation characteristics of MF Band spectrum is ideally suited to the delivery of domestic radio broadcasting over wide areas—but the effectiveness of AM is marred by the limitations of its analogue modulation system, its susceptibility to interference and its limited audio fidelity compared to FM and digital systems. The availability of AM-capable receivers is in the early stage of decline with an increasing number of brands only providing for FM and DAB modes. FM radio is capable of continuing to provide high fidelity audio and is less susceptible to interference than its AM counterpart. The current global consensus is generally to address the shortcomings of AM with a replacement technology. However, as yet, there is a much lower expression of interest in replacing FM services with digital alternatives. There have been many overseas trials of DRM+ and the standard is incorporated in national policy in a number of developing nations, but there is no apparent roll-out of any widespread DRM+ networks at this stage. SBS recommends further investigation of DRM technologies in Australia, noting that examples from Norway and the United Kingdom, as outlined in Attachment C, highlight the importance of policy direction and associated industry initiatives on driving consumer engagement with new technologies.

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ATTACHMENT A – COVERAGE AND TRANSMITTER SUMMARY INFORMATION

AM – Amplitude Modulation

Radio broadcasting, using AM technology in Medium Frequency band (MF Band) spectrum, has been in operation in Australia since the early 1920s.

Transmitters using MF Band spectrum provide contiguous groundwave coverage over wide areas, as shown at Figure A1. Transmitter power and the antenna system design determine coverage best suited to match the licenced area or to provide optimum reach of the signal to the audience whilst affording appropriate protection to other co-channel and adjacent-channel services.

The existing fleet of approximately 40 medium- to high-power transmitters, servicing the ABC audience, provides wide-area envelope of coverage across approximately 3,400 square kms and reaches approximately 23 million people as depicted.26 SBS AM transmitter coverage is subsumed within this outline coverage envelope. Other transmitters provide localised services and infill.

Figure A1: MF coverage – National Broadcasters: ABC Local Radio and SBS Radio27

There are currently approximately 300 MF transmitters in operation across Australia, ranging in power from 50 kW delivering wide-area regional services down to a few Watts for local services and infill.

26 Transmitter powers > 2,500 Watts. ACMA licenced broadcasting transmitters: https://www.acma.gov.au/Citizen/TV-Radio/Television/Lists-of-broadcasters/list-of-licensed- broadcasting-transmitters 27 Source: Broadcast Australia, May 2019

AM transmitters SBS ABC Commercial Community Re-Txn HPON BA contracted 628 110 Other - - 134 15 2 31

FM – Frequency Modulation

Frequency modulation was first developed in the early 1930s and proved to be a superior medium in terms of fidelity and less susceptible to electrical interference. FM broadcast services did not commence in Australia until 1974, initially in Sydney. There are currently over 2,600 FM broadcast transmitters licenced in Australia.29

FM SBS ABC Commercial Community Re-Txn HPON transmitters BA contracted 9 606 Self-help 143 480 (est.) Other - - 454 469 86030 212

Australian FM broadcasting utilises the VHF spectrum block of 87.5–108 MHz (FM Band). Propagation of these VHF-FM transmissions is predominantly line of sight; the range is subject to topographical screening, the chosen transmitter power and antenna pattern. Coverage is generally up to 150 km for high-power services. SBS FM radio services are provided in all capital cities and are further augmented by 143 licensed ‘self-help’ lower power infill services.31 The ABC network utilises a large number of low-power transmitters to provide infill coverage.

VHF-FM coverage for the high-power national broadcaster services (predominantly ABC) is shown in Figure A2 below. The FM land area coverage extends across approximately 1,200 square kms, just over one-third of the land area covered by AM, yet the population reach of 23 million people is almost the same as for AM as a function of the dispersion of the population and significant urbanisation.

Digital Radio – DAB+

Australia was proactively involved and instrumental in the incorporation of a high- efficiency codec into the DAB standard, from which the revised standard, ‘DAB+’, emerged in early 2006. The Australian industry recognised the importance of ensuring that DAB+ would not solely be an Australian adoption, and to this end, the industry proactively engaged with silicon chipset and receiver manufacturers to help drive mass production of DAB+ receivers in various form factors. Australia and Malta were the first adopters of DAB+. Refer to Attachment C for further information regarding DAB+ development and adoption overseas.

Digital radio (DAB+) is now provided in all capital cities; further commercial DAB (C-DAB) expansion will be driven by the establishment of commercial joint-venture companies

28 SBS MF radio services: Sydney, Melbourne, Canberra, Newcastle and Wollongong (2) 29 ACMA licenced broadcasting transmitters: https://www.acma.gov.au/Citizen/TV-Radio/Television/Lists- of-broadcasters/list-of-licensed-broadcasting-transmitters 30 Includes SBS and ABC Self Help 31 Self-help services are operated by the local community – e.g. council – with an initial funding grant provided by SBS for infrastructure establishment. Although licensed by ACMA, not all services may be in operation.

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(JVCs) in those markets seeking to introduce DAB+. Any further expansion of national broadcaster DAB (N-DAB) will be subject to the availability of future funding.

For the national broadcasters, the current DAB network (at July 2019) is comprised of eight high-power transmitters plus 16 low-power infills operating as on-channel repeaters or single-frequency networks.

The DAB+ land area coverage extends across less than 100,000 square kms, a small fraction of the land area covered by AM; refer Figure A3 below. Current DAB+ reach extends to 65% of the Australian population.

With increasing roll-out of DAB+ services into regional areas, coverage may be constrained by co-channel interference given the limited spectrum available to DAB+ services (2 x 7MHz channels, which equates to capacity for eight ensembles nationwide) and more complex network topologies will be required to optimise market-based coverage.

Figure A2: VHF-FM coverage – National Figure A3: DAB+ coverage – National Broadcasters: ABC Radio and SBS Broadcasters: ABC Radio and SBS Radio32 Radio33

32 Source: Broadcast Australia, May 2019. 33 Source: Broadcast Australia, May 2019.

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ATTACHMENT B – BROADCAST RADIO DELIVERY TECHNOLOGIES

AM – Amplitude Modulation

AM radio for domestic services utilises the MF Band of frequencies—526.5 to 1606.5 kHz (inclusive)—a spectrum block administered and coordinated by the International Telecommunications Union (ITU), a specialised agency of the United Nations.

The propagation characteristics of this spectrum block facilitate wide-area coverage of up to several hundreds of kilometres, largely independent of topography. The allocations by broadcaster in this spectrum block are carefully coordinated, both at a domestic level (by the ACMA) and at an international level by the ACMA and ITU.

Transmitter power and the antenna system design determine coverage best suited to match the licenced area or to provide optimum reach of the signal to the audience, whilst affording appropriate protection to co-channel and adjacent-channel services. MF transmitters provide contiguous groundwave coverage over very wide areas, as depicted in Figure A1.

A feature of MF spectrum is that night-time propagation (including dusk and dawn) extends coverage beyond the traditional target area which means that the wanted service may be impacted by interference from other co-channel and adjacent channel broadcasts many hundreds of kilometres distant.

As with all analogue systems, as the signal gets weaker as a function of distance from the transmitter, the signal becomes impacted by increased noise, and may also suffer from fading. Human-made noise materially impacts the quality of reception—particularly in urban/suburban environments—due to electrical interference such as: industry, fluorescent lighting, computer systems, and road management systems.

The MF Band spectrum with its propagation characteristics is well suited to the delivery of domestic radio broadcasting—but the effectiveness of AM is impacted by the limitations of its analogue modulation system and its limited audio fidelity compared to FM and digital systems.

FM – Frequency Modulation

Frequency modulation was first developed by Edwin Armstrong in the early 1930s and proved to be a superior medium in terms of fidelity and less susceptible to electrical interference.

Experimental FM broadcasts commenced in Australia in 1948, but with little interest shown in FM at the time of an Inquiry in 1957,34 the FM experimental stations were closed down in 1961; the nominal VHF FM spectrum block (88–108 MHz as adopted in Western Europe and North America) was allocated to television. In 1971–71, the Australian Broadcasting Control Board (a precursor to the ACMA) held another inquiry and went on to recommend the introduction of FM in UHF broadcast spectrum rather than in the international VHF FM band, so as to preserve the VHF allocations for television.

34 The Australian Broadcasting Control Board (ABCB) inquiry concluded there were no compelling arguments for the formal introduction of FM radio services; this was subsequently supported by the Radio Frequency Allocations Committee (Huxley Committee) in May 1961 gave priority to the allocation of VHF spectrum to television.

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Considerable work was undertaken to specify the requirement for unique FM receivers and plan the early FM network. However, a further inquiry in 1974, the Independent inquiry into frequency modulation broadcasting, overturned the previous recommendation, and mandated that FM was to be introduced into the VHF Band, requiring the progressive reassignment of certain television channels to alternative spectrum.35

VHF-FM coverage for the high-power national broadcaster services (predominantly ABC) is shown in Figure A2.

In many countries, FM is the platform which provides the core of high-fidelity radio broadcasting and is particularly well suited to music-genre broadcasters.

Ongoing radio broadcasting is considered to be ‘best use’ for the FM Band spectrum block, although the future is expected to increasingly include digital modes of broadcast transmission. Owing to the wavelength, and associated antenna size and efficiency, there is limited demand for this spectrum for other applications such as mobile broadband and machine-to machine (M2M) applications.

Digital (DAB) Radio

In the late 1980s, a consortium of leading European companies developed a standard for the digitisation of radio distribution networks—‘Project #147’ under the Eureka research and development program—which set the initial standard for DAB. DAB gained an initial foothold in Europe, albeit initially with varying degrees of success.

This standard is specified for operation in VHF (Band III) spectrum. It is an open and standalone standard and is not compatible or integrated with traditional AM and FM standards.

DAB was initially introduced in the UK by the BBC in 1995, providing a high-quality simulcast service, but at the time receivers were not mass produced—many were hand- built and extremely expensive. Given the high audio quality of the existing BBC FM services, the introduction of DAB simulcast services did not present a consumer proposition.

With the award of a UK commercial radio DAB multiplex licence in 1998, to Digital One, commercial viability was contingent on multiplex access seekers securing audience- based advertising and consumer take-up. To this end, Digital One proactively ran a marketing campaign to promote DAB and to drive receiver production to reach a sub- GBP100 price point.

The legacy DAB standard utilised low-efficiency audio codecs (MPEG-1, Layer II—or ‘MP2’) and presented a conflict between the number of services that could be aggregated in the DAB multiplex versus audio quality. Many of the UK services suffer from material audio impairments and audience complaints that the heralded ‘near-CD quality’ that DAB could offer was in fact materially inferior to FM. After initial launch, a

35 Twenty-seventh Annual Report of the Australian Broadcasting Control Board, paragraphs 75–78 https://apo.org.au/sites/default/files/resource-files/1975/12/apo-nid62987-1240601.pdf

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number of European countries discontinued DAB services due to low audience take-up (e.g. Germany, Sweden).

The Australian radio industry recognised the shortcomings of the legacy DAB standard (as adopted in the UK and elsewhere in Europe) where access to VHF (Band III) spectrum in Australia was already restricted by the presence of television. Industry participants worked proactively with the WorldDMB (now WorldDAB) Technical Committee through 2005–06 to incorporate a high-efficiency codec into a revised standard. In February 2007, an updated standard was formally endorsed which included the higher efficiency audio codec HE-AAC v2, leading to greater spectral efficiency through the carriage of a larger number of services within the multiplex. This revised standard, ‘DAB+’, is not forward compatible with the legacy DAB standard adopted in Europe. It was important to ensure that DAB+ would not solely be an Australian adoption, and to this end the radio industry proactively engaged with chipset and receiver manufacturers to help drive mass production of DAB+ receivers in various form factors. Australia and Malta were the first adopters of DAB+.

Propagation of DAB and DAB+ transmissions in VHF Band III spectrum is predominantly line of sight; coverage is generally up to 80 km for high-power services and range is subject to topographical screening and the chosen transmitter power and antenna pattern. Unlike analogue transmissions, the DAB+ services fail under ‘cliff-effect’ effect; at the edge of coverage, the onset of failure is that reception suffers intermittent losses and a further small reduction in signal level results in total reception failure. Wide-area single frequency networks (SFN) have been implemented in the UK. In Australia, low-power SFN facilities provide metropolitan infill in parts of Sydney and Melbourne Docklands.

Digital Radio Mondiale (DRM)

DRM is a digital radio standard for use in the existing radio broadcast bands (below 300 MHz) as currently used for AM and FM; DRM can be established in a number of modes as summarised below:

(i) ‘DRM30’ modes, which are specifically designed to utilise the AM broadcast bands below 30 MHz (this includes the MF Band); and (ii) ‘DRM+’ modes, which utilise the spectrum from 30 MHz to VHF Band III, centred on the FM broadcast Band II as depicted at Figure B1. In this document, the term DRM refers to the generic standard irrespective of mode.

DRM is an open standard and utilises COFDM and high-efficiency audio codecs; technical details are administered and published by ETSI.36 The DRM transmission can provide between one and four services—depending on the chosen modulation parameters.

36 www.etsi.org

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Figure B1: Frequency bands – context of DRM modes37

DRM provides a range of operating modes and techniques; for example:

 DRM allows the independent selection of modulation parameters (code-rates, constellation, guard intervals, etc.) to enable an optimum trade-off between capacity and signal robustness; and  DRM supports both multi- and single-frequency network operation (MFN/SFN), and hand-over to other frequencies which enables a broadcaster operating on several different platforms to hand a listener from DRM to DAB, AM or FM and back again.38 The appropriate signalling is intrinsically supported by DRM and DAB, and by data carriers on AM and FM (AMSS and RDS respectively).

DRM can also incorporate similar multi-media features such as Slide Show, Program Associated Data (PAD), Electronic Program Guide (EPG) and Transport Protocol Experts Group (TPEG) data to provide traffic information for route planning optimisation of in-car navigation systems. The standard also incorporates an Emergency Warning Feature (EWF), whereby DRM receivers are instructed to switch to an emergency program, such as a bush fire warning or flood alert.

DRM30 mode

DRM30 can also be configured in a ‘simulcast’ mode, similar to the In Band, On Channel standard (IBOC) as described below, where a digital sidecar (sideband) can be added to the analogue signal, enabling use of notionally the same frequency allocation, albeit with greater bandwidth.

37 Source: DRM Handbook (Revision 4, February 2019) - courtesy the DRM Consortium – www.drm.org 38 Switching to/from AM networks requires the incorporation of the ‘AM Signalling System’ (AMSS) into the traditional AM transmission = AMSS is published as ETSI standard TS 102 886. https://tech.ebu.ch/publications/trev_305-murphy

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Unlike IBOC, where the sidecar is symmetrically applied, for DRM a single digital sideband is applied as either an upper-, or lower-sideband, as depicted at Figure B2.

Figure B2: DRM30 simulcast mode showing the single digital sideband39

If the full digital sideband is adopted, as depicted (vertical bars), the bandwidth of the signal transgresses into the adjacent channel.

In 2006, SBS and Broadcast Australia established a DRM30 trial platform (at Gungahlin, Canberra). Details of the trial objectives, technical configuration and results are provided at Attachment E.

DRM30 has been used for many years by international broadcasters to deliver high- power short-wave services to overseas listeners. Until recently there had been no wide- area adoption of DRM30 to trigger mass produced, low price-point, DRM30 receivers for domestic listening in the MF Band. This has now changed with the widespread adoption of DRM30 in India—refer Attachment C.

DRM+ (or DRM Mode E)

DRM+ can be configured as a ‘standalone’ digital transmission, or can be configured in a simulcast mode; the spectral configuration is shown in Figure B3 below and the digital signal can be presented as an ‘upper’ or ‘lower’ sideband according to spectral availability (i.e. adjacent channel occupancy).

39 Source: DRM Introduction and Implementation Guide, Revision 4, published by the DRM Consortium (February 2019) – page 24.

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Figure B3: DRM+ simulcast mode showing the single digital sideband 40

Whereas in the AM simulcast mode, the DRM signal is carried through the common output amplifier (PA stage) of the transmitter, in the FM simulcast mode, the general configuration is for a separately generated DRM+ signal to be combined post the FM power amplifier (via a coupler) into the common antenna system. The coupling factor chosen is normally in the range 6 to 10 dB.

Protection ratios and spectrum masks need to be applied to adequately protect the co- existence of the adjacent FM and DRM+ services.

DRM+ is specified for operation in spectrum in the range 30–300 MHz; notionally in the Broadcast Services Bands I, II & III.

In-Band, On Channel (IBOC)

IBOC is a hybrid approach, similar to DRM in that digital sidebands of additional signals sit alongside the traditional AM or FM transmissions—utilising the notionally same frequency, albeit with greater bandwidth—ostensibly a ‘wide load’. IBOC, is a proprietary standard developed and licenced by iBiquity Digital (owned by DTS Inc. and part of the Xperi Corporation), branded as ‘HD Radio’ in the US. It was selected by the FCC and approved in 2002.

The IBOC system enables the analogue listener to maintain continued reception of the traditional analogue signal without the need for a replacement (AM or FM) receiver. As implemented, the IBOC digital sidebands generally carry a simulcast of the analogue signal with the benefit of greater fidelity and greater resilience to interference (particularly in the case of AM); the digital capacity can be used to carry an additional service, program associated data or other data services. Furthermore, the IBOC standard allows transition to an all-digital mode, dropping the analogue component and releasing capacity for additional program streams or data services. Further technical information

40 Source: DRM Introduction and Implementation Guide, Revision 4, published by the DRM Consortium (February 2019 – page 50).

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describing the modes of operation in the MF Band and FM Band is presented in the Digital Radio Guide, published by the World Broadcasting Union.41

In North America, the population density/radio market density means the MF Band spectrum is heavily congested. The MF Band channel bandwidth is narrower in the Americas so as to accommodate a greater number of stations (at 10 kHz channel spacing). At night, with the extended propagation properties of the MF Band signals, inter-market interference occurs, reducing the useable range of the wanted signal. With the introduction of IBOC to the AM stations in the MF Band, the sideband digital signal created new levels of interference to analogue services on adjacent and near-adjacent frequencies. For a period, the FCC restricted the use of IBOC at night, particularly along the Canadian border due to interference, although this restriction was removed in 2007. Canada has since also adopted the IBOC standard. No real solution has been found to the interference and it is likely that the greater transition to the use of digital IBOC receivers has reduced the audience impact through the greater resilience to interference impacts when listening in digital mode.

Satellite Radio

In North America, Sirius-XM provides nationwide radio broadcasting of over 150 services across the mainland US (excluding Alaska), major parts of Canada and Mexico using satellite technology comprising a 2.3GHz spectrum (S-Band) downlink, in a bandwidth of approximately 4 MHz.42

Originally, the service was delivered from three geosynchronous satellites operating in highly elliptical orbits so as to provide better overhead coverage, or ‘look angle’, to overcome local screening from ‘concrete canyons’ in urban areas and a relatively small number of terrestrial repeaters (circa 130). Reception of S-Band signals requires full line- of-sight visibility to the satellite (or repeater). Today, the services are provided from four operational geostationary satellites.

The terrestrial repeaters operate in the 2.3 GHz spectrum blocks allocated to SiriusXM and provide infill particularly in urban areas where the satellite reception is screened; the repeaters also provide a strong local signal to protect against receiver overload from near-adjacent telco/mobile communications services. It is estimated there are approximately 500 infill repeaters in operation although information is not publicly available.

A spectrum block in L-Band (1452–1492 MHz) is allocated to satellite digital radio services, although no information has been found to suggest this is currently utilised for direct delivery of satellite radio in any parts of the world.

Integrated Services Digital Broadcasting (ISDB-T)

The Integrated Services Digital Broadcasting (ISDB-T) is a Japanese standard for digital and digital radio introduced in 2003; it has subsequently been adopted in many parts of South America, Botswana, Sri Lanka and the Philippines.

41 Digital Radio Guide – World Broadcasting Unions , June 2017; pages 48–51 – https://tech.ebu.ch/docs/digitalradio/WBU%20Radio%20Techologies%20Guide.pdf 42 https://www.siriusxm.com/ourmostpopularpackages

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ISDB-T in Japan utilises UHF spectrum (470–770 MHz), each channel occupies 6 MHz bandwidth, subsequently fragmented into 13 segments; 12 of these segments are utilised for HDTV or SDTV payloads and the centre segment, ‘One-seg’, is utilised for mobile TV or digital radio services. Commercial One-Seg services were launched in Japan in 2006; by 2012, approximately 124 million cellular phones with One-seg capabilities had been sold.

The ISDB-TSB (Terrestrial Sound Broadcasting) system is an evolution of the ISDB-T One- Seg standard, which allow the transmission of high-quality audio coding, and efficient file delivery and utilises the lower part of the VHF band (90–108 MHz).

ISDB-TSB experimental stations have been in operation in Tokyo and Osaka since 2017. A receiver test centre has been established. However, at present, no receivers are apparently available in the commercial marketplace.

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ATTACHMENT C – SUMMARY OF INTERNATIONAL DEVELOPMENTS

Analogue Radio

AM radio is in material decline in Europe, with many countries closing down their AM transmitters or reducing the transmitted power (and as a consequence, shrinking coverage).43

Brazil has recently allocated an “extended FM” range of frequencies of 76.1–87.5 MHz to its existing allocation of 88.1–107.9 MHz as part of its AM to FM conversion program.

FM radio provides the main platform for radio delivery in virtually all markets—with the exception of Norway (as expanded below). Few countries are planning to replace FM services although they may adopt DRM+ services interleaved with FM services to introduce additional services into already congested spectrum. Refer below for details of DRM+ adoption and testing by country below.

Satellite Radio

In Europe, radio services are carried on satellite (e.g. UK Freesat), however, like VAST in Australia, these services are primarily Direct to Home (DTH) and require a dish antenna and dedicated receiver (STB). Freesat is not designed for delivery to in-car and portable in-home receivers.

Sirius-XM, a proprietary system, provides a subscription-based nationwide radio broadcasting across the mainland US (excluding Alaska), major parts of Canada and Mexico. The platform utilises four satellites in geostationary orbit, with an in-orbit spare.

Other satellite radio service providers/platforms have proven unsuccessful:

 WorldSpace commenced delivery of broadcast satellite radio directly to Africa in 1999 and subsequently to India. WorldSpace had plans to target Europe, but these were not realised; the company filed for Chapter 11 bankruptcy in 2008.  MobaHo! was a mobile satellite digital audio/video broadcasting service operating in S-Band spectrum at 2.3 GHz in Japan from 2004 but ceased operation in March 2009 due to failure to sufficiently grow its subscriber base.

Low Earth Orbit (LEO) satellite technology potentially offers a lower cost solution with improved signal reliability for the provision of radio delivery, whether utilising broadcast space segment (BSS) spectrum or providing mobile broadband IP-delivered services in telco spectrum segments.

43 AM switched off: Nordic countries; Germany, France – public service broadcasters; Luxembourg; Irish republic (2012); Netherlands and others.

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Digital radio market and regulatory developments

In its most recent market report (Q4 2018), WorldDAB has announced that more than 75 million consumer and automotive DAB/DAB+ receivers had been sold in Europe and Asia Pacific by the end of Q4 2018—up from 65 million in Q4 2017.44 However, this compares to more than 6 billion FM receivers worldwide.

Key findings from the WorldDAB report:45

 UK – 67% of households have at least one DAB radio and digital listening has been in excess of 50% for three successive quarters;  Germany – more than 11 million receivers have been sold;  Switzerland – 64% of all radio listening is via digital platforms;  Italy – 46% of new cars are now sold with DAB+ (up from 32% in 2017);  Norway – 6 million receivers have been sold; and  Australia – 69% of new cars are .sold with DAB+ (up from 47% in 2017).

A summary of DAB/DAB+ information summarising coverage and device penetration across parts of Europe and Australia is presented at Figure C1 below.

European Union – Regulatory policy

In December 2018, the European Electronic Communications Code (EECC) came into force and requires that by the end of 2020, all radios in new cars must be capable of receiving and reproducing digital terrestrial radio (e.g. DAB/DAB+) across all EU countries.46 It applies to all EU member states regardless of the status of DAB in each country. The EECC provisions only cover passenger vehicles and not buses and trucks.

The EECC also gives EU Member States the opportunity to introduce measures requiring consumer radios to be able to receive digital transmissions. France and Italy have adopted this requirement effective from 1 January 2020.

44 WorldDAB Market Report (28 November 2018) – https://www.worlddab.org/public_document/file/1077/WorldDAB_Infographic_Q2_2018_A4_with_source s_FINAL_updated_28_11_2018.pdf?1543396898 45 WorldDAB Market Report (28 November 2018) – https://www.worlddab.org/public_document/file/1077/WorldDAB_Infographic_Q2_2018_A4_with_source s_FINAL_updated_28_11_2018.pdf?1543396898 46 European Union Communications Code Annex XI (3) ‘Any car radio receiver integrated in a new vehicle of category M which is made available on the market for sale or rent in the Union from 21 December 2020 shall comprise a receiver capable of receiving and reproducing at least radio services provided via digital terrestrial radio broadcasting…’ https://eur-lex.europa.eu/legal- content/EN/TXT/PDF/?uri=CELEX:32018L1972&from=EN

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Figure C1: DAB/DAB+ Europe and Asia-Pacific47

The automotive environment

Radio is evolving in line with increased connectivity in the car and the introduction of voice control. Hybrid radio, ‘RadioDNS’, is an open standard which provides an enhanced radio experience in next-generation connected cars (e.g. Audi A8 in the UK) by exploiting the relative strengths of each platform:48

 Broadcast radio: free-to-air, robust, wide-area coverage (cf. cellular communications)  IP: richer data, return path, interactivity, personalisation

Hybrid radio is available in some new cars and in the planning stages for many car manufacturers; user experience will be key to its success. By design, hybrid radio can be integrated with many other in-car features and can also facilitate seamless migration between entertainment and radio platforms—for example:

47 Source: WorldDAB Market Report (November 2018) https://www.worlddab.org/public_document/file/1077/WorldDAB_Infographic_Q2_2018_A4_with_source s_FINAL_updated_28_11_2018.pdf?1543396898 48 Hybrid RadioDNS is an open standard, defined by ETSI standard TS 103 270

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 integration of TPEG information with the navigation system to provide details of road-traffic issues; and  ‘service following’ which provides hand-over of service to other frequencies when driving beyond primary coverage boundaries—whether DAB-to-DAB, or DAB-to-FM, FM-to-AM or DAB/FM to IP streaming and in reverse. The ‘Service Following’ capability is contingent on the inclusion of appropriate metadata in the broadcast streams (AMSS for AM networks; RDS for FM networks).

The deployment of hybrid radio services to facilitate a seamless switching user experience is recommended by the European Broadcast Union (EBU).

The WorldDAB Automotive conference, June 2019, hosted in Turin, provided an update on the implementation of the EECC by EU national administrations and a spotlight on broadcast radio’s evolution in the connected car, development of in-car entertainment systems in terms of smart, hybrid and voice-controlled radio.

A summary of additional features offered by RadioDNS is provided at the RadioDNS website.49

Software Defined Radio (SDR)

Software Defined Radio (SDR) products, designed to operate in multi-standard modes (e.g. AM, FM, DAB, DRM) and across all broadcast services spectrum, are making major inroads in the digital receiver market, particularly for in-car systems. The products are typically silicon chipsets or small modules that are integrated into car systems or portable/handheld devices which can be tailored to provide the required functionality and look-and-feel.

Further information, manufacturer products and references are provided at Attachment D.

49 RadioDNS website: https://radiodns.org/

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Developments by Country / Region

A high-level summary of digital radio developments by country and region is provided below.

European DAB/DAB+ markets Norway50 In 2017, Norway became the first country in the world to switch off national and large commercial FM radio stations; these services are carried using DAB+. Most local stations (approximately 200) remain on FM for reasons of economic viability.

Norway has approximately five million inhabitants and a topography that make rolling out nationwide infrastructure expensive. The strategy was that DAB nationwide infrastructure would replace FM, fueling faster digital growth.

The digital transition was industry driven, with the broadcasters stating that full deployment of DAB was contingent on the cessation of FM. The switchover was predicated on a clear and detailed plan, with broad political support. The need for a cost- effective distribution strategy made it difficult to support simulcast on both FM and DAB for a long period. Government policy required the DAB network meet a minimum population reach of 99.5% for national services and 90% for commercial services at the commencement of FM switch-off.

A distinct plan followed by both the authorities and the broadcasters ensured that DAB was installed in all new cars and that the Norwegian consumer electronics industry stopped selling radios without DAB (a strategy which preceded the implementation of the EECC), which was the case before the switch-off process was commenced. Such a coordinated and distinct plan was deemed crucial and necessary for a successful digital radio transition in Norway.

A recent statement by the Norwegian media authority, Medietilsynet, advised that FM broadcasting by approximately 200 local and community stations may continue until 2026 or beyond, subject to determination by parliament—a material extension from the original deadline of 2021. Medietilsynet considers the local and community stations are an important source of media pluralism. The conversion cost of the digitisation of all local stations to DAB has been estimated at €900 million ($AU 1.5 billion). 51, 52

50 https://www.worlddab.org/public_document/file/1125/One_Year_After_- _report_and_appendices.pdf?1553793724 51 http://digitalradioinsider.blogspot.com/2019/05/fm-radio-extension-in-norway-another.html 52 Representative proposal from the parliamentary representatives Åslaug Sem-Jacobsen, Geir Pollestad, Heidi Greni, Geir Adelsten Iversen and Nils T. Bjørke on the extension of a license for local radio on FM networks (Google translation to English) - https://www.stortinget.no/no/Saker-og- publikasjoner/Publikasjoner/Representantforslag/2018-2019/dok8-201819-040s/

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UK To date, there has been no formal policy direction or target date for analogue radio switch-off in the UK, although in May 2019, the Minister for Digital and the Creative Industries confirmed the government will soon commence a review of digital radio with the aim to conclude the review by mid-2020 now that digital radio listening exceeds 50%.

Since 2009 the government has adopted a ‘wait and see’ approach to digital take up; there has been no concerted government campaign to support the acceleration of digital radio, unlike the successful digital television switchover campaign.

Ofcom data on the sale of DAB sets shows a static purchase rate for the period 2010 to 2016, suggested as attributable in part to poor in-building penetration in urban areas and the over-packed multiplexes which results in audio quality inferior to that of FM.53

UK DAB coverage—to the home and along major roads—has grown over time, but there remain material differences in regions of Wales and Scotland, due to population dispersion, topography and the transmitter network density in these areas.54 Sweden55, 56 Despite its close links with Norway, the Swedish government rejected a transition to DAB following an extensive consultation and review by the National Audit Office. Reasons cited include the need to replace 10 million FM receivers, difficulty in achieving same coverage as FM, and interference risks to defence usage in adjacent Band III spectrum (225–245 MHz). Denmark Denmark has expressed plans for public service and commercial national networks to switch to DAB+ whilst retaining FM for local radio stations.57 Finland Finland rejected DAB in 2007 and has exclusively allocated the VHF Band III (174–230 MHz) to digital television broadcasting (DVB-T2)..58 Switzerland59 Switzerland had so far been the only other country, after Norway, to make a statement of intent to switch off FM radio by 2021. However, the radio industry has not yet taken decisions on planning for FM shutdown and press statements suggest this decision is now likely to be deferred until 2024, or later.

53 Ofcom Digital Radio reports 2010 to 2017: https://www.ofcom.org.uk/research-and-data/tv-radio-and- on-demand/radio-research/digital-radio-reports 54 Ofcom Media Nations: UK (2018); pages 68–69: https://www.ofcom.org.uk/__data/assets/pdf_file/0014/116006/media-nations-2018-uk.pdf 55 Public Service Council, Sweden, an independent non-profit think tank with the task of studying, defending and promoting the basic values of public service broadcasting; statement (March 2016) – http://public- service.net/docu/DABFactsSweden.pdf 56 Public Service Council, Sweden – Nordic Radio Workgroup report (May 2019) – http://public- service.net/docu/DABfacts2019rev.pdf 57 Ibid, page 2 58 Ibid, page 2 59 Article from Tages Anzeiger (Swiss German-language newspaper) (Google English translation available) – https://www.tagesanzeiger.ch/wirtschaft/standardder-umzug-auf-dab-verzoegert-sich/story/26333554

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DAB+ listening in Switzerland has declined, particularly across the younger demographic in the presence of continued FM listening and growing consumption through streaming. The DAB demographic will likely be enhanced by the impact of the EECC from December 2020; currently only 40% of in-car listening is by means of DAB+.

Financial support for the development of DAB infrastructure is available until 2022. However, if this support is not extended to align with any deferral of FM switch-off, the future digital delivery platform may be internet-based. Digital Radio Mondiale (DRM30 & DRM+) India All India Radio (AIR), the public service broadcaster, has adopted DRM30 as a digital replacement technology for AM and to date has progressively installed 35 MF transmitters (with additional transmitters under construction), providing DRM30 reach to an estimated population of 600 million people.

At June 2019, over 1.5 million new cars have been equipped with DRM receivers as a line-fit during manufacture. The in-car receivers are integrated with other dashboard applications.

The Indian automobile receiver industry has invested heavily in the domestic development of DRM capable receivers and chipsets. The core components of many of the receivers are of global manufacture, based on software-defined functionality, which is simply enabled as required (together with AM and FM).

For example, Hyundai, MG and Suzuki are three global manufacturers offering DRM as ‘standard’ fit in many of their models, together with two Indian manufacturers.

NXP and STMicroelectronics, global semiconductor solutions manufacturers, each have a major manufacturing and design presence in India. Refer to Attachment D for summary information of their products and reference information. Russian Following many trials and tests of DRM technologies in MF and Federation VHF spectrum, there have been a number of policy decisions and (DRM30 & statements regarding the adoption of DRM30 and DRM+ DRM+) technologies.60, 61, 62

Simulcast testing of DRM+ and FM are due to commence in mid- July 2019 in St Petersburg using Band II spectrum.

In early 2019, Moscow Technical University of Communications and Informatics published a paper outlining the potential use of DRM30 in the LF Band to provide cost-effective wide-area

60 Russian Radio Frequency Centre decided to introduce DRM30 in the MW and SW (decision no N 09-01-05 made on 20 January 2009). 61 https://www.drm.org/main-russian-network-operator-rtrn-drm-delivers-more-for-less/ 62 RIA Novosti news agency report, 18 September 2018 (translation): https://ria.ru/amp/20180911/1528303185.html

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coverage at a small fraction of the cost of the existing fleet of MF transmitters.63 Scotland In 2011, a high-power field trial of the DRM+ system in the FM (DRM+ trial) Band was conducted in an area of central Scotland, chosen 64 because of topographical challenges to radio reception. It demonstrated more robust and subjectively improved reception in areas where the FM signal is grossly marred by multipath signals. IBOC – ‘HD Radio’ US & Canada The US has approached the transition of free-to-air radio from analogue to digital through a proprietary standard developed and licenced by iBiquity branded ‘HD Radio’ using a technology known as ‘In-Band, On-Channel’ (IBOC). Some AM stations are petitioning the FCC to approve all-digital transmissions to replace the analogue component and in May 2019 the FCC issued a docket seeking public comment.65, 66

Over 40 major-brand car manufacturers provide integrated IBOC receivers as factory fit. A wide range of IBOC products are available for in-car, in-home and portable use.67

The IBOC system has been adopted in Canada and a number of other countries in the Caribbean and Central America (e.g. Jamaica, El Salvatore, parts of Mexico). Satellite Radio US, Canada In North America. Sirius-XM provides subscription-based & Mexico nationwide radio broadcasting of over 150 services68 across the mainland US (excluding Alaska), major parts of Canada and Mexico using satellite technology.

Sirius-XM uses a proprietary system and has developed software applications for use on iPhone, iPad devices and a streaming app for the Android platform.

At December 2018, Sirius XM had a base of 33.7 million subscribers. Approximately 60% of new cars are equipped with a Sirius-XM receiver, almost half of which secure paid subscriptions.

63 Digital Radio Broadcasting Network in the Arctic Region (April 2019): https://www.researchgate.net/publication/333072839_Digital_Radio_Broadcasting_Network_in_the_Arctic _Region 64 BBC Research White Paper – Results of the DRM+ high power field trial in the United Kingdom: http://cmfe.eu/docs/WHP199.pdf 65 Hubbard Radio, station WWFD, has been granted a one-year experimental authorisation to operate in an all-digital mode (‘MA3’) – https://www.radioworld.com/blog-1/hubbard-testing-all-digital-am-on-wwfd 66 FCC Media Bureau docket RM-11836 ‘Petition for Rulemaking to Allow the MA3 AllDigital Mode of HD Radio for AM Stations Revitalization of the AM Radio Service’ and associated public comment – https://www.fcc.gov/ecfs/search/filings?proceedings_name=RM-11836&sort=date_disseminated,DESC 67 Examples of HD Radio receivers for in-home, portable and in-car use – https://hdradio.com/get-a- radio/home-radios/

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In most cases the satellite receivers are integrated with other dashboard applications (e.g. navigation, audio).69

It is estimated 500+ terrestrial repeaters augment coverage to provide infill where direct satellite reception is screened and to provide protection against receiver overload from near-adjacent telco/mobile communications services.

Sirius-XM offers receivers for in-home, automotive, marine and aviation use. In-home signal repeaters are available to rebroadcast direct satellite reception into the home.70 5G Broadcast Scotland71 A 5G broadcast trial is currently operating in the Orkney Islands on the remote island of Stronsay, off the northern coast of the Scottish mainland in an area with slow broadband speeds and little or no digital radio coverage.

Special handsets have been issued to 20 users so they can receive live and on-demand radio programmes. The trial infrastructure incorporates a purpose-built 5G broadcast modem which carries thirteen radio stations, broadcast live over the 4G/5G system as well as providing mobile Internet access to participants.

The 5G modem is a complete hardware implementation of a transmitter and receiver and uses the new eMBMS features of the LTE Release 14/15 specification and the ability to dedicate 100% of the available capacity for broadcast. Results from the optimisation tests will potentially be incorporated into future releases of the 5G LTE standard.

71 https://www.bbc.co.uk/rd/blog/2019-04-5g-broadcast-modulator-modem

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ATTACHMENT D – SOFTWARE DEFINED RECEIVERS (SDR)

Traditional radio receivers were comprised of hardware to facilitate the functionality (e.g. mixers, filters, amplifiers, detectors etc.). Each model and brand would typically have its own production line. Commonality of manufacture would be complicated where a country required a particularly niche requirement (e.g. use of a specific, or limited spectrum block). Hardware-based receivers could not be readily modified to adapt to standards changes—for example, the inclusion of RDS in FM receivers or the adoption of a new, more efficient codec.

Software defined receivers are extremely flexible and, subject to certain constraints (e.g. frequency range, environmental conditions), can be designed to operate over very broad ranges of spectrum and therefore applied to broadcast and non-broadcast applications. The silicon chipsets and sub-boards are mass-manufactured and therefore low cost, ready to be integrated into a broad range of systems—for example hand-portable receivers and in-car systems.

Summary details of two global SDR manufacturers as provided below.

NXP Semiconductors (formerly Philips Semiconductors)72

Headquartered in Eindhoven, Holland, this Dutch global semiconductor manufacturer with 14 manufacturing plants, operating in over 35 countries, provides a broad range of media products for the home, in-car and portable market.73 Its products include a range of multi-standard and multi-tuner digital radio baseband processors which support AM, FM, DAB, DAB+, DRM, DRM+ and HD Radio (IBOC). The NXP products are widely deployed in the in-car systems in Europe and India. The mode of operation (whether, say DAB or DRM) is simply enabled at the end of the car production line, according to the local broadcast standard.

STMicroelectronics (ST)

A global semiconductor solutions company, headquartered in Geneva, Switzerland with 11 main manufacturing sites with a major focus on the automotive industry, this supplier provides fully integrated systems including receivers, media connectivity, navigation and human-machine interfaces. Its range of tuners are multi-standard front-end integrated circuits predicated on software-defined applications covering LF through to L-Band spectrum (150 kHz to 1.5 GHz) which support AM, FM, DAB, DAB+, DRM, DRM+ and HD Radio (IBOC).74

72 https://www.nxp.com/files-static/corporate/doc/fact_sheet/NXPCORPORATE.pdf 73 https://www.nxp.com/products/media-and-audio:MEDIA-AND-AUDIO-PROCESSING 74 https://www.st.com/en/applications/in-vehicle-infotainment-ivi.html

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ATTACHMENT E – SBS-BA DRM30 TRIAL (GUNGAHLIN 2006)

During the period May to July 2006, SBS and BA conducted a low-power trial of DRM30 technology at the Gungahlin MF transmission site (Canberra).

The primary trial objectives were:

 to determine suitable RF parameters for DRM30 operation in the Australian environment;  to assess the effectiveness of a low power DRM30 simulcast transmission in a suburban/urban environment o in home; and o in vehicle.

The trial equipment available to BA and SBS in 2006 was mostly ‘first generation’ DRM30 product.

Conventional AM operation is predicated on a channel bandwidth of 18 kHz (i.e. carrier frequency (Fc) ± 9 kHz. For the trial the AM channel bandwidth (and audio high-frequency response) was restricted to ±4.5 kHz bandwidth, centred on the carrier frequency of 1440 kHz with the DRM lower sideband of 9 kHz bandwidth centred at 1431 kHz. Refer Figure E1 below.

Figure E1: AM channel bandwidth – conventional mode and segmentation during the trial75

The trial transmissions were configured to provide a ‘simulcast’ of the AM service with the additional DRM30 sideband as depicted.

The behaviour and selectivity of conventional AM receivers in the presence of adjacent digital sidebands were assessed against various relative DRM30 power levels with respect to the reference AM carrier power. The blue ring in Figure E1 highlights the

75 Source: SBS.

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‘proximity’ issue which resulted in digital noise/crosstalk effects in some receivers as summarised in the key findings below.

Impact assessments were made of the overlapping DRM30 digital sideband on the adjacent channel AM transmissions, both for daytime (ground wave) and night-time (ground wave plus sky wave) propagation. Similarly, assessment of the impact of adjacent AM signals on the decodability of the DRM30 signal was undertaken.

SBS’s analysis of the audio quality at a number of different DRM30 transmission modes concluded that, for a 9 kHz simulcast, the low fidelity of transmission at 16-QAM (13.1 kbps) was unsatisfactory. The inclusion of Spectral Band Replication (SBR) was necessary in order to deliver DRM30 with reasonable fidelity; this required the adoption of the higher bitrate (but less robust) 64-QAM transmission mode, at 19.6 kbps. However, even at 19.6 kbps, some audio artefacts were noticeable on speech.

Key findings from the trial were:

 The signal field strength for satisfactory reception of the DRM30 simulcast in an urban/suburban environment was much higher than anticipated. Field strengths of ~60dBuV/m or greater were required for error-free mobile reception in an urban/suburban environment, even when using professional receiving equipment. However, satisfactory outdoor DRM30 reception was achieved in some areas at field strengths in the range 39-53 dBuV/m. Field strengths of 61dBuV/m or greater were required for indoor DRM30 reception.  The existing consumer DRM30 receivers of the day required a minimum field strength of 56dBuV/m to produce satisfactory outdoor reception under optimum conditions—in essence, the receivers were very insensitive.  Based on the receivers tested, the highest DRM30 simulcast power that could be reasonably used is -16dBc. There was significant potential for interference by the DRM30 simulcast transmission to reception of the adjacent channel (simulcast/companion) analogue signal, even at a recommended DRM30 simulcast power of -16dBc (DRM Handbook circa 2006). This interference was manifest as digital crosstalk, or digital high-frequency noise: o The potential for interference was worse for Hi-Fi tuners and car radios. Most portable receivers do not seem to be adversely affected by interference from the DRM30 simulcast—likely due to their lower Intermediate Frequency (IF) bandwidth as imported devices originally designed for the mass markets with a narrow channel raster spacing (of 9/10 kHz). o The potential for, and mitigation of, interference to existing analogue receivers needs to be investigated further.  At -16dBc, the simulcast signal fell well short of achieving equivalent coverage to that of the AM signal.  Encoding utilising SBR was required in order to satisfy certain audio quality thresholds; whilst the quality of music via a DRM30 transmission was determined to be very good by the panel of listeners, the quality of speech was found to have a “furry” quality compared to speech transmitted in the traditional AM mode.

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o SBR can only be transmitted at bit rates exceeding 16.48 kbps. This makes 64-QAM transmission mandatory in order for SBR to be transmitted. o The subjective impairments needed to be investigated further to see whether the problem lies in the DRM30 encoder or whether the artefacts are caused by incorrect levels or multiple analogue to digital conversion. This component of work was unable to be concluded during the trial window.

On conclusion of the trial and analysis of the results during 2006 and 2007, other than desktop research and industry engagements (e.g. seminars, vendor meetings), SBS has not since engaged in any further practical assessment of DRM systems.

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ATTACHMENT F – ENERGY CONSIDERATIONS – AM TRANSMITTER NETWORK

For the national broadcasters, 49 MF transmitters of the 113 operate at output power levels of 10 kW and above. These are the transmitters that provide coverage over a substantial part of the Australian land mass.

Table F1: MF transmitters and aggregate power and energy consumption estimates by broadcaster group 76

The DRM transmitter power levels required to deliver equivalent coverage are estimated at a power level of 4 to 6 dB below that of the AM carrier power (i.e. 25 to 40% of AM carrier power). The DRM transmitter (electrical conversion) efficiencies are cited to be in the range 70–80% .77 Furthermore, the DRM30 transmission (post analogue simulcast) can carry up to four program streams (quality subject to genre and codec), so facilitating material cost savings per program service.

76 Estimate based on average 74% transmitter energy conversion efficiency for the Nautel ND series which is representative of the high-power ABC MF transmitters (at 10kW and above). 77 Information sourced from the DRM Handbook (Revision 4, February 2019), Section 9.2.2, page 43 – courtesy the DRM Consortium – www.drm.org

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ATTACHMENT G – MOBILE CELLULAR COVERAGE & INFRASTRUCTURE

The coverage of the mobile cellular networks is provided in Figure G1 below. The Telstra network extends to over 10,000 base stations and provides coverage in all metropolitan cities, major regional cities and in over 1600 town and communities across Australia.78

Unlike the infrastructure utilised for high-power broadcasting, cellular infrastructure has more limited system redundancy and has limited power autonomy of no more than a few hours (typically 4 to 8 hours) provided by battery-supported UPS systems. Rural facilities are generally housed in small fibre-glass or metal cabins and are more vulnerable to the extremes of weather and bush fires.

Although the networks provide handover between cells, subject to capacity availability, the networks operate in UHF spectrum, and require virtual line-of-sight between the base station antenna and the handset. As a result, they do not provide the wide-area reliable contiguous coverage afforded by broadcast systems. The coverage maps below show the comparative coverage of Telstra 4G, Telstra 3G and AM radio.79

Figure G1: Coverage comparisons80

Mobile cellular network density has been progressively developed since 2006 for the 3G networks (although 3G will be progressively withdrawn from 2019 and replaced by 4G and ultimately 5G infrastructure); the 4G network has been rolled out in the period since 2011.81

78 Telstra published coverage information – https://www.telstra.com.au/coverage-networks/our-coverage 79 The Telstra network represents the “best case” scenario for mobile coverage. 80 Source: Telstra and Broadcast Australia. 81 Chronology of mobile cellular network development derived from Wikipedia and various industry websites – https://en.wikipedia.org/wiki/Telstra

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GLOSSARY OF TERMS

Term Meaning

5G PPP 5G Infrastructure Public Private Partnership – a joint initiative between the European Commission and European ICT industry

AIR All India Radio – the public broadcaster in India

AMC AM Companding – an energy saving technique which reduces the carrier power in proportion to the level of modulation AMC3 – carrier power nominally reduced by 3dB AMC6 – carrier power nominally reduced by 6 dB Companding typically operated in the range -3 to -6 dB

AMSS Amplitude Modulation Signalling System – a digital system for adding low bit rate information to an analogue amplitude modulated broadcast signal

BA Broadcast Australia – transmission service provider to SBS

Band I A broadcast services band of nominally 45–70 MHz previously licensed in Australia for the carriage of analogue television services, with some upper limit variation (74 MHz in OIRT countries)

Band II A broadcast services band of 87.5–108 MHz licensed in Australia for the carriage of FM radio broadcast services – also described as the ‘FM Band’

Band III A broadcast services band of 174–230 MHz licensed in Australia for the carriage of digital television and digital radio broadcast services

BSB Broadcast Services Bands – spectrum blocks licenced by ACMA for the carriage of broadcast services

COFDM Coded Orthogonal Frequency Division Modulation – a core digital modulation system which is utilised for digital radio and digital television transmission

DAB sub-band A sub-band within the Band III spectrum block allocated to DAB+ services throughout Australia. It utilises the ch9 and ch9A ‘television’ blocks

DRM DRM is the term used generically to describe all forms of Digital Radio Mondiale (i.e. DRM30 and DRM+)

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DRM30 Digital Radio Mondiale – the digital modulation scheme for use in spectrum up to 30 MHz; the scheme specifically applicable to MF broadcasting

DRM+ Digital Radio Mondiale – a digital modulation scheme for use in spectrum above 30 MHz and up VHF Band III

DSB Digital Sound Broadcasting – a term used in South Africa and other administrations

DTH Direct to Home (satellite feed)

EECC European Electronic Communications Code – which mandates a digital radio (DAB/DAB+) is fitted in all new cars across the EU from December 2020

EMEA Europe, Middle East and Africa eMBMS Evolved Multimedia Broadcast Multicast Services – a ‘broadcast’ mode of content/data delivery through an LTE (Long Term Evolution) network. eMBMS is also known as LTE Broadcast

ETSI The European Telecommunications Standards Institute (ETSI) is an independent, not-for-profit, standardization organization in the telecommunications industry in Europe ETSI produces globally-applicable standards for Information and Communications Technologies (ICT), including fixed, mobile, radio, converged, broadcast and internet technologies

EWF Emergency Warning Feature

FCC Federal Communications Commission – the spectrum regulator in the United States

FM Band A broadcast services band of 87.5 – 108 MHz licensed in Australia for the carriage of FM radio broadcast services – also described as ‘Band II’

GE75 A Geneva 1975 Agreement which covers ITU Regions 1 and 3 and employs a 9 kHz channel raster grid

HF High frequency – comprising a number of broadcast services spectrum blocks nominally in the range 3–30 MHz; otherwise refer to generically as ‘short-wave’

ICASA Independent Communications Authority of South Africa (the regulator)

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IF Intermediate Frequency

ITU International Telecommunications Union – a specialised agency of the United Nations – internationally coordinates the allocation of spectrum and setting standards on technical and operational matters

ITU-R ITU Radiocommunications Sector – one of three sectors of the ITU, and is responsible for radio communications

LF Band Low Frequency – a broadcast band not utilised in Asia-Pacific Allocated to broadcasting in ITU Region 1 Frequency range 148.5 to 283.5 kHz

M2M Machine-to-machine communications (Internet of things)

MF and MF Band Medium Frequency – a spectrum block of 526.5 to 1606.5 kHz in Australia, internationally coordinated

MFN Multiple Frequency Network

OIRT Organisation Internationale de Radiodiffusion et de Television (French) – an Eastern European network of radio and television stations, including other communist administrations

OTA ‘Over the air’ – traditional wireless transmission utilising broadcast services band (BSB) spectrum

PAD Program Associated Data

RAJAR UK Radio Joint Audience Research group – established in 1992 to align, design and operate a single audience measurement system for the UK radio industry serving both the BBC and licensed commercial stations

RDS Radio Data System – a communications protocol standard for embedding small amounts of digital information in conventional FM radio broadcasts. RDS standardises several types of information transmitted, including time, station identification, program information and ‘other network’ frequency information

SBR Spectral Band Replication

SDR Software Defined Radio – where the hardware implementation has been replaced by means of a computer or embedded system, typically using a field programmable gate array (FPGA)

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SFN Single Frequency Network

TPEG Transport Protocol Experts Group – a data protocol suite for traffic and travel related information. TPEG data can be carried over different transmission media (bearers), such as digital broadcast or cellular networks

WorldDAB/WorldDMB WorldDAB (formerly WorldDMB) is the global industry forum for digital radio, facilitating the adoption and implementation of broadcast digital radio based on DAB / DAB+

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