Australian Broadcasting Corporation

submission to

The Australian Government

Technologies for digital radio services in regional Australia

Discussion paper

December 2010

ABC submission on digital radio technologies for regional Australia

Executive Summary

The Australian Broadcasting Corporation (ABC) is committed to digital radio in Australia. Digital radio provides listeners better sound, clearer reception, easier tuning, the ability to pause and rewind live radio, information in text and pictures, an electronic program guide and more radio stations to choose from.

The Corporation is committed to its services, including digital radio services, being available to all Australians, who own and pay for those services, regardless of where they live. The notion of equitable access is enshrined in the ABC’s Act and Charter and is the basis on which it creates content across its many platforms.

Accordingly, the Corporation believes that digital radio should be rolled out to regional areas as soon as possible to ensure equity of services and to provide the public, broadcasters, retailers and the automotive industry certainty to invest in the platform.

The ABC considers that DAB+ in VHF Band III should be the primary platform for digital radio throughout Australia. DAB/DAB+ is the only proven digital radio technology with widespread international support for which receivers are readily and widely available. It presents the most viable technology for coverage of all metropolitan areas, regional centres and towns in Australia in the short-to-medium term.

14MHz in VHF Band III is inadequate for DAB+ local services in Sydney and adjacent markets (Wollongong, Central Coast and Newcastle), Melbourne and adjacent markets (Geelong, Bendigo and Ballarat) and Brisbane and adjacent markets (Gold Coast, Sunshine Coast and Ipswich). Additional VHF Band III spectrum needs to be reserved for digital radio.

Suggestions of commercial and national broadcasters sharing a single digital radio ensemble in some markets using only 14MHz is unacceptable to the ABC as it would reduce either the quality or number of ABC services provided within that ensemble.

The ABC would support further investigation of DRM30 and DRM+ to provide infill services/ wide area coverage to areas that will not be economically reached by DAB+; VHF Band I spectrum should be reserved for the possible future use of DRM+ for digital radio

The Corporation does not believe that the various other technologies listed in the discussion paper (L-Band DAB/DAB+, satellite radio, IBOC) are viable as a primary platform for digital radio in Australia.

The ABC believes that the current legislative definition of enhancements to digital radio programs to text and still images should be extended to include animation and video clips of a short

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duration, for example animated weather maps. For emergency broadcasting, these ‘enhancements’ could prove crucial in informing ABC audiences.

Introduction

The ABC welcomes the opportunity to respond to the Australian Government’s discussion paper on technologies for digital radio services in regional Australia and to contribute to the formulation of policy on the future of digital radio in Australia.

The Corporation commenced the broadcast of digital radio in the five mainland capital cities (Sydney, Melbourne, Brisbane, Adelaide and Perth) in July, 2009. These digital radio broadcasts use the Digital Audio Broadcasting technology, DAB+ in VHF Band III (Channel 9A). In each capital city, the ABC shares a single DAB+ ensemble with the Special Broadcasting Service (SBS).

Discussion

ABC support for digital radio The ABC considers digital radio to be more than just the next generation of radio; it is an integral part of the emerging digital media landscape. Analog media is coming under increasing pressure from new technologies and platforms. Multi-channel digital broadcasting, internet streaming, peer-to-peer file sharing, media-on-demand, podcasting and an increasing range of mobile devices are breaking down the traditional limitations of conventional radio and television, providing more convenient access and specialised content to increasingly fragmented and interactive audiences. Digital radio is far better placed to meet increased audience expectations and offer much more than the relatively passive listening experience of traditional analog radio.

The ABC has maintained a long-standing commitment to digital radio and has played a pivotal role in its development and introduction in Australia. Following a successful implementation of digital radio in the five mainland capital cities in 2009, the Corporation is well-placed to be an integral part of a successful roll-out to regional Australia, offering audiences the enhanced features and increased programming choices that digital radio can provide.

Digital radio’s benefits and content proposition

Digital radio gives listeners better sound, clearer reception, easier tuning (by station name), the ability to pause and rewind live radio, program-related and other information in text and pictures, and an electronic program guide which lets listeners search for and record programs much like digital television.

However, one of the main attractions of digital radio for audiences is access to new, different and compelling content and it is the opportunity to provide this type of content that underpins the ABC’s commitment to the platform.

Along with the digital simulcasts of its five analog radio services – ABC Local Radio, ABC , ABC Classic FM, ABC NewsRadio and – the ABC also currently provides five digital-

2 only radio services ABC Dig Music, ABC Jazz, ABC Country, ABC Grandstand Digital and ABC Extra. The ABC will launch a sixth digital only radio service in 2011; triple j Unearthed.

ABC Dig Music provides alternative, strongly Australian, diverse music – rock, pop, soul, folk, etc – for 30-45 year olds, an audience demographic which currently does not listen to ABC Radio as much as some others. Many of them were triple j listeners but have out-grown that station’s music; they are also not interested in classical music and are not drawn to ABC talk stations in significant numbers (particularly at the younger end of the demographic) and so have nowhere else to go. An alternative music service of this sort is also not provided by commercial or community radio in any consistent way.

ABC Jazz and ABC Country are also distinctive and strongly Australian services, responding to two major niche audiences currently under-served by radio generally. They build upon the ABC’s long- standing reputation and expertise in the area, in both radio programming and commercial CD/DVD production.

ABC Grandstand Digital capitalises on one of ABC Radio’s greatest strengths; it is the primary digital destination for radio sport, broadcasting all major ABC sports coverage as well as additional sport not found on ABC Local Radio, such as uninterrupted international cricket, A League soccer, continuous coverage of the Australian Tennis Open and alternative football codes. Currently a part-time service, the ABC aims to develop this service with more coverage as well as sports current affairs and analysis, as resources become available. Given the popularity of sport on ABC Local Radio, ABC Grandstand Digital considers it to be a positive driver for digital radio uptake.

ABC Extra is an occasional service (“pop-up station”) used for special event broadcasts; these range from a single day through to several weeks and have included such things as the 40th anniversaries of the 1969 moon landing and the Woodstock music festival, the 10th anniversary of East Timor’s independence referendum, coverage of the Melbourne International Arts Festival and the Sydney Writers’ Festival, and triple j Unearthed during Australian Music Month. It is a highly flexible and innovative way of providing listeners with new and different content which may not sit easily on other ABC services.

These new digital services have also enabled the ABC to better meet the needs of its existing audiences. For example, the digital version of ABC Classic FM provides more classical music instead of jazz programs which are on ABC Jazz. Similarly, the digital broadcast of ABC Local Radio provides general programming rather than cricket coverage, which is broadcast on ABC Grandstand Digital.

In 2011, ABC Radio will also launch triple j Unearthed as a full-time digital radio station devoted to new music from the triplejunearthed.com website. The station will be the only 100% Australian radio offering in the country, playing music solely from unsigned and undiscovered artists from metropolitan and regional areas around Australia. It will reflect Australia’s vibrant and thriving music scene and offer airplay to many artists that have never been exposed on the airwaves. The triplejunearthed.com website currently hosts around 60,000 tracks from 27, 000 separate artists. Artists that have previously risen to national prominence from triple j Unearthed include Missy Higgins, Grinspoon, Washington and Art vs Science.

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Commercial radio in Australia has also enthusiastically embraced new, digital only radio content with a range of content offerings; most metropolitan stations now provide digital multi-channels. There are now, for example, more than 40 digital radio stations available in Sydney and Melbourne. There will be more once the community stations begin digital broadcasting.

The future of radio is digital Digital radio has been enthusiastically adopted by capital-city audiences. It has far exceeded initial industry expectations, with nearly 200,000 receivers sold and well over 500,000 listeners in the first year. Better sound and reception, enhanced features and new stations have all been key drivers of this take-up.

The ABC believes that the long-term future of radio is digital. In a converged environment where all media is digital, it would be short-sighted to leave radio trapped in an analog environment and costly to leave it straddling both spectrums. Moreover, the digital experience has made audiences more demanding - radio will fall short of listeners’ expectations if it cannot offer the easy access to specialised content of other digital media. AM broadcasting also faces physical challenges, including electrical interference and reception issues in large glass and steel buildings, electromagnetic radiation (EMR) concerns and development pressures on the prime real estate on which transmitters are located. AM receivers are also becoming less available over time. Commercial and community broadcasters, and the Australian taxpayer, will not be in a position to support two sets of transmission and distribution infrastructure – analog and digital - in perpetuity and should not be required to do so. Indeed, the industry’s current content offering reflects a replacement rather than supplementary approach. Analog services are simulcast in digital in the first instance and then additional digital-only content provided. This is because, as listeners convert to digital, they expect to be able to continue to hear their usual radio stations as well as the new digital-only offerings; they do not want to have to switch platforms or receivers to receive their usual range of services. A supplementary approach to content delivery risks creating an analog/digital divide similar to the demographic divide that has evolved around AM and FM since 1980.

While the ABC accepts that a full transition to digital is some way off for radio it believes that a replacement approach should be outlined by Government. To this end, the Government should consider mandating digital reception capability in radios, as is happening in Europe, in order to ensure a smooth transition to digital.

Principles for digital radio in regional Australia

The ABC is firmly committed to the principle of equity of access to services and believes that its services should be available to all Australians, who own and pay for those services, regardless of where they live. Regional Australians should not be denied services available to city audiences, including access to the enhanced features and additional content that digital radio services provide. Should regional roll out of digital radio not proceed, ABC radio listeners in regional Australia will

4 receive fewer than half the ABC Radio services available to capital-city audiences. In the Corporation’s view, this would be an undesirable public policy outcome.

From a technology or platform point of view, digital radio’s success depends on its national availability. A key contributing factor of this success would be the adoption of a national standard for the primary delivery platform of digital radio.

Regional roll-out should be undertaken as soon as possible in order to provide certainty to the public, broadcasters and retailers and ensure its long term success. It is also important to provide the Australian automotive industry certainty, so that they install factory-fitted, in-car receivers. The geographically-restricted availability of digital radio broadcasts has contributed to vehicle manufacturers’ reluctance to embrace the technology, which in turn acts an impediment to consumer take-up as more than 30% of radio listening in Australia is in-car. The expansion of digital radio into regional Australia will help to address this issue.

VHF Band III DAB+ the primary platform

The ABC believes that there needs to be a single primary platform for digital radio in both metropolitan and regional Australia and that that platform should be DAB+. The DAB family of standards (DAB/DAB+/DMBA) in VHF Band III remains the only proven digital radio technology with widespread international support for which receivers are readily and widely available. As this is likely to remain the case for the short to medium term, DAB+ should be deployed nationally as the primary digital radio platform as soon as possible.

VHF Band III DAB+, currently and in the short to medium term, presents the most viable technology for coverage of all metropolitan areas, regional centres and towns and main connecting highways in populated areas. The ABC currently covers between 95 – 98% of the Australian population with FM. As its propagation pattern is similar to FM, DAB+ in VHF Band III has the potential to reach a comparable proportion of the population using a similar number of transmitters as the ABC’s present FM network, in most cases from the same sites on which the FM transmitters are located.

Spectrum requirements for VHF Band III DAB+

In its response to the Australian Government’s Digital Dividend Green Paper in February 2010, the ABC indicated that, to enable the expansion of digital radio regionally, the channel plan for the digital television re-stack should allocate three contiguous channels of VHF Band III spectrum - for example, channels 9, 9A and 10 – or 21MHz, for digital radio nationally.

The ABC is concerned that the Minister’s directive to ACMA, under which only 14MHz of VHF Band III spectrum is to be allocated for digital radio in capital-city markets, will constrain the industry’s ability to provide the full mix of national and appropriate local radio services in the markets adjacent to the major capital cities of Sydney, Melbourne and Brisbane.

The ABC has investigated its VHF Band III spectrum requirements for DAB+ for these areas, using a combination of multiple and single frequency networks to deliver the equivalent mix of appropriate

5 local and national services currently available in the capital cities. This investigation indicated that there is a requirement for 12 ensembles, or a full 21MHz, for Sydney and adjacent markets (Wollongong, Central Coast and Newcastle) and 10 ensembles, or 17.5MHz, each for Melbourne and adjacent markets (Geelong, Bendigo and Ballarat) and Brisbane and adjacent markets (Gold Coast, Sunshine Coast and Ipswich).

The Corporation is aware of suggestions that it may be possible to deliver digital radio in a number of regional markets, including those surrounding the East-Coast capital cities, using only 14MHz of VHF Band III spectrum by requiring commercial and national broadcasters to share a single digital radio ensemble in those markets. Such an approach is unacceptable to the ABC as its allocation of the national ensemble in each city is fully committed with digital content as outlined above.

Accommodating one or more commercial stations would require the Corporation to reduce either the quality or number of services it provides within a shared ensemble. It would enshrine a two- tiered system, reducing regional listeners’ access to digital radio services in many areas. In addition, the shared-ensemble model makes no allowance for digital community radio services and would constrain the possibility of growth for the community sector in those areas.

Provision of additional spectrum beyond the current proposed 14MHz is crucial to the success of the platform. Inhibiting the full range of relevant local and national services available in the major metro- adjacent and other regional markets will have an adverse impact on digital radio, relegating it to a supplementary technology and impeding its full national adoption.

Wide-area platforms

As noted above, VHF Band III DAB+ has the potential to reach up to 98% of the Australian population using a similar number of transmitters as the ABC’s present FM network. However, ABC Local Radio currently covers over 99% of the population largely through a number of strategically placed high- powered and medium-powered AM transmitters, as well as low-powered town-only FM relays to small communities in outlying regional and remote areas and domestic shortwave services across the Northern Territory. DAB+ will struggle to match this level of population coverage, as well as covering the connecting roads between towns in outlying regional and remote areas.

Other platforms, such as Digital Radio Mondiale (DRM30 and DRM+), may be potential candidates to address such wide-area regional and remote area coverage for digital radio in the longer term. DRM30, having been designed to work in the AM and shortwave bands below 30MHz, has the capability to cover large land masses, similar to that of present AM and shortwave radio transmissions. DRM+ transmission is above 30MHz, typically in VHF Bands I and II, and has propagation characteristics more like, though substantially better than, FM radio.

Low-powered DRM30 or DRM+ transmissions may also prove viable for suburban community stations in the longer term. However, as there is no spare spectrum in the AM Band in Australia to enable simulcasts of existing AM stations on DRM30 using separate frequencies, and, as a DRM30/analog simulcast on an AM station’s existing frequency substantially reduces coverage, there is no readily apparent transition mechanism to DRM30 for listeners to existing analog AM services.

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As a result, DRM+ may prove a more viable solution for in-fill and wider area coverage in rural and remote areas. The ABC considers that VHF Band I spectrum should be cleared during the analog television switch-off and the digital television restack and be reserved for the possible future use of DRM+ for digital radio.

The ABC would support further investigation of DRM30 and DRM+ as potential digital radio standards for wide-area coverage in regional/remote areas, particularly for ABC Local Radio, in longer the term. However, the Corporation also notes that there are a number of impediments to the immediate adoption of either DRM technology, particularly with regard to receiver availability. While there are many different types of DAB+ receivers and DAB receivers on the market, commercially available DRM30 receivers are extremely limited and, at this stage, there are no receivers for DRM+. In addition, there are also no dual-standard DAB/DRM receivers available and the ABC is unaware of any chip manufacturers planning to provide multi-standard chips incorporating both the DAB and DRM families of standards.

Neither DRM30 nor DRM+ is likely to be viable in the short-to-medium term. Continued investigation of the long term potential of DRM technologies should not be allowed to delay a regional roll-out of DAB+ as the primary digital radio standard serving the overwhelming majority of Australians.

Other technologies

The ABC does not believe that the various other technologies listed in the discussion paper are in any way viable as a primary platform for digital radio in Australia.

L-Band DAB+

While the DAB/DAB+ technology is also standardised within the L-Band frequency range (1452- 1490MHz), coverage at these frequencies is much more limited than that in VHF Band III due to propagation issues in the higher frequency range. Typically, more than four L-Band transmitters are required to replicate the coverage of a single VHF Band III DAB+ transmitter, making L-Band a very expensive option for widespread digital radio deployment. Additionally, there are very few L-Band or dual L-Band/Band III DAB/DAB+ receivers currently available or likely to become available in the short-to-medium term.

There have been a number of national L-Band deployments of DAB, most notably in Canada and Germany. For both coverage reasons and a variety of mainly local reasons, these deployments have not been successful and have not seen widespread consumer acceptance. This has, in turn, contributed to the current lack of receivers internationally.

However, it is recognised that most DAB chipsets include L-Band capability and so dual L-Band/Band III receivers could be produced reasonably cheaply should a mass market develop for them in response to a successful national deployment of L-Band DAB/DAB+. Should that occur, L-Band may prove a cost effective in-fill solution for limited black-spots in Australia at some future stage.

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Satellite Radio

Digital satellite radio has been primarily used for subscription-based services in the USA, typically in the S Band 2GHz radio frequency range.

Given the high cost of both space and ground infrastructure, the ABC considers that it is highly unlikely that this technology is a cost-effective option for a country with Australia’s large land mass and relatively small population on either a subscription or advertising supported basis.

IBOC

The US In-Band-On-Channel (IBOC) digital radio system, a propriety standard marketed as HD Radio, broadcasts digital channels in the sidebands of existing AM and FM frequencies.

IBOC has struggled to prove itself either technically or commercially. The commitment of broadcasters to the system has been patchy, receiver availability remains limited and there has been no great consumer take-up. Technically, IBOC has never been able to be made to work at night on AM frequencies due to sky-wave interference. This would be unacceptable in a country like Australia where half the radio listening is to AM services. Moreover, as IBOC is based on US spectrum plans which require 10MHz per AM channel rather than 9MHz as in Australia, it would require the complete re-planning of Australia’s use of the AM Band and it is doubtful it would be able to accommodate all current broadcasters.

Other regulatory matters

The definition of “digital program enhancement content” for digital radio in Section 6 of the Broadcasting Services Act 1992 (“BSA”) restricts enhancements to digital radio programs to text, still images and any additional forms specified in a legislative instrument by the Minister.

The ABC understands that the motivation for restricting enhancements to digital radio programs in this way was to ensure that digital radio services are not able to compete with television services.

Digital radio has the potential to allow radio to become a much more visual and interactive experience. However, the BSA currently restricts this development to the detriment of audiences.

The ABC believes that the definition of digital program enhancement content should be extended to include animation and video clips of a short duration to enable such things as transmission of broadcast web pages, animated weather maps and short video clips that illustrate news and sport coverage. As the nation’s emergency broadcaster, the ABC believes that, during natural disasters such as cyclones or bushfires, the ability to show animated maps would be of considerable value.

The Corporation notes that this sort of content is already widely available via mobile devices, including phones. In a digital radio context, it would be used to create richer radio rather than a poor substitute for television.

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It is enhancements of this kind that will ensure that digital radio becomes an integral part of the new digital multi-media environment. Conversely, it is such enhancements that will help drive the take-up of digital radio, enabling digital radio to play this integral role.

Conclusion

The ABC considers that this review provides a valuable opportunity for Government to end the divide that presently exists between regional and mainland state capitals cities and to develop a long-term strategy for the national roll-out of digital radio in Australia.

A clear and comprehensive policy and strategy for the national roll-out of digital radio is required in order to provide the certainty required for investment in this new technology. Critical to this planning is the choice of technology.

The Corporation would be pleased to continue to work with the government to help to plan for a national roll out of digital radio and to secure the future of digital radio in Australia, for all Australians.

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