Comments on the Submissions to the Amendments to the ABC Act 1983

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Contents 31 Alan Hughes ...... 2 1 Julian Lawrence ...... 4 6 David Alford ...... 4 18 Peter Marks ...... 6 22 Frank Fedrick ...... 6 29 John Alexander Faulkner ...... 6 Alan H 20170 504

31 Alan Hughes

The ABC can save the $1.9 million that they are seeking by switching off AM transmitters for NewsRadio, and ABC Local Radio in , , , Adelaide and Perth. This will leave DAB+ digital radio for those audiences.

Electricity consumption of analog ABC/SBS transmitters in DAB+ areas1 Total Average AM electrical power is greater than 750,000 Watts Total AM Energy used in a year is greater than 6.6 million units (kWh) Price of the Energy used based on Synergy Domestic A1 tariff $1.7 million a year

Switching off ABC FM and JJJ in the above cities will increase the savings. The electricity consumption of FM transmitters cannot be calculated using publically available data. Ask Broadcast . Electricity consumption of backup Local Radio and Radio National transmitters is not included. The ABC Annual Report makes no mention of the total electricity consumption for the whole network. Neither does it mention the amount of carbon dioxide created to make this electricity but boasts about the replacement of some lamps in studio complexes.

Repeaters I mentioned that additional very low powered repeaters will be required on existing TV translator sites in mainland State capital cities. Existing DAB+ repeaters. They are on the same channel as the main transmitter. NSW: Market St Sydney (including Mosman), Collaroy Plateau (inc. Manly), Bilgola Plateau (for Bouddi), Redfern, Hawkesbury Heights (for Sydney North West), Gregory Hills (Picton). Qld: Mount Mee Vic: Collins St Melbourne (Melbourne Inner Suburbs), Port Melbourne, Darley WA: Mindarie, Perth City

11 Calculations based on 100 % modulation, no transmitter inefficiencies, excludes power for cooling and Diesel for backup power. The tariff paid by Broadcast Australia is not publically available.

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SA: No repeaters. TV translator sites requiring low DAB+ power repeaters Bold indicates broadcaster owned. NSW: Woronora Note: The ABC Central Coast has FM transmitter and as well as NewsRadio. JJJ and ABC Classics are currently poorly covered from Sydney or Newcastle. Note this is a separate licence area for commercial radio. Commercial wants DAB+ in this region. Vic: Ferntree Gully, Healesville, Marysville, Monbulk, Rosebud, Safety Beach, Selby, South Yarra, Upwey, Warburton Note: Geelong is a separate commercial licence area. Commercial Radio Australia is not pushing for DAB+ in this area which contains 3 additional TV translator sites. Qld: Boonah, Brisbane North West, Brisbane South East, Esk, Kooralbyn, Maroon, Mount Alford, Rathdowney Note: Sunshine Coast and Gold Coast are separate licence areas. All ABC analog services are on FM translators on the Gold Coast. Commercial Radio Australia is pushing for DAB+ in this region. The Sunshine Coast has all ABC analog services except JJJ on FM. Commercial Radio Australia is not pushing for DAB+ in this region. WA: Lancelin, Singleton, Perth Coastal, Roleystone, Two Rocks. Note: Mandurah is in a separate licence area, but is also covered from ABC South West. Toodyay (Not officially part of the Perth Metropolitan area) is fed from Dalwallinu and Northam AM and Mawson FM. SA: Adelaide Foothills, Angaston, Cape Jervis, Carrickalinga, Craigmore/Hillbank, Eudunda, Gumeracha, Lyndoch, Maitland, Mannum, Myponga, Normanville, Strathalbyn, Swan Reach Victor Harbour, Yankalilla.

The ABC seems to think you can listen to their programs via VAST when mobile The automated Satking satellite TV antenna is designed for caravans and it automatically lowers if the caravan is moving at greater than 10 km/h. So listening to the radio component of the VAST signal mobile will be very slow!

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1 Julian Lawrence There is still considerable HF broadcasting even if some “first world” counties have stopped transmitting it. Australia is unique in that we are the largest island with mostly a 370 km territorial sea limit, with large areas of low population density. This description does not fit many of the countries of Asia. I have listed in my submission a list of high frequency broadcasters in Asia and Oceania.  Viewer Accessed Satellite Television VAST is a television service with some audio channels from ABC/SBS radio stations tacked on. VAST receivers are DVB-S2 with MPEG-4 decoding for HD and SD signals. They contain conditional access because VAST contains commercial broadcasters for the licence area for the Western and Eastern foot prints which overlap on terrestrial licence areas. The commercial broadcasters sell advertising on the know number of potential viewers and purchase price of programs is on the same basis, thus it is important to restrict access to VAST viewers who are outside terrestrial commercial broadcasters coverage. Also advertisers don’t want to pay for coverage in areas where their customers are unlikely to reach them.  There are two other competitors for the South African satellite receiver boxes. One is Australian designed and manufactured overseas and the other is Japanese.  Mobile VAST will not work because a dish must be kept pointed at the satellite even when the vehicle changes direction, goes up and down hills and this is even worse on boats. Only ships which are stable enough and have an expensive servo controlled dish mount can keep the dish pointed at the satellite. The omnidirectional antenna on the bull bar for an HF receiver can receive signals from any direction.  The Skymuster satellite NBN is for fixed locations. The only mobile satellite internet which is available is marketed at mining companies and governments because of the huge costs.

6 David Alford  “Digital radio, as in DAB+ (an area that the ABC has stated they would redirect the funds to) may in fact become another AM Stereo, Betamax, HD DVD or DRM for shortwave style story that doesn’t take off. Digital radio hasn’t made its way out of the city areas and as I understand it has had limited take up due to quality issues (low transmission quality for multi stations in the same bandwidth) and reception limitations in moving vehicles. That’s not to say it won’t take off but it shouldn’t be at the expense of tried and proven communication platforms and disadvantage listeners that often have limited options.” The latest GFK ratings for DAB+ is 3.5 million listeners in a total population of 14 million people including babies. The car importers/manufacturers also install DAB+ receivers on the production line but they don’t advertise it. Manufacturers include Holden, Ford, Toyota, Mazda, Hyundai, Mitsubishi and Kia. India has just completed high powered DRM coverage of the whole country. Hyundai and Mahindra & Mahindra are installing DRM receivers in their Indian cars as standard equipment.

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The low transmission quality is a false fact which has been circulated on the internet, which was started in the UK which uses an older, less efficient system with too many broadcasters. It certainly is not true of the ABC. The sound quality of ABC local radio on DAB+ in metro stations is in stereo which has the high pitched sounds and no background noise which is not true of the AM version of this program. Radio National metro has similar characteristics. Ask the complainer to nominate which ABC program and which sound, demonstrates low transmission quality.  The reason why DAB+ hasn’t moved out of the cities is because of; o Smallest coverage area for the power used. . DAB+ has the smallest coverage area due to its very high frequency of transmission. There is even repeaters within the current coverage areas and more are required. . DAB+ operates from 195 – 209 MHz which is double the FM band 87.5 – 108 MHz but for large coverage areas a lower frequency is required. 47 - 68 MHz is cleared of analog TV channels 0 – 2 and is suitable for DRM+ and DRM30 is available for the MF band currently occupied by “AM” radio and the HF band. . The ABC covers regions and uses AM in the 0.531 to 1.602 MHz band and some high powered FM to cover larger areas than DAB+. DRM can digitise all the lower frequency bands to give the same coverage area as existing AM and HF transmissions. o DAB+ broadcaster sharing costs . DAB+ is designed for a large number of broadcasters to share a single transmitter including its costs this works in the metropolitan areas. . The ABC/SBS transmitters are paid for by the Commonwealth Government so there is no sharing of cost. Since there is only 8 DAB+ transmission channels, the ABC/SBS will be forced into single frequency networks. So outside of the capital city ABC/SBS will have to buy data from the commercials for the transmission of ABC local radio because the program content is not identical in each location. . In regional and remote areas there is generally one commercial broadcaster per licence area who transmits an AM and an FM program. There is little chance of sharing costs. DRM+ is matched to these broadcasters transmitting their pair of programs in really good quality and adding text and images which can convey advertising. o Insufficient channels . There is only 8 transmission DAB+ channels and for regional use the transmitters on the same transmission channel can’t be less than 336 km apart, whereas DRM+ there is 169 channels which would have to be a slightly greater distance apart before the same transmission channel can be reused. o DAB+ is incapable of replacing high frequency radio because of its very limited coverage area.

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18 Peter Marks  Radio New Zealand International still transmits both DRM and AM but not at the same time. http://www.radionz.co.nz/international/listen  VOA Radiogram is experimental. It and it requires a computer connection to the radio. DRM is capable of transmitting text and images and sound simultaneously at a much lower data rate and the display is integral within the DRM receiver.

22 Frank Fedrick  Whist high powered FM transmitters have a coverage up to 100 km, Darwin’s FM is medium power but all of the other transmitters are extremely low powered. Mobile phone towers and the very low powered FM have a similar coverage areas ie only in the village in which they are located. A typical example is http://www2b.abc.net.au/reception/frequencyfinder/asp/largemap_test.asp?trans missionid=3903&presdir=

29 John Alexander Faulkner

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 http://www.gospell.com/china- gr_216_new_generation_drm_receiver_am_and_fm_stereo_reception- 8536660.htm This radio is made in China too. It receives HF DRM as well as HF AM (short wave). It has a screen because it can display transmitted text and coloured still pictures. Note: Under bad reception conditions the text and images will not be replaced until it is error free. The broadcaster will repeat the text and images continuously until they change the content.

 BBC still transmits from Thailand and Singapore http://downloads.bbc.co.uk/worldservice/schedules/frequencies/bbc_world_service _east_asia_frequencies.pdf and in DRM digital http://www.drm.org/wp-content/uploads/2016/10/BBC-DRM-Schedule-2016- Asia.pdf  “Digital modes (DAB+ and DRM) can provide excellent quality, but they have the problem of the “digital cliff”. Whereas an AM signal will vanish slowly into the static, a digital signal is either there or not.” o When an AM transmitting is transmitting at maximum volume, 67 % of transmitted power is contained in the carrier which carries no information. If AM is transmitting silence the carrier is 100 % of the signal power. By contrast DRM contains no carrier and uses a few low powered pilots to perform the functions of the carrier. As a result the digital cliff will occur when the AM version is already unintelligible. The South African sound grab example in my submission demonstrates this. o Remember also that the text received will be stored until a valid replacement is received.

 “DRM receivers are expensive and in short supply; they do not perform well at high noise levels. DRM chips are power-hungry and they quickly exhaust batteries.” o Remember: Australia was the first country to start DAB+ transmissions. Receivers were modified UK DAB models and were expensive at the time, a chain store is selling them for $29. The price of receivers depends on demand. o India has a population of 1300 million people. http://www.drm.org/digital- radio-mondiale-drm-digital-radio-for-all-india/ Hyundai i10 and Mahindra cars now have DRM radios built in. o Indonesia has a population of 200 million http://www.drm.org/digital-radio- mondiale-drm-welcomes-radio-republik-indonesia-rri-to-drm-consortium- and-signs-cooperation-agreement-to-introduce-drm-digital-radio-technology- in-indonesia-in-2016/ and https://youtu.be/ZkkasCan4Yg

7 o New Software Design Radios use a single chip which drastically reduces production cost and power consumption. A program for SDR these is available from https://www.iis.fraunhofer.de/content/dam/iis/en/doc/ks/bb/DRM_Receive r_Kit_Flyer_Englisch.pdf o The SDR receiver based on a tablet, to cost around $Au140

http://titusradio.com/wp-content/uploads/2016/08/Titus_quad-fold-2.pdf This radio will receive DRM30 and DRM+ along with DAB+, FM and AM. o I am yet to see the power consumption of DRM receivers. This was true of DAB+ radios back in 2009, but there are much better integrated circuits now. Radios with the ability so show text and pictures will use more power than those without, however in the meantime, rechargeable lithium batteries are now commonly used and they store much more energy. It is not a problem in cars either.

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