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Ian Devlin, The Student Radio Association Ltd, c/o The Radio Academy, 5 Market Place, London, W1W 8AE, Ian Vaughan, Floor 6, Dept Consumer Policy, OFCOM, Riverside House, 2A Southwark Bridge Road, London, SE1 9HA Dear Ian, I am writing on behalf of the Student Radio Association Ltd (SRA), in response to your proposals for access and inclusion. Our response is not confidential. We agree with OFCOM’s proposed prioritisation of improving current generation broadband standards. Current generation broadband speeds are sufficient for the minimum requirements of our members (i.e. audio streaming). However, student radio is constantly evolving and universal coverage of a minimum standard would be welcomed by the student radio community. Every member of the Student Radio Association Ltd is reliant on sufficient broadband provision for listeners, especially with regards to online streaming of audio. Therefore, we believe that achieving a minimum standard that is sufficient for multiple audio streams, in addition to standard web use, would be welcome. We are concerned by the increased number of ISPs that use “bandwidth throttling” technology. OFCOM must be provided with the necessary legislative power to ensure that the minimum broadband speed proposed by the Government is provided by ISPs. In addition to the above, we believe that the current status of a possible digital radio switchover needs to be clarified by OFCOM at the earliest opportunity. We therefore urge OFCOM to make this its next priority. We see a need for OFCOM to ensure that Access and Inclusion applies to both providers and consumers of radio. It is an essential to the survival of student and indeed all voluntary radio stations in the UK that FM frequencies are maintained in their current analogue form for the foreseeable future, or for there to be a provision of funding to assist voluntary radio stations in the UK to be able to switch to DAB / DRM. We retain our view, as stated in our 2007 response to OFCOM’s “Future of Radio” consultation, that if commercial stations make the transition to digital only broadcasting, that available VHF Band II spectrum should be allocated to stations wanting to transfer from LPAM licenses. We also re-iterate to OFCOM our position that talk of analogue “switch-off” is postponed indefinitely until a suitable transition to DAB / DRM platforms becomes feasible. We therefore see OFCOM’s future role in promoting access and inclusion as an additional voice to promote and ensure that the interests of student radio stations in the UK are given fair consideration in future consultations regarding digital radio provision. In summary, we believe that OFCOM’s main priority or current generation broadband is the correct one. However, we believe that the current situation regarding digital radio and the possibility of a switchover needs to be clarified at the earliest opportunity and that the SRA should be invited to contribute to any further discussions on the issue. Yours Sincerely, Ian Devlin Development Officer, Student Radio Association .

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