19 December 2009 - DIGITISATION OF BAND II – ECC REPORT 141
AER POSITION

The Association of European Radios (AER) is a Europe-wide trade body representing the interests of over 4,500 commercially-funded radio stations across the EU27 and in Switzerland.

AER's main objective is to develop and improve the most suitable framework for private commercial radio activity. AER constantly follows EU actions in the fields of media, telecommunications and private radio transmission, in order to contribute, enrich and develop the radio sector.

AER therefore welcomes the opportunity to comment on the very comprehensive and very well written draft European Communication Committee (ECC) within the European Conference of Postal and Telecommunications Administrations (CEPT) report 141 on the future possibilities for the digitalisation of Band II (87.5 - 108 MHz) – draft ECC report 141. A few amendments to the latter are however indicated in the enclosed document as suggested by the ECC. These amendments are based on the following considerations:

Commercially-funded radios constitute indeed a unique network of small and medium-sized enterprises (SMEs) , contributing to cultural diversity, media pluralism, access to creativity, social inclusion. They also offer free-to-air services of general interest. Indeed:
- they evolve in highly competitive environments
- their programmes encompass, broadly speaking, all possible formats, from debates to music-only
- as for the music broadcast, within one market, as soon as there is demand expressed, it has to be fulfilled; so, most of the musical expressions are represented
- most of them are non-politically affiliated, and certainly keep the freedom to express their opinion
- their audiences are mostly local and regional, sometimes national
- during natural, major or minor disaster, radio is one of the first tool to inform the public
- they strive to develop on all possible platforms

Although radio might not evoke spontaneously the most modern medium, it has, for the past 50 years at least, been granted with all its attributes: ubiquitous, mobile, simple-to-use and free-to-air. This also makes radio the most intimate medium: the features mentioned above enable our audience to cultivate a personal relationship with our programmes, our DJs, our hosts, and our brands. Our listeners thereby access programming they enjoy, and useful information . Thus, Band II is the frequency range between 87,5-108 MHz and only represents 20,5 MHz. Nearly every single frequency is used in this bandwidth. Thanks to the broad receiver penetration and the very high usage by the listeners this small bandwidth is very efficiently used.

It should be underlined that, in most of Europe, currently and for the foreseeable future, there is only one viable business model: free-to-air FM broadcasting on Band II. On-air or internet-based commercially-funded digital radio has indeed not yet achieved widespread take up across European territories. These two means of transmission will be part of the patchwork of transmission techniques for commercially-funded radios in the future, but it is hard to foresee when . 

So no universal switch-off date for analogue broadcasting services can currently be envisaged and decision on standards to be used for digital radio broadcasting should be left to the industry on a country-by-country basis.

Radio’s audience is first and foremost local or regional. Moreover, spectrum is currently efficiently managed by European states and this should remain the case: national radio frequency landscapes and national radio broadcasting markets are different, with divergent plans for digitization, diverse social, cultural and historical characteristics and with distinct market structures and needs. European States already coordinate their views through existing international fora, such as the International Telecommunications Union (ITU) or the European Conference of Postal and Telecommunications Administrations (CEPT). For Band II, the GE84 plan is currently widely applied and is adequate for the current and foreseeable future.

So no further change to the GE 84 plan should be suggested, but the plan should be applied with consideration to the technological development (and its enlarged scope of possibilities) throughout the past 25 years. In any instance, regulation must be tailored to local needs in order to allow the best possible development.

Finally, AER would like to recall that European radios can only broadcast programmes free of charge to millions of European citizens, thanks to the revenues they collect by means of advertising. However, these revenues are decreasing all through Europe due to two factors: the shift towards internet-based advertising, and the recent financial crisis. For 2009, radio advertising market shares are forecast to decrease by 3 to 20% all across Europe compared to 2008 . However, any shift towards digital radio broadcasting entails very long-lasting and burdensome investments. Nevertheless some individual nations may wish to proceed with a move to greater digital broadcasting at a faster rate, as there will be no ‘one-size-fits-all’ approach.

So any shift towards digital radio broadcasting will most likely require a very long process. Decision on the adequate time-frame should be left to each national industry: as a matter of principle, transition to any improved digital broadcasting system should benefit from a long time-frame, unless there is industry agreement to move at a faster rate.

Corresponding changes have been added to the draft ECC report 141 as enclosed.

To end up with, AER would like to recall that, in most of Europe, currently and for the foreseeable future, there is only one viable business model: free-to-air FM broadcasting on Band II; hence:
- no universal switch-off date for analogue broadcasting services can currently be envisaged
- no further change to the GE 84 plan should be suggested, but the plan should be applied with consideration to the technological development (and its enlarged scope of possibilities) throughout the past 25 years
- any shift towards digital radio broadcasting should benefit from a long and adequate time-frame

AER remains available to explain this position in further details, should this be helpful to the ECC.

ENDS
19/12/2009

Contact details:  
Frederik Stucki
AER Secretary General
76, av. d’Auderghem,
B-1040 Brussels,
Belgium
Tel: +32 2 736 9131
Fax : +32 2 732 8990
www.aereurope.org