Radio Spectrum Policy Group – Future of Radio Broadcasting

21 January 2011 – RADIO SPECTRUM POLICY GROUP – FUTURE OF RADIO BROADCASTING IN EUROPE – 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 is located at:

Association Européenne des Radios
76, av. d’Auderghem,
B-1040 Brussels,
Belgium

AER’s Interest Representative Register ID Number is 6822083232-32.

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 warmly welcomes the opportunity to express its views on the report prepared in the frame of the Working Group of the Radio Spectrum Policy Group (RSPG) RSPG10-39 on the Future of Radio Broadcasting in Europe (herein after “RSPG report on the Future of Radio Broadcasting”). This document constitutes a very thorough and in-depth presentation of the state-of-play of digital radio’s development across Europe, and AER thanks RSPG for this extensive piece of work.

On-air broadcasting radios reach massive audience on a daily basis in all EU Member States: between 60 and 85% of the EU population on average listens to radio for at least 2 or 3 hours per day, as shown by national audience measurement.

Commercially-funded radios indeed constitute 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:
– 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 or to participate to the public expression of the opinions of their listeners
– their audiences are local, regional, or national
– they strive to develop on all possible platforms
– during natural, major or minor disasters, radio is the first – and possibly the only remaining – tool to inform the public

Radio is the most intimate medium, and has been so for the past 50 years at least: it is indeed ubiquitous, mobile, simple-to-use and free-to-air. All these features 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, useful / crucial information.

AER would first like to underline that it is highly unlikely that internet transmission can efficiently replace broadcasting. Therefore, radios’ activities do and will require use of spectrum, as a primary user.

This element is of utmost importance and entails two main consequences: while terrestrial digital radio broadcasting most likely constitutes radio’s future main means of transmission, it is very difficult today to say when or how. In other words, it is essential that the RSPG report on the Future of Radio Broadcasting outlines in its conclusions the following:
– no universal switch-off date for analogue broadcasting services should be envisaged at EU level and decisions on standards to be used for digital radio broadcasting should be left to the national markets
– 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

It is also fundamental to recognize the fact that European States should decide how to bring forward digital radio development. AER therefore warmly welcomes RSPG’s acknowledgment of this fact as a starting point of its report on the Future of Radio Broadcasting.

One of the main questions raised by the RSPG report on the Future of Radio Broadcasting indeed relates to the continuity of analogue radio broadcasting systems in Europe. The RSPG report on the Future of Radio Broadcasting furthermore refers to the European Conference of Postal and Telecommunications Administrations’ (CEPT) Electronic Communications Committee (ECC) in its report 141 of May 2010 on “Future Possibilities for the Digitalisation of Band II” (herein after “ECC 141 report”). So, AER would recommend that the RSPG report on the Future of Radio Broadcasting clearly states the same conclusion: “No universal switch off date for analogue services in Band II can be planned”, at least not one that is imposed across all EU states.

FM on band II remains an efficient, simple-to-use and free-to-air technology for the vast majority of radio stations across Europe. This efficiency relates to the business-model: it is actually an essential part of the main business model for commercially-funded radio. Besides, free-to-air FM broadcasting on band II only represents 20,5 MHz. Across Europe, 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. The success of FM is also evidenced by the fact that even the most state-of-the-art communication devices such as mobile phones, smartphones and “media-players” have FM receivers included. Furthermore, by its free-to-air, free-to-online, widely-spread, mobile, simple and direct model, commercially-funded radio plays a general interest role for citizen information, cultural diversity, media pluralism, access to creativity, and social inclusion.

It is fundamental not to forget that radio also plays another central general interest role. When there are catastrophes or other emergency situations, citizens naturally switch on their FM radio to be informed, advised or warned, and governments explicitly ask them to do so: FM radio is, for the time being, the most immediate, most efficient and technically most reliable means of mass communication; furthermore, it will still reach its audience even in the event of a power failure, as many receiver devices are powered by batteries. Commercially-funded radios are indeed as much essential players of the society’s response to major catastrophe as they are an important part of cultural diversity: FM radio must be considered a critical infrastructure. Therefore, one cannot consider a complete migration to digital terrestrial broadcasting – and certainly not an analogue broadcasting switch-off date – before every car and every household can receive a digital signal, and are equipped by a sufficient number of digital receivers. AER therefore perceives FM – although analogue – to be a state-of-the-art efficient technology.

However, digitization is the future of radio broadcasting, and digital terrestrial radio broadcasting will mainly use band III (174-230 MHz) or L-band (1452-1492 MHz) in Europe: plans to migrate from a satisfying analogue technology to digital technology are being actively discussed and tested. Any shift towards digital radio broadcasting entails long-lasting and significant 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. AER therefore warmly welcomes the RSPG report on the Future of Radio Broadcasting’s statement: “Up until now it has been within every country to decide on how to approach the introduction of Digital Radio Broadcasting. This situation shall of course prevail”. This point is fundamental, since digital radio’s development should reflect each EU Member States’ economic, geographic and cultural conditions – as was the case with FM radio’s development.

AER finally welcomes one of the titles of the RSPG report on the Future of Radio Broadcasting’s: “The digitalisation of radio has been, and still is, a long term process”. It is however difficult to understand why this statement implies that digitization of radio would need to be coordinated at EU level, or led by the EU: while some markets experience a lack of FM frequencies, it is not the case for all. Besides, if digital broadcasting will constitute the main means of transmission for radio in the future, it is economically unsustainable to speed up the digitization process from Brussels – as it was done with TV. As one can infer from the RSPG report on the Future of Radio Broadcasting, the situation of radio can indeed not be assimilated to the situation of TV. These two media are even hard to compare: as mentioned in the RSPG report on the Future of Radio Broadcasting, one “must keep in mind that the two cases differ in one major aspect – and that is the issue of spectrum efficiency. There will of course be a ‘spectrum gain’ in moving towards digital broadcasting – as in the TV switchover – however, this gain does not have the same economic driving force behind it.” For AER, this distinction is essential. Furthermore, one should not underestimate the fact that the pace of “natural” device replacement by consumers is by far faster when it comes to TV receivers. FM radio devices are often being used for several decades before being replaced, whereas the useful life of a TV set is usually much shorter, for various reasons.

How can the EU help?

The RSPG, in this consultation, asks for “[s]uggestions on the best approach to move digital radio broadcasting forward in the single market and the possible next step(s) that RSPG could take”.

AER would suggest fostering a favorable environment for digital radio’s development. In that sense, the RSPG could recommend:
– preserving access to bands II, III and L for radio broadcasting
– maintaining exceptions to market-based approaches to spectrum management in the bands mentioned above
– supporting / creating digitization public funding-schemes for all radio actors and consumers
– extending licenses terms

First, one should recall that markets will decide what is the best suited technology for digital radio broadcasting in Europe: a choice endorsed by consumers. However, as the situation stands now, the most likely scenario for the development of digital radio in Europe will take the form of a combination of different technology standards: terrestrial commercially-funded digital radio and internet-based economically sustainable radio will be part of the patchwork of transmission techniques for commercially-funded radios in the future, but it is hard to foresee when. But, to be very clear: terrestrial broadcasting is the only conceivable transmission technique enabling radio with a sustainable / efficient business-model. Therefore, as planned in ITU / CEPT negotiations, band II, band III and L-band should be preserved for radio broadcasting. AER would recommend clearly stating this point in the RSPG report on the Future of Radio Broadcasting.

Moreover, and as most of them are SMEs, commercially-funded radios are in no position to compete for access to spectrum with other market players. So, now and for a foreseeable future, commercially-funded radios need guaranteed access to spectrum, in all bands described above: regulation must be tailored to local, regional or national needs in order to allow the best possible development of radio. In these bands, market-based approaches to spectrum management (such as service neutrality or secondary trading) should not be enforced.

Furthermore and as already mentioned, FM radio is free-to-air, and already enables good sound-quality. FM is also mobile and ubiquitous. There are millions of FM-sets in the EU. Switching from analogue to digital broadcasting will represent an important cost for consumers: there is in Europe on average 6 FM-receivers per households. So, economic incentives for consumers are necessary. But this is far from being enough, as interesting content, produced by broadcasters, should also be offered to the consumers. However, commercially-funded radio broadcasters have to make extremely large investments in new networks for digital broadcasting, causing many actors to hesitate. The most important costs are nonetheless related to simulcasting: programmes should be broadcast at the same time via analogue and digital technologies for a long period of time. AER would therefore suggest setting public support-schemes to:
– create appropriate transmission infrastructures,
– enable all consumers to invest in new digital radio receivers and
– enable radios to maintain simulcasting of their programmes for an appropriate period of time

Finally, and as also already mentioned, a long period of time is necessary for a smooth transition from analogue to digital technology broadcasting. Indeed, there are millions of FM-radio receivers in the EU and these need to be replaced much less often than TV receivers: a radio receiver often lasts a lifetime. Commercially-funded radio broadcasters will need to simulcast their programmes in analogue and digital technologies. From that perspective, it would be important to extend the term of radio licenses, enabling appropriate timeframes for commercially-funded radios for return on investments.

AER remains available to explain this position in further details.

ENDS
21/01/2011

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
http://www.aereurope.org/

On-air broadcasting radios reach massive audience on a daily basis in all EU Member States: between 60 and 85% of the EU population on average listens to radio for at least 2 or 3 hours per day, as shown by national audience measurement.

Commercially-funded radios indeed constitute 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:
– 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 or to participate to the public expression of the opinions of their listeners
– their audiences are local, regional, or national
– they strive to develop on all possible platforms
– during natural, major or minor disasters, radio is the first – and possibly the only remaining – tool to inform the public
Radio is the most intimate medium, and has been so for the past 50 years at least: it is indeed ubiquitous, mobile, simple-to-use and free-to-air. All these features 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, useful / crucial information.

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