09 February 2010 – RSPG REPORT ON RADIOS’ CURRENT AND FUTURE SPECTRUM USAGE:
A MIX OF ANALOGUE AND DIGITAL – AER INPUTS
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 would therefore like to provide the Radio Spectrum Policy Group (RSPG) with inputs on one of the items on its draft Work Programme: “Technology impact on spectrum management”, and the intended report “highlighting the spectrum usage situation by radio broadcasting service”.
Commercially-funded radios 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. 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 decades, 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 . Radio plays a fundamental role in today’s society: it is often quoted as the most trusted medium by citizens and is entrusted with many public interest obligations. It therefore needs exclusive access to spectrum, managed by EU Member States.
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. Thus, Band II is the frequency range between 87,5-108 MHz and 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 . 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).
As a reminder, radio is broadcast all through Europe on Band II (87.5-108 MHz), Long waves (148.5-283.5 kHz) and Medium waves (520-1,610 kHz). Radio’s plans to broadcast digitally could use the Band III (174-230 MHz), the L-Band (1452-1492 MHz) and / or Band II, depending on the EU Member States. Band II and will remain for the next years the main band used by radios. For Band II, the GE84 plan is currently widely applied and is adequate for the current and foreseeable future.
Going on with securing access to spectrum in Band III and L-Band for digital radio is still paramount for its development on-air. This access was secured by EU Member States in international fora, such as ITU and CEPT, and should be respected . Although, for the European Commission, development of wireless broadband appears to be one of the essential elements to ensure an Information Society for All, including in rural areas, on-air radio is still one of the most used means of social inclusion.
So, now and for a foreseeable future, commercially-funded radios need guaranteed access to spectrum, in all bands described above. Besides, no further change to the GE 84 plan should be suggested, but the plan should be interpreted and 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. 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 were forecast to decrease by 3 to 20% all across Europe compared to 2008 .
In some countries (e.g. France and the UK), a part of the revenues derived from the TV digital switchover was supposed to be allocated to the support of digitisation schemes for radio. This is no longer the case. In most countries, it is still unclear who will bear the costs of the digitisation process.
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.
It should also be recalled that commercially-funded radios are SMEs, and are in no position to compete for access to spectrum with other market players. So, market-based approaches to spectrum (such as service neutrality or secondary trading) should not be enforced in bands where commercially-funded radios broadcast or may broadcast.
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
– now and for a foreseeable future, commercially-funded radios need guaranteed access to spectrum, in all bands described above. Besides, 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 RSPG.
AER Secretary General
76, av. d’Auderghem,
Tel: +32 2 736 9131
Fax : +32 2 732 8990
AER’s Interest Representative Register ID Number is 6822083232-32