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The consultation on Licensing "Community Audio Distribution System" closed on 19 October 2004. Ofcom received 27 responses, all expressing support for its introduction and some of these expressed a number of concerns and questions.

Ofcom is grateful for all responses to the consultation, and has considered all comments received. Of the concerns and queries raised we do not consider that any justify halting the introduction of the new CADS provision on an experimental basis. Therefore Ofcom can confirm that the licensing regime will begin as of 4 November 2004 for an experimental period of 12 months.

During this trial period Ofcom encourages users to give feedback on the progress of the regime to aid Ofcom in coming to a final decision on the viability of the scheme. These comments along with results from Ofcom's own monitoring and evaluation process will inform the decision to be made in late 2005.

For more information on how to apply for a licence, access the Licensing information document below or call Denise Carter on 0207 981 3169

Responses Summary and replies

Commonity Audio distribution system Consultation responses

This document details all comments received by Ofcom in response to the consultation held between 10 August and 19 October 2004. It appears in three sections, one focussing on the positive comments received, the second on the concerns that were expressed and the third listing all questions raised from respondents.

Positive Comments:

1. This will be a valued service to the community.
2. There has been a definite increase interest for these kind of services amoung the elderly and handicaped that aren’t always able to attend religious services.
3. Sharing the UKFM band with religious transmissions would be a good idea since in recent years the use of this band has been low.
4. Very definitely yes. In Warrenpoint we are a community of c.7.000 people. Each day we broadcast our religious service and in addition funeral services, weddings, and special services at Christmas and Easter. It was only when the broadcasts stopped that we became fully aware of what it meant to people.
5. I would favour holding A Wireless Telegraphy Act Licence. I do think it would in some way heighten the degree of responsibility and accountability of those providing the service.
6. We have learnt from listening too many of the villagers that they do want to attend mass but don’t always have the time to go to church. Conversely, we have an increasing number of people in their 80s who through illness have become physically limited in their travel thereby not being able to go to church but still wanting to.
7. We support the need for the a licence.
8. The provision will open up a new service that will benefit both the user and the service provider.
9. The proposal is a great step forward, we would like to congratulate Ofcom on their initiative and forward thinking in running this consultation.
10. I strongly believe that CADs should go ahead.

Concerns expressed:

	Concerns	Ofcom’s Response
1.	Clearly any attempt to co-locate CADS on the CEPT channels would not be acceptable both from a regulatory and practical channel occupancy point of view.	Ofcom does not propose to extend the CADS service to the CEPT CB channels.
2.	I am concerned with interference and content, so I recommend you should give spot AM or FM broadcast frequencies to such communities (to whom you grant licences and subject them to various broadcast content measures) since approved low power AM and FM radio broadcast transmitters and antennas are inexpensive, can co-exist, and AM/FM radios are ubiquitous. This is especially useful when such transmission installations are likely to be permanent.	This is not a broadcast service and therefore has not been allocated broadcast frequencies, nor is it subject to the same level of protection from interference that broadcasters receive.
3.	I fear that religious services could be jammed or verbal abuse transmitted particularly in the unfortunate light of the politics surrounding them. I conclude that CADS should not share the spectrum where the public has ready and easy access to disrupt or interfere with that signal.	The CADS trial service is available on a shared basis with other religious and CB users. The only rights of protection are where a transmission is being deliberately disrupted or where the interference comes from a religious station which has not adhered to the technical parameters (e.g. maximum transmitter power and maximum transmitter height). In this event you should inform your local Ofcom office. Ofcom encourages those users within the same geographical area to coordinate their use of the channels across the band since this will reduce the likelihood of receiving interference from other CADS users.
4.	Church services usually last around an hour, and we think it might be tiring listening to a transmission of that length and in addition, many of the elderly people to whom this service would be of most benefit are hard of hearing, which we think would increase the problem. CB quality is classically designed for short burst of conversation, where sound quality is not a major issue.	A number of religious organisations asked Ofcom to provide spectrum for this service. To be successful the service needs to operate in spectrum where inexpensive radio equipment is available suitable for the churches needs. We believe that the CB spectrum satisfies these requirements.
5.	We would need to be reassured that the use of the service in a built up area will not lead to ‘blind spots’ and interference to transmissions.	Ofcom is unable to give such an assurance with any radio system.
6.	Our church is situated within 1 mile of two military/police installations. The consultation document states that there will be minimal risk of interference but we would be concerned that this may only be found out once we have committed ourselves to installing the system. It would be reassuring if Ofcom were to offer a ‘test’ for interference before congregations commit themselves to buying equipment.	Ofcom is unable to offer such a service. This may be something that your dealer could help with.

 

Questions raised:

	Questions	Ofcom’s response
1.	If more than one of our churches within the Free Presbyterian Denominations wish to take part in this trial. Do they have to fill in separate applications or will one form do for the whole denomination?	Each individual church which wishes to take part in the trial needs to apply for a licence. The reason for this is two fold: firstly each church needs a licence to legally transmit its service and secondly knowing how many individual churches are taking part in the trial will help us assess the success of the trial.
2.	The broadcasts should be ‘live’ or a programmed specifically created for transmission later is permitted ?	It is permissible to record a live religious event and play back the recording at a later time. You can not play back a ‘studio’ recording that was not made at a live religious event.
3.	Are there going to be special provisions for churches in a rural areas with hilly terrain, which may need to use a higher than normal transmitter antennas? Is the bandwidth allocated is sufficient for churches and CBrs to use?	The trial will consider these issues. Ofcom intends to be as flexible as possible in resolving issues raised by the trial.
4.	Is Ofcom providing equipment for a ‘pilot’ church to participate so that other interested congregations can get a feel for how the system works and its quality?	Unfortunately Ofcom is not able to supply any equipment..
5.	How is Ofcom going to safeguard against misuse by fake organisations or the content of broadcasts from fringe religious organisations?	The service is open to any religious organisations within the trial area.
6.	Will there be set channel for each Church in say a town to reduce interference, and if so who would have priority on that channel, the Church or CBer?	It is not Ofcom’s role to plan this network. Local churches will need to cooperate with each other to agree a mutually acceptable channel plan.

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