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Isle Of
Man International Broadcasting Company Ltd
Response To The Third Stage Of Spectrum Pricing Consultation Document
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P 0 Box 279, RAMSEY, Isle of Man, IM99 4HT
Tel: 01 624 818151 Fax: 01 624 817094 Email: loMIBC@longwaveradio.com
www.longwaveradio.com
Licensing Policy Unit
Radiocommunications Agency
LONDON
E14 9SX
20th December 1999
Dear Sirs,
SPECTRUM PRICING - LONG WAVE
We would like the Agency to consider reducing the fees charged to
long wave broadcast stations on the following grounds:
- The space occupied by AM stations is very narrow compared to FM or
DAB. In this respect, AM broadcasting could therefore be considered to be relatively
very spectrum efficient.
- Each AM transmitter occupies only 9kHz of spectrum, is coordinated
only once and does not need a lot of the Agency's time. The cost of managing a LW
allocation is extremely low, yet, traditionally, the cost of the frequency to the
broadcaster is very high - a considerable six figure sum, quite out of all proportion to
your costs.
- The Agency and others have been making concessions to broadcasters
who pioneer using wider swathes of spectrum (e.g. DAB). Presumably this is in
recognition of the lower number of existing listeners to these services, probably for
another decade or more. The Radio Authority recognises that AM broadcasting is less
popular and it charges less for a national AM radio licence than it does for the national
FM licence.
- During the initial three years of a new radio station's operations,
particularly where it is pioneering a new allocation, the station is effectively adding
value to the part of the spectrum concerned, enabling higher fees to be charged in later
years, perhaps when a larger audience has been developed.
- The Long Wave Band is not so sought after as FM, evidenced by the low
number of applications for such allocations. A lower percentage of domestic
receivers have LW.
We contend therefore that it might be appropriate for the Agency to
REDUCE the annual WTA licence fee for national AM radio broadcasters, particularly for
Long Wave, where there is only one single frequency and one transmission site in use.
I have raised this matter on several occasions with Jim Norton and with David
Toman. I would appreciate this request being considered by the Agency when it
considers its new charging/pricing policies.
Yours sincerely
Paul Rusling
Chief Executive
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