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Radio
Authority
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The Licensing Policy Unit,
Radiocommunications Agency,
Wyndham House,
189 Marsh Wall,
London.
E14 9SX.
22nd December 1999
Dear Sir, Madam,
"Spectrum Pricing: Implementing the Third Stage and Beyond"
The above document published by the Agency invites, in its paragraph 1.3, general comments on the consultation process which it describes.
The process itself appears well-founded and structured, and I note that the issues of spectrum pricing as it might apply to broadcasting are to be addressed in a subsequent and specific consultation exercise, in the near future. We shall of course welcome the opportunity to make substantive observations then.
However, I feel I need to make a few comments on the above consultative document, and particularly on the scene-setting paragraphs relating to broadcasting. I believe that many of my concerns, from a sound broadcasting perspective, could actually be allayed by recognising that despite several appropriate references to sound, it is television and the future of the UHF bands which may have been uppermost in the Agency's mind in drafting the document.
Para. 3.18. states that, other than some 1.5 GHz spectrum for T-DAB, there are 'unlikely to be major changes to broadcast spectrum allocation'. I hope this is an oversight, or else that the reference to analogue to digital switch-off is very broadly cast in its implications. There is clearly a need for further VHF Band III spectrum to be allocated to digital sound broadcasting, at the very least to enable any significant dividend to be realised through the eventual cessation of FM broadcasts in Band II, quite apart from any expansion in the number of services.
Para. 3.22 It may seem like a semantic point, but I think it is important to clarify that lack of capacity for simulcasting local sound broadcasting (on analogue and digital) services is not so much a lack of capacity on the multiplexes themselves where these will exist in the next four years or so, but, through limitations of spectrum, an absence of any local multiplexes in many areas, on which existing analogue local radio stations could secure carriage.
Para 3.23 This paragraph, about alternative delivery systems, appears to use the word 'broadcasting', when it should say 'television'. 'Radio' as in 'sound broadcasting' is different. It is different because it has for decades now been a mainly portable and mobile medium, whereas television is basically fixed: the choices made for the DTV system in the UK underline that point.Even if it may not be appropriate from the technical standpoint in the 'era of convergence', to confine indefinitely our view of sound broadcasting media to conventional models (including digital radio), it is as essential to sound broadcasting as it is to mobile telephony,' (a) to use radiocommunications, and (b) to use frequencies whose propagation characteristics are suitable for wide-area terrestrial coverage. The geographical distribution of consumers seen from the perspective of service provision implies an upper limit in frequency which is lower for mobile/portable broadcasting than it is for switched -including packetised- services such as telephony.
We welcome the treatment of spectrum pricing on a 'per sector' basis; each sector being different. However, the achievement of spectrum management objectives through spectrum pricing, and particularly through administrative price-determination (as is appropriate) does involve changes to allocation, as much as changes to the detail of use within an allocation. This can be inferred from the document, referring as it does to possible partial reallocation of the UHF TV bands after analogue switch-off. The nature of analogue to digital transitions does seem to imply a degree of musical chairs in everyone's interests, hence DAB is in Band III, not Band II, TETRA is in a different allocation from PAMR, and so on. This aspect of overall management is dealt with largely in the periodic publication of spectrum management strategy by the Agency, but the use (if any) of spectrum pricing as a tool for aiding that strategy will need to be made clear as these developments unfold.
I hope these comments are of some use. We look forward to participating in the synthesis and development of policy on spectrum pricing as it will apply to broadcasting.
Yours faithfully,
Mark Thomas
Director of Engineering
c.c David Toman, Radiocommunications Agency
The Radio Authority
Holbrook House
14 Great Queen Street
Holborn
London
WC2B 5DG
Tel: 0171 430 2724
Fax: 0171 405 7062
Chairman
Sir Peter Gibbings
Chief Executive
Tony Stoller
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