FM switchover.....Coalition steamroller?

[Gordon]

They know their regulations to a T though don't they!? I wouldn't agree it's whitewash but it's certainly impenetrable bureaucratic legalese. You can just imagine a self satisfied CS sitting there and enjoying saying NO you can't have it because I can stop you with my rule book. Why didn't they just write a report for publication and keep the confidential stuff separate so that them wot needs to know in government can see it but no-one else knows it exists?

We all understand commercial confidentiality. It's not so much what the rules say it's the way they tell you they can't release it - in plain English please.

Did the person give you a name? Was it a DCMS person - it sounds as if it was - or some other department altogether?

[Resurrection Man]

......

Did the person give you a name? Was it a DCMS person - it sounds as if it was - or some other department altogether?

Yes, it was signed and it was a member of the Freedom of Information (aka Shhhh...we're not going to tell you) team at DCMS.

When I read your abbreviation 'CS' I am afraid that the phrase Civil Servant wasn't the one that first sprang to mind

[Resurrection Man]

Looking at the questions that they have asked in their methodology to create the new Cost Benefit Analysis, there is one blindingly blatant lie. The scenario is that they are asking people for their willingness to pay and how much for 'benefits'.

For analogue they ask this question...A6: "You may experience sound interference."

For digital they ask this question ...D6: "You have clear sound and no background
interference."

Yeah, right. So you never get any burbling on digital radio then...perfectly clear all of the time....see that pig flying. Perhaps they should rename their report 'Loaded Questions'R'Us'

[Gordon]

Agreed, the questions asked of the interviewees are slanted to say the least. There is also evidence that the interviewees did not all perceive the questions to be the same and so gave answers that they subsequently would change. I suppose that is the nature of people but questions in a survey should be as transparent as possible.

I don't have many reservations about the basic structure of the methodology, much of it derives from the treasury rule book, it's the verity and reliability of the raw data [eg consumer response to interviews, surveys etc] used to plug into the arithmetic that I have great trouble with. Nothing of that arithmetic is explained as far as I can see so the numbers [eg in the last CBA of 2009] seem to come from thin air.

At least the Annexe B of this latest report has a bit more detail about consumer response in it, however skewed it may seem. There's a long way to go yet before consumer views get properly exposed in this project. The few strongly opposed people on tis board together with others on similar boards and those that responded to the House of Lords inquiry in 2010 add up to a few hundred, or perhaps thousand, are contrasted with the vast silent majority of the millions that own DAB receivers and that government will assume are happy with what they are getting.

DRUK seem convinced that extra marketing push is all that's needed [assuming the transmitter build out] but that push has nothing new to say. The latest WTP survey suggests that the threshold is about £42 to attract people to switch - that assumes the issue is all about price which it is not. It might be relevant in a free market scenario - ie the Business As Usual or Do Nothing scenario identified in the report - but I don't see how it applies in a switch under duress. If you don't really want something no price will attract you will it?

[Resurrection Man]

Gordon, you make some very good points. Will you be responding to the DCMS request for comments?

[Gordon]

Gordon, you make some very good points. Will you be responding to the DCMS request for comments?

Ahem! Yes, but not personally, through another channel with others. To attone for past sins I am concerned as a volunteer supporter with a charity or two. I've submitted a commentary to the editor/collator of the group concerned. Deadline August 31st approaching fast!

I'd encourage anyone else who feels strongly enough about some of these CBA issues to send in comments, preferably rational, however short, because the more people respond at all will help concentrate the minds of government a little more on consumer interests - every respondent is a voter!!

They ask a number of specific questions which would take time and some expertise to respond fully but one doesn't have to be that detailed to express a view and communicate concerns.

Any rant will simply be ignored. Not that I would presume to put words in anyone's mouth, adapt as you wish, but one could use the usual pointed but restrained language, eg:

"I/We welcome this opportunity [always a good start in a response] to respond to DCMS' request for input concerning the methodology to be used in framing and expressing a Cost/Benefit Analysis for digital switchover of the UK radio infrastructure.

It is clear that much work remains to be done [ie the present work isn't very convincing] in clarifying the credibility of the factual evidence that is used in calculating whatever cost or benefit that may accrue to the public as a result of the switchover.

Whilst the process described seems logical and structured and involves a number of important and relevant parameters, the raw data that feeds into the arithmetic that ultimately produces a numerical answer is highly suspect and is in great need of refinement. It is recognised in this latest report and its annexes, as well as the analysis reported in 2009 by Price Waterhouse Coopers, that uncertainties remain in the analysis and its input data and that it is far from complete or sufficiently accurate to provide a credible basis for government decisions at this time.

It is however clear that there is widespread public concern about a number of factors relating to DAB and its slow rate of adoption; furthermore, the public at large have a clear high regard for current FM services and have expressed that regard by not voluntarily changing to DAB in large numbers. There are some well known technical reasons for this lack of take up which have contributed to the fact that only 20% of listening is reported on the DAB platform. The proposed threshold for a government decision on switchover of 50% listening to radio by digital means is too low, despite that criterion being the result of studies by the Digital Radio Working Group. It clearly leaves 50% of the listening public, many of them in disadvantaged groups, in a position of being forced into a change, at their own expense, that they have not seen fit to take voluntarily. This is excessive coercion.

I/we therefore encourage government to take due note of these concerns and this strong regard for FM and to ensure that any CBA is credible, accurate and fit for purpose and has been scrutinised by means of wide public consultation before it is acted upon."

I hereby waive my copyright in these words.

Go on, it'll only cost a a couple minutes to clip this text or something like it and to send it to this address:

CBARadio@culture.gsi.gov.uk ACTION THIS DAY!

I'm sure they will do what they want anyway but at least the body of public opinion will be on record. One has only to look at the overwhelming adverse comment on switchover to the House of Lords inquiry in 2010 to see what they are in danger of ignoring. Whilst I see the broad strategic goal od switchover the devil is in the detail.

This consultation is not the end of the road yet by a long way on this CBA issue, it will continue for some time yet and we, the group, will be following it doggedly in an attempt to focus it!

[Old Grumpy]

Excellent wording, Gordon.

Have duly sent off.

OG

[mangerton]

Thank you, Gordon, for doing the spade work. I have sent a copy to the DCMS, with this addition, relevant to this part of the country:

The loss of FM will be felt more acutely in many parts of Scotand where the introduction of the digital TV service BBC Alba has been brought about by the removal of the main BBC FM radio services, during the evenings, and where no alternative means of reception exists.

I have also sent a copy to my MP. I don't think he'll act on it, or even understand it, but at least he can't say he didn't know about it!