FM Switchover- response deadline looming

[Gordon]

Just a short reminder to those who contributed [and anyone else really] to the thread on "FM switchover ...coalition steamroller" in this group that the deadline for responses to a DCMS consultation on the Cost/Benefit Analysis methodology for FM switchover expires this Friday August 31st. If you want to have your say and object now's your chance. Silence is assent.

Thanks to those of you that have already sent in your responses. The address to send your objections to is:

CBARadio@culture.gsi.gov.uk

The consultation documents are here:

http://www.culture.gov.uk/news/media_releases/9176.aspx

[Lateralthinking1]

Just a short reminder to those who contributed [and anyone else really] to the thread on "FM switchover ...coalition steamroller" in this group that the deadline for responses to a DCMS consultation on the Cost/Benefit Analysis methodology for FM switchover expires this Friday August 31st. If you want to have your say and object now's your chance. Silence is assent.

Thanks to those of you that have already sent in your responses. The address to send your objections to is:

CBARadio@culture.gsi.gov.uk

The consultation documents are here:

http://www.culture.gov.uk/news/media_releases/9176.aspx

Thanks Gordon. I am not sure whether my sending an e-mail simply saying "I object to the proposals" will be very helpful.

It would have been better to have had a series of questions as was the case in, say, the proposed forestry sell-off and the consultation exercises in which I was heavily involved when employed. What we heard then from the public was that we were drafting the questions to get the answers the Government wanted so this one at least avoids that trap. On the other hand, it could just be deliberately half-baked. It isn't what I would call a consultation as I would once have recognised such things.

What I do know is that winning technical arguments will not necessarily be persuasive but anything of a legal nature could be. If anyone can think how the proposals would discriminate against racial groups or women, DCMS will have to go back to the drawing board. I am not sure how in the first case it could be proven if the impacts are mainly on rural areas but someone inventive might find some logic to support the second. That it will be detrimental to the less well-off is, of course, likely to be totally ignored.

Do you have a copy of your response that you would be willing to share or, if not, some pointers for a layman like me?

[Gordon]

Thanks Lat, I agree with your comments and it is true that the documentation is complex and so quite difficult to respond to without a great deal of reading. A cynic might say that is deliberate to put consumers off!! The main approach we have taken is to challenge the factual basis of the CBA and some of the criteria for switchover. If you read [I'm not suggesting you do because it is very long] the House of Lords inquiry into TV and Radio switchover published in March 2010 you will see great deal of resistance expressed by quite a few industry people that were interviewed or submitted written responses. A few consumers responded as well, almost all objecting strongly suggesting the whole thing doesn't need a CBA because it is obvious that the idea is daft!! If we say nothing government machine willl take us to support their actions.

I and and some colleagues have prepared a response but it is being collated by someone else so I don't have a copy yet. I can send you a copy [Word, 5 pages] of my contribution for further reading if you like - it's too long to post here. FF has my email and could [because she is a very kind and helpful person!! ] forward a copy to you if I sent it to her? Or is there another way of posters sending each other attachments?

In the thread I referred to in #1 I did suggest a form of words that people may think useful enough to register concerns, one ortwo have I think taken them and used them:

"I/We welcome this opportunity 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 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."

[Lateralthinking1]

Thanks Lat, I agree with your comments and it is true that the documentation is complex and so quite difficult to respond to without a great deal of reading. A cynic might say that is deliberate to put consumers off!! The main approach we have taken is to challenge the factual basis of the CBA and some of the criteria for switchover. If you read [I'm not suggesting you do because it is very long] the House of Lords inquiry into TV and Radio switchover published in March 2010 you will see great deal of resistance expressed by quite a few industry people that were interviewed or submitted written responses. A few consumers responded as well, almost all objecting strongly suggesting the whole thing doesn't need a CBA because it is obvious that the idea is daft!! If we say nothing government machine willl take us to support their actions.

I and and some colleagues have prepared a response but it is being collated by someone else so I don't have a copy yet. I can send you a copy [Word, 5 pages] of my contribution for further reading if you like - it's too long to post here. FF has my email and could [because she is a very kind and helpful person!! ] forward a copy to you if I sent it to her? Or is there another way of posters sending each other attachments?

In the thread I referred to in #1 I did suggest a form of words that people may think useful enough to register concerns, one ortwo have I think taken them and used them:

"I/We welcome this opportunity 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 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."

Many thanks Gordon for this detailed reply. I may well simply use that wording with your agreement. I was at the heart of the public consultation exercise which I believe led to the biggest ever response in the UK. 500,000 responses - and on the worst days it felt like I had seen every one! Generally between 1997 and 2010, some added weight was given to what the Labour Government used to call key stakeholder groups - a phrase that is not now in favour - so it helps if people can claim truthfully to represent an organisation. As far as the public are concerned, numbers matter as much as the content. That is my view of what used to happen anyway. It is probably still the case given Caroline Spelman's sudden change on the forestry proposals following a public outcry.

Various phrases are crossing my mind hazily - risk assessment, environmental impact assessment, disability assessment etc. Not having been in media policy I am not sure if and how they would apply. But there do seem to be many requirements in most areas of policy change so it is worthwhile insisting that DCMS are transparent, unlike Lansley with his hidden NHS risk register. I am also trying to think of recent parallels. The requirement to fit technology in vans to minimise emissions was, I think, at the owners' expense but it came from Europe so the legislation is quite different. Then we had all the business with the new light bulbs which seemed to be a case of having no say. I suppose what I am saying here is that it is good to think broadly - what are the precedents, if any, and the practical impacts on the country, the regions, the localities, the media markets, businesses and individuals. There are many potential angles. Also think in terms of broadcasting precedents - VHF-UHF, FM introduction etc.

I would be interested to read your response. frenchfrank - This is the relevant part of Gordon's e-mail. Are you able to advise Gordon, me and everyone else who would be interested to see a copy of his response? The consultation closes this week.

I and and some colleagues have prepared a response but it is being collated by someone else so I don't have a copy yet. I can send you a copy [Word, 5 pages] of my contribution for further reading if you like - it's too long to post here. FF has my email and could [because she is a very kind and helpful person!! ] forward a copy to you if I sent it to her? Or is there another way of posters sending each other attachments?

[Nick_G]

Hi all. I'm a new member on this board. I don't listen to Radio 3 that much but I do enjoy some of the programming such as 'Late Junction' and I listened to the John Cage Prom a week or so ago.

I was one of those people who bought an Arcam Alpha 10 DAB tuner, way back in 2000, when all the main BBC stations (1-4) were all at 192kb/s and sounded very good. I naively assumed that the new services were going to be launched on a second multiplex, so I was disappointed when the BBC decided to cram them into the existing multiplex with an attendant deterioration in audio quality. Since then it seems to have been downhill ever since. I didn't know enough about the background behind DAB at the time and assumed that the platform would improve with time. How wrong I was!

I'm not against DAB as an idea - if done properly it could be great. But I am appalled at the way DAB has been implemented in this country: it is out-of-date, inefficient and therefore not cost-effective. I dread to think of how much money has been sunk into the DAB black hole, and is, IMO, part of the reason why the radio industry is in such a perilous state. They (wrongly) put all of their eggs in the DAB basket back in the 90s and now it's not as big a hit as originally anticipated. So a big waste of money! In theory, a system like DVB-T2-lite would be ideal: the data capacity of each mux is 2-3 greater than a DAB mux, whilst at the same time occupying the same amount of bandwidth. So in theory the BBC could probably broadcast Radios 1-6 in 'HD Sound' and still have capacity left over. Not only that but the error correction and robustness is superior to DAB+. However, it's a moot point as it's not yet a recognised digital radio standard. Perhaps that will change in the future. Such a system would save the broadcasters lots of money if they kept the same bit-rates using AAC+!

I emailed a modified version of Gordon's post as follows:

"Dear Sir,

I welcome this opportunity to respond to DCMS' request for input concerning the factors and methodology to be used for a new Cost/Benefit Analysis for digital radio switchover.

It is clear that much work is needed to determine the credibility of the evidence that is used in calculating the cost or benefit that may arise to the public.

The methodology appears logical and structured and includes a number of important and relevant criteria. However, I'd like to know how the figure of £761 million was arrived at. Without this information it is very difficult to make an evaluation. The report itself says that there is insufficient information and analysis in order to inform Government on a decision.

It is clear to me, after reading various public comments that there is widespread concern about switchover, and this is reflected in the fact that the listening figures for DAB are only at 20%. There are several technical reasons for this, which are well publicised. The Consumer Expert Group suggested a tipping point for a decision at 70% of listening being on digital platforms, and I would agree with them. 50% is too low - it leaves half the population being forced to change from FM/AM, which is too heavy-handed in my opinion.

I 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.

Yours sincerely, etc."

Someone also pointed out on another forum (which often has debates on DAB) that there is a possibility that the money for simulcasting FM & DAB will run out before the public are ready to switch over. This would apply more to the commercial sector, although there may be resistance from the public regarding license-fee money continuing to be spent on the continuation of the platform, and therefore encouraging a switchover. From watching news articles about DAB over the years, the comments from the public suggest that the idea of a switchover is not a popular one!

Regards,
Nick

[Gordon]

Welcome aboard Nick, and thanks for your support! I dont suppose that you live somewhere around N Hampshire do you?

[Resurrection Man]

Hi Nick and welcome. Over from Digital Spy, I see

Looking at the Cost Benefit Analysis of Radio Switchover in Section 7....Transmission Cost Savings...they state the DAB cost but omit the FM cost. Why is that?

They have also gone into inordinate detail on the consumer aspect. However, their sample size for detailed research is only 20 as far as I can see. Is this a statistically significant number?

EDIT: I have also questioned with them the concept of Willingness To Pay as a valid metric for calculating the benefit of a switchover to consumers. It is a far cry from asking someone how much would they pay to be able to pause the radio and actually getting them to put their hand in their pocket. A far more meaningful question would have been to ask their interviewees 'Given that you are happy with your FM radio, would you pay anything to get a DAB one'. We all know the answer to that one and which is why they did not ask it.

However, the biggest 'lie' in their questionnaire is Digital D6 which states that digital radio is interference free and so attracts a 'willingness to pay' £x. This is an out and out lie as DAB can also get interference. The fact that later on in the report they state that this question, out of all of them, is the one reason why people might consider buying a DAB radio and hence attracts a Willingness to Pay value to feed into their CBA, makes the CBA invalid.

[Gordon]

..... some added weight was given to what the Labour Government used to call key stakeholder groups - a phrase that is not now in favour - so it helps if people can claim truthfully to represent an organisation. ...

The Digital Radio Action Plan project has a number of stakeholder groups and one is the Consumer Expert Group that Nick_G referred to; another represents the motor industry. The CEG has representatives at the Ministerial level of the project so can be heard at that level if not listened to. CEG has raised many of the issues we have seen in our posts here over a period of time. It includes many charities that represent the interests of the disabled etc and so is a kind of stakeholder body for those people. It also has the Voice of Listener and Viewer [VLV] which is also a charitable body that has for many years championed consumer issues in the media and has become quite influential.

Nick makes some very good points but we are where we are and the 13 million DAB receivers out there would make a change of standard in the short term quite difficult. Even if we did change to say DAB+ the extra capacity would not necessarily be used to increase bit rates/quality there would be a temptation to just add more services so that even more FM stations can be moved off that band. The Minimum Receiver specification to be used in conjunction with switchover, IF it happens, requires DAB+ to be present in readiness for a future migration. Some already do include it; I have a Sony that does. At least one silicon company makes a multi-standard chipset that can do all DAB, DAB+ and DMB as well as FM. But where is the space for simulcast during a transition going to come from?

This issue will not get any easier and it will not go away if pressure is maintained on government to see the consumer's view which might just have an impact. This CBA is just another stage in the process but it must be bomb-proof otherwise the whole justification is a house built on sand. I don't find the existing state of it as convincing at all and I see no killer application to justify switchover; more channels is just not appealing and consumers have shown that.

Anyway, that's enough from me for now on this subject - until the next utterance from government or OfCom.

[LeMartinPecheur]

Didn't have time to read the backgound paper but sent off Gordon's proforma anyway, with a small addition about the extra costs for motorists in getting the new radio properly fitted - not inconsiderable IMV.

[Nick_G]

Welcome aboard Nick, and thanks for your support! I dont suppose that you live somewhere around N Hampshire do you?

Thanks for the welcome

Yes I live about half way between Newbury & Winchester. Is that near you Gordon?

We are where we are, quite true. And that place where we have ended up is a mess! I fear that the whole DAB situation has been handled so poorly that continuing with the status quo will only end in failure. There isn't enough money or resources available IMO to make plain vanilla DAB an attractive enough proposition for the public to switch over. Years of sticking their heads in the sand/fingers over their ears has meant that perhaps the Government & industry have left it too late. I hope not, as FTA digital radio done properly would be excellent. However, the internet might yet sneak up from behind and overtake DAB. With IPv6 (which includes multicasting as standard) and 4G taking off in the next few months, I wonder if in 15-20 years time (by which we may be ready to actually do a switchover) then access via the internet will be far more important. As I said before, I would like DVB-T2-lite to be added to the digital radio standard so we can have a world-class FTA system. It has already been tested in Denmark.

One thing about the RAJAR figures for internet listening: they only take into account live listening of UK stations. No listen again, podcasts, overseas stations or internet-only services are included. Since their methodology doesn't reflect how radio is consumed via the internet, I don't believe their figures, and I suspect they are underestimating this sector considerably.

I hope we can find a way out of this mess, but I'm not sure what the best solution to the problem is.

Regards,
Nick

[Resurrection Man]

.....

I hope we can find a way out of this mess, but I'm not sure what the best solution to the problem is.

Regards,
Nick

Keep simultaneous transmission of FM and DAB as now. Fund any DAB expansion from a levy on the price of DAB sets.

[Resurrection Man]

Gordon, just received a copy of your very eloquent response.

[Dave2002]

Keep simultaneous transmission of FM and DAB as now. Fund any DAB expansion from a levy on the price of DAB sets.

The issue of "local" FM transmission after a putative switchover has not been filled in at all. I assume that any private enterprise which decided to rebroadcast digital content over FM channels would be prevented from doing so, both by copyright laws and by the re-allocation of spectrum making the use of FM impractical.

This is slightly facetious, but some governments have expressed interest in private enterprise and initiative. I could set up an FM transmitter so that at least people in our road could receive FM taking feeds from digital sources. I would be breaking several laws and perhaps causing havoc.

I note from all the documentation the emphasis on "consumer led" indicators for switchover. The documentation does make it clear that DAB take up is not the same as listening to DAB. In the modelling document the modelling plucks out purchases of digital kit with figures of 20%,40% and 90% of what it calls "non DAB households" following an announcement of switchover. This is for both Scenario 1 and Scenario 2. Scenario 3, which has different dates for switchover for Northern Ireland and Scotland has slightly different values.

It appears from the table that switchover would occur within 2 years of an announcement, which seems far too short a time period. This looks like a 3 year period, but the announcement year is year 0, with switchover 2 years later.

If I were modelling these things, I would also make guesses to the values, but I would acknowledge that they may be very wrong. The assumption of 90% take up in the switchover year might be justified by the "fact" that existing FM services would be cut off, which is hardly a consumer led strategy. 90% is a large figure to speculate on, except in the case of coercion, which perhaps is the deliberate intention.

There are so many flaws and dubious arguments in this whole business - it's very depressing. I don't now know what the switchover period for TV was - but I think it was at least 5 years. It is also very possible that TV purchases are rather different from radio, since TVs perhaps don't last as long, and many families seem strongly motivated to buy TVs.

It'll take a very long while to make something sensible of this.

The WTP (Willingness to Pay) arguments are interesting, but they also seem to assume that only one radio will be purchased. There is also confusion reported in the various "experiments" regarding consumer attitudes, where many possible consumers are confused. As pointed out, these are simple survey or focus group views, and may very probably not reflect what consumers will actually do. However the observation that consumers are confused makes it likely that many will not appreciate that buying a DAB set will not simply provide additional services, but will actually be the only way that they can receive radio after switchover. I suspect that many will not interpret switchover as switch off FM.

It's quite a muddle.

[Gordon]

Thanks for the welcome

Yes I live about half way between Newbury & Winchester. Is that near you Gordon?

Near enough!! I thought I recognised the name from other boards - I suspect we live in the same town on the Test and the A34. I live in K Park. We must have a beer sometime!! We have enough pubs to choose from - but we'd best be quick before they all close down.

We are where we are, quite true. And that place where we have ended up is a mess! I fear that the whole DAB situation has been handled so poorly that continuing with the status quo will only end in failure. There isn't enough money or resources available IMO to make plain vanilla DAB an attractive enough proposition for the public to switch over.

Agreed! I think it suffered from the old traditions in broadcasting that new technology was introduced with the BBC in the lead and then the public gradually took it up at their own pace. Such things always took a long time for the public to flush old technologies out with enforement at the very end - not at 50%!!! No one asked for DAB any more than they did say FM, Stereo or colour TV but at least with colour or stereo there was an immediately obvious benefit that you didn't need a CBA to prove! It was all more or less public service then anyway. Nowadays technology moves so fast that any one thing doesn't last very long before something " better" turns up, look at DVB-T1, some people hadn't even got that far before T2 came long and used for HD on Freeview. Because it is more or less on the Shannon limit probability is that T2 is the end of that particular road [better be careful predicting].

Years of sticking their heads in the sand/fingers over their ears has meant that perhaps the Government & industry have left it too late. I hope not, as FTA digital radio done properly would be excellent. However, the internet might yet sneak up from behind and overtake DAB. With IPv6 (which includes multicasting as standard) and 4G taking off in the next few months, I wonder if in 15-20 years time (by which we may be ready to actually do a switchover) then access via the internet will be far more important. As I said before, I would like DVB-T2-lite to be added to the digital radio standard so we can have a world-class FTA system. It has already been tested in Denmark.

I'd agree with most of that. It will take a Europe wide decision and WorldDAB to add DVB-T2. I think they are thinking but [according to my industry sources that go to committees] not getting very far. I think that after about 2030, which is the limit of this CBA, broadcasting as we know it will be very much changed both technically and regulatorily [Communications Bill coming soon]. I think that by then broadband will be dominant using both wired and wireless [4G in UHF] technologies BUT the networks will have to be dimensioned to handle vast amounts of MultiCast streaming. The technologies exist and by then will be refined - unless something else turns up in the meantime and I shall be well out of it one way or another.

One thing about the RAJAR figures for internet listening: they only take into account live listening of UK stations. No listen again, podcasts, overseas stations or internet-only services are included. Since their methodology doesn't reflect how radio is consumed via the internet, I don't believe their figures, and I suspect they are underestimating this sector considerably.

I hope we can find a way out of this mess, but I'm not sure what the best solution to the problem is.

Regards,
Nick

That is true of RAJAR which has no remit to collect listening to anything other than UK broadcast source material. This whole DAB/FM debate is about the UK industry. Any policy will only be applied insofar as it affects public broadcasting to UK regulated services. The internet is on the edge of that. Any lost listening will be a boost to the figures where DAB is dominant in what's published but you are right that a lot of digital listening is lost but what you can say is that it isn't on DAB. If broadband listening in all its forms can help get up to this ridiculous 50% figure then it is likely that the dominant method may not be DAB so why are spending more money on it and not on improving broadband reach which also has other benefits!?!? I believe our town is on the way to being a Superfast town - at a price I'm sure!! Some of my neighbours think that they'll get it automatically when it comes on line!

Another statistic that interests me is that there are supposedly 13 million DAB receivers out there, That is a cumulative figure so some of them must have died or been replaced by now. This is about half the UK households but I do not believe that half our households have DAB, more likely some have more than one, like us here with 3. If those Radios also have FM then who knows which is being used? If 30% of listening is Digital how does that get translated to households? Many of the published stats don't add up.

As to the solution I don't know either but part of it is a much clearer communications strategy going forward to 2030 with convergence of means of delivery driving the thinking. Sadly that's what the minister thinks he's doing!! How long will he be there for though? - another part of the problem. We do not want narrow vested interests and short termism in government. That is why this CBA is so important to get right - we want an answer that comes fromrelevant, reliable and tested data not a pre-cooked answer that the data is made to fit.

[Gordon]

to #13:

Yes Dave, many of your points I''d agree with. The local FM licences will be published as and when the legislation is written and then you can apply and see how far you get!!

As to WTP I think it's not an approriate measure. Anyway it isn't the point any more, sets are available at the WTP point that surveys have established so why isn't there a mad rush to buy?!? Consumers are not not buying DAB because they are expensive it's because they don't like DAB and more channels doesn't attract enough, there's plenty of choice on FM already!!