Q: Who is the government commissioning to produce an objective report on the costs & benefits of DAB radio switchover? A: The government

For two decades, the British government has pursued a policy to replace analogue radio broadcasting with DAB digital radio broadcasting. Why? The real reasons might as well be lost in the mists of time (or maybe were never made public). However, this has not stopped the government and its civil servants continuing to pursue the same digital radio switchover policy since the 1980s, despite overwhelming evidence that the surrounding media landscape has changed beyond recognition in the interim.

Because the government policy to replace AM and FM radio with DAB radio had never been decided on the basis of consumer demand, commercial necessity or global standards, it was unnecessary for officials to produce a document that justified it logically. When a government decides that a particular policy is necessary, it can make legislative change happen without recourse to the consumer market outside of Parliament or the Ministries. Politics and the real world do not inhabit the same space.

In the case of DAB radio switchover, the government made no effort to produce a cost/benefit analysis until 2008, when PricewaterhouseCoopers [PWC] was commissioned by Ofcom. However, the resulting 91-page report did not provide the solid, positive argument for DAB radio switchover that the government had desired. So the PWC report was hidden from the public for a year, eventually to be released and trivialised by civil servants [see my blog entry Feb 2010].


In contrast to the government’s unbridled enthusiasm for DAB, the PWC report felt that “the [radio] industry and consumers may fail to see the benefits of digital radio over the longer term.” It concluded that “there are relatively few up-sides to the estimates and several significant downside risks” from its cost/benefit analysis of DAB radio switchover [see my
blog entry Jul 2010].

The House of Lords Select Committee on Communications, in a report on digital radio switchover in March 2010, expressed its dissatisfaction with the government’s attempt to bury the evidence from this PWC report:

“We strongly regret that the cost benefit analysis carried out by PricewaterhouseCoopers was not published at the time it was delivered to Ofcom and the Department for Culture, Media & Sport in February 2009.”

The government responded that “technical difficulties” had prevented the report’s publication for nearly a year. As excuses go, it would probably have been better for the government not to have responded at all.

After this embarrassing debacle over the PWC report, the government must have wanted to commission a further report that would conclude what PWC had not: that DAB radio switchover is a wonderful thing and that there are sensible economic arguments to justify forcing it upon the British public.

In June 2009, the government’s Digital Britain report promised: “We will conduct a full Impact Assessment, including a Cost/Benefit Analysis of Digital Radio Upgrade.”

In January 2010, Ofcom’s Peter Davies offered
evidence to the House of Lords Communications Committee that another report would be done:

Baroness McIntosh of Hudnall: “What about your own impact assessment?”

Mr Davies: “We haven’t done an impact assessment yet.”

Baroness McIntosh of Hudnall: “But you have been asked to – correct?”

Mr Davies: “At some point in the future. I think the Digital Britain report said that we would be asked to do one, but we haven’t been asked to do one yet. Obviously we would need to do that and we would need a much fuller cost-benefit analysis before any final decision was taken.”

In June 2010, the government stated:

“We agree that a full impact assessment is an essential part of informing the Government’s decision on whether and when to move from a primarily analogue to a digital radio landscape. Work has already begun to collect the evidence needed to support an impact assessment and analysis should begin shortly.” [emphasis added]

Here we are now, in January 2011, and there remains no sign of the long promised cost/benefit analysis of DAB radio switchover, despite the new government continuing to pursue the digital radio switchover policy of the previous government. However, in December 2010, a document from the Department for Culture Media & Sport [DCMS] (marked “UNCLASSIFIED”) disclosed:

“The Government launched a joint Government and industry Digital Radio Action Plan on 8 July 2010. This Action Plan sets out the process for providing ministers with the information and assurances necessary to make a decision on whether and how to proceed with a Digital Radio Switchover. … Fundamental to the information provided to Government as part of the Action Plan will be a comprehensive Cost Benefit Analysis on the proposals for a digital switchover. … Government is conducting the modelling of the costs and benefits in-house. This research will provide robust evidence of potential costs and benefits to consumers of digital switchover to be incorporated into the Government’s Cost Benefit Analysis.”

So the government has confirmed that the government decision on digital radio switchover will be informed by a government cost/benefit analysis of digital radio switchover that utilises government modelling of the costs and benefits. It appears that, in the case of DAB radio switchover, the government has decided to be judge, jury and executioner too. This smacks more of ‘big brother’ than of the Conservatives’ much touted ‘big society.’

The unclassified DCMS document hinted that the earlier PWC report had not produced the desired results:

“A similar piece of work was carried out by PricewaterhouseCoopers in 2008 to inform the work of the Digital Radio Working Group into the future of digital radio and the potential for switchover. That Cost Benefit Analysis raised a number of caveats, chief among which were the gaps in research into consumer behaviour and willingness to pay. Although the radio ecology has changed since that Cost Benefit Analysis was produced, the document provides useful insights and the recommendations made by PricewaterhouseCoopers on further research remain valid.”

So what will be in the government’s new cost/benefit analysis report? The latest version of the government’s Digital Radio Action Plan explained:

1.4 IMPACT ASSESSMENT
Carry-out an impact assessment of the options and timings of the Radio Switchover. This will include, but not limited to, the following:
*the costs and benefits of any interventions to enable the switching the migration of all national and large local radio stations to DAB and alternative uses for the analogue spectrum vacated after the Radio Switchover;
* the rural impact of implementing the Digital Radio Switchover;
* Impact on energy consumption of a Switchover; and
* Environmental impact of analogue receiver disposal following Switchover.”

Interesting to see that neither the ‘consumer’ nor the ‘listener’ are mentioned here. For this workstream, the “first report to Ministers” is not scheduled until Q4 2011. It is evident that there is little urgency to execute this new cost/benefit analysis or for it to make a significant contribution at this juncture to any government re-evaluation as to whether to proceed with DAB radio switchover. If a cost/benefit analysis were a genuine priority, why was:
* the PWC report buried in February 2009 for a year;
* a new cost/benefit analysis promised by Digital Britain in June 2009 but not prioritised subsequently;
* the government saying in June 2010 that “work should begin shortly” on the analysis;
* a “first report” of this work now not scheduled to be presented until Q4 2011?

If the government’s DAB radio switchover policy were but a minor issue within the DCMS Ministry, all this deceit, delay and manipulation might be considered trivial. It is not. In December 2010, Minister Ed Vaizey admitted that he receives more correspondence from angry consumers about DAB radio than about any other issue within his portfolio.

So why are we witnessing such a continued lack of government transparency on the DAB radio switchover issue, despite prime minister David Cameron’s commitment in November 2010 to make the UK “the most open and transparent government in the world”?

Cost/benefit analysis of DAB radio: Murdoch rushes in where governments fear to tread

Governments have had plenty of practice, over many years, of hiding reports from the electorate. In some cases, they might justify this as a matter of national security or military expedience. However, it is hard to understand how the UK government thought it could justify hiding from the public a cost/benefit analysis of digital radio switchover it had commissioned and then, a year later, have believed the matter had been successfully buried. But so it was, until the House of Lords Communications Committee intervened in early 2010.

On 6 February 2009, PricewaterhouseCoopers [PWC] delivered a 91-page report entitled ‘Cost Benefit Analysis of Digital Radio Migration’ to Ofcom. It contained a number of serious reservations that any benefits would arise from switchover to DAB radio, even by the year 2030:

“The results suggest that there are relatively few up-sides to the estimates, and several significant downside risks. … The results suggest that there is a very long pay-back from the Digital Radio Working Group [DRWG] policy ‘investment’ – the Net Present Value [NPV] turns positive after 2026. This result assumes that the existing multiplex licences are extended to 2030, as per the DRWG recommendations. Without the licence extension or any other policy instruments that provide clarity on the long term future of commercial radio, the industry and consumers may fail to see the benefits of digital radio over the longer term. Our analysis suggests that the NPV is negative should either of these two proposals not be implemented.” [emphasis added]

Since then, parliamentary policy has failed to provide “clarity on the long term future of commercial radio,” as evidenced by last week’s wholly ambivalent government statement about digital radio switchover. As a result, just as PWC predicted, industry and consumers increasingly “fail to see the benefits of digital radio over the longer term.”

The PWC report, and its verdict that digital radio switchover offers almost no benefits, remained hidden from public view from February until November 2009, when an appendix to the government’s Digital Economy Bill mentioned it casually. That citation raised questions: what was this PWC report, and why could not the public see it?

When the House of Lords Select Committee on Communications convened in January 2010 to consider the digital switchover issue, it asked those same questions of the Ofcom officers it invited to present evidence:

Baroness McIntosh of Hudnall: We understand that you commissioned a report from PWC last year into the costs and benefits of digital switchover in radio, but you didn’t publish it. We know, therefore, what we have learned from the Department for Culture, Media & Sport about what it said. It appears that it found, for example, that the benefits could – and I emphasise the word “could” – outweigh the costs by £437 million after 2026, but that conclusion is hedged about with quite a lot of caveats to do with what would have to happen in order for that good outcome to eventuate, and that if those things didn’t happen, then quite quickly you would get into a position where the costs would outweigh the benefits. Can you tell us a bit about that report? In particular, can you tell us why you haven’t published it? Do you think that, given what it appears to say – I choose my words carefully – about the constraints on potential for benefit, that it should have been available to inform the Government’s digital policy? ….. [edited]

Mr Peter Davies [Director of Radio Policy & Broadcast Licensing, Ofcom]: We were asked to commission it by the Government. We then commissioned it from PWC with a lot of input from various government departments and then submitted it to the Secretary of State.

Chairman: So you decided not to publish it.

Mr Stewart Purvis [Partner for Content & Standards, Ofcom]: …. [edited] On this particular occasion, it was decided in conjunction with the Department that work would be sent to the Department. Perhaps the most important thing is for Peter to respond to your characterisation of the work, but, in a sense, we have not hidden the piece of work. Indeed, I think it is now available to you. Is that right?

Baroness McIntosh of Hudnall: In, as they say, a redacted form.

Chairman: Just to be absolutely clear, the Department asked you to commission the work from PWC. Is that what you are saying?

Mr Purvis: They asked us to commission the work. Did they ask us specifically from PWC?

Mr Davies: Not specifically from PWC.

Chairman: The Department said to Ofcom, “Ofcom, you go and commission this particular work.” Is that the position?

Mr Davies: Yes.

Chairman: You then got the work which then came back to you and then you sent it to the Government and the Government said, “We’re not going to publish this in full.”

Mr Davies: I think they have certainly made it available to various groups. I think consumer groups have had it for some time.

Chairman: Fine. There will be no problem, therefore, in this Committee having the full report. …. [edited]

Baroness McIntosh of Hudnall: The thing that is slightly troubling – perhaps only to me, but a bit – is that when you see what appears to be evidence that the costs and benefits are, let’s say, finely balanced, or could be, that the drive towards digital migration, one might think, was driven more by the technology than by the needs either of the broadcasters or the consumers.

The Committee’s displeasure with Ofcom and the government was evident both in this exchange and in its subsequent report on digital switchover, published in March 2010, which stated:

“We strongly regret that the cost benefit analysis carried out by PricewaterhouseCoopers was not published at the time it was delivered to Ofcom and the Department for Culture, Media & Sport in February 2009.”

The government’s response to the Committee’s statement, published in June 2010, was:

“The Cost Benefit Analysis produced by PricewaterhouseCoopers, to accompany the work of the Digital Radio Working Group, was widely distributed amongst broadcasters and consumer representatives. However, there were technical difficulties which prevented the initial publication of the report on the DCMS website; these were rectified and the report published in February 2010.”

“Technical difficulties” for a whole year? As excuses go, this really takes the biscuit. It seems unlikely that the PWC report would ever have been made public, if not for the intervention of the House of Lords Communications Committee in January 2010 (first publication of the report’s findings was in this blog a few days later).

The PWC report did not offer the government the support for its digital radio switchover strategy that it had anticipated, so now it has to commission a further cost/benefit analysis which it hopes will produce a more favourable outcome. Is the government in a hurry to complete another study evaluating the supposed benefits of digital radio switchover? Hardly, judging by the evidence.

In June 2009, the government’s Digital Britain report had promised:

“We will conduct a full Impact Assessment, including a Cost/Benefit Analysis of Digital Radio Upgrade.”

In January 2010, Ofcom’s Peter Davies had offered evidence to the House of Lords Communications Committee:

Baroness McIntosh of Hudnall: What about your own impact assessment?

Mr Davies: We haven’t done an impact assessment yet.

Baroness McIntosh of Hudnall: But you have been asked to – correct?

Mr Davies: At some point in the future. I think the Digital Britain report said that we would be asked to do one, but we haven’t been asked to do one yet. Obviously we would need to do that and we would need a much fuller cost-benefit analysis before any final decision was taken.

Most recently, in June 2010, the government stated:

“We agree that a full impact assessment is an essential part of informing the Government’s decision on whether and when to move from a primarily analogue to a digital radio landscape. Work has already begun to collect the evidence needed to support an impact assessment and analysis should begin shortly.” [emphasis added]

Why bother with yet another report at this late hour in DAB’s history? Someone else has already done the sums. News International has just run its sliderule over the idea of launching a national digital radio station ‘SunTalk’ (a brand extension of its national daily newspaper ‘The Sun’) on the DAB platform. Its result was: DAB radio is not a viable commercial platform.

According to The Guardian: “News International management were considering extending the [SunTalk] station’s reach by launching it nationally on DAB digital radio. But it is understood they baulked at the extra cost.”

If Murdoch cannot see a way to make a profit from a broadcast platform that is crying out for compelling content, then how exactly does any other content owner think it can make a financial return from DAB radio?

It’s the platforms Rupert Murdoch rejects ….

Benefits of DAB radio “insufficient compared to its cost per user” warned EU report … in 2002

Sometimes it proves useful to take a look backwards to try and understand where you are now. In 2002, a 236-page report was produced for the European Commission on the topic of ‘Digital Switchover In Broadcasting’ by BIPE Consulting. Re-reading it is a stark reminder that the current problems with DAB radio implementation in Europe had been anticipated at least eight years ago.

Firstly, the BIPE report admitted that a significant motivation for introducing DAB radio was so that existing licensed European broadcasters could maintain market control in the face of competition from IP-delivered radio content produced by pesky foreigners:

“Some radio broadcasters consider digital radio as a question of survival in the long term … digitisation of content, transmission and multipurpose receivers could squeeze out the possibility of having a dedicated radio platform with its own players, services and listeners. The fact of having a dedicated [DAB] platform could maintain the existing value chain. If not, alternative, third-party digital platform operators will enter the game, and this could reduce radio specificity as it is understood today or even break the radio business model.”

Many of the problems of implementing DAB were identified then:

“New frequencies have to be found to simulcast analogue programmes and new expected ones (which is not the case with digital TV that can be simulcast in the same bands); very high digital receivers prices create a chicken-and-egg situation; while pay TV is a strong driver of TV digital migration, a pay-radio business model seems not to be sustainable so far; RDS, data services and free-to-air multi-channel FM reduce the attractiveness of digital radio.”

And the huge challenge of convincing consumers was made very clear:

“Analogue radio receivers are low cost devices offering numerous, free-to-air channels and with FM audio quality. In this context, the benefits of digital radio as presented by the DAB model so far are insufficient compared to its cost per user.”

The long period of consumer migration from AM to FM broadcasting in Europe was recognised:

“More than 30 years of simulcast AM/FM were necessary to substitute nearly completely AM by FM listening. This lengthy duration covered network deployment, frequency release, launch of music channels (the killer application), and diffusion of FM functionality through the installed base of all the receivers.”

The report identified the “major obstacles to digital radio migration” as:
• Receiver cost
• Low consumer awareness
• No pressure to release the FM band (“DAB is costly in terms of bandwidth used and difficult to insert in existing radio bands. … But the quantity of spectrum released by terminating analogue radio services is much less significant than the potential release of spectrum following the turn-off of analogue terrestrial television broadcasting.”)
• No pay model driver
• No clear killer application (“Together, FM and RDS already combine a certain degree of quality with important data services.”)
• Lack of interest for higher quality sound
• Lack of interest from carmakers
• Necessity of a European market (“Low cost receivers require addressing mass markets. Different national timing in the digitisation of radio does not create the conditions or incentives for achieving critical mass.”)
• The installed base of receivers (“There are between 3 to 5 radio receivers per household, many of them being lower cost receivers. To replace such an installed base means achieving low costs and/or to supply attractive, new services.”)
• Other standards than DAB are possible (“This competition may reduce the mass-market achievement in Europe.”)
• Lack of radio spectrum capacity for DAB (“The DAB multiplex is much larger than one FM channel: insertion in the FM band is not possible, spectrum efficiency is poor.”)
• Multi-channel is already a feature of analogue FM radio (“Additional services will have a marginal effect.”)
• DAB licences have sometimes been delayed.

Finally, the report identified what it called “a chronic chicken-and-egg situation” whereby:
• “Receivers remain expensive because there are no scale effects. This reduces audience and revenues of radio broadcasters who demand that manufacturers decrease receiver prices in order to provoke a mass-market and to trigger mass audiences ;
• There is no specific advantages [sic] in digital radio, no killer application, nobody buys digital receivers, the audience remains negligible, and prices stay high.”

There was even a graphic to illustrate the problem:

This all feels very much like DAB in Europe … eight years on. And, to hammer home the impending fragmentation of radio delivery platforms, the report’s recommendations noted that:

“Digital radio will probably be delivered through a much larger variety of technologies and platforms than analogue radio, which is essentially terrestrial. These will involve broadcasting or point-to-point, online or on-air, satellite, terrestrial or cable delivery, DAB, DVB or DRM technologies. These techniques will be competitors but very complementary for consumers and broadcasters.”

The questions all of this raises are:
• How did the UK government’s Digital Radio Working Group spend one year (2007-2008) considering how to make DAB radio a success in the UK but not reference this 2002 report?
• How did the UK government’s Digital Britain consultation spend much of a year (2008-2009) looking for the answers to DAB radio implementation but not reference this 2002 report?
• Did DAB stakeholders in the UK read this report in April 2002? And, if so, did they simply choose to ignore it?

[thanks to Eivind Engberg]