Car industry: “gaps in digital coverage are a major deterrent to [the] introduction of digital radios”

The Society of Motor Manufacturers and Traders [SMMT], representing 500+ companies in the UK car industry, has submitted written evidence to the House of Lords Communications Committee inquiry into digital radio switchover. Its members have itemised a number of concerns about the practicalities of the government proposal that all new cars be offered for sale with DAB radios by 2013:
• “the apparent perception that the markets for in-vehicle radios and domestic radios are similar, if not identical, and that any assumptions about the speed of take up can be applied to both markets
• the timeline for adapting the existing vehicle parc [cars already on the road]
• the continued availability of traffic information after 2015 to those driving vehicles which are not digitally-enabled
• the extent of radio transmitter coverage
• the need for broadcasters to promote the advantages of digital radio to consumers to create demand
• safety and security issues arising from the use of digital convertors
• the need for pan-European approaches to the introduction of digital radios in vehicles.”

The key issue raised by SMMT concerning the necessary robustness of DAB in-car reception across the whole of the UK would require a massive investment from the radio industry to rectify:

“SMMT members are clear that the gaps in digital coverage are a major deterrent to their introduction of digital radios as standard equipment. As outlined [below], any vehicle manufacturer bears the reputational risk if a radio in one of its products appears not to work properly. Drivers have become accustomed to the gradual deterioration in FM reception which occurs throughout parts of the UK and recognise this is not the fault of their radios. At the present stage of digital roll-out, shortcomings tend to be blamed on the vehicle manufacturer.

SMMT members therefore welcome the statements in the [Digital Britain] report that:
• one of the criteria for deciding the date of the Digital Radio Upgrade will be whether national DAB coverage is comparable to FM coverage and that local DAB radio reaches 90% of the population and all major roads
• the BBC should begin an aggressive roll-out of the national multiplex to ensure that its national digital radio services achieve coverage equivalent to FM by 2014.

However, there is also a need for a plan to enable reception on those stretches of road, primarily tunnels and long underpasses, where reception goes ‘dead’ for a short period. At present, for instance, FM coverage in the Dartford Tunnel is addressed by special measures. In shorter tunnels, the FM signal tends to deteriorate but not disappear, whereas the digital signal disappears entirely.

SMMT noted that:

“There appears to be an assumption that the market for in-vehicle radios and that for domestic radios have similar, if not identical, features. In fact, they differ in five main ways:
• in the automotive market, the vehicle itself, not the radio, is the reason for the purchase
• vehicles are required to undergo an approval process which is far lengthier than any applying to consumer goods
• the sizes of the two markets and their dynamics are vastly different, where customers purchase new radios more frequently than they do vehicles
• if a radio in a vehicle fails, or even only appears not to work properly, blame is attached to the vehicle manufacturer, whereas the reputational risk if a domestic radio fails is borne by the radio manufacturer
• in automotive applications, the radio is not static. It moves between transmitters and, therefore, complete and national coverage of the digital radio network will be required.”

SMMT’s concern for new cars is that:

“meeting a deadline of 2013 will be a challenge for vehicle manufacturers who began product development in 2009, but we expect it to be achievable. A bigger challenge is represented by those models already on the market or most of their way through the development cycle, where the manufacturers will have to decide whether to divert engineering resources to the task of digitally-enabling them or provide new vehicles with digital convertors.”

SMMT’s concerns for the cars already on UK roads are:

• “The [Digital Britain] report suggests that the majority of the vehicle parc should be converted to digital by 2015, with low-cost convertors for the remainder.
• Vehicle manufacturers are certain that retrofitting of digital radios on a large scale is impractical. Vehicles’ electronic systems have become increasingly integrated; often, the radio is part of this integration and cannot easily or economically be replaced. A radio has to operate in the vicinity of sensitive electronic components, and poor integration has a detrimental effect on other systems.
• Retrofit also affects the perceived quality of the vehicle:
          *  antennae have to be chosen very carefully – reception from an internal antenna may be poor if a vehicle is fitted with infra-red reflection glass, or if a magnetic antenna base is fitted to an aluminium body
          *  poor refitting of trim items removed to permit a retrofit will cause rattles.
• Drivers will, therefore, be reliant on the use of digital convertors to enable continued use of their analogue radios after 2015. As vehicles have very long lives, most of the vehicles first registered since 2006, if not earlier, will still be in use in 2015. It is likely that over 20 million vehicles will have to be so fitted, and very likely that most of the necessary sales will be made in the few months before the date for digital migration. The commitment for a cost:benefit study to be conducted before any digital migration date is announced is therefore welcomed by vehicle manufacturers because it should firmly identify the progress made towards digitally-enabling the car parc.”

The message from the car industry seems clear – why should they risk their reputations by installing DAB radios that will suffer poor reception due to lack of a robust DAB radio transmission system in the UK?

The bigger question is – why would consumers pay extra for a DAB car radio that offers increasingly little additional mainstream content over a standard FM radio?

Digital radio switchover: a Broadcasting Minister’s last day: "there is nothing that I am trying not to say"

Apologies: this is an extremely long blog entry. I suggest it is worth persevering with because, more than any other ministerial statement, the transcript below illustrates perfectly the government’s mistaken determination to press ahead with its policy to adopt DAB radio. During the weeks it has been sitting, the House of Lords Communications Committee has become increasingly adept at understanding the flaws and contradictions in the Digital Economy Bill’s radio clauses, which is why their dialogue here with the Minister crackles with suspicion.

Siôn Simon handles his government script with the aplomb of a dodgy used car salesman, combined with the smug self-satisfaction of a schoolboy who can proffer a verbal comeback to any question asked of him. In December 2009, Simon had to repay £20,000 in parliamentary expenses for a second home he was renting from his sister between 2003 and 2007. Embarrassingly, the Broadcasting Minister reveals here his mistaken belief that the government’s proposed 2015 digital radio switchover date is written into the Digital Economy Bill. It isn’t.

I could itemise the many flaws in the Minister’s replies to the Committee’s questions, but it would spoil your reading fun. Your starter for ten – Halfords does not stock DAB radios.

House of Lords
Select Committee on Communications
“Digital Switchover of Television and Radio In The UK”
10 February 2010 [excerpt]

Witnesses:
Mr Siôn Simon, a Member of the House of Commons, Minister of State for Creative Industries
Mr Keith Smith, Deputy Director, Media in the UK, Department for Culture, Media and Sport

Chairman: Good morning. Thank you very much for coming, you are very welcome to the Committee. Now, Mr Simon, you are the Broadcasting Minister.

Mr Simon: For the moment, until the end of today.

Chairman: Well, that is what I was going to raise with you. How long have you been in this post?

Mr Simon: I have been in this post since, I think, the beginning of June last year and today is my last day, so this will be my final appearance before a Select Committee and I am looking forward to it tremendously.

Chairman: Well, before you look forward to it too immensely, let me ask you a question, and I ask the question because, on my reckoning, there have now been five broadcasting ministers since May 2006. That is a very high turnover. Do you think that these frequent changes help in making policy?

Mr Simon: I think I should have been appointed in 2005, but —-

Chairman: But Number Ten actually omitted to do so?

Mr Simon: They omitted to do so and, as you know, you will have to ask the Prime Minister about the appointment of ministers because that is his decision, not mine.

Chairman: Well, the resignation of ministers, on the other hand, is very much in the hands of ministers, is it not? You are not even going to take the Digital Economy Bill through?

Mr Simon: I have had great enjoyment and satisfaction dealing with it as it has been through all the various stages of consultation with stakeholders across industry and Parliament since I inherited the White Paper. The White Paper was published the week I was appointed, the Digital Britain White Paper.

Chairman: By your predecessor who also only lasted a year.

Mr Simon: I think he did an outstanding job actually, I must say. Having come in and inherited his output, I think Lord Carter did a very, very sophisticated, subtle and impressive job across a whole range of industry sectors.

Chairman: At any rate, you enjoyed it so much that you are not going to stay for a couple of months?

Mr Simon: It has been an absolutely tremendous pleasure and privilege. I think it is one of the best jobs in Government. I have lots of reasons that I am stepping down as I am deciding to do other things and I am also stepping down from Parliament.

Chairman: What are the other things you are going to do?

Mr Simon: I am going to run, if I can, to be the first elected Mayor of Birmingham, which will probably be a couple of years, but is a job worth doing and worth planning for.

Chairman: Well, as a Birmingham MP for 27 years, I am probably the person round this Committee who has most sympathy with that ambition, although I do not think the job actually exists, let alone you are going to win it. Quite seriously, do you really think that these swift changeovers of ministers actually do the policy process any advantage?

Mr Simon: I do seriously have to tell you that I am a junior minister and junior ministers, as you know with all your experience, are not responsible for the appointment of ministers, the policy towards the appointment of ministers or the length of tenure of ministers. You need to take that up with the Prime Minister; it is not a matter for me.

Chairman: Well, I doubt very much whether the Prime Minister is going to agree to come to this Committee, given all the other things he has got on his mind just at this period in Government, but never mind.

Lord Maxton: Do we know who your successor is going to be?

Mr Simon: I do not know.

Lord Maxton: Presumably, somebody will have to be appointed this afternoon if you are going this afternoon?

Mr Simon: Again, it is a matter for Downing Street, not for me or officials.

Chairman: So you are going this evening and we do not know who is going to take your place?

Mr Simon: I think it is fairly common procedure that it is after the one minister has resigned that the next one is appointed, so I assume there will be an announcement from the Prime Minister in due course about what arrangements will need to be made.

Chairman: Okay, I do not think we are going to get much further on this particular path. Let us ask you about the digital switchover. This is a short inquiry that we have conducted and most complaint, I think, has been about radio. There seems to be enormous uncertainty amongst the public about what is happening and indeed what the case for radio switchover is. We have just been talking to consumer groups and, just to give you some flavour of what they said initially, one said he could not see any advantage, another said it was difficult to see what the benefits are and a third said that they were concerned about the expense of throwing away sets, and I think that is one of the issues that has come through from some of our correspondence as well. What would you say are the advantages of digital switchover as far as radio is concerned?

Mr Simon: I think there are several advantages. Firstly, digital has practical and technical advantages of benefit to the consumer, so there is a whole range of extra functionality and interactivity that you get from a digital radio set that you will not from analogue. It is also the case that the FM infrastructure, the transmission infrastructure of FM, is ageing, FM is an old analogue technology, and the likelihood is that in the medium term the question will arise anyway of whether this infrastructure can economically be renewed and the likelihood is that it probably would not be economic to renew this infrastructure. What you would be faced with in that case would be a piecemeal disintegration of the FM infrastructure in a disorderly way and an inevitable move by the market towards digital. What the Government is, therefore, doing is trying to help manage this move in an orderly and efficient way.

Chairman: So what would you say to the member of the public who has written a not untypical letter to us in which he said, “We have acquired a large number of FM radios over the years, all of which work perfectly. Five of these are used regularly in different rooms. Why should we ditch these for no good reason?”?

Mr Simon: Well, firstly, they will not necessarily have to ditch them; it will depend what services they are using them to listen to, and it may be that there are different members of the family using different sets in different rooms at different times to listen to different services. It is reasonable to assume, therefore, that in a typical family some of those sets in some of those rooms will be used to listen to the kinds of local commercial services or community radio services which will remain on FM, indeed which will be expanded and have their presence secured on FM and remain available. Now, clearly it will be the case that, in order to listen to major national or large regional broadcasters after 2015, consumers will need some kind of upgrade to listen to digital. It is very likely that a relatively cheap, small add-on which converts an analogue set to a digital set will become available before the switchover date. We are talking to manufacturers, and I cannot guarantee what manufacturers will manufacture, but we think it very likely that a small, cheap converter will be available and people will purchase over time new sets.

Chairman: Well, we will come to that point. Can I just ask one broader point though than that. Ofcom commissioned a cost-benefit analysis of digital radio migration from Price Waterhouse. That report found that the benefits might outweigh the costs only after 2026. Is that the basis upon which you are planning as well?

Mr Simon: I think that the report that Ofcom commissioned was into the recommendations of the Digital Radio Working Group, which were different from those which eventually made it into the Digital Britain White Paper and the Digital Economy Bill, so, to be honest, it is not really a straight comparison because the Price Waterhouse report was not into what is going to happen, it was into a different set of recommendations by a different group.

Chairman: I hear what you say, but why has the Price Waterhouse report not been made public?

Mr Simon: Clearly, there has been a little bit of difficulty about this. There is no sense at all in which it was intended not to be made public. It is now on the DCMS website. It should have been on the DCMS —-

Chairman: In a redacted, blacked-out form.

Mr Simon: I believe that the form that it is in on the website is redacted to remove commercially sensitive information, which is the usual practice with commercially sensitive information, but I am told that the Committee has been supplied with an unredacted version by Ofcom, and any stakeholders who have asked for a copy have been sent a copy. We should have put it on the website more quickly. There were technical difficulties to do with the report not having been written internally and being supplied in the wrong format and so on which meant that it did not get on the website. There has been no intent whatsoever, and there is no intention, to keep private the report.

Chairman: Well, we, I gather, have received the report this very morning, so we obviously have not looked through it yet

Lord St John of Bletso: I noticed in the written evidence from DCMS that one of the challenges of the digital radio switchover will be converting the occasional radio listener rather than the avid listener who has already invested in DAB sets. There has been also a commitment to a further cost-benefit analysis of the digital radio upgrade. What is the timetable of this proposed new cost-benefit analysis, and will you wait for the outcome of this analysis before taking further decisions to go forward?

Mr Simon: I think the commitment with the digital radio upgrade is for a full impact assessment and a cost-benefit analysis particularly of the need for, the case for and the design of a possible digital radio help scheme. As to the sense in which there is a cost-benefit analysis of the whole programme, rather than a kind of discrete piece of commissioned work, like the report we were just talking about, this would be a constant, ongoing process of review which is starting this year and will be constantly reviewed, measured and updated as the programme unfolds.

Lord St John of Bletso: We have, as I understand it, 90 per cent still on analogue and ten per cent on digital, but have you estimated the effects of the costs and revenues to the different radio stations and the bodies arising out of digital migration, and how will profitability change and who will benefit? That is really what we are trying to get at.

Mr Simon: I think the percentage already listening on digital is higher than that, I think it is more like 20 per cent, and we are committed to not switching over until listenership on digital is at least 50 per cent and coverage is at least comparable to FM, which would be 98.5 per cent. Can you just tell me a bit more as I was not quite sure exactly what you wanted in your subsequent question?

Lord St John of Bletso: It was just the phasing of the transfer as far as not just the timing of the cost-benefit analysis, but what the effects would be and the costs and revenues for the different radio stations and others.

Mr Simon: The intention is that the radio market be much more distinctly than it currently is organised into three distinct tiers, so a national tier at the top, which would be digital, a large regional tier, which would also be digital, and then at the lowest end a local tier, which would be small, local commercial broadcasters and community radio stations who would remain on FM. The effect would be that some currently medium-small commercial broadcasters would probably grow their broadcast areas and migrate on to digital. Some of that size could potentially shrink slightly and stay on FM, the underlying dynamic being that it is much cheaper to stay on FM than go on to digital, and there would be small commercial broadcasters for whom it would not be economic to migrate to digital which has inherently a much bigger footprint.

Lord Maxton: I am not quite clear where the BBC would fit into that because they provide national and local services.

Mr Simon: If I may say so, my Lord, that is a very good question and the answer is that in the crucial matter of building out extra transmitter infrastructure so that the coverage of digital matches by 2015 the current coverage of FM, which is about 98.5 per cent of the country, the assumption is that the commercial sector and commercial operators would fund that build-out as far as it was commercially and economically viable, and then the assumption is that the BBC, with its obligation to provide a universal service, would fund the probably seven or eight per cent of the build-out which was not commercially viable.

Lord Maxton: But they were only talking about 90 per cent, the BBC were last week.

Chairman: Is it going from 90 to nearly 100 per cent?

Mr Simon: Very roughly. It is between 90 and 98.5 which, it is assumed, would not be commercially viable.

Chairman: But you are assuming that the cost of that will be taken from the licence fee?

Mr Simon: I am assuming that the BBC would be building those transmitters. We are talking about a cost of probably between £10-20 million a year.

Chairman: So it would be taken from the licence fee?

Mr Simon: I think the assumption is that the BBC would be able to absorb that within its current budgets.

Chairman: Well, the BBC said to us that actually they would like to talk to you about the licence fee, so there may be a constructive dialogue to be had there!

Lord Maxton: Obviously, what you are saying does imply a fairly major restructuring of the radio industry. I assume you are going to be consulting on this, are you?

Mr Simon: We are, and have been, consulting continuously. I have had two summits with small commercial operators who, at the beginning of the process of talking to them, were a bit concerned.

Lord Maxton: Can I link this to one of the Government’s other quite right policies, which is extending broadband to everybody. Where does that fit into radio because it seems to me that people are already selling internet-available radios so that you can pick up radio stations from wherever?

Mr Simon: It is all part of the same, I think, pretty relentless drive towards digital, but they are different strands of the same broad movement rather than being directly interlinked or dependent, so internet radio listenership forms part of the digital radio listenership, but it actually forms a very small part of the digital radio listenership and there is still a case and a clear need for an explicitly transmitted-over-the-airwaves radio digital output as well; you
cannot do it all on the internet.

Baroness McIntosh of Hudnall: I just wanted to go back to two things that you said in your last couple of answers, Minister, and the first one was about the 50 per cent target for digital listenership before making the decision to migrate to digital. We had evidence from the witnesses who were here immediately before you that there is a strong likelihood that the 50 per cent of people who, at that point, would not have taken up the digital option may include a high proportion of vulnerable listeners. Do you have any observations, or indeed has your Department done any research, to demonstrate whether or not that is likely to be the case? Also, you made the point about the BBC becoming responsible for making up the shortfall between 90 and 98.5 per cent, and the evidence that they gave us last week demonstrated, or they believe it demonstrates, that the level of investment to produce that last eight to ten per cent’s worth of coverage is enormously much greater than the level of investment that has been necessary, or will be necessary, to arrive at 90 per cent. I think, from memory, they were talking about having 90 transmitters currently and needing to invest in a further 140 in order to meet that remaining ten per cent. That is a pretty big ask, and I just wonder whether you would, in the light of that, be prepared to reconsider your answer to Lord Fowler about where the money is going to come from.

Mr Simon: If I could take those two, in the first case we have not commissioned research about that yet. Intuitively, I suspect that you are probably right and that there will be a disproportionately high number of, for instance, older, disabled or other vulnerable people in the cohort that is not digital by the time we switch over, so, for that reason, we will be commissioning a full impact assessment and cost-benefit analysis, looking into exactly those issues and using that information to determine, and what would be the details of, some kind of digital switchover help scheme in just the same way that we commissioned research which informed the digital TV switchover Help Scheme that we have ultimately put into place and which is, I think, widely held to have been pretty successful. On the second question, we have been talking to the BBC very closely and very recently about this and, no, I am pretty clear that what I said initially was right, that we are talking about costs of somewhere between £10-£20 million.

Baroness McIntosh of Hudnall: Sorry, £10-20 million per annum, you said earlier?

Mr Simon: Per annum, yes.

Baroness McIntosh of Hudnall: Over what period? An additional net £10-20 million spend for the BBC into an indefinite future or over a specified period of time?

Mr Simon: No, over the period of the switchover, after which the BBC’s costs would decline by up to £40 million a year because they will only be transmitting on one platform and the cost of analogue will be deleted. The basic principle is that the market will pay the cost as far as it is viable. For those people who live in areas, presumably almost always more rural areas, where it is not commercially viable to build out digital transmitters, then the BBC, because it has in its Charter an obligation to provide a universal service, will likely be bound to build out those transmitters. In our conversations with them, they have recently seemed to recognise that and I certainly have not had a sense from them that they believe that the cost would be prohibitive.

Chairman: I am bound to say, it is not the flavour of the evidence that they gave to us last week. I think Lady McIntosh makes an extremely good point here. Rather than continuing this, we had better just recheck with the BBC what exactly it is that they want and require here, but, I have to say, your evidence is slightly at variance with what the BBC were telling us.

Baroness Howe of Idlicote: I think quite a number of the questions I was going to ask have been answered, but I am still not clear about this £10-20 million that you are talking about with the BBC. Presumably, this will be extra money over and above what they are getting at the moment that you are negotiating with them?

Mr Simon: This is not money that we anticipate giving to them. It is a cost which we anticipate will accrue to them when they are building out new transmitters in order to meet their obligation in respect of universality.

Baroness Howe of Idlicote: So there will be a difference in that they are prepared to go up to 90, but not beyond that?

Mr Simon: The commercial sector will build out to 90 per cent and for the rural areas, the seven or eight per cent beyond that which the commercial sector would not build to because it would not be commercially viable, the assumption is that the BBC will build out that step further and that that will cost them about £10-20 million a year during the period of switchover, which they will later recoup as they make savings from not transmitting anymore on analogue.

Chairman: So you are cutting the budget of the BBC by £10-20 million in that period?

Mr Simon: Well, I do not have any control over the budget of the BBC.

Chairman: You are telling them what to do!

Mr Simon: I am not telling them. I am just telling you what the assumptions are about where the likely build-out will come from.

Baroness Howe of Idlicote: I also want to go back to this whole business of just when the radio switchover is actually going to happen as there are huge question marks over this. I know the target is 2015, but, as you probably also heard, a lot of people do not even want it to happen. If we are looking at FM and the extension of time that may well be required, is the Government prepared to give a guarantee that FM will remain right the way through whatever period it is, even if it takes another ten years or even longer for the total switchover to take place?

Mr Simon: I think the Government can guarantee that FM will remain for the foreseeable future. The Government cannot give guarantees indefinitely, but for the foreseeable future the part of the FM spectrum which will be used for local commercial and community radio will continue to be available for that.

Baroness Howe of Idlicote: Well, could you please define for me the ‘foreseeable future’? How far beyond 2015 would that be?

Mr Simon: I cannot put a number on it, but I would have said it would be well beyond 2015, well beyond.

Baroness Howe of Idlicote: Well, 2020, say?

Mr Simon: My personal guess, for what it is worth, is probably well beyond that.

Baroness Howe of Idlicote: You are probably aware that there will be, and there are already, efforts to get on the face of the Bill a guarantee that it will stay for as long as that.

Mr Simon: A point I would make is that, as far as we are aware, we cannot find any evidence anywhere that the FM spectrum will be, going forward, of any particular economic value to anybody. We are not aware of anybody being likely to want it and certainly to want to pay anything in order to use it for anything else. As long as it remains viable for people to use it for radio, as long as people want to continue to use it for radio and as long as the infrastructure still works, then there is no reason at all why it should not continue. It could be another 50 years.

Baroness Howe of Idlicote: But you did in fact say that it was an ageing infrastructure. Have you got any guess about how long it would remain a viable infrastructure to be used?

Mr Simon: I honestly do not know. There is no sense whatsoever in which I am prevaricating or equivocating, there is nothing that I am trying not to say, but I simply cannot give you any certainty because there is no certainty.

Baroness Howe of Idlicote: I wonder whether Mr Smith might have an answer.

Mr Smith: I have nothing really to add to what the Minister has said. Again, and it is a personal view, but I would expect FM to be available well into the future and I think I would share the Minister’s view of beyond 2020, but we do not know precisely when. The infrastructure is an ageing infrastructure, but who knows how long it might last.

Lord Inglewood: I would just like briefly to turn back to the question of extending the DAB national network because it has been measured in the discussions so far by reference to the percentage of the population, but, since the population is scattered relatively randomly across the country, of the final ten per cent of the population, how much in terms of the total number of transmitters and transmission stations does that represent? In fact, in terms of the total cost of rolling this out, that last ten per cent is going to cost a great deal more than the first ten per cent, is it not?

Mr Simon: In answer to the first question, nobody knows how many transmitters —-

Lord Inglewood: No, but just an order of magnitude; I am not interested in specifics.

Mr Simon: I do not know.

Lord Inglewood: But it is much more than ten per cent of the total cost of the thing, is it not?

Mr Simon: Certainly, you would expect for the non-commercially viable, rural final percentage that the unit cost would be higher than doing the middle of big cities obviously, yes.

Baroness McIntosh of Hudnall: Just on the question of who is listening, there appears to be some evidence, including from Ofcom’s research, that most people who listen to the radio at the moment are pretty happy with what they have got now and that actually this notion of extensive choice and interactivity, which is the key selling point really of digital radio, as you said yourself at the beginning of your evidence, actually does not weigh that heavily with most consumers. We also have heard evidence from John Myers, who was commissioned by the DCMS to report on this, that there is a considerable oversupply of radio services in the sense that there are too many stations out there fulfilling need which is perhaps not as great as they need it to be to be commercially viable, so are you convinced that there really is the consumer-led demand for a digital switchover, or is this really being driven by the fact that the technology exists and, because we can do it, we will do it?

Mr Simon: In the first instance, I think the clearest evidence that there is a demand for digital radio is that in the last ten years ten million digital radio receivers have been bought, and many of them in the earlier years quite expensively and many of them repeat purchases. For a new technology from a standing start where the existing technology remains in place and is dominant, I think that is clear evidence of significant demand and it is a market that continues to grow.

Baroness McIntosh of Hudnall: Before you go on from that, could you just tell us what the percentage of the absolute number of radio sets is, as far as it can be estimated, in the country?

Mr Simon: It is impossible to say because there are wildly different estimations of how many radio sets —-

Baroness McIntosh of Hudnall: Well, on what do you place reliance?

Mr Simon: The estimations of the number of analogue sets in existence, which I can think of having heard, varies between about 40 million and 100 million plus, and it is a technology that is 100 years old, so that is a massive accumulation of equipment and it is, therefore, very difficult to compare with a ten-year-old technology. Out of maybe 50 million meaningful analogue sets, if there have been ten million digital sets sold in the last ten years, I think that shows significant consumer demand for a new technology. On the second question about whether the market is oversupplied, firstly and fundamentally, the size of the market is a matter for the market and for the consumer and it is not ultimately my job to manage the size of the market. However, one thing that we are trying to do with this move, as I have said, is to stratify the market into large national, large regional and very local services, which should mean that, rather than everybody in their rather disorderly fashion competing perhaps on unequal terms in one chaotic market, people can do business more efficiently in a more discrete market, and local commercial radio stations, for instance, can do local commercial advertising that will not overlap and be in competition with big national chains and so on.

Baroness McIntosh of Hudnall: So, leaving aside just the generality of choice as a benefit in itself, if you had to say what the benefits are to consumers of the particular way in which the Government is driving the digital switchover in radio, what would you put as your two or three most significant benefits? Would it be, for example, an extension of nationally available commercial broadcasters on digital platforms, or what would it be?

Mr Simon: I think it would be, firstly, that the technology offers additional benefits, so it offers for most people more stations more clearly defined and a better mix of the different tiers, additional functionality, interactivity; digital radios do things that analogue radios do not. Secondly, I think it offers the consumer an orderly, consistent and coherent pathway to a digital future which is inevitable. The FM technology is ageing and the economics suggest that it would not be economic for major broadcasters to replace that infrastructure nationally and, rather than let it disintegrate in a piecemeal way and let it be replaced in a piecemeal way and have consumers all over the country who no longer can get the services that they have been used to, I think it is appropriate for the Government to try and manage this transition in a coherent way.

Chairman: What I do not quite understand is that you talk about new services being provided, but they are going to be provided in an industry, or you are relying on them being provided in an industry, a particularly commercial industry, which is going to be competing with the BBC, which obviously one wants to see, but that commercial industry itself is struggling, not to survive, but certainly struggling in very, very difficult economic circumstances at the moment. I do not quite see where this expansion is going to come from.

Mr Simon: I am not saying that the aim of the policy is to expand the market for commercial radio. The aim of the policy is to manage the transition in a way that works both for the businesses of the broadcasters and for the consumers and to manage the experience in a way that works for the consumer. As you say, the commercial radio market in terms of revenue has shrunk by a third over the last ten years as advertising revenues have shrunk for all broadcasters, print media and so on. It is a business in which people are under real pressure and that is why, among the overwhelming majority of commercial broadcasters, there is a strong support and an appetite for a clear, managed, relatively swift, but not rushed, pathway to digital where, although in the first instance they will have some additional cost, they can see a future in which they can do more business and make more money.

Lord Inglewood: Just really arising out of that and something you said earlier, it is not part of your case, is it, that, if the analogue network were not ageing and hence degrading, that would not be the reason for moving to digital? The reason for moving to digital is not because the analogue network is simply breaking down, is it?

Mr Simon: The fact that the FM infrastructure will need to be replaced in the short to medium term and that it looks like that replacement would not be economic is certainly one of the underpinning factors.

Lord Inglewood: But that goes back to the question of Lady Howe’s, does it not, that the foreseeable future is actually defined by the capability of the FM infrastructure to deliver the services it currently does?

Mr Simon: I am not sure I understand the question. I understood her question.

Lord Inglewood: Yes, but she said, “How long is it going to go on for?” and you said, “For the foreseeable future”, which was fair, but I think in fact that the way it is defined is that it will go on, according to the evidence you have subsequently given us, for as long as the FM transmission infrastructure is capable of delivering it. When it collapses, that is —-

Mr Simon: They are two different points though. There is the question of how long it will be possible for some people locally to continue to broadcast on FM, which is a different question from at what point do businesses need certainty about the capital investment decisions they might need to take in the future to renew the major national infrastructures.

Lord Inglewood: Sorry, but I may have misunderstood your evidence, in which case I apologise, but I thought what you said was that you did not believe that the industry was prepared to invest for the further life that the FM infrastructure would require.

Mr Simon: That is correct.

Lord Inglewood: If that is the case, why are they prepared to invest in the infrastructure for digital, which is part of the proposal that you are describing to us?

Mr Simon: Because renewing an old technology with its limited functionality does not make economic sense to them, whereas investing in a new technology with additional functionality does. When it comes to making the investment decisions, they are not going to buy the old kit again, they are going to buy the new kit.

Lord Inglewood: I understand the argument, thank you. The other thing I wanted to ask you about was right at the outset when there was a bit of verbal sparring going on between yourself and our Chairman, reference was made to things, such as cheap sets and set-top boxtype devices that would enable analogue radios to pick up digital and so on, and you used the subjunctive, that they might well become available, it was very likely. Is there any assurance that you have been given by any of the manufacturers about the actual provision of these products and, if there is not, as events move on, if it becomes apparent that a lot of this hardware may not be available, will that delay and/or postpone any digital switchover?

Mr Simon: Their adaptor-type technologies are already available for cars, so you can already buy a little thing in Halfords that you can put on your analogue car radio that will enable it to receive the digital signal. I do not think that you can easily get hold of such a product to adapt a domestic transistor radio, but the technology already exists. I am led to believe that they would not be difficult to manufacture and there is no reason to believe that they would be. We are talking to manufacturers who say that such products are on the way.

Lord Inglewood: Do you know in what sort of price range these things might be?

Mr Simon: I honestly do not off the top of my head.

Lord Maxton: On Amazon, £65.

Mr Simon: Currently?

Lord Maxton: For the car one, and you have to buy an aerial as well.

Mr Simon: We expect all of these prices to come down a lot.

Chairman: They have already come down quite a bit, have they not?

Mr Simon: Yes, they have come down tremendously. Digital radios themselves, the cheaper sets, you can now get a set for less than £25, which is very, very greatly less than the cheapest even a couple of years ago. As the market expands, the costs will come down, and it is expanding all over Europe. We are also working with, and encouraging, manufacturers to use, without being too technical, what is called the ‘World DMB Profile One chip’, which is compatible all across Europe, and that will give them great European economies of scale which again should make it easier for them to produce even cheaper sets and adaptors. In answer to the question, if nobody produces these things at affordable cost, would that delay switchover, I think it would depend what effect that had on the market. If that meant that nobody bought them and nobody bought any digital radios either and we did not get over the listenership threshold, then yes, it would delay. If it simply meant that people did not bother with an adaptor, but bought new digital radios, then it would not.

Lord Inglewood: I sense you sense that this is not actually going to be a problem.

Mr Simon: That is my belief.

Baroness Eccles of Moulton: I think, Minister, it is quite clear to us that there is going to be plenty of equipment around for converting, multi-chip, et cetera, et cetera, but why are we continuing to base the whole of our digital radio switchover on what is becoming an outdated system, which is DAB, as opposed to what other countries have done, which is either to scrap DAB or start off with DAB+? Why have we allowed ourselves to get caught in being committed in an early stage of the development of the switchover to what is now not the most up-to-date and modern form of broadcasting?

Mr Simon: That is a very good question which lots of people ask. The answer is that we were in this country by far the earliest adopters as a market of digital radio and we took it up far more quickly and far earlier than anybody else, as a result of which the amount of stock in the market that you would have to write off in this country is vastly greater than European comparators. There are ten million DAB sets, many of which have been bought at early adopter prices in the market in the UK and, if we abandoned DAB, it would mean that all those early digital adopters had their digital investment written off after a very few years, which just seems really counterintuitive in terms of how to drive the market towards digital and hardly also would seem likely to inspire much confidence in those people to make them very likely to buy another digital radio of the new standard. What we are saying is that the new sets henceforth should have the DMB World Profile One chip in, which is DAB, DAB+ and DMB compatible, and it would mean that you could use it anywhere in Europe and receive all that mix of signals. It does not preclude us in the future from moving to a technology which is greater than DAB, but it is a cost-benefit decision that has had to be taken and the clear consensus, not just in the Government, but of the regulators and stakeholders, has been that writing off the ten million DAB sets that have already been bought would be counterproductive.

Baroness Eccles of Moulton: Is including the new chip in any radio that comes on to the market from hereon going to be mandatory in the same way as fitting seatbelts in cars became mandatory?

Mr Simon: Not in the same way in the sense that, I think, seatbelts in cars was a piece of primary legislation, but mandatory in the sense that we will work with manufacturers in order to draw up the technical specifications for the new generations of sets, and they will be the formal technical specifications which will be adopted, hopefully, European-wide, so in that sense mandatory.

Baroness Eccles of Moulton: So you would not be able to sell the set if it did not meet the technical specifications?

Mr Simon: You would not be able to sell an approved set. It would not be a crime to sell a set, but it would look like a dodgy set.

Lord Maxton: France is setting the law which says that by 2012, I think, all radios sold must be DAB+ and that would include all car radios, which is the market area which we really have not looked at, but it is a very important area. Is it right that 20 per cent of all radio listening is in cars? That is a very large percentage, but it is a very difficult area to switch from FM to digital, even with the device which we have talked about already, is it not?

Mr Simon: Our targets are switchover by 2015 and new cars all being digitally radio-ed by the end of 2013. That is our clear target. Now, obviously, even if all new cars are digital by 2013, that still leaves the majority of the car stock analogue for a while beyond 2015, at which point one hopes that the price of the adapters, which you can already buy in Halfords, has come down considerably from the price that you mentioned on Amazon. I did not think they were that expensive in Halfords.

Lord Maxton: Well, they are £79 in the shop and, to be honest, with the reviews they have had of them, you have to almost buy an external aerial.

Chairman: I would not take him on on this!

Mr Simon: I am not going to, not for a minute am I going to! He is obviously speaking with some authority.

Lord Maxton: It will cost you another £12 or £13 on top.

Mr Simon: All I can say is that manufacturers assure us that this technology will be getting cheaper, better and more widely available over the three years before cars go all digital and over the five years until digital switchover. That is a long time for them to make big improvements.

Lord Maxton: I have not got one yet, by the way!

Mr Simon: I guessed!

Chairman: But you said that the target date is 2015?

Mr Simon: Yes.

Chairman: That remains the target date, does it?

Mr Simon: That is the firm target.

Chairman: That is a firm target date and, therefore, will that go into the Bill as a date, the Digital Economy Bill going through at the moment?

Mr Simon: Is it not on the face of the Bill?

Mr Smith: The Bill sets out the conditions which would have to be met for the target to be set.

Chairman: But I think I am right, am I not, that 2015 is not there as a target?

Mr Smith: It is not on the face of the Bill, you are absolutely right.

Chairman: Why not?

Mr Simon: Because it is a target.

Chairman: An aspiration?

Mr Simon: No, I am happy with the word “target”. It is a firm target, but it is not an inflexible or dogmatic target. It relies on our having met the listenership test, met the coverage test and, if we do not meet those tests, then we will not hit that date. We believe that we can, and should, hit that date.

Lord Inglewood: It will not be brought forward?

Mr Simon: That is very optimistic.

Lord Inglewood: I am just asking, not suggesting.

Mr Simon: I think it is unlikely.

Chairman: So you may miss the target. That is basically what you are saying.

Mr Simon: I am saying that, if we do not satisfy the criteria, then we will not do it if the nation is not ready.

[this is an uncorrected and unpublished transcript]

DENMARK: government contemplates DAB radio’s future

Politicians in Denmark are presently considering what to do about digital terrestrial radio. The next funding period for state radio runs from the beginning of 2011 to the end of 2014 and will have to take into consideration a political decision taken in June 2009 to forge ahead with the migration from analogue radio to the DAB platform. Presently, only state radio stations are available on DAB.

The governing Liberal Party says it “wants to create real competition in the radio market” because state broadcaster Danmarks Radio has “a de facto monopoly over radio in Denmark and so the diversity and choice in radio remains limited.” The party decided in 2009 that it would support FM switch-off as a means to create a “new start” for radio in Denmark. To ensure that DAB will prove an attractive investment proposition for commercial radio, FM would be switched off between 2016 and 2018. The Liberal policy document states:

“An expansion of DAB radio allows for a potentially very large number of different radio channels. This expansion is in full swing in all major European countries, several of which already offer between 60 and 100 digital radio channels, while Denmark currently only offers 20 channels in total. The technological opportunities need to be exploited for the benefit of listeners. And development of DAB also provides the opportunity to create a balanced radio market, where there are real opportunities for development of commercial radio, which has proven not to be possible on the FM band. We should therefore concentrate on the offensive deployment of DAB. England has the full support of all radio operators in the country who decided to work for the switch to DAB in 2015. Recently, France decided that DAB radios must be in all French cars from 2014 and, in March 2009, the German Broadcasting Commission decided to roll out DAB+ in Germany. Although progress has been slow, and in some places has become completely stagnant, there is no longer the same uncertainty that DAB (Eureka147 standard) is the future of radio.”

The Liberal Party document goes on to cite the ‘success’ of DAB in the UK and mistakenly believes that UK government policy is to switch off FM (a fallacy shared by many):

“Today, around 8% of total radio listening [in Denmark] is on DAB. In England, that figure is 12.7% and soaring. To ensure that DAB is an attractive platform for both listeners and investors, it is important that DAB radios are made attractive by adding more unique content. This is the same set of conditions which must be present in other countries that anticipate the same trends. For example, Norway has estimated that at least half of the population must have a DAB radio before [analogue] switch-off can be announced. England will switch to DAB in 2015. Moreover, it is recommended that all cars sold in England from 2013 must be equipped with DAB radios. This decision is backed by both the public service and commercial radio stations. The assumption is that DAB listening will reach 50% in 2015 and coverage will reach 90% of the country and all main roads. Lord Carter’s report ‘Digital Britain’ in January 2009 also defined a set of criteria that must be met in order to close [analogue radio] permanently.”

Ellen Trane Nørby, media spokesperson for the Liberals, said: “Danmarks Radio is proposing that we switch off analogue radio in 2015, but they offer no viable way to get Danes to listen more to DAB.” Nørby believes that the biggest driver for DAB take-up will be when state radio channels are progressively removed from FM: “The people who listen to DAB are heavy listeners to the channels they cannot find anywhere else. If the offerings on DAB are not unique, why would you buy a DAB radio?”

Nørby said that the transition to DAB needs to adopt a realistic timescale: “Today, we are in a situation where most listening takes place on FM and each of us has about five FM radio receivers, compared to only 1.5 million DAB radios [sold in total]. Therefore, it is important that we have a real debate over the future of digital radio, and how we progress safely from FM to DAB. The honest discussion we propose is in contrast to others who say simply that we must switch off [analogue radio] but do not explain how.”

Although the Liberal policy document is resolute about digital radio switchover, Nørby appears more circumspect in interviews. In December 2009, she said: “It is not enough simply to say that FM will be switched off in 2015 without considering a discussion on content. …. Driving the take-up of digital television was the Danish desire to have a flat-screen TV. I have seen no Christmas boom – and we have not seen this for many years – in the sales of DAB radios. That’s why we Liberals have been so critical of the migration plan, because DAB has not won as much grassroots support as you could ask for.”

The government proposals drew a critical response from Michael Christiansen, chairman of Danmarks Radio. He said: “The Liberal Party proposal is a barely disguised attempt to destroy Danmarks Radio’s stations. … The proposal totally disregards modern Danish music by moving the P3 channel over to DAB at a time when it its coverage is not enough. … Replacing P3 [on FM] with a more or less indifferent foreign [commercial] radio channel, I cannot take seriously. We want to help the drive towards DAB, just as we have driven the migration to digital TV. But no one thought of closing down DR1 or DR2 [TV stations] on analogue until digital TV signals were available [to all]. The notion is so far out that I find it hard to relate to.”

European commercial radio trade group says ‘no’ to universal FM switch-off date

At the start of its annual conference held in Brussels on 11/12 February 2010, the Association of European Radios [AER], the trade group representing 4,500+ European commercial radio stations (including RadioCentre members in the UK), issued the following press statement:

“AER considers that setting a date for the switch-off of analogue radio services is currently impossible. Indeed, the question of which kind of technology will be used should be solved first. Hence, broadcasting in FM and AM shall remain the primary means of transmission available for radios in all countries, with the possibility to simulcast in digital technology, until market developments enable a potential time-frame for general digitisation of radio. Transition to any digital broadcasting system should benefit from a long time-frame, unless there is industry agreement at national level to move at a faster rate.”

This statement followed on from a policy paper the Association had published a few days earlier, responding to the European Commission’s Radio Spectrum Policy Group plans for its draft Work Programme. The paper said, in part:

“It should be underlined that, in most of Europe, currently and for the foreseeable future, there is only one viable business model: free-to-air FM broadcasting on Band II. Thus, Band II is the frequency range between 87.5-108 MHz and only represents 20.5 MHz. Across Europe, nearly every single frequency is used in this bandwidth. Thanks to the broad receiver penetration and the very high usage by the listeners, this small bandwidth is very efficiently used. On-air or internet-based commercially-funded digital radio has indeed not yet achieved widespread take up across European territories. These two means of transmission will be part of the patchwork of transmission techniques for commercially-funded radios in the future, but it is hard to foresee when.

So no universal switch-off date for analogue broadcasting services can currently be envisaged and decision on standards to be used for digital radio broadcasting should be left to the industry on a country-by-country basis.

Radio’s audience is first and foremost local or regional. Moreover, spectrum is currently efficiently managed by European states and this should remain the case: national radio frequency landscapes and national radio broadcasting markets are different, with divergent plans for digitization, diverse social, cultural and historical characteristics and with distinct market structures and needs…..”

“Finally, AER would like to recall that European radios can only broadcast programmes free of charge to millions of European citizens, thanks to the revenues they collect by means of advertising. These revenues are decreasing all through Europe due to two factors: the shift towards internet-based advertising, and the recent financial crisis. For 2009, radio advertising market shares were forecast to decrease by 3 to 20% all across Europe, compared to 2008.

In some countries (e.g. France and the UK), a part of the revenues derived from the TV digital switchover was supposed to be allocated to the support of digitisation schemes for radio. This is no longer the case. In most countries, it is still unclear who will bear the costs of the digitisation process.

However, any shift towards digital radio broadcasting entails very long-lasting and burdensome investments. Nevertheless, some individual nations may wish to proceed with a move to greater digital broadcasting at a faster rate, as there will be no ‘one-size-fits-all’ approach.

So, any shift towards digital radio broadcasting will most likely require a very long process. Decision on the adequate time-frame should be left to each national industry: as a matter of principle, transition to any improved digital broadcasting system should benefit from a long time-frame, unless there is industry agreement to move at a faster rate.

It should also be recalled that commercially-funded radios are SMEs, and are in no position to compete for access to spectrum with other market players. So, market-based approaches to spectrum (such as service neutrality or secondary trading) should not be enforced in bands where commercially-funded radios broadcast or may broadcast.

To end up with, AER would like to recall that, in most of Europe, currently and for the foreseeable future, there is only one viable business model: free-to-air FM broadcasting on Band II; hence:

• no universal switch-off date for analogue broadcasting services can currently be envisaged
• now and for a foreseeable future, commercially-funded radios need guaranteed access to spectrum, in all bands described above. Besides, no further change to the GE 84 plan [the 1984 Geneva FM radio broadcast frequencies agreement] should be suggested, but the plan should be applied with consideration to the technological development (and its enlarged scope of possibilities) throughout the past 25 years
• any shift towards digital radio broadcasting should benefit from a long and adequate time-frame.”

NORWAY: every fifth radio sold is an internet radio, every eleventh is DAB

In Norway, sales of internet radio receivers are booming. During the final quarter of 2009, 22% of radios sold were internet radios, up from only 1% a year earlier, according to Norwegian website Sandnesavisen. By comparison, only 66,000 DAB radios were sold in 2009, 9% of the total 729,000 radios sold during the period, according to data from the Electronics Industry Foundation. Additionally, 200,000 mobile phones were sold in Norway during 2009, none with DAB capability but many with integrated FM radios.

Erik Andersen, information officer for the Electronics Industry Foundation, said: “We estimate that there are somewhere between 12 and 15 million FM radios that are in regular use around the country while, in comparison, only approximately 290,000 DAB radios have been sold in recent years.”

Andersen is not surprised by the rather low DAB radio sales, and finds it problematic that a date for FM band switch-off has not been announced which could be referred to. “We have no desire to mislead customers so, as long as politicians do not give us a switch-off plan, we advise enquiring customers to buy an FM radio,” said Andersen.

Jarle Ruud, acting general manager of Digitalradio Norge, the organisation charged with ensuring a speedy and smooth transition from analogue to digital radio in Norway, said: “This is a classic ‘chicken and egg’ situation, both in terms of sales volumes versus a switch-off date, and the channel selection on DAB.” Just as consumers are hesitating to buy a DAB radio before the government announces a switch-off date, Ruud thinks there are many radio stations that refuse to invest in digital transmission equipment because of the potentially lengthy and costly period of dual distribution.

The sales trend came as no surprise to Øyvind Vasaasen, media manager at NRK (state broadcasting) and chairman of Digitalradio Norge, who said: “This is what we predicted. We have remarked to the authorities that sales appears to have stabilised at around 60,000 DAB radios sold per year, and this is also the result for 2009. It shows that the sales trend is far too slow.”

Geir Friberg is managing director of Norway’s largest local radio group, Jærradiogruppen, which owns more than 20 of the approximately 150 local stations in Norway. He said: “There is really no great difference between FM and DAB. There are too few radio stations that broadcast on DAB today, and listeners cannot hear the difference between FM and DAB.” Friberg believes that adding more FM stations may even be a better policy than DAB.

Per Morten Hoff, general secretary of IKT Norge (Norway’s IT industry interest group), queried the accuracy of the published sales figures: “More and more consumers have eyes for internet radios, and the Norwegian company TT-Micro has alone sold 20,000 web radios. Since these radios can also receive FM, DAB and 13,000 internet stations, they are strangely classified as ‘DAB radios’ in the statistics. This is apparently to show that DAB is not a total failure. The true DAB sales are probably no higher than 40,000 units, and that figure is getting smaller. There is also the riddle that sales of mini-TV’s are included in the sales statistics of DAB radios.”

Jørn Jensen, president of World DMB Forum, responded: “Hoff does not know what he’s talking about. Radio broadcasting on DAB and DAB+, as well as mini-TV’s in DMB, all use DAB technology.”

At the beginning of February 2010, the Norwegian media regulator, Medietilsynet, submitted a 145-page document to the government on the digitisation of radio broadcasting. This is in preparation for a White Paper on digital radio that will be published by the government during 2010. The report was commissioned to map the Norwegian local radio industry’s opinions on the migration to digital radio and how it could be achieved. It collated responses from 55 parties and it concluded:

“The results of the survey reveal that virtually all local radio licensees believe that the digitisation of local radio will have economic consequences for them as businesses. The players fear that a transition will be so costly that only a few of the current licensees will survive digitisation. The consequence may be that ownership diversity disappears and that the market is left with big group operators. Besides mentioning competence-building, information and predictability, the majority of licensees believe that the most important measure the government can contribute to the digitising process is financial support in one form or another.

Local radio licensees who participated in the survey are roughly evenly split down the middle on their view of whether local radio should be digitised or not. Those who are negative to digitisation weigh the economic aspect heavily. When asked what distribution platform they see for themselves as the primary platform for local radio in the future, 52 percent responded analogue broadcasting via the FM band, 33 percent broadcasting via a digital platform such as DAB, DRM, etc and 9 percent broadcasting via the internet……”

“Amongst local radio licensees, 78 percent are negative about a switch-off date for analogue local radio broadcasting. 18 percent are positive about a switch-off date.”

Vigleik Brekke, chairman of the Norwegian Association of Local Radio (NLR) said that there was no economic reason for many of his 150 member stations to migrate to digital transmission. “Closing FM radio will create problems for stations,” he said. “They will not be able to survive.”

Professor Lars Nyre of the University of Bergen’s Institute of Media Studies said he was sceptical about DAB, especially as FM radio seemed to be perfect for listeners.

Asked whether the government’s White Paper will include a switchover date, Norwegian Culture Minister Roger Solheim said: “This is an important issue, and we aim to present the facts in 2010. One of the key questions we want to work with in the White Paper is whether we should fix a switch-off date.” Asked if his predecessor Trond Giske’s policy still held sway that half of Norway’s households should own a digital radio before a switch-off date is announced, Solheim said: “It is certain that digital radio will come, we see that too, in the developments. The question of the timing, and the state’s role in it, we must come back to in the White Paper.”

According to industry data, one in three households in Norway buy a new radio each year. Each household owns between 6 and 7 radios.

Digital radio stations: listeners abandon ship

The latest RAJAR radio audience data demonstrated one thing clearly: the UK radio industry’s strategy for its digital stations is in tatters. Audiences for digital radio fell off a cliff during the last quarter of 2009. This did not appear to be the result of any specific strategy shift (no station closures, only one minor format change) but more the result of increasing public malaise about the whole DAB platform and the radio content that is presently being offered on it (plus a little Q4 seasonality) . The figures speak for themselves.

Total listening to digital radio stations is back down to the level it achieved in 2007, following a period of sustained growth between 2000 and 2007. Far from moving towards some kind of exponential growth spurt as the industry had expected, total listening now seems to have plateau-ed. It appears that market saturation has already been reached for much of the content presently available on digital radio platforms, considerably earlier than had been anticipated, and at a level of listening that cannot justify these stations’ existences for their commercial or BBC owners.

In the commercial sector, only Planet Rock has maintained its momentum, probably a reflection of its commitment to offering its listeners genuinely unique content. Elsewhere, the jukebox music stations have suffered massive falls in listening, possibly a result of their ease of substitution by online offerings such as Spotify and Last.fm, and of owner Bauer’s policy to curb investment in digital radio broadcast platforms and content.

Commercial radio has talked the digital talk for years about striving to make DAB a successful platform, vaguely promising new digital radio ‘content’ that it has still not delivered. Instead, it has spent the last few years cutting costs, consolidating, lobbying the government, complaining about the BBC, closing its digital stations and contracting out its DAB capacity to marginalised broadcasters (religious, ethnic, government-funded and listener-supported stations) that will never attract mainstream audiences to the platform (and whose listening is not even measured in the RAJAR audience survey).

From the listener’s perspective, the only thing that has happened to the DAB platform in recent years is the disappearance of commercial digital stations such as OneWord, TheJazz, Core, Capital Life and Virgin Radio Groove. For the average consumer, the arrival of Traffic Radio, Premier Christian Radio or British Forces Broadcasting Service are hardly replacements.

A report commissioned by RadioCentre from Ingenious Consulting in January 2009 concluded:

“Commercial radio is now at a crossroads with respect to DAB. It needs either to accept that the commercial challenges of DAB are insuperable and retreat from it – such a retreat, because of contractual and regulatory commitments, would be slow and painful; or strongly drive to digital.”

In the year since this report was prepared, commercial radio has done neither. Instead, it has spent a small fortune on parliamentary lobbying, not one iota of which has had a direct impact on 10 million increasingly baffled DAB radio receiver owners. These latest RAJAR data convey their clear message that content is their only concern.

For the BBC, the problem is somewhat similar. With the exception of Radio 7, listening to its digital radio stations remains unimpressive, despite them benefiting from massive BBC cross-promotion over many years. Some stations are outright disasters – Asian Network is listened to less now than it was almost seven years ago, when only 158,000 DAB radios had been sold. Some stations are simply not suited to the DAB platform – 1Xtra targets a youth audience who listen to a lot of radio online and via digital TV, but who have little interest in DAB (particularly as DAB is not available in mobile phones). Some stations will become redundant in an increasingly on-demand world – Radio 7 would eventually be little more than a shopfront for the huge pick’n’mix BBC radio archive to be made available to consumers online.

For the BBC, it is becoming increasingly hard to justify spending, for example, £12.1m per annum on the Asian Network when its peak audience nationally is only 31,000 adults. Broadcast platforms such as FM attract huge audiences for a fixed cost, making them the most efficient distribution system for mass market live content. As a result, Radio 1 costs us only 0.6p per listener hour. By comparison, the Asian Network is costing 6.9p per listener hour, probably making it more expensive to ‘broadcast’ than to send each listener a weekly e-mail attaching the five hours of Asian Network shows they enjoy.

The BBC should still be congratulated for creating new digital radio services in 2002 that attempted to fill very specific gaps in the market which commercial radio was unlikely to ever find commercially attractive. This is precisely why we value a public broadcaster in the UK. However, the BBC digital radio strategy over the last decade has suffered from:
•   The BBC’s evident inability to successfully execute the launch of genuinely creative, innovative radio channels that connect with listeners (GLR, the ‘new’ Radio 1, the original Radio 5)
•   The BBC pre-occupation with constantly creating new ‘broadcast channels’ when most niche content is more suited to narrowcasting and delivery to its audience via IP (live, on-demand or downloaded).

For the UK radio industry, its digital ‘moment of truth’ has belatedly arrived. A new strategy now has to be adopted which does not continue to raise the DAB platform to the level of a ‘god’ that has to be worshipped above all others. The future of radio is inevitably multiple-platform and the industry’s focus has to be returned to producing content, rather than trying to control the platforms on which that content is carried.

I suspect that Tim Davie, director of BBC Audio & Music, will eventually lead these winds of change, following in the wake of director general Mark Thompson’s pronouncements at the end of this month as to where the internal financial axe will fall. Where the BBC leads, commercial radio will inevitably (have to) follow.

The future digital radio strategy is likely to be ‘horses for courses’. Rather than all radio content being delivered via all available platforms, it will in future be delivered only where, how and when it is most demanded by listeners. Our economic times make this mandatory. The DAB platform’s mass market failure will make it necessary.

Renewal of national commercial radio licences: debated in the House of Lords

House of Lords
8 February 2010 @ 1723
Digital Economy Bill
Committee (7th Day)

Clause 31 : Renewal of national radio licences
Debate on whether Clause 31 should stand part of the Bill.

Lord Clement-Jones: My Lords, before I propose that the clause not stand part, I must apologise. As a result of the way in which the business of the House has been organised today, I shall not be able to be here for about two hours of the Committee’s proceedings. I very much regret that, as many important matters remain to be debated. However, since the business was switched at extremely short notice — I hope that the Whips are whipped for it in some future incarnation —

Lord Davies of Oldham: Oh!

Lord Clement-Jones: I am of course not referring to the noble Lord, Lord Davies. Moving this business from Tuesday to Monday at very short notice is not a happy situation. I therefore hope that Ministers will give full and frank responses as if I were present. I am very grateful to my noble friend Lord Addington, who has kindly agreed to step into the breach when I am not able to put the arguments. I propose that Clause 31 should not stand part. Under this clause, the national analogue radio stations talkSPORT, Classic FM and Absolute Radio are receiving valuable seven-year extensions to their licences. In exchange, the existing licensees have been asked to give their support to an early switchover, with the proposed 2015 date coming much earlier than that recommended by the Government’s 2008 Digital Radio Working Group. However, there is a view among some operators that extensions to these licences are not worth the damage to radio of a digital switchover policy which assumes an unrealistic timetable for digital switchover and which fails to provide solutions that allow all local radio stations to move to digital. They do not accept that as a reasonable quid pro quo for an early switchover. They believe, on the contrary, that the industry’s engagement with the digital radio switchover proposal has been distorted by its interest in licence extensions which are essentially to do with the attractiveness of the current analogue model for radio rather than the proposed digital model. Their view is that Clause 31 will deprive the Government of revenue due from re-auctioning the licences for these national analogue stations. However, the Government have failed to publish an assessment of how much revenue will be lost to the Treasury under this approach. The Government need to justify the advantage of the clause against the background of the following factors: that the sums lost to the Treasury will clearly amount to tens of millions of pounds over the lifetime of the extended licences; and the lack of evidence about whether digital investment by the holders of these licences will continue without the extensions. On the face of it, many are already, contractually or otherwise, committed to digital even without this.

Lord Howard of Rising: My Lords, although I share a number of the noble Lord’s concerns, I do not think that removing the clause would be helpful. It is a facilitating clause that enables the move to switchover at a later date, and it does not set in stone when the switchover will take place or indeed that it must happen. It is more important that the Secretary of State considers a range of issues before nominating a switchover date than that the process in its entirety is stopped. I believe that the level of digital radio listening should be much higher than the Government have suggested. It would also be very much better if the fact that the FM spectrum will remain in use for local and community radio stations was on the face of the Bill. More progress should be made in creating a help scheme and a recycling scheme. We should be focusing on these issues rather than on an attempt to derail the digital switchover process completely.

The Lord Bishop of Manchester: My Lords, I recall that last week the noble Lord, Lord Clement-Jones, and I supported each other’s amendments, but sadly that relationship is about to be broken albeit, I hope, temporarily. To allow the Bill to pass without this clause would pose a real problem for the entire digital radio project. The three commercial stations currently granted national analogue licences cater for a broad range of tastes, from Beethoven and Brahms to Bon Jovi, via the latest soccer score from Bolton Wanderers. Their collective appeal has been vital to encouraging digital take-up by listeners, with around a fifth of their current audiences now listening via a digital platform. To disrupt that migration would be rather unwise. Re-advertising these national licences with just a few years to run before we expect to switch off the service seems to be sending the wrong signal to both the industry and to listeners. It seems to suggest that we are not fully committed to digital as the future, that we doubt whether we will be in a position to switch over the bulk of national stations in seven years, and that we can expend less energy on the steps that are undoubtedly still needed to get listeners to switch to digital, especially through pushing down the cost of DAB radio sets and through getting DAB into more cars as standard. I do not think that any of those things are the right course. If, as I understand it, the message from the legislature to the private sector is to be, “We want you to invest in this new technology, market it to your listeners and encourage them to adopt the new listening platforms”, surely we cannot keep expecting these companies to keep on writing blank cheques. We all appreciate that digital platforms are still in their relatively early days. It has to be remembered that not one digital radio station has yet posted a profit. For their pioneering endeavours, they deserve the stability that this reprieve offers them. One does not often hear pleas for breaks for business from these Benches, but this is a case of tidying up the licensing regime to make it serve the purposes of the digital age.

Lord Eatwell: My Lords, I declare an interest as chair of the consumer panel of Classic FM. This panel is entirely independent of the company. It is devoted to maintaining the standards of Classic FM and the widespread broadcasting of classical music by the independent sector. If this clause does not stand part of the Bill, your Lordships should be aware that the future of Classic FM will be severely compromised because it is a requirement of existing law that the analogue licences are auctioned. As at present conceived, analogue licences do not have a clear format specification. There is not a licence for classical music. There is simply a licence for non-speech, which is the licence held by Classic FM. If these national stations were to be auctioned in the near future, I would be willing to bet the noble Lord who is opposing that Clause 31 shall stand part of the Bill at least a bottle of claret that this licence would be secured by a pop music station, and that Classic FM would disappear. I wonder whether the noble Lord has taken into account that possibility in his proposal.

Lord Young of Norwood Green: My Lords, key to supporting the drive to digital is to encourage and to allow broadcasters to invest in their digital futures. Experience shows that licence renewals, which are linked to the provision of a digital service, are a key incentive. At a time when the Government are asking the industry to contribute to a focused and intense drive towards digital, we believe that it would be wrong to remove this incentive. Clause 31, alongside Clause 32, would allow Ofcom to grant a further renewal period of up to seven years to analogue licence holders who also provide a digital service. Clause 31 relates specifically to the national analogue licences, although the rationale for the decision for extending the renewal is identical for both national and local licences. I do not want to take up too much time because noble Lords who have contributed to this debate have put many of the arguments excellently. The noble Lord, Lord Howard, talked about the necessity to maintain the clause. The right reverend Prelate displayed a very catholic — I hope he does not mind me using the word — taste in music from Beethoven to Bon Jovi, which I liked. In his analysis of the need for Clause 31, he is absolutely right. As he said, we cannot expect companies to carry on writing blank cheques. We need to give them an incentive. My noble friend Lord Eatwell’s analysis of Classic FM was exceedingly apposite. We believe that this clause is essential for the reasons stated by a number of noble Lords. In those circumstances, I support the Motion that this clause stands part of the Bill.

Lord Clement-Jones: My Lords, I thank the Minister for that reply. I also thank other noble Lords for contributing to the debate with some fairly bloodcurdling prospects. However, I do not think that the Minister has answered the question about why these extensions are required. I put this proposal somewhat as a devil’s advocate. By and large, I believe that the majority of the radio industry is behind the scheme as put forward by the Government, but there is a significant minority of interest which is not. That is why I put forward the clause stand part debate. But if I was in their shoes, listening to what the Minister had to say, I would consider that his arguments were entirely circular and that the Government have done this because they needed to and that this was the best way forward. I do not think that any real forensic argument has been put forward by the Minister. I could probably put forward rather better arguments than the Minister has. I certainly could have put my finger on areas where investment is needed, since I have been briefed by some of the major radio players. The Minister has been extremely half-hearted in responding. This is the one bit of this Bill which is the Government’s opportunity to set out their stall in terms of their digital radio policy, other than the amendments we have already dealt with. We had quite a useful debate on our last Committee day, but the Minister has not really answered the questions in a robust way. Certainly, he has not set out the stall for the Government’s policy in terms of the extensions of these national analogue radio stations. We are talking about digital radio switchover. What is it about these extensions that will make those radio stations invest more when they migrate to digital? That is what it is all about. The Minister did not even attempt to talk about the amount of money that the Treasury would forgo. Some estimates have put that as high as £73 million, which is a large amount of money. I do not think that the Minister dealt with that either. The Minister has been extremely disappointing. I do not think that that minority of radio stations will be particularly happy to hear the Minister’s lack of engagement with their arguments. It is almost as if he has taken a view that only a minority of radio stations is concerned, that the bulk of the radio industry is quite happy and that therefore that minority will be overridden without so much as a buy your leave. That is an unfortunate position to be in. This House, above all, is about rational debate and about putting forward the arguments. To be frank, in previous amendments to this clause, the Minister put forward some useful points — he certainly did in response to some of mine — but when I have tried to elicit an overarching policy, he has been lacking and I have been somewhat disappointed.

Clause 31 agreed.
Clause 32 agreed.
Amendment 241B not moved.
Clauses 33 and 34 agreed.

Clause 35 : Local radio multiplex services: frequency and licensed area

Amendment 241C
Moved by Baroness Howe of Idlicote
241C: Clause 35, page 39, line 3, leave out “local”

Baroness Howe of Idlicote: My Lords, this amendment, which relates to the provisions for digital radio, seeks to allow for the efficient use of the radio spectrum and for a potential increase in radio listening choice for the people of Northern Ireland. Although national BBC services are available via digital radio in all four parts of the United Kingdom, the national commercial multiplex is unavailable in Northern Ireland. The reasons for that are historical and technical, and relate to how the same frequencies were used in the Republic of Ireland. The result is that stations, including Absolute Radio, Planet Rock, BFBS radio and Premier Christian Radio, cannot be heard digitally in Northern Ireland. There is some hope that the spectrum position will change. However, as currently worded, even if that spectrum were to become available, Ofcom would not have the powers to allow it to be used by the national commercial multiplex. That is clearly an anomaly and, I suspect, an oversight. It would result in the inefficient use of spectrum and an artificial restriction on the radio-listening choice for some citizens. This amendment seeks to correct the situation and, without obliging, would enable Ofcom to increase the coverage of the national commercial multiplex. Were this to become technically possible, Ofcom would follow the process already proposed for similar expansion of local digital radio or multiplexes using the framework already in the Bill. This amendment, while modest and not contentious, will have benefits for the people of Northern Ireland and clearly will be welcomed by the radio industry, so I hope that the Government will be prepared to accept it. I beg to move.

Lord Young of Norwood Green: My Lords, this amendment would allow Ofcom to vary the frequency or licensed area of national, as well as local, radio multiplex licences. On the face of it, this is not an unreasonable change and would potentially enable the national commercial radio multiplex to extend its coverage to Northern Ireland. However, Clause 35 was structured specifically with reference to local radio multiplexes so as to allow them to merge or be extended in order to close the gaps in local radio multiplex coverage in the UK not currently served by DAB. Simply removing the word “local” from the text may not be the best way to achieve the desired result. Consideration needs to be given to what variation powers Ofcom should have with regard to national multiplex licences and to the basis on which such powers should be exercised. We have some sympathy with what the noble Baroness is trying to achieve and the Government will consider this issue before Report. With that assurance, I hope that the noble Baroness will feel able to withdraw the amendment.

Baroness Howe of Idlicote: My Lords, I am pleased to hear that, even if this amendment is not entirely appropriate according to the Minister, serious consideration is going to be given to how this can be made possible. Under those circumstances, I beg leave to withdraw.

Amendment 241C withdrawn.
Amendments 241D to 241F not moved.
Clause 35 agreed.

Clause 36 : Renewal of radio multiplex licences
Debate on whether Clause 36 should stand part of the Bill.

Lord Clement-Jones: My Lords, Clause 36 deals with the renewal of radio multiplex licences and it inserts a new Section 58A after Section 58 of the Broadcasting Act 1996. The House of Lords Delegated Powers and Regulatory Reform Committee, which we always listen to with some respect, had some interesting words to say about this clause: “It is impossible to tell from the Bill whether the policy is that the licences should or should not be renewable at all, let alone for what period or on what grounds. Indeed, paragraph 56 of the memorandum candidly admits that the relevant policy decision has yet to be made. We draw attention to the skeletal nature of the power in clause 36, to enable the House to examine it further and determine whether it is justifiable in this context”. I am merely a humble hand maiden of this House in tabling this clause stand part debate, and I hope that the Minister can give us further enlightenment.

Lord Young of Norwood Green: I have never had to respond to a hand maiden before in this House. I am still wrestling with that analogy. The Government stated in the Digital Britain White Paper that we would work with the industry to agree a plan to build out the DAB infrastructure to current FM coverage. We recognise the need to limit as much as possible the impact of such build-out on radio stations. One way this can be achieved is to allow multiplex operators to spread the cost of the investment in the new infrastructure by extending the period of their licence. We have suggested that licences could be extended up to 2030. The renewal of multiplex licences as a means to support digital radio was first introduced in the Broadcasting Act 1996. However, these renewal powers only apply to licences which were granted within 10 years of the 1996 Act coming into force. Therefore, there are a number of multiplex licences which are currently not eligible for a renewal. If renewals are to provide a real support to the build-out of DAB coverage to FM levels, they need the flexibility to achieve three objectives: first, to allow the extension of the licence period for those licences which are already eligible for, and in some cases have already been awarded, a renewal under the existing terms; secondly, to allow the renewal to apply to all multiplex licences, including those not currently eligible within the existing provisions; and thirdly, to ensure that any further renewals are awarded with conditions which link them to the progress to digital radio switchover, and more specifically to an agreed build-out plan and timetable. The link to a DAB coverage plan for switchover, which is likely to take a year to agree, is why we believe these powers are most appropriately applied via an affirmative order. I note concerns about the breadth of the order-making powers and I hope that I have satisfied noble Lords that they are justified because of the range of changes needed to implement this policy.

Lord Clement-Jones: I thank the Minister for that brief but — I hope to discover on reading Hansard — informative statement. As somebody who is not fully conversant with the radio multiplex licence variations, that was not the clearest possible answer I could have asked for. I hope that it will make sense on further consideration. It seemed to tell me that the Government need the maximum possible flexibility without having determined exactly which licences require extension. I am not sure that takes us a great deal further than what the House of Lords Delegated Powers and Regulatory Reform Committee said, but perhaps, as I say, on reading Hansard it will all become blindingly obvious.

Clause 36 agreed.
Clause 37 agreed.

Costs/benefits of digital radio switchover: why the government buried the evidence

Digital radio switchover was first mooted in the 1980s and started to gather momentum following the first UK public demonstration of the DAB digital transmission system at the Radio Festival in Birmingham in 1991. New Scientist magazine reported then that DAB radio could be up and running in the UK “by the mid-1990s”. However, it was not until 1999 that DAB radio was launched publicly and DAB radio receivers were made available commercially.

Over this period of decades, it would have been sensible to commission some kind of cost-benefit analysis to assess if there were a potential net benefit to radio listeners, to the radio industry, and to the UK generally of embarking on a plan to convert the whole nation to digital terrestrial radio. If such an analysis was ever published, I must have missed it.

We are now in 2010, an incredible 29 years after research and development first started on DAB radio technology. The issue of digital radio switchover has been the subject of a succession of government initiatives since the end of 2007 (the Digital Radio Working Group, Digital Britain, the Digital Economy Bill). Has the government shared with the public a cost-benefit analysis which demonstrates that the public policy on digital radio pursued over the last 20+ years is somehow worthwhile? No. Does such a cost-benefit analysis exist? Yes. Can we see it? No. Where is it? Apparently, gathering dust on a government or Ofcom shelf.

How do we know this? A parliamentary committee recently delved into these facts during its current investigation into the issues surrounding digital switchover in the television and radio markets (see transcript below). Ofcom has remained remarkably silent on the issue of digital radio switchover in recent years. The regulator’s director of radio, Peter Davies, was last seen speaking publicly about DAB in November 2008 when he admitted that new legislation would be necessary to salvage the DAB platform. A little earlier, in April 2007, Davies had prematurely declared that “we are potentially at a Freeview moment with digital radio.” Three years later, radio’s ‘Freeview moment’ seems as far over the horizon as ever.

The first we knew that the government had commissioned some kind of cost/benefit analysis [CBA] for its proposed digital radio switchover was in November 2009 when the Digital Economy Bill was published. The government’s accompanying Impact Assessment document stated:

“The partial Cost Benefit Analysis conducted by Price Waterhouse Cooper (PWC) for the Digital Radio Working Group, which is available on the DCMS website, suggests the Digital Radio Upgrade could reduce the total transmission costs for the radio industry from £87.9 million to £64 million….”

“First, by supporting greater investment in DAB infrastructure a greater number of consumers will have access to DAB and the quality of reception will improve. Secondly, consumers will benefit from access to a wider range of services, specifically new national stations and functionality, such as pausing and rewinding live radio. Finally, the released analogue spectrum will allow for a greater range of community radio stations, as well as possible non-radio services. The PWC partial CBA for the Digital Radio Working Group suggests the value of these benefits could be in the region of £1.1 billion, over a period from 2009 to 2030…..”

“The significant consumer costs of the Digital Radio Upgrade in the non-voluntary conversion of analogue sets to digital, including the cost of in-car conversion. The PWC report suggested the cost of such conversion to be in the region of £800 million, again over the period from 2009 to 2003.” [typo – “2003” should be “2030”]

Although this document stated that the PWC report was available from the government’s web site, I have searched for three months and still never found it there. Nevertheless, the 91-page report entitled ‘Cost Benefit Analysis of Digital Radio Migration’, prepared for Ofcom by PWC on 6 February 2009, contains a number of very serious reservations that there will be ANY benefit from digital radio switchover, and it states:

“The results suggest that there are relatively few up-sides to the estimates, and several significant downside risks. … To a significant extent, the positive Net Present Value [NPV] of the Cost Benefit Analysis relies on two crucial parameters. The first is the Digital Radio Working Group [DRWG] recommendation that an enlarged regional [DAB] multiplex network should be implemented. Failure to implement would result in a substantial negative NPV. The second critical parameter is the time horizon. The results suggest that there is a very long pay-back from the DRWG policy ‘investment’ – the 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]

The PWC report explicitly noted for Ofcom the limitations of its analysis, as a result of the lack of consideration it had assigned to external factors. These paragraphs probably explain why the government has been so keen to keep the report away from public scrutiny:

“The scope of this study is limited to the assessment of the DRWG policy. The overall digital radio policy appraisal process would need to take into account other policy options and ‘states of the world’. With this in mind, we highlight three issues in particular:

1.    The impact of recession: We have assumed no change in commercial radio sector structure and health beyond a consensus view of advertising forecasts. As this CBA is conducted for the time period to 2030, short term recessionary impacts may have only a limited impact on the longer term outcome for the industry. On the other hand, the current economic downturn could still affect the short and medium term investments required for marketing or coverage extension, which in turn could delay the desired DRWG policy outcome.

2.    Other policy options: We recognise that to reach a view on this question of how to drive digital radio penetration and listening (which in turn delivers consumers’ and citizens’ objectives) requires a full assessment of the costs and benefits of a number of policy options; this study has examined one, the DRWG policy. This is the only policy assessed in this study and the policy is at an early stage of its development; Government and Ofcom could give consideration to other possible policy options. In addition, we recommend modelling a number of other ‘business-as-usual’ scenarios taking into account different assumptions, and assessing how they affect the CBA of the DRWG policy.

3.    Other digital platforms: This CBA assumes that DAB listening will continue to be the leading platform for digital radio listening. The DRWG has reinforced the view that ‘a radio-specific broadcast platform is an essential part of radio’s future’, and that DAB is the ‘most effective and financially viable way of delivering digital radio’ for the medium to long term. A long term view needs to account for the possibility of technology obsolescence or replacement. At present, there is no consensus view that suggests otherwise. However, there are signs that internet listening may begin to take off if internet radios are more actively promoted and technologies such as WiFi or mobile broadband mature and become universally available. A number of the cost and benefit categories assume an impact from increasing the coverage of DAB (for example, consumer benefits from increased coverage is assumed based upon the incremental benefits to consumers who could not receive digital radio stations). Should these trends continue, or a more structural shift to internet to occur, there would be a smaller benefit from increasing the coverage of DAB; consumers either have alternative access to digital radio even within out-of-coverage areas, or would prefer a non-DAB solution when they receive DAB coverage.” [emphasis added]

In the 12 months since the PWC report was prepared, all three of these assumptions have been undermined by subsequent events:

1.    The health and structure of the commercial radio industry have changed considerably during 2009:
•  Commercial radio’s financial health has been impacted severely by the recession. The sector’s revenues were down 19.5%, 10.8% and 12.5% year-on-year in the first three quarters of 2009. Revenues from national advertisers were down 28.8%, 16.1% and 16.5% respectively
•  In January 2009, an analysis commissioned by RadioCentre found that “the [commercial radio] industry as a whole is now loss making”. Hours listened, revenues and profitability have all fallen further since then
•  At the beginning of 2009, Global Radio was the biggest owner of DAB multiplex infrastructure. Since then, it has disposed of its entire stake in the national DAB multiplex and most of its stakes in local DAB multiplexes to transmission provider Arqiva, demonstrating the radio sector’s inability to generate profits from the DAB platform after 10 years

2.    The policy recommendations for digital radio switchover made by the Digital Radio Working Group have since been amended by the Digital Britain report and the Digital Economy Bill. The recommendations of the Working Group’s Final Report published in December 2008 had included:
•  “Government should agree a set of criteria and timetable for migration to digital”, whereas no criteria or timetable are specified in the Bill
•  “A long term plan should be developed to move all services to digital”, whereas the Bill acknowledges that some local radio stations will never have the opportunity to migrate to digital
•  “The BBC should build out its national [DAB] multiplex across the UK to reach FM comparable levels [of coverage]”, whereas the BBC has acknowledged that such expenditure is constrained by the Licence Fee settlement
•  “The government should consider funding options to enable this important investment [in DAB infrastructure]”, whereas the government has made no financial commitment to the build-out of DAB multiplexes
•  “The government must consider the case for a [import] duty exemption for digital radios”, a proposal that is not mentioned in the Bill
•  “Consumer groups believe that, once an announcement [of digital switchover] is made, no equipment should be sold that does not deliver both DAB and FM”, a proposal that has been dropped

3.    The DAB platform has failed to grow in 2009, as had been forecast by the government, Ofcom and the Digital Radio Development Bureau [DRDB]:
•  Volume sales of DAB radio receivers were down 10%, down 1% and down 6% year-on-year in the three most recent quarters for which data have been released by the DRDB
•  Listening to radio via digital platforms accounted for 20.9% of total radio listening at year-end 2009, compared to the 26% forecast by the government’s Digital Britain report in June 2009 (and compared to the 42% forecast by Ofcom in November 2006)
•  Listening to commercial radio via digital platforms accounted for 19.7% of commercial radio listening at year-end 2009, compared to the target 30% announced by RadioCentre in January 2007
•  Total hours listened to digital-only radio stations at year-end 2009 were at their lowest level since 2007, demonstrating that digital radio content is failing to drive consumer take-up of digital radio
•  Unused capacity on the DAB platform has increasingly been filled during 2009 by non-commercial, government-funded, listener-funded, religious or ethnic radio services, rather than by mainstream, mass appeal stations
•  The commercial radio sector launched no completely new broadcast digital radio stations in 2009 (Absolute Xtreme was replaced by Absolute 80s), and the BBC is expected to announce cuts to its digital radio stations at the end of this month

As a result of these developments during 2009, the minimal, long term benefits from digital radio switchover identified by the PWC report a year ago are likely to have been diminished to the point where there may no longer be any benefit evident at all, even as far into the future as 2030. So how can the government still justify pursuing its policy of digital radio migration? It cannot, which is why it remains so reluctant to engage in an analysis of the facts, the numbers, the data and the evidence, all of which clearly show that this misguided, poorly executed, top-down attempt to switch radio broadcasting in the UK to the DAB platform is likely to become a ‘white elephant’ that has already cost the radio industry getting on for £1 billion.

House of Lords
The Select Committee on Communications
“Digital Switchover Of Television And Radio In The UK”
27 January 2010 [excerpts]

Witnesses:
Mr Stewart Purvis, Partner for Content and Standards, Ofcom
Mr Peter Davies, Director of Radio Policy & Broadcast Licensing, Ofcom
Mr Greg Bensberg, Senior Adviser, Digital Switchover, Ofcom.

Baroness McIntosh of Hudnall: I feel we could get back on to slightly safer territory and the notion of cost and benefit. 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 DCMS 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? Can you also tell us about your own impact assessment on radio digital migration, which I believe you have been asked to undertake? Will this include a full cost-benefit analysis? When are you intending to publish it? ….. [edited]

Mr Purvis: There are a lot of questions there. Peter commissioned the piece, so I am going to ask him to talk to them, but let me say that you have talked about informing the Government’s decision and one of the main points of doing this was to help inform the Government’s decision. It was a government decision as to whether this information should be published or not. But, we felt, as part of the ….

Lord Gordon of Strathblane: Sorry, it was your document, though, wasn’t it?

Mr Purvis: No, it was actually a PWC document.

Lord Gordon of Strathblane: It was commissioned by you.

Mr Purvis: Commissioned by us, yes.

Lord Gordon of Strathblane: Surely, it would be your decision to publish.

Mr Davies: 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.

Baroness McIntosh of Hudnall: Who owns it?

Mr Purvis: Whenever you commission a document from an outside source, in a sense the ownership of the detail must lie with the people who actually did the work, but, in a sense, when you commission it, obviously you commission it with a purpose and the purpose was to give it to the Government.

Baroness McIntosh of Hudnall: With respect, that is not necessarily true.

Mr Purvis: No, there are options.

Baroness McIntosh of Hudnall: I have work commissioned from me and it may be, and often is, on the understanding that the ownership of what I produce falls to the person who commissioned it from me.

Mr Purvis: Yes, that’s true, but in terms of the ownership. But in the sense of the responsibility for the detail of the commission, the source of the commission must inevitably take its full share of that. But there are a number of options which apply when these pieces of work are done. 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.

Mr Davies: I think they have made available the redacted version rather than the full report. The reason for that is some of the numbers in there are commercially sensitive, but there is no reason why the Committee should not have the full report.

Mr Purvis: You certainly have seen the conclusions.

Baroness Howe of Idlicote: I just wonder who has paid for it. Has it come out of your budget?

Mr Davies: Yes.

Baroness Howe of Idlicote: Even more indication of ownership.

Baroness McIntosh of Hudnall: Shall we go back to the questions. We now know why you didn’t publish it. Am I right in thinking that, notwithstanding the fact that you did not publish it, it did influence the Government or is in the process of influencing the Government as far as their policy on digital migration goes?

Mr Davies: I think it is one of the inputs to government thinking, certainly. We were very careful when we sent it to the Secretary of State to make clear what all the caveats were. You are absolutely right, there are a lot of caveats around it. This is a piece of work which is at a very early stage of the process. We were very clear to government that they should not use this as the means of making a decision, but it might help to inform the decision.

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. That’s the question that seems to me still to hang in the air. Is this technology-led or is it consumer-led, if we wrap into ‘consumers’ both the people who are the end-users and the people who are using the technology to deliver a service?

Mr Davies: I think that is why there are so many caveats around it, because it needs to be, as you say, consumer-led. So, some of the conditions that would need to be met for the figure to come out positive are that coverage needs to be built out, that the content proposition needs to be right, that a lot of the benefit in there is from additional choice for consumers. That is obviously down to industry to provide. That is not something that either government or Ofcom can do. One of the main caveats was the need to roll out the regional layer [of DAB multiplexes] that we were talking about earlier, to become a new national layer, so providing more choice of mass market stations, if you like. So it is absolutely consumer-driven, but where that leads you, I think it is probably too early to say, and, as you say, it is very finely balanced.

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.

Baroness McIntosh of Hudnall: So that’s a future thing.

Criteria and a date for digital radio switchover: debated in the House of Lords

The news that the government’s proposed ‘digital radio switchover’ will no longer involve ‘FM switch-off’ was first reported in this blog in June 2009, which stated:

“In the 13-page radio section of the Digital Britain Final Report published yesterday, there was not one mention of the word ‘switchover’ in the context of ‘digital radio switchover’. Neither was there a single mention of the word ‘switch-off’, as in ‘FM radio switch-off’. Throughout the document’s radio section, the new buzz phrase is ‘Digital Radio Upgrade’, meaning a drive to make DAB radio better and improve its consumer take-up. In Digital Britain, the notion of switching off FM radio broadcasting, notably for local stations, has been buried for good.”

However, between June 2009 and now, this issue – that the government will NOT switch off FM broadcasting – has been clouded by continuing statements from some radio lobbyists and in many media outlets which imply that FM radios will no longer work after switchover. If I were cynical, I might think the motivation is to panic citizens into buying DAB radios – a consumer response which would itself help the industry reach the criteria necessary for ‘switchover’ to happen.

As for those criteria, and the government’s favoured switchover date of 2015, I have consistently predicted that the criteria stand absolutely no chance of being reached by 2015. For a long time, the government and large parts of the radio industry loyally stuck with these targets, imagining that somehow, if you say something frequently enough in public, it will come to pass of its own accord. However, in recent months, with 2015 rapidly approaching, there has been a sudden U-turn. Until then, the radio industry had been vociferous in demanding the government fix a ‘switchover’ date as early as possible. Now, suddenly, a date – any date – is no longer deemed desirable.

A blog entry here last month noted that neither the criteria, nor the 2015 date for ‘switchover’, are mentioned anywhere in the Digital Economy Bill:

“Figures. Numbers. Dates. Criteria. This kind of factual evidence or hard data might obstruct a future decision to force consumers to switch to DAB radio.

……… the criteria and the switchover date that had been agreed upon by stakeholders, over two years of deliberations, have now quietly been relegated to oblivion.

When would digital radio switchover have happened if the agreed criteria had been implemented in law? Probably never.

When will digital radio switchover happen now? Whenever those in power want it to.”

A debate on Wednesday night in the House of Lords (see below) considered several amendments to the Digital Economy Bill which would have put specific criteria back onto the legislative table and would have ensured that all radio stations (large and small, BBC and commercial) are given an opportunity to migrate from analogue to DAB transmission. These amendments were eventually withdrawn, after the government Minister offered vague assurances that FM would not be switched off “for the foreseeable future”.

As a result, on paper, if the Digital Economy Bill is ever legislated, ‘digital radio switchover’ (which no longer involves FM switch-off) can be made to happen whenever and however the government wants it to.

In practice, digital radio switchover will inevitably never happen. Consumers appear increasingly disinterested in DAB radio. Besides, we have yet to hear one radio station owner promise they will turn off their analogue transmitters forever and, in that instant, cut their listenership by half just because the other half are thought to be listening via a combination of DAB, digital TV and the internet. You would have to be mad to do that. And, yes, the radio industry could be considered ‘crazy’ for continuing to go along with this bizarre notion that it is prepared to cut off its own nose to spite its face.

Eventually, it will end in tears.

Amendments 238, 239 & 241
Moved by Lord Clement-Jones

238: Clause 30, page 33, line 19, at end insert —
“(2A) The Secretary of State may not nominate a date for switchover —
(a) unless it can be established that all local commercial radio stations will have the opportunity to move to digital audio broadcasting,
(b) until the proportion of homes in each of the four nations of the UK able to receive —
        (i) national BBC services,
        (ii) national commercial radio services,
        (iii) local BBC services, and
        (iv) local commercial radio services,
via digital audio broadcasting is equal to the proportion able to receive them via analogue broadcasting,
(c) until digital audio broadcasting accounts for at least 67 per cent of all radio listening, and
(d) until digital audio broadcasting receivers are installed in 50 per cent of private and commercial vehicles.”

239: Page 33, leave out line 21 and insert —
“( ) must ensure that all commercial and BBC radio services broadcasting in the UK have the opportunity to switchover on the same date,”

241: Page 34, line 1, leave out “2” and insert “4”

Lord Clement-Jones: In moving Amendment 238, I shall speak to Amendment 239 and 241. It is a wonderful thing to make one’s debut at 8.30 pm. I will try to do it with some brio. This amendment is designed for two particular purposes: not only to explore some of the detail of this clause, which seeks to implement a very important part of the Bill, but to test the coherence of the Government’s policies and objectives in this respect. On these Benches we recognise many of the benefits of moving from analogue to digital; of course we do. However, we believe the Government have been fundamentally poor in the way in which they have communicated their objectives and in the way in which they described both those and the processes involved in switching over. We are particularly concerned about the impact on local FM radio and what one might call ultra-local radio in that respect. A great deal of reassurance is needed about the future of FM. It is not just purely about freeing up space on the analogue spectrum for FM by migration from analogue to digital. The Government need to explain other aspects too. Why are we adopting DAB rather than DAB+, which would allow a much more local feel to our radio experience and enable many more ultra-local radio stations to migrate? The Government also need to explain — the Minister has made an attempt to do so — why the target of 2015 has been set. There are other details involved. One of the great forms of reassurance that the Government have tried to give to ultra-local radio FM stations is this notion of a common electronic programme guide. That is a great idea, but what is its practicality? What timescale is envisaged? The Government need to deliver much more clarity in this respect and other aspects. Will there be adequate supplies of radios that enable listeners to tune in to both FM and digital radio? It is fairly basic: will the domestic consumer be able to have access to those, or will most manufacturers switch over to pure digital? The availability of digital car radios is a particular concern. I shall illustrate where I believe there is some incoherence in this regard. It is almost as if two separate hands wrote Chapter 3b of the White Paper. That chapter is headed “Radio: Going Digital”. Paragraph 20 of that chapter states: “However, it has always been our intention that the ultra-local services which remain on FM after the Digital Radio Upgrade should only do so temporarily”. Later on, the paper — I leave the Minister to find his own copy — is written in very different terms. It talks about a much longer-term future for FM. Which is it? Will FM be a permanent or temporary part of the radio landscape? These things need sorting out as part of the Bill. Even if you talk to those intimately involved in the digital switchover, you will not get a precise answer about whether FM is here for the long term. As I understand it, technically, ultra-local radio is far better staying on FM almost in perpetuity, provided the two forms of spectrum can be afforded, and provided the receivers allow the receipt of both FM and digital for the foreseeable future. There is no particular reason why some of these ultra-local stations should indeed switch over. Why should they not be encouraged to stay where they are? That would seem to me to be a very coherent way of expressing government policy. However, of course, many operators want to have a broader canvas for their stations. That is entirely acceptable too. Where they wish to make that investment and have a broader scope for their radio services, that seems to be entirely right and proper. The Digital Britain White Paper talked about the triggers for the switchover to digital radio. In referring to those, the Minister said that it was not simply the case that half of all listening should be to digital and that the relevant date should not be set until national DAB coverage matches that of FM and 90 per cent of the population have access to local DAB. The clause we are discussing — this is what Amendment 238 is designed to do — does not refer to any of that. All it does is talk about the report submitted by Ofcom, to which the noble Lord, Lord Howard, referred. It does not give any direction to Ofcom. One assumes that Ofcom will refer to the government policy as set out in the White Paper, but there seems to be no duty on it to do that. That seems to constitute a gap in the provisions. We on these Benches believe that the Government need at least to give reasons why some conditions are not appropriate. We do not necessarily believe that all of these additional conditions are the right ones, but we do believe that certain of those should be additional to those stated, so that all local stations have digital migration pathways. Currently, more than 120 stations lack viable digital migration pathways. All categories of commercial and BBC stations should be treated equally, creating a level playing field going forward. The switchover date — 2015 — is based on an assessment of DAB listening rather than digital listening, which includes digital television and the internet, as this will replace FM and AM as radio’s broadcast backbone. People are listening more and more to radio over the internet. As regards the whole issue of vehicle reception, I think that less than 1 per cent of cars can receive digital signal at the moment. I think the Government estimate that only 10 per cent of vehicles will be able to receive it in 2015. We are trying to get a more coherent policy and a switchover that accords more to the reality of what listeners are doing. There is absolutely no point in the Government being so far ahead of what listeners want to do that they create a reaction against their own plans. Amendment 239 is another measure designed to test the earnest of the Government. The Government have rather arbitrarily decided that switchover should take place two years after notice of it is given. Amendment 241 seeks to change that. There are concerns about the speed of switchover. Amending the notice period would allow more time to solve the issues around consumer take-up, such as those involving vehicles, and would allow digital solutions to be provided for all stations which want them. A four-year period would be far more realistic in terms of recognising the considerable challenges involved in the digital switchover. Amendment 239 states that the Secretary of State “must ensure that all commercial and BBC radio services broadcasting in the UK have the opportunity to switchover on the same date”. That is another way of testing the Government’s proposals in this respect. Are they saying that, at the end of the day, all these stations need to switch to digital, or are they saying that FM has a future in the long term? What is the purpose behind the switchover? It seems to me that the Government have not expressed their intentions very clearly. I hope that this is an opportunity for them to do so. I beg to move.

The Lord Bishop of Manchester: My Lords, Amendment 238 has been put eloquently by the noble Lord, Lord Clement-Jones, and with all the promised brio. However, he has set in that amendment probably rather an ambitious goal. Some may say that it is too ambitious. It may, of course, have the impact of delaying the switchover date from the much bandied-about year of 2015. However, as we heard from the Minister earlier, that is not a precise date. The amendment may also effectively force something of a reappraisal of how digital radio is rolled out between now and switchover. But, that said, I believe that neither of those consequences would be to the detriment of the well-being of the radio industry. The noble Lord referred to Ofcom. In order to make switchover manageable and help local stations remain viable in these challenging economic times, Ofcom has proposed a series of defined areas within which stations in the same commercial family will have more flexibility to share resources and locations. As your Lordships will know, that has been welcomed as a helpful step by many of the large and small commercial stations. Nevertheless, it throws up anomalies, especially where radio groups would be barred from broadcasting to some of their network from locations that are actually far closer to their listeners than those from which they are allowed to broadcast. I say this not to criticise Ofcom’s sterling efforts in coming up with solutions to try to make life easier for these vital local stations. The regulator is trying to be flexible and responsive in a rapidly changing arena. Yet that is precisely the point. It is almost as if, at the moment, we are rushing towards a finishing line when the course has not even yet been chalked out. This amendment helpfully acknowledges that the route to an appropriate digital platform is not yet entirely clear, especially for many smaller stations. I have concerns over the specific proposal that sets a target of two-thirds of listening on DAB before switchover simply because it does not quite recognise the mixed radio economy that we are moving towards, to which the noble Lord, Lord Clement-Jones, referred. If a growing proportion of us are listening to radio via our computers, mobile phones and digital TV sets, with only a small remnant still listening on analogue, it would be unfortunate if the wording of primary legislation made it such that we could not set a switchover date just because DAB was specified as the only non-analogue platform. But, with those reservations, on the whole I support Amendment 238.

Baroness Howe of Idlicote: My Lords, I will briefly add my support for these amendments. There clearly has to be a rethink on this whole area. There are so many different interests and people who have been hoping and planning. At Second Reading, I remember my enthusiasm for immediate digital switchover as far as radio was concerned. It would be a splendid way for me to be able to enjoy my journeys up and down to Warwickshire without having to fiddle around and change the frequency on the radio, which is presumably a fairly dangerous practice anyhow. So, although one may not agree with every word, this points out to the Government that there is going to have to be a more up-to-date assessment of where we are and how quickly, if at all, we are going to reach the desired goal of switchover and meet the needs of local radio stations, particularly the commercial ones.

Lord Young of Norwood Green: My Lords, the proposed amendment inserts specific switchover criteria into the Bill which must be satisfied before the Secretary of State can nominate a date for switchover. We agree that it is important for the Government to consider a wide range of issues and views before setting a date for digital switchover. We seem to be referring to 2015 as though we have set a date. I reiterate that that is a target. As with TV switchover, the announcement of a target date is essential in uniting the industry in creating the impetus to ensure that progress towards switchover conditions is made. For example, within six months of 2015 being published in the White Paper, progress with car manufacturers had advanced further than in the previous six years. We still believe that 2015 is an achievable deadline and the certainty of a timeframe is in the best interests of listeners and the industry as a whole. However, I stress that it is still a target. We expect broadcasters and network operators to work towards that deadline but a final date will only be set when progress measured against consumer-led criteria is clearly on target. We do not believe it is appropriate to insert the level of detail proposed by this amendment into legislation as it would fail to grant sufficient flexibility to address the inevitable changes in the market over the next five years. As this amendment raises a number of themes, I will take each of the issues raised in turn. It was an omnibus address delivered with brilliant brio. First, the proposed amendment requires a DAB network large enough to accommodate all commercial radio stations before a switchover date is nominated. We believe that this is the right ambition, but impractical in the short term. With over 50 BBC services, nearly 350 commercial stations, and 200 licensed community stations, the current DAB infrastructure cannot support a wholesale move to digital. We believe a mixed landscape of FM and DAB, as set out in the Digital Britain White Paper, is a better solution. It will allow small commercial stations and community radio stations to remain on FM, which was a point of concern expressed by the noble Lord, Lord Clement-Jones. In the case of community radio stations, it will allow for more services to be launched. On the question of whether FM is temporary or permanent, FM is the right technology for community and small local radio stations for the foreseeable future, following switchover.

Lord Clement-Jones: My Lords, it is permanent.

Lord Young of Norwood Green: I feel I am being lured into saying “never say never” or “never say ever”. We certainly see it for the foreseeable future following switchover. That is pretty generous. We are trying to reassure the noble Lord. It is the right technology for community and small local radio stations. We cannot predict exactly how technology will develop for ever and ever, but we are saying “for the foreseeable future, following switchover”. That is a pretty good guarantee. Secondly, this amendment would require DAB networks in the UK to reach the same number of households as analogue. Again, we agree with the principle and we are working with the industry to secure this outcome as quickly as is feasible. However, the definition of analogue coverage is too broad, encompassing long wave, medium wave and FM. It also provides no clarity as to whether it is a high-quality stereo signal or a low-quality mono signal. This amendment would result in multiplex operators and broadcasters bearing the full cost of a near universal DAB network for the longest possible time. Thirdly, the amendment proposes to require that 67 per cent of all radio listening be to DAB before a switchover date can be set. We agree that the digital radio switchover should be market-led and dependent on the take-up and usage of digital radio. However, this criterion places too great an emphasis on DAB over other digital technologies. The issue is not whether listeners choose to consume radio via DAB, the internet or digital TV, but the extent to which they have access to digital radio technology and are using it. Also required in this amendment is that DAB receivers are installed in 50 per cent of private and commercial vehicles. We believe there would be significant challenges in measuring success against such a criterion. In addition, such a legal requirement would fail to take account of the adoption of in-car radio converters or future technological developments. Just as we had the development of the Digibox in relation to enabling analogue TVs to carry on working, so it is obvious that we will see the price of in-car converters come down and that technology developed. All DAB radios include FM: that was another point that was raised. We are working with car manufacturers with the aim that, by 2013, all radios sold with vehicles will be digitally enabled. There are already devices on the market that will convert an FM car receiver so that it can receive DAB, and the market in this area is likely to grow considerably. It is huge: there are millions of analogue car radios. We are trying to cover all the areas of concern. Amendment 239 would also require that all commercial and BBC stations have the opportunity to switch over on the same date. It removes the flexibility granted to the Secretary of State to nominate different switchover dates for different services. Although it remains the Government’s intention that all services specified by the Secretary of State should switch over on the same date, flexibility is needed to ensure that the switchover can be delivered most appropriately for listeners. With TV, the gradual approach is working well, so we are making a plea here for flexibility. Amendments 241 would increase the minimum notice period from two to four years. We believe that this would unnecessarily extend the costs of dual transmission for broadcasters, and slow down the rollout of the DAB network. The noble Lord, Lord Clement-Jones, asked about our motivation. Part of it is the most effective use of the spectrum; another part is to ensure that people are given the best possible service. The noble Baroness, Lady Howe, said she had to fiddle with the knob on her car radio. It is time that she updated it to one with RDS, which will automatically change the frequency for her as she drives along. I cannot guarantee her a government handout, but it is well worth it. The right reverend Prelate was concerned about local radio and defined areas, and made a number of interesting points. We will look carefully at his remarks in Hansard and write to him on the issue. We will make copies available to all noble Lords who have contributed to the debate, because these are points of common interest. I apologise for going on at length, but this is an important debate that encompasses a wide range of issues. I have tried to address all the points raised and understand the concerns, and I hope that, given my response, the noble Lord will withdraw his amendment.

Lord Clement-Jones: My Lords, I thank the Minister for that comprehensive reply, particularly since it was on the run: it was not obvious from the amendments how broad the debate was going to be. He has addressed almost all the issues, except the one that I raised about DAB+. I forgive him for that, although if he does have an answer —

Lord Young of Norwood Green: I do have an answer, but forgot to make a note of the question. The advantage of DAB+ over DAB is the greater capacity that it provides for services on the same frequency, allowing a digital multiplex to broadcast around 20 rather than 10 services, thereby giving more stations the opportunity to move to digital. However, we believe that the benefits of DAB+ are more than outweighed by the negative impact on existing DAB listeners. Only a very small fraction of the 10 million digital receivers that have been sold are capable of receiving DAB+, and any technology change would make these receivers effectively redundant. That would significantly delay the switchover timetable and increase the time during which broadcasters would bear the burden of dual transmission costs. Nevertheless, the Government have been clear about their intention to promote receivers that are capable of receiving DAB+ and other digital technologies that are used across Europe. This will protect receivers against any change of technology in the future. We are trying to take into account the concern in that area. I apologise if I put that over quickly, but it will be on the record.

Lord Clement-Jones: My Lords, I thank the Minister for that suite of answers to the various points raised. I also thank those who took part in the debate; the right reverend Prelate and the noble Baroness, Lady Howe. Not every jot and tittle of the amendment necessarily carries all the weight that it should. We are looking for pointers from the Government. Although some of the White Paper sets out the conditions and criteria, they are not in the Bill and there is uncertainty, albeit among a minority of radio operators. The future of FM has not been made clear. I take the words “foreseeable future” in these circumstances to mean semi-permanent. There is a fear that FM stations “left behind” on analogue will be second-class citizens who will not be there for long — they will be hustled across into digital — when actually, in terms of cost and reception, ultra-local radio is probably best left on FM. It may be that the Government wish to release that spectrum, have a fire sale and flog off FM to the highest bidder — I know not. The Government need to be crystal clear about those issues. The use of the “mixed landscape” wording by the Minister was very healthy; no wholesale move in the circumstances is healthy, as it has been described to us that digital will be a great advantage to the larger national radio stations but not to the smaller ones. I understand what the Minister was saying about the vehicle aspect. I hope that he is correct in saying that the ability to convert to digital by various gizmos, which will not cost the public an arm and a leg, will be increasingly possible. I think he mentioned the 2015 gate but I do not know what percentage of in-car use was associated with that. Clearly, there is some considerable optimism about the switch taking place within the next three or four years. That is ambitious. On two years versus four years, I cannot help reflecting that the two-year period is more, not for the listeners’ or the radio operators’ convenience, but for the Government’s convenience because they want a decision made and they want to be able to consider the future of FM after that. That is the impression given to date. In a sense, two years is a very aggressive period, once the notice has been given, in which to expect that migration to take place. That is the fear behind that short period. Basically it is for the Government’s convenience rather than for allowing things to take place in an orderly fashion. This has been a very useful debate. I thank the Minister for what he has said. Obviously, some reflection is required. We have all had an enormous amount of correspondence from radio operators and no doubt we shall reflect with them between now and Report about whether further tweaks are required to this part of the Bill. In the mean time, I beg leave to withdraw the amendment.

Amendment 238 withdrawn.
Amendment 239 not moved.
Amendment 241 not moved.

[For the purpose of transparency, I was one of the parties invited to present evidence before the House of Lords Select Committee on Communications the morning of this debate.]

Small local stations & the Digital Economy Bill: debated in the House of Lords

The issue of the potential impact on small, local radio stations of the government’s proposed ‘Digital Radio Upgrade’ was first raised in this blog in July 2009, which stated:

“… the potential losers from Digital Radio Upgrade would seem to be:
• commercial stations presently carried on local DAB multiplexes who might have to be bumped because there is no longer the capacity after amalgamation
• local commercial stations presently carried on their local DAB multiplex who will have to quit DAB because they do not wish to serve the enlarged geographical area after amalgamation of multiplexes (for example, the cost of DAB carriage for Kent/Sussex/Surrey is likely to be considerably higher than Kent alone)
• new entrants

In the rush to frame proposals in Digital Britain that respond to the circumstances of the large radio players with substantial investments in DAB infrastructure, it might appear that the voices of the smaller local commercial radio stations have got lost in the stampede of lobbying. These stations might be small in number but many of them remain standalone, so they will not benefit financially from the relaxation of co-location rules. Digital Britain is condemning many of them to remain on FM (or AM), leaving the large radio groups to dominate the DAB platform.

Although the proposals in Digital Britain have been framed to ‘help’ local commercial radio, overwhelmingly they will reduce the financial burden of group radio owners with local station operations in adjacent areas, and of group owners who have invested in DAB infrastructure. There is little in the way of financial benefits for independent local commercial stations, or for potential new entrants, both of whom face being crowded out of the DAB platform.”

Last night, the House of Lords debated three amendments, amongst several, to the Digital Economy Bill which proposed that the voices of small, local FM radio stations and their listeners should be considered before the government commits the UK to digital radio switchover.

These amendments were eventually withdrawn after debate (see below) during which the government minister, Lord Young, made vague assurances that the views of listeners and others would be canvassed.

RadioCentre, the commercial radio trade body, subsequently commented: “Clause 30 (which relates to the switchover powers) was debated in detail, with proposed amendments withdrawn following debate and assurances from Government.”

Amendments 236 & 237
Moved by Lord Howard of Rising

236: Clause 30, page 33, line 17, after “to” insert “ — (a)”
237: Page 33, line 19, at end insert “; and
( ) the needs of local and community radio stations; and
( ) the needs of analogue radio listeners.”

Lord Howard of Rising: My Lords, in moving this amendment, I will also speak to Amendment 237. The amendments are designed to ensure that attention is paid to the local and community radio sectors and the many millions of analogue radio listeners — to which I should add the providers of satellite systems about which the noble Lord, Lord Maxton, spoke. They should all be listened to before any decision is taken about switchover. We on these Benches have not hidden the fact that we remain unconvinced that the Government’s plans to switchover in 2015 are realistic. We do not believe that audiences will be ready by then. The audience must remain at the forefront of all our considerations when we debate these parts of the Bill. As drafted, the Secretary of State will have to pay heed only to Ofcom and the BBC. Despite the BBC’s dominance in the radio industry, there is a strong argument that it would be helpful for community and local radio stations to be consulted. Indeed, the whole commercial radio sector should be included. It does not seem unreasonable to suggest that the Secretary of State consult the other parts of the industry that will be affected. It would also seem both reasonable and important for the Secretary of State to consider the needs of those who listen to analogue radio. The Government stated in their final Digital Britain report that they would start the countdown to switchover once digital listening made up 50 per cent of radio listening. That seems far too low. It would still mean that there were millions of listeners not using digital. Our amendment would ensure that the needs of those listeners were taken into account before the Secretary of State could nominate a switchover date. The amendment is simply an attempt to ensure that all who will be affected by switchover are considered before the Secretary of State nominates a date. As I have said, it does not seem unreasonable to ensure that listeners are placed at the forefront of these considerations. I hope that the Committee will agree. I beg to move.

Lord Gordon of Strathblane: My Lords, I think that I can offer some reassurance to the noble Lord opposite. Unless all those targets were going to be met, virtually the entire commercial radio industry would not support the clause, which it does, with one minor exception. The feeling is that this is an empowering clause that does not oblige the Secretary of State to set a date. Indeed, he can set a date and then withdraw it if precisely those targets mentioned by the noble Lord are not met. The radio industry seems to feel that the Government have got it right. I hope that that reassures him.

The Lord Bishop of Manchester: My Lords, in speaking to the amendment moved by the noble Lord, Lord Howard of Rising, I recall that in an earlier debate this evening, the noble Lord, Lord De Mauley, expressed deep disappointment that I was not supporting an amendment that stood in the names of the noble Lords. I hope that they will now feel slightly happier, because I support this particular amendment. I do so because the Bill as it stands provides very little safeguard for those who are living in remote areas, some of them perhaps still relying on long wave, let alone FM, for their radio reception. I take the point that the noble Lord, Lord Howard, made about the Digital Britain report. If I recall correctly the point was made at Second Reading that, when 90 per cent has been reached, there will still be one in 10 people — some of whom would presumably lose access via their radio to all the national, BBC and commercial radio stations — for whom we really ought to have the greatest concern. Short of listening via the internet — which I know the noble Lord, Lord Maxton, though no longer in his place, would be urging us to do — or Freeview, there is nothing that the 10 per cent would be able to do until the DAB signal catches up with the FM one. Through this and other similar amendments, I hope the Government will come to recognise that there are some very serious reservations about giving the Secretary of State the power to set the switchover date without proper statutory consideration of the wider impact of that decision on those communities who are often disconnected from British society physically, and those small stations that serve them. I am much in sympathy with the amendment.

Baroness Howe of Idlicote: My Lords, we shall come to rather more detail about this aspect shortly. I, too, support the amendment and the basis on which it is being put forward. We spent this morning taking evidence from the commercial radio stations, both from those which disagreed with the main grouping and those which had done some amount of research over time. The more one looks at this whole area, it is quite clear that there is a big problem about when this is going to happen, stretching into the future, causing a considerable number of problems. At the very least, this amendment requires others — those concerned and those involved — to be consulted. So, like the right reverend Prelate, I certainly support the amendment.

Lord Young of Norwood Green: My Lords, Clause 30 states that before nominating a switchover date, the Secretary of State must have regard to any reports submitted by Ofcom or the BBC under the terms of Section 67(1)(b) of the Broadcasting Act 1996. The purpose of these reports is to review how long it would be appropriate for radio services to continue to be broadcast in analogue form. These reports should have regard to the provision of digital radio multiplexes, availability of digital radio services and the ownership of digital receivers. In order to produce these reports, Ofcom is required to consult multiplex licence holders and digital radio service providers. In addition — here I address the concerns of the noble Lord, Lord Howard, the noble Baroness, Lady Howe, and the right reverend Prelate the Bishop of Manchester — the Secretary of State must, on requiring these reports, consult such persons representing listeners and such other persons as he thinks fit, as provided in Section 67(4). The noble Lord, Lord Howard, talked about plans to switchover in 2015. That is a target that we have set, not a precise date, as I hope he will recognise. The experience that we had with the TV switchover, which in some ways was even more fraught with difficulty, has been an outstanding success so far. One of the largest switchovers, in the Manchester area, recently went over without a hitch. We had a lot of preparation, help and assistance. We want to adopt a similar approach. It is not just about the 50 per cent of listeners. We have also talked about DAB achieving the same coverage as FM, which is something like 95 per cent these days. We are well aware of the importance of that. I also point out another factor which I think is important. The prices of reasonable quality DAB radios have been coming further and further down. That is important for less advantaged parts of our population. We are aware of the concerns expressed. We believe that the clauses have got it right. We understand the concerns, which is why I have taken time to give some further assurance. Given the breadth of the requirements to consult already proposed in the draft Bill and our commitment to consult widely before setting a date, we believe that the amendment is unnecessary. With the explicit assurances I have given, I hope that the noble Lord will feel able to withdraw the amendment.

Lord Howard of Rising: I thank the Minister for his remarks. I am grateful to the right reverend Prelate the Bishop of Manchester and to the noble Baroness, Lady Howe, for their support for the amendment and to the noble Lord, Lord Gordon, for his reassurance. All I am doing is asking the Government to pay attention to and listen to the listeners before they take too drastic an action and leave a lot of people very unhappy. From his remarks this would appear to be the case, so I beg leave to withdraw the amendment.

Amendment 236 withdrawn.
Amendment 237 not moved.

Amendment 239A
Moved by The Lord Bishop of Manchester

239A: Clause 30, page 33, line 21, after “services,” insert “while retaining the use of the FM Band for those local and community radio services, including special interest services, for which digital transmission using DAB is not a suitable method due to —
(i) the size of local DAB multiplex areas, or
(ii) the unavailability of capacity on the local DAB multiplex,”

The Lord Bishop of Manchester: This amendment pursues further the issue about retaining the use of the FM band for local and community radio services. I invite your Lordships to put yourselves in the shoes of someone running a small FM radio station, serving a population of 100,000 people in and around, let us say, King’s Lynn. As it stands, that station’s future seems to be to bid for a space on a local multiplex. That would mean that it would begin broadcasting to almost 600,000 people. Such a shift would significantly change the character of that station. Listeners from a much wider area would start to phone in to programmes and would, for instance, start to demand their own slice of news output. The station manager would be forgiven for wishing to stay on the FM band as long as possible, until a better solution was found for smaller stations to find a home on the digital spectrum. Consider then the prospect of the only way of going digital to be to join an even larger regional multiplex which covers the whole of East Anglia and serves well over 1 million listeners. That is the kind of situation that is faced by a number of small commercial radio stations if digital rollout continues as planned. Their pathway towards a digital future seems shrouded in a kind of fog, partly because of the large size of DAB multiplex areas and the lack of capacity on some multiplexes .Forcing those small-scale stations to broadcast to much larger areas than their current coverage would alter their feel and alter their connection with their audience. It would undermine the integrity that they hold as local broadcasters and potentially damage their ability to service platforms which stimulate and reflect local democracy and social action. There is also a danger that counter-intuitively such stations would struggle to attract advertising spend from local businesses which do not wish to market themselves to audiences up to 100 miles away. So, socially and commercially, beaming local stations to regional audiences is, frankly, not in anyone’s interests. As for the lack of space on DAB in some areas of the country, take, for example, the multiplexes currently covering Humberside or, in my own area, of Manchester where there is virtually no space available. Even with just the larger stations currently on board, capacity is running out in some areas. I understand that some stations that gain access are broadcasting in mono rather than in stereo in order to preserve bandwidth. The limitations of DAB for local and community stations are well acknowledged by Ofcom. Indeed, it is already planning for small-scale commercial and community stations to stay on FM in the medium term as the most appropriate technology for those stations in terms of both coverage and cost. The vacation of FM band space by the removal of national and large local stations would free up more capacity for smaller stations. Ofcom sees this as a natural staging post in radio’s digital evolution. Nowhere, however, is this halfway house given a firm legal footing. In case my amendment is misinterpreted as a luddite attempt to hold back the march of progress, let me make clear that it is intended as a temporary but crucial platform to support the transition to digital of small-scale local stations, which not only serve geographically defined areas, but also identity-defined and interest-defined groups. Your Lordships may remember the furore caused when in 1992, BBC Radio 4 proposed to transfer use f its long-wave frequency to a rolling news service. The BBC reckoned that FM reception was good enough and the vast majority of the country could pick it up without a problem. But those living in remote parts of the United Kingdom, and even in exceptionally hilly inland parts, knew different. The determination to push ahead with cutting Radio 4 from the long wave was met with purposeful if well-mannered resistance, as one might expect from Radio 4 listeners. In fact, I am told that the sight of 200 protestors in tweed and twinsets marching down Upper Regent Street was enough to help the BBC to see the error of its ways. Let us not make a similar mistake. After all, FM had at that point been around for almost 40 years. We have had DAB for less than a decade. The future of local radio — which is so crucial to forging community cohesion and identity, and promoting local social action and democracy — should not be left to chance. That must mean embracing a multi-platform ecology which creates a pathway towards digital broadcasting for local radio, retaining space for them on FM until such time as a digital platform offers them the right environment to continue what they do best. I beg to move.

Lord Clement-Jones: My Lords, the right reverend Prelate has said so much of huge value — an absolute tour de force on behalf of ultra-local radio. Of course from the remarks made in the previous amendment, I not only put my name to this amendment, but fully endorse what he said. It is that kind of certainty which is crucial, and this is a very elegant way of keeping it in the Bill. I hope consideration will be given to that, because — and this is not intended as a pun — a signal is needed in this area. We need a very strong signal — not just a digital or political signal — to FM radio, to ultra-local radio, that they have a future which is secure. That is exactly what the right reverend Prelate, whom nobody could accuse of being a luddite, has advocated.

Baroness Howe of Idlicote: My Lords, the right reverend Prelate has put it beautifully: “multi-platform ecology”. I like that and it sets the pattern for the future rather well. Clearly, this amendment hits on the crucial area of what will happen in the mean time and what is to be done concerning FM. We need some reassurance on this point; I think the Minister said that it would be around indefinitely. At the moment, we know that Ofcom grants only short licences. There have been quite a number of complaints from the radio stations that not to have the certainty granted to them by, say, a 10-year licence means that their likelihood of failure is considerable. That side of things would be helped if the Minister could confirm that FM will definitely be there, and that licences can be given as people gradually go over to digital and more space on FM becomes available. We know that there are minimal alternative uses for the FM spectrum besides transmitting radio. It is not therefore likely that the Treasury will want to make vast sums out of it, as it clearly did when it realised its potential. It has already had its fair share from that — or unfair share, depending on how you look at it. Please can we therefore have two assurances from the Minister? We should all try to move as fast as possible and with all encouragement towards the digital switchover, because we can see the disadvantages in having that laggard time that many seem to envisage. Indeed, one person giving us evidence today said that, concerning radio, there was really no possibility of a digital switchover; he was as dispirited as anyone could have been about the process. Any form of encouragement that the Minister can give would be welcome, certainly on the future use of FM and on longer licences. Those two things were very much endorsed by the people who gave evidence this morning to the Select Committee on Communications.

Lord De Mauley: My Lords, it is late and I shall be brief, but when we finally switch over to digital transmission it is important to be sure that the Government stay true to their promise that the FM spectrum will remain available for use by local and community radio stations. The Digital Britain report said that that was the Government’s plan, but it would give a great deal more reassurance if such a promise was contained in the legislation.

Lord Young of Norwood Green: I thank the noble Lord, Lord de Mauley, for his brevity. It is not as if I am not paying attention, or giving this less than its due, but we have already travelled over some of this terrain. However, I shall endeavour to reiterate the assurances. For small, local commercial and community stations, both the coverage area of a digital multiplex and the cost of its carriage are too great at present. That is one reason why we believe that those stations are best served by continuing to broadcast on FM. We have also committed to retaining FM for radio after the digital radio switchover. Of course, the Government will not stop any station that wants to and can move to digital, but we will reserve capacity on FM for those which have no obvious route there. I want to address a couple of the concerns that the right reverend Prelate expressed. How will we support those stations which remain on FM? In order to ensure that stations on FM can operate and compete with services on digital after switchover, the Government have already said that we are committed to establishing a combined electronic programme guide for radio. That will allow listeners to access stations via the station name, irrespective of the platform carrying the service. Listeners will therefore move seamlessly between bands, selecting stations simply by name; that is currently not the case when listening to FM and AM stations on an analogue radio receiver. We are working with the industry on that issue and encouraging its development.

Lord Clement-Jones: We have been given that assurance on a number of occasions. The Minister in the Commons, who recently announced his resignation, sadly, has given that assurance about the electronic programme, but no date was put on it. It is simply that they are working on it. This is a crucial aspect in retaining people’s ability to tune in to FM.

Lord Young of Norwood Green: I will see whether I can find any further information. This is a genuine commitment. It is all part of the backdrop against which this debate is taking place. We have set 2015 as a target, but there is not a headlong rush to it. We are trying to ensure a number of things, and this is one of them. I can give a progress report on where we are: it is a clear commitment. The right reverend Prelate asked about making FM continue to be attractive to advertisers and listeners. The key to the switchover of radio will be establishing three distinct tiers of radio — local, regional and national — which will provide unique content and are sustainable in their markets. The services that will populate FM will have a distinct role in providing very local material and reflecting the communities they cover. Due to the very local nature of their content and the refocusing of the large regional stations, these services will benefit from less competition for local advertising funding. I hope that is of some help. The noble Baroness, Lady Howe, asked whether Ofcom will offer analogue licences for longer than five years. The duration of analogue licences is a matter for Ofcom. However, it has suggested that, subject to the outcome of the Bill, it will consult on this issue. We support this process as there is clearly a strong argument for allowing analogue licences over a longer licence period. I, too, rather like the elegant phrase “multi-platform ecology”. I wish I had thought of it myself. We have not included in the legislation a commitment to retain FM because the Bill is not intended to set out all the details of the digital radio switchover but to enable a switchover to take place how and when that is appropriate. We agree with the right reverend Prelate’s phrase “a multi-platform ecology” — imitation will soon be the sincerest form of flattery on this one. To do this, Clause 30 provides for changes in the licensing terms of those services for which it will no longer be appropriate to continue on analogue once the switchover date is nominated. For those licences where analogue broadcasting is the most appropriate or only means of broadcasting, these powers need not apply and their terms will be unaffected, including the right to broadcast on an analogue frequency. The continuation of FM is therefore already provided for in this legislation and should be read alongside the commitments in Digital Britain. In the interests of time, I shall not say any more. I have tried to give as many assurances as I can. We share noble Lords’ concerns. We want this to be successful. We should take heart from how successfully we have handled the switchover to digital TV. That has been a success story. Lots of concerns were expressed at the beginning, and we had to work to ensure that people who had fears about handling the new technology were assisted. We got it right. I am not saying that that should be a blanket assurance for everything, but we should not forget how well we handled that. It gives us a good background of experience upon which we can build. I thank the right reverend Prelate for this part of the debate. I trust that the assurances that I have given will enable him to withdraw the amendment.

The Lord Bishop of Manchester: I thank the Minister for his response to this debate. I am also grateful to the noble Lords, Lord Clement-Jones and Lord De Mauley, and the noble Baroness, Lady Howe, who made very helpful comments. I welcome the Minister’s assurances about the continued provision for local stations to use the FM band. He said that we had been over this ground several times, but we have done so partly because of the seriousness of the issue and partly, as the noble Lord, Lord Clement-Jones, said later in the debate, because of the need to pin the Government down to get the precise assurance that people need. I am sure that those who run and who listen to these media services will feel encouraged by the general direction in which all this is going. Again, the noble Lord, Lord Clement-Jones, was absolutely right to say — it may have been a parlance, but it is a very good way of saying it — that these people really do need a clear signal from the Government that is very much along the lines of what the Minister has said. Having said that, I suspect that this needs to be repeated and to be made even clearer. As those of us who have the privilege of sitting on the House of Lords Select Committee on Communications know, there is a huge difference between the switchover to digital television — this has indeed gone very smoothly, although it is not without its teething problems — and the digitalisation of radio. It has been made very clear to us in the evidence that we have received that the whole business of the digitalisation of radio is much more complex. While the Government and all the digital facilitators need to be congratulated on what they have done in the switchover to digital television, let us not think that because that went so easily it will be the same for radio. There are some very different and deeper issues that we must look at. That said, I utterly agree with the Minister and all noble Lords who have contributed to the debate that we want to keep up the momentum. We really do want to go along with what the Digital Britain report has said and get ourselves going in the technological direction in which we are set. Unnecessary delays are certainly not welcome. Finally — I think the Minister alluded to this in an earlier debate — there is the issue of manufacturers moving towards products that use a combined station guide, rather as Freeview and satellite television do for television, so that people can choose stations by name, whatever the band they are using. This kind of mixed economy of stations, both analogue and digital, will be the simplest way of getting through the many complexities that are on our path. I am most grateful to the Minister, and I beg leave to withdraw the amendment.

Amendment 239A withdrawn.

[For the purpose of transparency, I was one of the parties invited to offer evidence before the House of Lords Select Committee on Communications yesterday morning.]