Ofcom DAB Consultation Companies' Submissions Published

21st March 2005

All the commercial radio groups' submissions to Ofcom's DAB public consultation have been published on their website along with some of the individuals' responses (Ofcom are still going through the individuals' responses and hope to have published them all by tomorrow).

The commercial radio groups all agree on the issue of reducing the bit rates and they are predictably in favour of this -- although GWR admit that there is no need to lower the bit rates to allow the introduction of new stations because, in their opinion: "Technology and data services are likely to become the significant driver of DAB uptake in the future, rather than increased choice of audio services".

GWR and Digital One (66%-owned by GWR) submitted a rather whinging and tiresome response where they tried desperately to find excuses why any new national DAB multiplexes would be detrimental to the development of DAB. In reality, Ofcom will see straight through these flimsy excuses as simply protecting the position of Digital One as being the only national DAB multiplex operator.

Other than the GWR's and Digital One's complaints, all the other commercial radio groups are in favour of licensing the 2 national DAB channels under the Broadcasting Act rather than Ofcom's proposal to licence them under the Wireless Telegraphy Act. Personally, I find it surprising that none of the commercial radio groups wanted to try and win an auction to have complete control of a national channel, but from reading their responses I think they're afraid that auctioning-off such national channels would allow the mobile phone companies to enter the fray, in which case the mobile phone companies could easily out-bid the commercial radio groups due to the massive resources they can draw on. However, I think their fear is unfounded because I doubt the mobile phone companies would be interested in these channels due to the fact that they would be limited to using the spectrally-inefficient DMB if they wanted to provide mobile TV services.

Unfortunately, the superior DVB-H system requires at least 3 contiguous DAB channels so it can not be used unless Ofcom get their finger out and try to use the DAB spectrum more efficiently. Up to now it is hard to imagine a less efficient use of the DAB spectrum than the UK's implementation, because DAB can use national single-frequency networks (SFNs) which are the most efficient use of the spectrum, but so far the frequencies have been largely squandered on regional multiplexes and an overemphasis on local multiplexes, with the result being that we have lots of quasi-national stations which fill-up the local and regional multiplexes, which is the least efficient way for such stations to be distributed nationally, and is against the desires of the commercial radio groups themselves (apart from GWR, for the reasons I've discussed above). For more details about how DAB could be implemented far more efficiently, see the DAB vs DVB-H vs DMB page.

The reason why I very much doubt that the mobile phone companies would be interested in implementing DMB in these national Band III channels is because they would only be able to carry a total of 6 mobile TV channels (3 channels per multiplex assuming a mobile TV channel bit rate of 384kbps), which is hardly an attractive proposition to sell to the general public, and I would expect that the mobile phone companies will wait to use the vastly superior DVB-H system, because it will be able to carry up to about 30 mobile TV channels in a single multiplex.

However, assuming that Ofcom do go along with the wishes of the majority of the commercial radio groups and licence the 2 national DAB-compatible channels under the Broadcasting Act, then the multiplexes will not be used for DMB for mobile TV, and will be awarded using the "beauty parade" method, which chooses the "most attractive" proposal primarily based on the range of services that the proposal aims to provide.

So, although the prospect of the BBC basically having no chance of acquiring any capacity may have passed, it now remains to be seen whether the BBC can actually get any additional national capacity, or whether their huge gamble with the audio quality of their stations on DAB -- and indeed gambling the audio quality on DAB across the board, because the BBC are supposed to be the standard-bearers for quality -- has completely backfired and DAB will forever provide low audio quality. If it is the latter then the only decent thing to do would be for Jenny Abramsky to retire and Simon Nelson to resign.

On a lighter note, all the commercial radio groups seem to be in agreement, or at least not against, the relaxing of the 10% limit on non-TV services on DTT so, assuming Ofcom advise Tessa Jowell to relax this 10% limit then it seems very likely that Freeview will be getting more commercial radio stations. Whether the commercial radio groups decide to increase their bit rates, however, is obviously doubtful given their record of providing such abysmal audio quality on DAB despite the fact that most commercial DAB multiplexes aren't even full.