DMB0005
Written evidence submitted by Maxxwave Ltd
RESPONSE TO DCMS SELECT COMMITTEE
On behalf of the majority of existing AM broadcasters
Overview
Maxxwave was commissioned in 2022 by the majority of AM broadcasters (we can provide a full list on a a confidential basis) to represent their interests following the dramatic rise in wholesale energy costs as a result of the invasion of Ukraine and to consider the future of AM broadcasting in the UK.
We engaged with almost all AM licensees and had a number of open and confidential discussions to understand their business models, their needs and demands.
In essence we found two distinct categories of users – those who see AM as a legacy broadcasting platform that they are seeking to retire and those who wish to retain AM long-term. It is predominantly the “mainstream” commercial stations (as represented by RAJAR/Radiocentre) who see it has a limited future and the minority stations (who due to their nature often are poorly represented) are the ones who see a longer-term future in AM, with IP being the replacement, not DAB.
We had in-depth discussions with Ofcom and DCMS which lead to several of our proposals being implemented in the Media Bill.
This submission is to underline the importance of certain clauses in the proposed media bill, as well as to ask for further consideration to be made around digital switchover criteria.
We have deliberately kept this submission brief and concise with the expectation that we can articulate further on specific points if so required.
Our original “white paper”, which is very lengthy and provides considerable background to AM, is attached as an annex to this submission (with some sections redacted for confidentiality reasons, although we are prepared to provide a full copy on a confidential basis).
In brief
On-demand analogue licenses
We are very pleased to see this provision in the Media Bill and the accompanying briefing notes capture our submissions well. We have attached our White Paper, which contributed towards this clause being included, and articulates the points better.
We have clearly demonstrated that small-scale AM stations are perhaps more viable in 2023 than ever before, due to spectrum being vacated by high-power UK and international stations, far lower cost and advances in electronic design in the past 40 years and the potential for wider audio bandwidth.
In 2023 and onwards it is possible to establish a local small-scale AM installation covering an entire city or region for a fraction of the historic cost. This AM installation can now provide audio quality comparable to the lower bitrate DAB services that we see.
There are a number of obligations (legislative and international) that require Ofcom to make spectrum available to new entrants, but the current prescriptive awards process is too cumbersome and inappropriate for 2023, being established in the 1977 Annan Report.
This on-demand licensing process will align analogue licensing with C-DSP and DSP digital licensing and will ease the regulatory burden upon Ofcom, removing a legislative burden that is no longer necessary.
We believe that this will open up a new wave of specialist radio stations for niche audiences – we see strong demand from ethnic minorities, especially South Asian stations (Noting India has committed to AM broadcasting for the foreseeable future due to the excellent coverage of difficult terrain, such as in India), specialist radio stations (the successes of Radio Caroline, Carillon Radio and others only serve to demonstrate this) and those for deprived and other specialist communities, such as Christian communities.
It is clear DAB will not cater for these specialist stations due to cost, geographical coverage and the often unique coverage footprint they require which often aligns very poorly with existing DAB multiplexes.
As the more “mainstream” stations naturally migrate to digital platforms (noting all analogue services under these proposals will be free to surrender their license without penalty at any time) then this will free up analogue spectrum that could be used by a new wave of minority broadcasters.
Leaving it to Ofcom to decide if they wish to implement on-demand licensing (or retain the current competitive process) appears to be the best option, in the interests of the UK consumers, to maximise listener choice and reduce regulatory burdens through removing bureaucratic processes that are not relevant in 2023 and beyond.
Radio Selection Services
We have already submitted evidence to DCMS that Radio Selection services are the biggest hurdle towards IP broadcasting, which we strongly support as the future of radio. IP broadcasting will offer vastly more stations and at a far better quality than any analogue or DAB platform ever can.
We ask that the existing provisions in the media bill are retained and strong consideration is given to the difficulty of minority stations that typically use AM to pay high entrance fees or not being able to access existing radio selection services.
Digital Switchover
The Ofcom 2007 “Future of Radio” consultation sets down the groundwork for a digital switchover. One stark point is that it estimated in 2017 that 90% of listening would be digital, with the remaining 10% of listening being to stations that are not catered for by digital platforms due to geographical coverage. It is very clear these predictions are a long way off being accurate – 15 years after this report a number of people are still listening to analogue in areas that DAB and other digital platforms are widely available.
Consideration needs to be made therefore as to “Why?”. There are three reasons given for digital switchover in the 2007 report:-
However, what is clear is that the AM and FM spectrum cannot be repurposed for DRM/DAB, as there are no receivers capable of receiving DRM, and no DAB radios in the UK cover the 88-108mhz frequency band currently used by FM. The technology envisaged in 2007 has not been developed and due to the large installed base of receivers is unlikely to ever be implemented.
Ofcom has actually recently rejected a proposal to install a test DAB transmitter in the current FM band on the basis of lack of receivers and therefore the spectrum is better used for FM.
Furthermore, the 55-88mhz spectrum has sat mostly unused in the UK since the cessation of 405 line TV in 1985. The spectrum around 250-500khz and 1650-1800khz also has similarly sat mostly unused in the UK for many years. These bands enjoy almost identical characteristics to AM/FM spectrum and if no use for these bands has appeared in 30 years, it is unlikely that any use will appear for the AM/FM bands if they were similarly vacated.
Therefore, we strongly contend that the original basis for full forced digital switchover – repurposing the spectrum for other uses – is flawed, especially as the original basis was to reuse the band for digital broadcasting, which is clearly not possible, as admitted by Ofcom.
However we believe that no intervention is required to give a natural digital migration. Much of the broadcasting industry has criticised the costs of simulcasting, although we note that local licenses may surrender their license without penalty at any time. Therefore, nobody is obliging local commercial licenses to simulcast on analogue platforms, and they are free to cease analogue transmission whenever they so wish, as several AM “mainstream” and BBC stations already have done.
We would like to see the BBC permitted to cease analogue FM transmission whenever they so wish – BBC Radio 3 uses more FM spectrum than all of community radio combined and has far less listeners. BBC Radio 3 vacating FM spectrum would allow community stations to migrate to clearer frequencies with higher power, and open up spectrum for a new wave of local broadcasting.
Furthermore, removing higher power national broadcasters such as the BBC from FM would allow some of the AM services to migrate to FM, which we argue is far more likely to be in the consumer interests.
The problem is that with this discussion of “digital switchover”, it is giving great uncertainty to the AM broadcasters, many of whom would like to invest in new transmitters and infrastructure, much of it over 40 years old, but are unable to do so as the current DCMS “Up Next” document suggests there is less than 2 years lifespan left in AM broadcasting.
We suggest the solution could be to insert one line within the Broadcasting Act 1996, Section 67 which reads:-
1(a)(iv) Demand for the current spectrum occupied by AM/FM by other users and if those proposed uses would better serve the UK interests than maintaining the spectrum for AM/FM broadcasting
AM Broadcasting - 2025 and Beyond
A White Paper
CONFIDENTIAL PARTS REMOVED
NOTE:
This report is presented in its entirety, as originally written
We are satisfied with the proposed wording in the Media Bill surrounding on-demand licences, and this document is included for completeness to give suitable background
At the time of writing this document, the long-term effects of the war in Ukraine on the wholesale energy market were not fully realised. However, in view of this the report is even more valid – the high power “national” networks are now even less viable but the low power “local” services have had little impact.
Since writing this report, National broadcaster Absolute 1215 has now closed down due to unsustainable electricity costs
November 2022
Prepared By:
Maxxwave Ltd on behalf of Small-Scale Independent AM broadcasters
Contents
1977 Report of the Committee on the Future of Broadcasting (Annan Committee)
How the 1977 Annan Committee findings influence AM policy in 2022
1977 to 2025 – are the recommendations still valid?
Need for a broadcast license and frequency coordination
Transmission power and transmission costs
1: National groups (Global, Bauer, etc). This includes the BBC
2: Small independent stations (Commercial and Community)
3: Low-power AM broadcasters (LPAM) that are licensed for a single site
Lack of representation of SS-AM broadcasters in RAJAR data
Interest from new broadcasters
Introduction and high-level predictions
Alternate uses of the AM spectrum
Obstacles to continuing AM broadcasts
Alternative licensing processes already in place within Ofcom for other spectrum uses
Novel licensing approaches abroad – Netherlands and others
Approaches for allowing access to AM spectrum with a low regulatory burden beyond 2025
A minor amendment to the existing RSL (restricted service license) legislation
Creation of a “light” WT Act license that could accompany an existing C-DSP or DSP BA license
For ease of reading, we have placed a summary of our findings below:-
- High power (>5kW EMRP) AM transmission for large regions is already unviable for new installations and is likely to become unviable for continued legacy operations by 2025
- With the discontinuation of high power transmissions both domestically and abroad, a significant number of clear frequencies are becoming available that could be suitable for low to medium power use
- Low to medium power AM transmission is becoming viable due to significant electronics advances in the past 30 years combined with a significant increase in clear AM spectrum
- Low to medium power AM transmission has the capability to provide town and city-wide coverage at lower cost than DAB and SSDAB
- An increase in audio bandwidth to 9khz with modern processing will not result in any significant interference to other services but will dramatically improve audio quality
- Post-2025 there is likely to be sufficient spectrum to accommodate around 40 low-medium power services in every area of the UK, giving greater capacity than FM or SSDAB
- There still exists a strong demand and support for AM as a broadcast platform, often in collaboration with IP
- The current licensing regime, predicated on the basis of demand outstripping supply, presents a significant obstacle to licensing new services and therefore the AM spectrum is likely to be empty and unused without a new method of licensing services
- A new “light touch” on demand licensing process akin to a DSP license but with spectrum attached should be developed to allow access to the AM spectrum, with the only condition that content of some description must actually be broadcast in the AM mode (to prevent spectrum hoarding or use by non-broadcast)
- This new process could either use the existing RSL framework, removing the power limit and requirement for single contiguous site or could use a new framework, perhaps using the existing DSP framework for compliance
- It is our strong belief that the requirement to broadcast will by itself be sufficient to prevent spectrum hoarding as users are very unlikely to wish to incur the cost of maintaining multiple transmitters simply to prevent other users of the spectrum
- The current license regieme for AM is too cumbersome and it is unlikely it will ever be justified by Ofcom as an appropriate use of their resources, therefore it is unlikely those wishing to use the AM spectrum will ever be able to gain access to it
- Existing broadcasters, especially national broadcasters, who wish to discontinue transmission should be free to do so at any time without losing their access to the reserved capacity on the national DAB multiplexes (noting this was written prior to Absolute Radio ceasing AM transmission)
Maxxwave has been commissioned by a number of Independent Small-Scale AM broadcasters (see Appendix A) to look at the future of AM broadcasting in 2025 and beyond. We refer to these as SS-AM (Small-Scale AM)
This stems from the UK Government’s White Paper “Up Next – The Government’s vision for the broadcasting sector” (29th April 2022), in which section 6.11 suggests that, based on current RAJAR listening trends, AM listening is likely to fall to commercially unsustainable levels by 2025.
The SS-AM broadcasters have been very clear that they see a long-term future for AM, and we have spoken with a number of other stations who have indicated an interest in launching new services on AM.
Furthermore, we look at how we have arrived at the Status Quo with respect to AM and licensing, and question if the presumptions which have been made surrounding the regulatory framework are still valid, and if the regulatory framework could actually be hampering the interests of SS-AM broadcasters, rather than facilitating them as the original intentions were.
Lastly, we look at what potential changes to regulation could be made, how other countries are handling AM broadcasting into the future, and what the benefits to the UK of making changes are.
The first question, and part of our research, focused on “Why are we here?”. It cannot be denied that in 2022 AM broadcasting is in rapid decline, and it is unlikely to ever return to become the primary means of radio broadcast that it was until around 1990. It also cannot be denied that changing economics, such as electricity costs, installed transmitter plant in many cases being well beyond expected service life, means invariably some AM transmissions will soon have to cease.
It must be remembered that AM is simply a form of modulation, independent to the actual frequency on which it is carried. It technically could be possible to carry AM broadcasting in the VHF spectrum (and the original proposals for VHF were for it to be used by AM transmissions, rather than FM). It would also be possible for the spectrum currently occupied by AM to be used by another modulation scheme, such as DRM (Digital Radio Mondiale, a digital radio system similar to DAB, but using the low frequency MF spectrum where AM broadcasting sits).
AM, as a modulation code, is relatively inefficient. It perhaps requires the highest transmit power to achieve a given audio quality out of all the commonly used modulation schemes. FM requires around 25% of the transmit power to deliver the same audio, DRM requires around 10% of the transmit power. AM therefore, is an inefficient modulation scheme from a transmission perspective.
However, from a reception perspective, AM is very simple to receive, using very simple circuits that are very power efficient and give long battery life, measured in the weeks or months as opposed to hours for a DAB receiver. There is a large installed user base of low-cost receivers, as opposed to employing an alternative scheme such as DRM, for which relatively few receivers exist today.
With respect to the low frequency spectrum that it occupies, this has the ability to travel considerable distances, giving coverage of an entire region from a single transmitter. It propagates excellently in mountainous terrain. However, at night it is capable of travelling thousands of miles, which means distant high powered transmitters in other countries have the potential to cause significant harmful interference during night-time hours. This night-time interference is the core reason for the entire demise of AM
The entire “beauty parade” licensing structure that we have today for licensing broadcast stations was established by the 1977 Annan Committee. The process of advertising a license through a “round”, inviting interested parties to submit their applications, then assessing the applications against specific criteria were all enshrined into process by the 1977 Annan report.
Furthermore, the 1977 Annan Report established the principles for Commercial Radio broadcasting within the UK. There are a number of points of relevance from this report:-
- 2.6: The radio broadcast services must be licensed. Firstly, such that the content can be controlled and regulated. Secondly, in order to avoid unwanted and potentially deliberate interference, a regulator must co-ordinate the radio spectrum to ensure that stations within an area all have unique frequencies such that they have a reasonable chance of being received without avoidable interference from a nearby transmitter
- 2.20: Due to the heavy use of the AM spectrum in Europe in 1977, it was only possible to cover the UK with one commercial service per area, which would overall give 70% of UK population by day, 25% coverage by night
- 3.1: The 1977 Annan Report recommendations would be considered valid until around 1992
- 3.14: The number of licences that can be issued are constrained by the laws of physics which constrain the number of services that can be provided. If the spectrum were unlimited then there is no need to limit the number of services
- 4.4: Due to lack of spectrum on the AM waveband (only 5 frequencies across the whole of the UK for commercial radio in 1977), it was suggested that simulcasting should be ended and separate services on AM/FM should be implemented to increase consumer choice
- 4.5: A diversity of broadcasting services is essential. Some services will naturally cater for niche audiences, and therefore will need large coverage areas in order to be sustainable, and therefore are naturally better served by AM
- 4.10: A lack of choice means a lack of accountability as the minority groups are not specifically served by a service. “Full service ILR” therefore is far from desirable as the minority groups concerns can be dismissed as they will be outnumbered by the majority of the audience who will find the minority programming a nuisance. “Full service ILR” was a “fix” to give all audiences access to radio broadcasting with limited spectrum.
- 7.4: Licensing decisions must be made nationally in the interests of best use of limited spectrum. If the licensing decisions were devolved this could create hostility due to competing interests for limited resources.
- 13.22: This details the license award process and the origins. The radio broadcasting licensing process was modelled broadly on the 1967 ITV regional franchise award process
- 14.1: It is preferable that all areas of the UK are able to access a localised service, even if this means that major conurbations have to compromise by sharing a single local service. It is not desirable for the spectrum to be used to provide multiple services in the urban areas and the rural areas are left with no localised service.
- 14.2: All areas of the UK should have at least one local radio service
- 14.8: As far as frequency resources allow, stations should be based upon community of interest, to serve specific subsections of the population who share a common belief, interest, rather than generic services which attempt to cater for the entire population within a specific geographical area
- 14.10: A station should embed itself within its target community and “report from within”, rather than being a distant observer from afar
- 14.15: Radio Broadcasting can bring a number of benefits to a community, and it must be recognised that many stations return social profits through investing socially in their community, rather than financial profits which often are for a small group of individuals
- 14.28: Due to lack of spectrum in 1977, particularly the AM broadcasters needed very tightly controlled, monitored and maintained antenna patterns. It was therefore felt in 1977 that self-operated transmission was not possible and therefore the regulator (IBA) was responsible for providing the transmission facilities, as well as the content regulation. The broadcaster was solely responsible for generating the content.
- 14.31: Due to the scarcity of spectrum and high demand, there must be no auto-renewal of licences and licenses must be fully readvertised at the end of their period.
- 18.12: It is only programmes that are made by the community that can give the most accurate representation of that community’s tastes and interests. For niche communities, public service broadcasting or simply having access to a programme on another station will not give the editorial freedom to give an accurate representation of minority communities.
- 24.3: AM spectrum was so scarce in 1977 that consideration had been made of reducing the audio quality to “telephone quality” in order to give more stations. It was recognised already that AM broadcast quality was poor, but to increase the audio bandwidth was impossible as it would reduce the number of broadcast stations to a level which was simply unsustainable. It was therefore elected to retain the audio quality that was fundamentally established in the 1920’s as it represented the best compromise between quality and quantity
- 24.5: In 1977, there was one national (198khz LW) and one local LF channel (225khz LW). There were 2 national MF channels (BBC, later to become Talksport and Virgin 1215) and 11 local channels (BBC and commercial local radio). There was access to two common international low power MF channels. In 1977, Radio 1,2,3 and 4 were all on AM nationally
- 24.18: It was concluded that the future of radio broadcasting in the UK was therefore through FM, not AM. International interference was expected to dramatically increase, particularly from Spain that had not signed the international frequency co-ordination agreements due to Franco’s Fascist government in force at the time, and with the 1976 transition to democracy in Spain, by 1977 dramatically increased harmful night-time interference had begun to the BBC and commercial stations. The BBC Radio 3 frequencies were considered so unusable due to the new Spanish stations that it was advocated that Radio 3 AM should be scrapped and the frequencies re-used for high power local stations that would overpower the incoming interference.
- 25.6: It was considered a matter of urgency to expand the FM band up to 108mhz (it only was available up to 97.6 in 1977) as it was considered that a full transition to FM may be required due to the expected interference from new Spanish stations
- 26.4: The BBC must expand its FM transmitter network as a matter of urgency due to the high risk of increasing international interference
Throughout the entire Annan Committee report, it regularly makes reference to shortage of AM spectrum and the concern of harmful night-time interference from potential new stations in Spain (which by and large did not actually materialise).
The “solution” was to install transmitters that were dramatically over-power that would provide a very high field strength within the local area. Transmitters up to 100 times more power than would typically be required were installed to provide high protection against international interference which mostly never materialised.
Due to the congestion in the AM broadcasting band at the time, no country was prepared to allow any other country to have additional spectrum, as it would have meant giving up some of their own spectrum usage. Therefore high power AM stations with complicated antenna arrays to serve relatively small areas were employed. These were very costly to install and operate, requiring significant amounts of land.
Furthermore due to the lack of spectrum, the broadcast audio quality was artificially constrained.
The 1990 Broadcasting Review advocated for very little change to the AM arrangements, and overall in 1990 the situation had not significantly changed from 1977. As the spectrum was still congested, increasing the audio bandwidth was not possible. There were no wide-area regional frequencies available and generally it was felt that FM, which had only recently been expanded in 1990, was the future, able to offer low cost local services.
We fully agree with the primary recommendation of the Annan Committee – there is a need for the content to be regulated and therefore it is necessary for a license to be issued to each individual service. This process is no more cumbersome than a DSP license, which has no other obligations upon the broadcaster.
We agree that is it necessary for a central body (such as Ofcom) to co-ordinate frequencies to avoid deliberate or accidental interference and therefore give optimal use of the spectrum. We have already demonstrated that with AM this process is considerably simplified and could simply use a lookup table.
We also agree that some form of “use it or lose it” requirement is essential, that a broadcaster must actually be on air at the licensed transmitter power. Otherwise “spectrum hoarding” could occur, whereby an operator purchases all the spectrum to deny others access. We feel the costs of operating an AM transmitter are sufficient that only those who see a benefit to the service will actually maintain a service on air.
We would suggest a period of 6 months is suitable that if a transmitter is off-air or otherwise not broadcasting content, or is operating at reduced transmission power then either the license conditions are altered to reflect the actual radiated power, freeing spectrum for other broadcasters to reuse the spectrum elsewhere, or the license is revoked.
The main point which is laboured by the Annan Committee, which underpins the entire policy and approach to AM broadcasting we have today, was lack of spectrum.
In 2022, most of the high power broadcasters have vacated the AM spectrum. Several European countries that had the most draconian technical restrictions, such as Germany (partially political, due to the ability of AM to traverse long distances and the nature of the Cold War propaganda), vacated AM completely some years ago as their AM installations were never at all satisfactory.
Spain has indicated their intention to end commercial broadcasting on AM, but the Spanish state broadcaster (RNE) has committed to maintaining their rural transmitters for the foreseeable future, owing to the large distances that can be covered by single transmitters, the rugged mountainous terrain in Spain and the fact rural Spain has one of the lowest population densities in the world. AM broadcasting is the only viable means of broadcasting to many rural locations in Spain.
In 2022 therefore it is clear which broadcasters internationally intend to remain and which broadcasters have ceased broadcasting. Domestically, there are a number of services which also have indicated their intention to leave AM post-2025.
It therefore can be stated with a reasonable degree of confidence that there will be around 70 AM frequencies available in the UK.
We therefore find overwhelming evidence to suggest that AM spectrum scarcity no longer exists and therefore any recommendations which are made which are as a result of scarcity in 1977 must be reviewed.
Audio Bandwidth
As far back as 1977 it was recognised that the quality of the audio from AM broadcasting was poor and below the expectations of the general public, and consideration was made to increase it. However, increasing the audio quality would decrease the number of stations that could be broadcast.
In 2022, the spectrum congestion issues do not remain. Furthermore with modern digital audio processing, audio quality and the spectral purity of transmitters can dramatically improve. Therefore it is possible with a minor adjustment to the Ofcom technical code of practice to dramatically improve the quality of AM broadcasting without significantly decreasing the number of stations that could be carried.
Therefore we see no reason why the audio bandwidth and quality of AM broadcasting could not increase, as was advocated for in 1977 but dismissed due to lack of spectrum.
Licensing Process
The entire cumbersome “beauty parade” licensing process that exists, and Ofcom has already acknowledged is resource-intensive and therefore prevents new analogue licences to be advertised, derives from the need to attempt to give maximal value to the public from a very limited amount of spectrum which would only support one service per area.
It was estimated that the demand:supply ratio in 1977 was around 30:1 – there were around 30 interested parties for every available service.
In 2025, there will be sufficient AM spectrum for around 40 local higher quality AM services to be installed in every area in the UK (currently in 2022 this figure is around 25). It is extremely unlikely that there will be more than 5-10 potential services in any area. Therefore we believe the demand:supply ratio is now around 5:40, or 1:8, effectively there will be vast swathes of AM spectrum that will remain vacant for many years, even if licences were issued on a “first-come-first-served” basis.
We therefore see no evidence at all to justify the cumbersome “beauty parade” licensing system over “first-come-first-served”, a model which was considered in 1977 and only dismissed due to spectrum scarcity. This cumbersome “beauty parade” model will only serve to prevent any further AM licensing rounds and offer no benefits whatsoever to the UK public.
Transmission power and transmission costs
The costs of establishing new AM services have often been cited as a factor preventing new entrants to the market, and the costs of maintaining AM services have also been cited as a factor to cease broadcast of existing services.
It cannot be denied that high power AM broadcasting, in the order of over 500W EMRP, which represents almost all of the National UK AM broadcast installations, is likely never going to give any form of return on investment post 2025, and is going to be commercially completely unsustainable.
Powers of up to 10W EMRP, however, have been demonstrated to typically deliver good coverage for around 5-10 miles, and typically are comparable in cost to FM transmission. These power levels offer similar coverage to a typical SSDAB multiplex with a lower cost of installation, operation and maintenance to SSDAB carriage costs when taken over a 5 year period.
All things considered, we find that when modern power levels are used, as opposed to the dramatically over-engineered power levels advocated for in the 1977 Annan report, AM is a cost-effective means of broadcast for regional stations up to around 25 miles range, delivering a coverage across an area of approximately 50 miles at a lower cost than FM or SSDAB.
We therefore find no reason to license new services at such high power levels, and commend the work of Ofcom with the new community AM services they have licensed in the past 15 years at far more appropriate power levels. These power levels give good regional coverage at affordable costs.
We therefore find no reason why SS-AM broadcasting could not be sustainable for the foreseeable future.
We recognise that certain frequencies are congested historically by other UK services at high power, and reducing the power of some services and maintaining incoming interference levels will be impossible without a frequency change or all services on a certain frequency reducing simultaneously. Therefore if existing AM broadcasters wish to change frequencies or reduce power, we note that this process is already available through Ofcom, and was recently undertaken by Absolute Radio and Talksport.
We have made an in-depth analysis of the Green Paper, White Paper and the 1990 Broadcasting Act. Whilst it makes considerable changes to AM, such as introducing two National AM commercial licenses (today held by Talksport and Absolute Radio), it does not advocate for any significant changes to AM policy, except allowing broadcasters to own and operate their own transmission systems.
This is perhaps because the 1977 Annan Committee made such an in-depth analysis of AM, and the situation had changed very little between 1977 and 1990 with respect to the AM spectrum, international interference or any International agreements.
We therefore consider that the 1990 Broadcasting Act is irrelevant to the future of AM broadcasting beyond 2025 and this document as the only significant amendment to AM that it makes, namely creating two National AM licences, are likely to come to an end by 2025 anyway, and we believe National Broadcasting on AM will not ever be economically viable again.
The shortness of this section in relation to the 1990 Broadcasting Act does not accurately reflect the hundreds of hours that were taken considering the 1990 Act and the background papers, and we recognise the 1990 Act is still the current legislation, but in the context of looking forwards for AM, all parties appear to be in agreement with ending INR on AM and therefore the 1990 Act has nothing more to add to the status quo in 2022 for AM.
Today we can categorise the AM broadcasters into three general categories:-
1: National and Networked AM broadcasters – These generally form part of a group, such as BBC, Manx Radio, Global, Bauer or Wireless
2: Local independent AM broadcasters – These are independently owned, with no networking arrangements between AM licences. Some partially simulcast on FM or DAB, but overall all still have significant amounts of coverage that are only served on AM
3: Low-power AM broadcasters
In 2022, there are 198 licensed AM transmitters in the UK:-
134 (69.6%) fall into Category 1 (BBC, National, Owned by a Large Group and Manx Radio)
30 (15%) fall into Category 2 (Independent Community or Commercial)
34 (17%) fall into Category 3 (LPAM)
These groups are well represented by Radiocentre and traditionally have had a strong voice into government policy.
All of the services available on AM are available on DAB and in all cases the DAB coverage exceeds the AM coverage. Whilst there may be some small pockets of population not served by DAB, overall the population served by DAB is higher than AM.
Stations in this category have made it extremely clear they wish to leave AM at the earliest available opportunity.
We agree that running National networks and high powered AM transmitters is costly and would go as far as to suggest that there are very little, if any, listeners to these particular AM transmitters.
It is worth noting that by number of stations, there are only around 10 stations in this category. This category has a strong voice with respect to policy, is well surveyed by Radiocentre, RAJAR and others, but is actually a small minority with respect to the number of stations.
The defining characteristic of these stations is that none have networking arrangements in place and a number are not on DAB.
They all serve niche audiences (see Appendix A) and clearly are of significant value to their audience to justify the cost of retaining their transmitters.
This category is the one which we concentrate on most closely as it is the one we work with the majority of these stations on an everyday basis.
There is only one LPAM service that is not on a LPAM license (Radio Seerah, Leicester). However the fact that Radio Seerah can provide a service that they claim to cover “Leicestershire and Rutland” on the same power as most of the LPAM services demonstrates the distance that AM can travel on a clear frequency.
These services fall into two categories primarily:-
A: Those trying to genuinely serve only a single site (such as a hospital)
B: Those who realise that the “overspill” coverage is significant and both serve a single site and the surrounding community (typically 3-5km, that of most FM community radio stations).
We note that the second usage scenario is a very grey area legally. They legally are permitted to cover this area, as their transmit power allows their signal to travel 3-5km, but their Broadcasting Act license prohibits them acknowledging this overspill coverage. This has been a very grey area for many years and is effectively a “loophole” that some stations have exploited to set up local stations, in the same way many community and commercial stations acknowledge listeners in their overspill licensed service area.
We have corresponded with around 50% of the LPAM licences and of those around 50% indicate (confidentially) they fall into usage case B – these are in effect localised community licences on a LPAM license.
Of those in usage case A, they have indicated that they are likely to consider migrating to FM on the new Ofcom interference limited FM license product.
Of those in usage case B, they have all indicated they believe their service is of strong value to their audience and they intend to stay on AM. Some may consider simulcasting on limited-interference FM services also.
Considerable mention has been made by Radiocentre and DCMS in their white paper regarding the cost of AM transmission and linking this to the viability of keeping the service running. (Noting this report was originally written before the full long-term effects of the war in Ukraine on wholesale electricity prices was fully realised).
In terms of cost of keeping an AM transmitter on air, there are three factors; Music rights licences (PRS/PPL) – often already covered because the station simulcasts on DAB in the area, Ofcom license fees – often relatively insignificant and transmission costs.
Transmission arrangements on AM generally fall into two categories – “self provision” and “complete broadcast”. On FM there are a far greater variety of models, but on AM our research strongly indicates that all licensees adopt only two models.
For “complete broadcast”, there is very little competition within the market, primarily owing to the sunk capital within existing masts and structures. The predominant operator is Arqiva. We have evidence from a number of broadcasters that Arqiva is not co-operative about allowing access for third-parties to install transmitters on their masts (which for AM were inherited from the IBA). Therefore with Arqiva the choice for broadcasters is either to pay a considerable annual fee or to establish an alternative site if you wish to try to reduce costs. Arqiva has already admitted they are having issues owing to the age of the transmitters, but does not appear willing to allow third-parties to replace the transmission plant and pay simply for site access at a fair market value.
For “self provision”, this is the route adopted by a number of smaller broadcasters. However owing to the nature of establishing an AM site and the legacy nature of many of these licences, this option is not available to all licensees as finding suitable transmission sites is often problematic, especially in city centres. Often the only available sites are ex industrial and on at least one occasion considerable expense were sunk into establishing a replacement site to move away from Arqiva to find that historic deep ground contamination from over 100 years ago rendered the site unusable for AM.
Therefore as of 2022, the primary modes of actually broadcasting AM are:-
1: Having a managed solution, generally provided by Arqiva who have access to legacy sites under a legacy arrangement. We note from several broadcasters concerns that these legacy sites are not being made available to third-parties to take over, potentially raising competition concerns. It is our belief that Arqiva is charging approximately £30-60k per annum for a typical county-wide AM service.
2: Self-installing a fresh mast on undeveloped land, generally rural. We note that some broadcasters, such as Radio Caroline, have managed to secure use of redundant mast structures and opted to refurbish these structures and installed a fresh transmitter connected to this refurbished mast. Generally this option costs around £20k to establish but then has ongoing costs of typically £5-10k per annum for a county-wide AM service. (These costs are still valid even with the wholesale energy increases as the transmission powers are low).
3: Using an existing building or structure to support a wire antenna (such as a redundant chimney or similar). This solution often is limited to around 100W EMRP maximum but is suitable for a 10-20 mile radius of coverage. This option is limited to city -wide services but appears to cost around £5-10k to establish and typically £2-5k per year per annum running costs for a city-wide service. (These costs are still valid even with the wholesale energy increases as the transmission powers are low).
Most SS-AM broadcasters use a mix between options 1 and 2. Most low power AM broadcasters use a mix of options 2 and 3.
Great emphasis has been made by RAJAR and Radiocentre that AM listenership is in decline. We have no reason to dispute the figures provided, and therefore fully accept the figures provided, for RAJAR listed stations. These indicate that by 2025 listenership will fall to levels that RAJAR listed stations will find AM unviable. As noted elsewhere in this document we welcome these stations closing down their AM transmitters and would not wish for any broadcaster to be forced to continue transmission that they no longer find affordable.
As noted below however, there is significant evidence that this RAJAR data is contrary to the findings of SS-AM broadcasters.
It is vitally important however that we declare that we have found no correlation between the RAJAR listening figures and the SS-AM broadcasters. We explore this now in more detail.
When we look at the list of RAJAR listed AM broadcasters, we find firstly that these broadcasters are currently simulcasting on DAB and/or FM. AM is not their only or primary form of broadcast. It is also clear that over a period of time there is not a mass-exodus of listeners. We therefore think it is clear and logical to declare that listeners are transitioning from AM to DAB, and believe this is the message that is being given by Radiocentre and RAJAR.
What needs to be considered therefore is “What is happening with listeners where a station is only on AM?”. This is the case with most of the SS-AM broadcasters – as we have demonstrated elsewhere in this document, they currently have no viable alternative to broadcast other than AM and IP.
What is clear is that these stations are also not seeing any long-term loss of listeners. If anything, due to their specialist nature, they have all actually been seeing an increase in listenership over the past few years as they have benefitted from the consolidation of “mainstream” stations and the loss of specialist programming on these stations.
We have a number of stations who have been in contact who have some presence on SSDAB in areas which does not correlate with their SS-AM transmitter footprint. These stations have identified little to no response in the SSDAB areas, but strong interaction and takeup in the areas which is served by their SS-AM transmissions.
A number of stations have also conducted their own listenership surveys. They are seeing that listeners are still using AM platforms, and if anything the listenership levels on AM are growing. To declare that AM is an “outdated platform” ignores other evidence that consumers are not particularly influenced by the perception of a platform, and if anything this is actually a benefit – Vinyl Record sales are now at an all-time high, a number of “retro” technologies are currently en vogue.
Frequently the audio quality of AM is raised. As we have noted elsewhere in this document, as the AM platform for SS-AM broadcasters is generally the only available platform, SS-AM broadcasters frequently reinvest in new modern digital signal processors and modern transmitters. On the other hand many AM transmitters operated by networks such as “Greatest Hits Radio” are still the same transmitters that were installed over 40 years ago and offer vastly inferior audio performance, giving a far poorer listener experience.
To summarise regarding listenership on AM for these SS-AM broadcasters:-
DAB, and SS-DAB have been frequently touted as a replacement for AM.
Overall we are broadly supportive of SS-DAB, and we note that Ofcom has decided to prioritise their resources in licensing SS-DAB and pause analogue licensing. Ofcom cites the cumbersome licensing process as being a poor use of limited resources. We are broadly in agreement with this and the entire purpose of this document is to advocate for a simpler licensing process for AM which would allow the resumption of new AM licensing.
What is clear with AM is that it allows a platform for wider area coverage, typically county-wide, typically offering the same coverage as a “local” DAB multiplex.
What is also clear is that SSDAB is offering dramatically smaller coverage.
We have strong feedback from stations that to replicate their existing AM coverage, it would typically require 9-15 SSDAB mulitplexes. These multiplexes do not offer contiguous coverage, often are not synchronised therefore not giving seamless regional coverage and the costing of going on 9-15 multiplexes is proving to be around the same cost as going on a “local” regional multiplex.
The issue that we have with this document is that costings have been provided to us in confidence. Local and SSDAB multiplexes are only making pricings available under NDA. In some cases AM broadcasters costings are also considered confidential. Therefore we cannot directly list costings.
What we can, however, do is show a comparison table:-
| AM | Local DAB | Multiple SSDAB |
Coverage | Regional | Regional | Regional with holes |
Coverage quality | Fully contiguous | Contiguous | Roaming is problematic |
Access for new stations | None – Ofcom are not licensing new stations | Very limited in some areas | Variable – some SSDAB multiplexes are “full” already |
Audio quality | With 9khz AM audio, quality is broadly equivalent across all platforms | ||
Capital cost | AM is around 10 times the build cost of DAB | ||
Annual cost | AM is around 10%-30% the running costs of DAB | ||
5-year cost | Taken across 5 years including build, AM is typically half the cost of DAB For after 5 years, AM is 10-30% the running costs of DAB | ||
The primary drawback for AM is that the listener perception is poorer.
For niche stations, particularly those which are the only station catering for a particular audience, AM is a very viable platform with strong support and listenership which offers regional coverage to audiences that value it the most at a low ongoing cost. Due to the high value listeners place upon the content, the shortcomings of the platform are often overlooked
All stations we spoke to indicate they have strong support for their IP platforms alongside their AM transmission. All stations indicate that there is strong growth in IP listenership.
However most of the SS-AM broadcasters also indicated they do not believe IP platforms will fully replace their AM transmission. Two broadcasters, Carillon Radio and Radio Caroline indicated their AM platform is a very important part of their offering, and even if listenership was over 95% to IP platforms, they would be likely to retain the AM transmission anyway (remembering the spectrum has no apparent other value than AM broadcast).
We support and encourage the growth of IP platforms and any regulatory support that can be put in place to ensure that it is available.
Stations have indicated the following areas of concern with IP:-
Overall the SS-AM broadcaster’s complaints about AM do strongly suggest regulatory intervention is required within the IP radio market.
We have spoken with a number of different parties regarding establishing new AM transmission, and believe there is a reasonable level of demand.
Today, in 2022, there is no means by which a new station can obtain a new wider area AM license. We can see that some licenses have been traded and some new low power AM services have been established in the past 5 years, but as Ofcom has not advertised any new AM licenses since 2016, there has clearly been no new AM broadcasters taking to the airwaves.
Recently a number of stations celebrated the anniversary of the 1967 Marine Offenses Act, and a number of special events were held to commemorate this. Strong feedback has been given from these events that a number of parties would like to establish low power services (typically 1W EMRP). The power often quoted is 100W peak transmit power (as with the Netherlands), which equates to 25W carrier power, and with typical antenna efficiencies from low cost services, this will be around 1W EMRP in reality, which is how we have derived this figure.
It is legally possible to apply for a RSL license in 2022 for AM (LPAM) that will allow 1W EMRP, but the problem is legally it is restricted to a single contiguous site without a permanently resident population, which means that the low power localised stations for which there is strong demand cannot legally be licensed through the existing LPAM system, and Ofcom will not run any analogue licensing rounds.
We are therefore highly confident that there is demand for a light license to allow broadcasting on AM, along the lines of the “DSP” license for DAB, but currently there is no suitable license product available.
Beyond 2025, we need to consider what the landscape is likely to look like on the AM spectrum. For this we are using the broadcaster’s own signalled intentions and therefore make the following assumptions, based upon the data provided by the broadcasters themselves:-
We have researched a number of technologies, including IoT, SCADA, utilities and other potential digital users. They all indicate that the spectrum has the potential for extremely low data rate communications, but have no interest or desire to operate such a network.
There were commercial data networks below the AM broadcast band (around 475khz) and above the AM broadcast band (around 1700khz), and theoretically this spectrum still remains available for licensing. However no commercial service has expressed any interest in using this spectrum and the services previously using this spectrum have all vacated around the year 2000 when data services on mobile telephone networks were expanded.
There is a “teleswitching” service on Radio 4 Long Wave (198khz), which has for many years indicated it wishes to leave and sees no long-term future in the low frequency spectrum.
The spectrum is not capable of supporting even moderate data rates (above 50kbits/sec) and therefore is of no interest to mobile phone networks.
The only potential use for this spectrum remains AM broadcasting. The fact that the adjacent frequency spectrum has been clear for so long demonstrates this spectrum has no other use.
We have already considered in detail the issues surrounding AM broadcasting such as increasing cost of electricity, aging equipment, decline in listener figures, changing listener perceptions.
However as a broadcast platform, it fundamentally will remain available for the foreseeable future. Due to the extreme simplicity of the electronics, it is highly likely that AM radios will be available at a low cost for the foreseeable future. It does not rely on any custom chipsets and AM receivers can be purchased today for under £2, and it still represents the most efficient use of batteries with some AM receivers (such as crystal sets) requiring no battery whatsoever.
The biggest obstacle therefore to continuing AM broadcasts is going to be new services accessing broadcast licences.
Ofcom has stated on multiple occasions that they have limited resources. They also have stated they therefore intend to use these resources in licensing SSDAB as the AM licensing process takes exactly the same amount of resources but the benefit to the consumers they consider is far lower.
It is firmly our belief that this AM licensing process is completely out of date and has no relevance in 2022, let alone beyond 2025.
For spectrum uses where there is more spectrum than demand, typically a “first come, first serve” basis is utilised. This approach is used in:-
- Restricted service licences (such as 1W LPAM on-site licences)
- Fixed link licences such as studio-transmitter links
- Fixed link licences such as used by mobile phone companies, wireless broadband, etc
- Business radio such as taxis, airports, couriers, etc
- Certain amateur radio products such as repeaters, beacons, data gateways, etc
All these license “products” still require a degree of technical co-ordination, which for AM we have demonstrated could be simplified and achieved in under 30 seconds, and the basis is when no suitable spectrum can be identified, the license application is refused.
Some of these products have a requirement you must use the product to prevent “spectrum hoarding” to establish a form of monopoly, which we support.
For some spectrum uses, you obtain a license to operate in a certain spectrum range, and then it is for the users to identify the exact frequency to be used. This approach is used in a wide variety of applications, such as:-
- DSP/C-DSP licences for DAB (the spectrum coordination is achieved through the multiplex operator)
- Amateur radio (a technical examination of the operator is required which covers selection of frequency)
- “Light license” wireless broadband such as 5.8ghz (although the equipment has software mechanisms to co-exist more peacefully with other spectrum users)
For AM broadcasting we consider self-coordination not to be a suitable means of allowing spectrum access. It is highly likely some groups could cause harmful interference either deliberately or accidentally.
Furthermore having a degree of assurance that your frequency will be available long-term is essential to the listeners of a station. In some areas of the world FM spectrum is issued on this “self-coordination” basis and it is not at all successful.
We would very strongly therefore not support a self-coordinated approach to AM spectrum licensing as we consider it would not be in the interests of either broadcasters or listeners.
Within the Netherlands it has been recognised that there is demand for access to AM spectrum. Therefore a “low power AM” license class has been defined as follows:-
- Stations can operate up to 100W transmitter power (it is measured as transmit power not EMRP to simplify the regulatory burden, but we consider it a matter for Ofcom to define the power and means of measurement)
- The regulator issues a frequency assigned to the license for a specific transmitter site
- The frequencies are reused with a simple distance-based algorithm (as we have already demonstrated this would allow the technical aspect of the licensing process to be carried out in just 30 seconds)
- The licences still have an obligation for content standards
There are today around 50 of these services on air across the Netherlands, and this novel licensing approach has been declared a success. A number of other countries are now following this licensing process.
There are three processes that appear to be suitable for allowing new AM services to be established:-
Each approach has its own merits and we explain the approaches in more detail below:-
Currently low power AM services can be licensed under the existing RSL legislation. However these are limited to a single contiguous site with a non-permanently resident population.
This legislation could easily be adapted by removing the requirements for “single contiguous site” and “non-permanently resident population”. Ofcom already has the rest of the licensing process in place and this could allow, with only very minor legislative changes, access to the spectrum for low power services.
However this approach would raise some issues when considering regional AM services. This is unlikely to provide a pathway for regional AM services to be established.
This would likely result in quite some work with respect to legislation. However, it would be perhaps the “cleanest” way of resolving the spectrum.
Essentially, as has already been described, licensees would simply be able to apply for a license when needed. Statutory criteria with respect to license eligibility would remain and fitness to hold a license, as well as the standards compliance requirements.
However the burdensome advertisement and competitively awarded assessment process would be completely removed, as is already the case with the RSL product.
This approach would be the “cleanest”, creating a completely new “first come, first-served” license product.
The essential requirements such as having to actually broadcast would also be retained such that broadcasters cannot obtain spectrum and fail to use it, denying others of the opportunity to broadcast.
This approach would effectively allow a broadcaster to apply for a WT Act license for a transmitter to accompany their existing DSP/C-DSP license. In effect an AM transmitter would be treated as a multiplex.
The existing DSP/C-DSP license application process could be used, providing a streamlined process for Ofcom. Stations are likely to partially simulcast on DAB and AM, and this would mean that any station just applies for an AM WT Act license, which Ofcom could assess quickly and with very low administrative burden.
These WT Act licences would be “first come first served”, and this approach could be used to converge the entire analogue and digital licensing process, considerably reducing the legislative burden for Ofcom.
The requirements of actually broadcasting would be contained within this new WT Act license.
This approach is our preferred method by far as it would require little legislative change but also would represent a very low burden on Ofcom on an ongoing basis.
Ofcom would be free to define the maximum power level for this product, which we believe should be around 5kW EMRP maximum. If a service fails to deliver their fully licensed EMRP within a period of time (perhaps 6 months) then their license will be amended to their installed EMRP or revoked if they are not actually transmitting.
Indication of which stations Maxxwave represents has been removed for confidentiality reasons but can be supplied on request. It is above 90% of the below list with only a small number opting to be self-represented, although their needs are well represented within this report.
Panjab Radio | Greater London | AL000050 |
Sabras Radio | Leicester | AL000058 |
Premier Christian Radio | Guildford | AL000080 |
Lyca Radio 1458 | London | AL000156 |
Lyca Dil Se 1035 | London | AL000160 |
Radio XL | Birmingham | AL000171 |
Asian FX | London | AL000172 |
Premier Christian Radio | London | AL000176 |
Asian Sound Radio | East Lancashire | AL000183 |
Sunrise Radio | London | AL100581 |
Sunshine Radio (AM) | Ludlow | AL102759 |
Desi Radio | Southall | CR000061 |
Flame CCR | Wirral | CR000155 |
Radio BGWS | Farnborough | CR000210 |
Radio Warrington | Warrington | CR100137 |
Akash Radio Leeds | Leeds | CR100143 |
Bradford Asian Radio | Bradford | CR100145 |
Salaam BCR | BURY | CR100168 |
Dales Radio | Yorkshire Dales | CR100180 |
Radio Panj | Coventry | CR100535 |
Radio Caroline | Suffolk | CR101725 |
Carillon Wellbeing Radio | Coalville | CR101731 |
Radio Seerah | Leicester | CR101765 |
Radio Ramadan 365 | Glasgow | CR101766 |
Canterbury Hospital Radio | Canterbury | LRSL000052 |
Stag Radio | Guildford | LRSL000063 |
Livewire Radio | Norwich | LRSL000110 |
Radio Stortford | Bishops Stortford | LRSL000118 |
Acacia Radio | Annesley Woodhouse | LRSL000192 |
BFBS | Bovington | LRSL000204 |
BFBS Gurkha Radio | Innsworth | LRSL101592 |
BFBS Gurkha Radio | Warminster | LRSL102186 |
BFBS Gurkha Radio | Abingdon | LRSL102769 |
BFBS Gurkha Radio | Hullavington | LRSL103007 |
BFBS Gurkha Radio | Perham Down | LRSL103008 |
RaW 1251 AM | Coventry | LRSL103079 |
Hub Radio | North Bristol | LRSL103086 |
L and D Radio | Luton & Dunstable | LRSL103107 |
Kingstown Radio | Kingston-Upon-Hull | LRSL103112 |
Radio City Swansea | Swansea | LRSL103247 |
University Radio York | York | LRSL103660 |
Radio Redhill | Redhill | LRSL104018 |
Mid-Downs Radio | Haywards Heath | LRSL104208 |
BFBS Gurkha Radio | Catterick | LRSL104239 |
BFBS Gurkha Radio | Stafford | LRSL104240 |
BFBS Gurkha Radio | Blandford Forum | LRSL104241 |
BFBS Gurkha Radio | Brecon | LRSL104242 |
BFBS Gurkha Radio | Nuneaton | LRSL104243 |
BFBS Gurkha Radio | Camberley | LRSL104245 |
BFBS Gurkha Radio | Gillingham | LRSL104246 |
BFBS Gurkha Radio | Folkestone | LRSL104247 |
BFBS Gurkha Radio | Aldershot | LRSL104248 |
BFBS Gurkha Radio | Salisbury | LRSL104357 |
Radio Cavell | Oldham | LRSL104365 |
Radio Clatterbridge | Clatterbridge | LRSL104423 |
CHR 1431 AM | Chichester | LRSL104431 |
Anker Radio | Nuneaton | LRSL104494 |
Carillon Radio | Coalville | LRSL104520 |