Written evidence submitted by Gary Madeley

General issues: Are there any issues missing from the draft Bill within the scope of public service broadcasting, video-on-demand or radio?

As far as I can see, the Draft Media Bill has nothing to say about technical standards for broadcast digital media, and specifically about minimum bandwidth and resolution requirements to achieve an acceptable level of sound and picture quality.  I would very much urge you to add a section to this bill to give Ofcom the power to demand minimum technical standards of broadcasters and transmitter operators.


Most televisions sold today have either a Full HD (1920 x 1080) or a 4K (3840 x 2160) picture resolution, yet, since the launch of Freeview HD in 2009, we have seen a reduction from 18 HD TV channels at its peak in 2013, to the present nine.  This is tiny in comparison to the 100+ SD TV channels available on Freeview, many of which have inferior picture quality to the earlier analogue 625-line system.  Yet, out of an estimated 18 million[1] households that watch TV on Freeview, only around two million[2] use an SD Freeview TV or set-top box as their primary household set.  The balance is clearly the opposite of what it should be.

The reduction in the number of HD Freeview channels is directly due to the closure of the COM7 and COM8 DVB-T2 multiplexes.  These were closed to allow a large chunk of the UHF spectrum to be reallocated to 4G and 5G mobile services.  Out of the remaining six national multiplexes, only one (PSB3/BBCB) now uses the DVB-T2 mode that is required to broadcast HD channels.  Ironically, the BBC is obliged to carry HD versions of the main commercial public service channels on this multiplex and so has no capacity for HD versions of its own News and Parliament channels.  Freesat, which has more multiplexes, carries 22 HD channels but the majority (150+) are SD only[3]Compare this to France, which has fewer free-to-air channels overall but nearly all of which are available in HD on both terrestrial and satellite platforms.

The Draft Media Bill should grant Ofcom the power to force the operators of the five DVB-T mode multiplexes to upgrade their equipment to DVB-T2 and to force the broadcasters of all Freeview channels, or at the very least the public service broadcasters, to broadcast all channels in Full HD (by which I mean 1920 x 1080, not 1440 x 1080 anamorphic), by making each a condition of their respective licences.  This may result in a net loss of channel capacity, but would place quality firmly above quantity (as was originally promised when the BBC rescued digital terrestrial television from ITV Digital in 2002).


When DAB launched in 1995, we were promised CD quality.  This promise was later withdrawn when the BBC reduced the bit rates on its national DAB multiplex to accommodate a number of additional digital-only stations.  Despite this reduction in quality, the BBC has maintained a credible stereo broadcast for the majority of its music stations (Asian Network excepted).  However, this is not the case for the commercial multiplexes, where a large number of music stations are broadcast in mono.

Stereo FM radio has been available in the UK since 1973.  It’s quite unacceptable that, fifty years later, as the nation is being encouraged to switch to digital, DAB should be taking us back to the days of mono AM radio.  When I asked David Lloyd, co-founder of Boom Radio, why his station was being broadcast in mono on national DAB, he explained that stereo DAB carriage costs approximately double that of mono carriage and that his small station could simply not afford to broadcast in stereo[4].  I assume that’s because the multiplex operators charge by the bit and stereo requires twice the bitrate (approximately).

The Draft Media Bill should grant Ofcom the power to force the operators of all DAB multiplexes, by making it a condition of their licences, to change their pricing model and provide a minimum bandwidth to all music and arts stations to allow them to broadcast in high quality stereo.  As with my television proposal, this may result in a net reduction in the number of stations, but would again shift the emphasis from quantity to quality.

Gary Madeley – Private Individual – Discerning viewer and listener (17/05/2023)

[1] Source:

[2] Source: Reply to my email about the closure of BBC News HD on Freeview from Kieran Clifton (Director, Distribution & Business Development, BBC) (06/07/2022).

[3] Source:

[4] Source: Reply to my question submitted via the Boom Radio website (18/03/2021).