Funferal

ComReg radio consultation – act here

ComReg, Ireland’s Commission for Communications Regulation, is currently running a consultation process in response to their document on Radio Spectrum Management policy until 2007 (ComReg 05/01). I’ve drafted a submission in association with a number of colleagues, as part of a policy group called Scagaire. However, I’d like to make it easy for others to make short submissions in relation to a number of issues raised in the document. The deadline is this Friday (4th March, 2005) at 5pm. Submissions should be marked “Reference: Submission re ComReg 05/01” and emailed to sinead.devey@comreg.ie
Below the fold I list some of the questions asked and some of the points we have raised in our submission. Please use your own language where possible – much of what follows is excerpted from the submission Scagaire will be making – and check document 05/01, or with me, if you want further detail of what ComReg is proposing.

Q. 3. Is there any further detail ComReg has not taken into account in this general assessment of the economic and social impact of radio spectrum?
ComReg mentioned non-economic impacts in passing but concentrated on economic impact – GDP contribution and employment figures. In relation to broadcasting they discussed ‘consumer surplus’ – the extent to which the TV license isn’t at the maximum the population would bear. This is inappropriate and insufficient as a means of measurement.
In relation to community radio in particular, GDP impact is not an important goal nor is it the most significant impact. Community stations provide space for interaction among community members, outlets for small community-based organizations, and opportunities for individual citizens to gain experience and express themselves. Further, each week hundreds if not thousands of people contribute thousands of hours towards the operation of community radio stations, both on and off air. Apart from the benefit to listeners and communities from the availability of the content produced by these stations there is extensive evidence that there are substantial social and economic benefits from involvement in such socially-grounded activities. Putnam’s Bowling Alone, for example, connects a lack of hobbies and social life with destruction of community and attendant loss of economic activity. None of these contributions are measured in GDP.
Q. 15. Do you consider that there will be significant demand for DVB or DAB technologies?
We suggest that Ireland, andComReg, consider following the lead of countries such as Germany in looking towards adopting a more advanced service than DAB (Eureka 147) to accommodate audio service needs. We also believe that ComReg needs to guarantee the availability of audio services, specifically local and community services, and the spectrum space necessary to maintain and develop them. We therefore disagree with the suggestions made by ComReg in 04/93 that Ireland should adopt DVB-T without allocating specific space for audio services and that priority should be given to building networks that will mainly facilitate stations of a national scope – to do so undermines the value of local and community broadcasting.
Q. 18. Do you have a view on the balance between licensed and licensedexempt spectrum that will best facilitate wireless broadband?
We support significant expansion in the amount of spectrum available for unlicensed use for the purposes of wireless broadband provision. We advocate the explicit mandating of sharing as part of any declaration of the license-exempt status of a piece of spectrum. We further support regulation of the equipment permitted to ensure that good neighbour activity is supported. We note that it is important, for community networks to be effective, that consumers retain the right to share or resell their internet access with others through such networks, and we ask ComReg to ensure that telecommunications operators do not place restrictions on the service that consumers have already paid for.
Q. 26. Do you agree that there is a demand for the provision of religiousand community based Wireless Public Address services in Ireland?
This is a complex topic and the Scagaire response is a nuanced one, as we believe the issue has ramifications for the broader situation of community broadcasting.
Anecdotal evidence suggests to us that many Irish churches currently operate radiosystems for the purpose outlined here – to allow parishioners to experience Mass from their homes – and as ComReg notes these systems constitute unlicensed transmissionson the broadcast band. It seems clear that if the proposed ‘wireless public address services’ were to be made available they would attract a user base.
We must stress, however, that such services are no replacement for community access to the standard broadcast spectrum. This service, if implemented, must not be used to undermine the status of community radio services. Nor are we certain that this proposal will sufficiently meet the needs and desires of those wishing to provide access to religious services to members of their communities.