Funferal

Religious broadcasting in Ireland

Ireland doesn’t currently have any religious broadcasters – though RTÉ does carry various christian services on Sunday – but it’s a major target, at present, of those looking to change that. I’ve previously posted on the (failed) application by a church group in Galway that receives the bulk of its income from a US-based church.
Now this week there are two relevant developments. First, the BCI has announced that there has been one application for each of the potential community of interest stations in Athlone, Dundalk and Carlow towns. Each of the applicants seems to be a christian group – the Athlone and Carlow groups are called Athlone Christian Media Ltd. and Carlow Christian Media Ltd., respectively (can you say boiler-plate?) and the Dundalk application is by WordFM Limited. Since the BCI hasn’t licensed religious groups in the past I wonder if there’s a significance to their inclusion in the press release of the phrase:

The assessment of each application will be guided by the criteria laid down in the Radio and Television Act 1988, the Broadcasting Act 2001, the BCI Community Radio Policy document and the Guide to Submissions issued by the BCI.

The other development is that ComReg has released its response to the consultation process it ran on radio spectrum management. This was the consultation process to which Scagaire submitted. Long-time readers will recall that one of the issues we addressed was a proposed “Wireless Public Address Systems in the band 27.6 – 27.99 MHz to meet the needs of religious and other community organisations.” The only identified use of this was for churches to transmit their services to those who can’t physically attend – many Irish churches currently operate unlicensed/pirate operations on the FM broadcast band for this purpose.
The Scagaire submission expressed concern that this proposal was being made at the same time that ComReg was proposing that community broadcasting be excluded from digital broadcasting when that transition happened, arguing that this service should not be used as a means to undermine community broadcasting – especially given the restricted nature of what is proposed here. It is useful, I think, to quote in some detail from our comments:

We have, however, a number of concerns about the proposal. First, while this offers a solution it is not certain that it is the best solution, or even a sufficiently efficient and effective solution. Transmissions on the broadcast band have the advantage for churches(and others) that no additional or specialized equipment is needed at the listener end. Although we are generally supportive of the idea of opening more spectrum to non-commercial purposes we are unsure whether introducing a new class of operations that seem incompatible, technically and practically, with other systems is the most useful approach.
Our most significant concern with this proposal, however, arises from the use of the term ‘community’ to describe the proposed services, given the disdain that ComReg has demonstrated for existing community broadcasting elsewhere. As described above,ComReg has ignored community radio in its calculation of the value of broadcasting – both in excluding it from its enumeration of the classes of broadcasters contributing to GDP and in not considering any rubrics that would measure, or even recognize, the social value of broadcasting. Further, in 04/93 ComReg, in answer to a DCMNR consultation paper, rejected all suggestions as to how community radio might be accommodated in a future DAB system, suggesting that it should remain on FM, proposed that DAB should be designed to cater primarily for large-scale radio operations, and pushed for DAB to be a purely commercial operation free of regulation such as must-carry rules. ComReg’s response to our queries on this issue, in which we questioned the basis and development of ComReg’s position on community radio as enunciated in 04/93, suggest that ComReg has not engaged with or properly considered the implications for community broadcasting in constructing its position on this matter.

Given our concerns I was particularly interested in seeing how ComReg responded to this part of the consultation process. First, it was interesting to see that there were a total of 35 submissions to this consultation process. As a discussion on boards.ie noted several of the submissions were linked to churches. Indeed I counted 5 church/christian groups, including Focus on the Family Ireland and the coyly titled Centre for Justice and Liberty (a British group that campaigns specifically on the rights of christian broadcasters). At least 11 submissions were by commercial entities (I say at least because I wasn’t able to identify “Three” which is a rather enigmatic title – could well be a reference to the Trinity). Three more were by non-telecom centred state agencies – Met Éireann, ForFás and the Competition Authority – and 14 by individuals. And of course one by Scagaire. Looking through the individuals and throwing some (not all) of the names into Google I was able to identify at least one person who has submitted on media issues to DCMNR previously from a Christian perspective. My guess is that at least some of the other individuals were pushing for religious services.
It’s not surprising, perhaps, that ComReg notes that more than half of all respondents commented on this. What is interesting is their claim that all respondents welcomed the proposal. Scagaire’s response didn’t go so far as to welcome it – we said it would find a user base but as noted above questioned the context. This got left out of ComReg’s summary of responses:

There was considerable interest and comment by more than half the respondents to the consultation on the topic of wireless public address systems. All respondents broadly were supportive of the proposal (Question 26). The respondents also commented that the demand in particular for religious broadcasting services necessitated a national solution. This included calls for a fully fledged national radio service comprising a national network of local radio stations and the provision of additional spectrum for non-commercial use. The spectrum to be used for Wireless Public Address Systems was generally acceptable as long as the equipment used ensured that the service would be nonexclusive and work on a non-interference basis. The proposed fee for this service was found to be acceptable by all respondents who commented on this question, as long as the fee was only used to cover administration costs.

However, in the following (short) ComReg commentary on the submissions they do appear to have been addressing our concerns, since nothing they mentioned in the above section would prompt the to point out:

Following consultation with the Broadcasting Commission of Ireland (BCI), ComReg has established that the proposed service is not a broadcasting service and does not therefore come under the BCI regulatory regime. This is reflected in four key characteristics which define wireless public address systems and place it outside the broadcasting space.

So I think we’ve has some success in laying down a marker here.
On another note, ComReg notes, in listing sundry items raised in submissions, that:

Twelve respondents to the consultation brought up the issue of reassigning two medium wave frequencies, originally allocated to the Russian Federation, to Ireland for the establishment of Christian broadcast services.

What was that I said about some of the individual submissions pushing the christian broadcasting approach, in addition to the five identifiable groups? And the ComReg response? Well, read for yourself:

ComReg is aware of this issue and had been working thorough the ITU with a view to coordinating these two frequencies (549 kHz and 846 kHz) for use in Ireland. This work is being carried out in accordance with the treaty covering the use of this spectrum.
The current status after more than two years of effort is as follows:

• Co-ordination for use of the frequency of 846 kHz in Ireland is complete. Due to the nature of radiowave propagation at these frequencies, this frequency is not usable above 300 watts in Ireland in order to avoid harmful interference to the service area of a cochannel transmitter located in Rome. It is doubtful if use of this frequency, at such a low power, is of any practical use in Ireland.
• Co-ordination for use of the frequency of 549 kHz in Ireland is reaching a conclusion. Current indications are that the frequency may be usable below 40 000 watts in order to avoid harmful interference to the service area of a co-channel transmitter located in Spain.

Once co-ordination and reassignment is completed these two frequencies will be made available for licensing by the Broadcasting Commission of Ireland (BCI). The BCI has the legislative responsibility for licensing Irish independent broadcasting services which includes national television, national radio, local, community, community of interest and institutional radio services; as well as services on digital cable, MMDS and satellite systems.

Wow – you’ve got to hand it to the Christians, they know how to use a system. Who knew this was an issue? Notice, too, the careful wording of ComReg – they don’t license broadcasters. They merely make spectrum available to those licensed by the BCI. I wonder, though, the extent to which ‘this issue’ is being driven by Christian media groups. Are ComReg merely trying to get the frequencies for general allocation by BCI, or is there an implicit/explicit understanding that this will probably be allocated to Christian services.
So, there you go – not two developments as promised, but three.