I’ve already contacted RTÉ, and include the text of my email below.

A Chara,I wish to express my concern regarding the decision by RTÉ to cease broadcasts on the medium wave band, and hope that the move can be reversed.

Most Irish listeners use the FM band. Those who do not often live in rural areas and are unable to receive an FM signal. The provision of a medium wave signal relates directly, therefore, to RTÉ’s public service remit and the desire that there be a universally accessible broadcast service. The claim that the continued service on long wave will be sufficient does not stand up to scrutiny given the absence of long wave on most modern domestic receivers.

Others have drawn attention to the role of MW in cross-border relations. I won’t repeat their claims here, but would urge you to pay close attention to them.

I would like to draw your attention to one final point. Requiring that those unable to receive FM now purchase receivers with long wave capability places a particular burden on these listeners just a short time before it is expected that all listeners will need to transition to digital receivers (of one type or another). Should the long wave band transition to DRM (as RTÉ has indicated with its tests last year) that would mean that listeners, often the elderly and those on limited incomes, would be required to purchase receivers now, only to have to have those receivers become obsolete within a short number of years. This approach to the changing nature of the broadcast environment seems somewhat short-sighted, and destined to cause disquiet and a lack of confidence among the public in general.

I urge RTÉ to defer its decision on the medium wave transmitters and to open a public consultation on the future of RTÉ’s distribution of content to the public it serves. As a central part of Irish cultural and social life, the Authority owes the public no less.

Is mise, le meas,

Andrew Ó Baoill

LW is not present on most domestic receivers at this stage, so it will be a difficult transition for some people. Thus, in a certain sense, the burden is being moved from RTÉ (who were spending large sums maintaining and operating a MW network) to individual listeners. 

I was subsequently contacted Enda O’Kane, who has been campaigning for some time for the adoption of DRM (Digital Radio Mondiale – not Digital Rights Management!) by RTÉ, particularly on the 252 frequency on the Long Wave band, and who we have covered on several occasions here. He pointed out a number of arguments for opposing the RTÉ move, including the following: 

1. Similar to my argument about transferring the burden/cost of accessibility from RTÉ to individual listeners, Enda points to some of the advantages of MW for the elderly, those with limited vision (since the band is less cluttered it’s easier to tune in a specific station), and those travelling (as you don’t need to move up and down the dial as you move from place to place).
2. Northern Irish audiences: “Cutting service also contradicts the sprit of the Good Friday Agreement. Parts of Northern Ireland, including the Falls and Belfast still rely on medium wave. RTE medium wave, and Radio Ulster from Lisnagarvey, are traditional cross border cultural links enjoyed by all. They serve all ages and social groups.”
3. Emigrant communities: “For the past number of years, RTE has been running its long and medium wave transmitters on close to half their allocated power, thus reducing its service to Northern Ireland, the UK and beyond, contrary to custom and practice, as well as the spirit of the recent Broadcasting (Amendment) Bill 2006, which specifically provided for the broadcast of radio to our emigrant communities.”
4. Cutting Medium Wave before the Long Wave signal is transitioned to digital is premature, will cost listeners unnecessarily, and undercuts the transition to DRM or other digital radio formats. Noting that RTÉ have installed and tested a DRM transmitter on the 252kHz waveband, but not yet transitioned to the digital standard he argues that
   • “In cutting off the medium wave transmission prematurely, RTE have abandoned a principle which served then well over many years: when a new technical standard is being introduced, it’s vital to maintain the existing one during the transition period to allow the public time to switch over…. The principle has not been pursued here. Medium wave should be recognized as an integral tool in the strategy toward digital radio; and
   • “Those who purchase a longwave radio now will find it obsolete when RTE cuts the existing longwave signal and sends out a digital signal in its place. They will end up having to buy a second radio to continue listening on longwave after this change occurs. For that reason,  RTE must continue with the medium wave service to give an alternative to longwave until a longwave digital signal is sent out.”

 These are important arguments, which deserve consideration and attention. Is RTÉ seeking short-term gains (by shutting off power to the MW transmitters) at the expense of future success of any transition to digital on the long-wave band? Groups like Éan are of course concerned about the immediate impact on “emigrants in Britain and beyond, as well as people in the North” – an important issue in itself – but there are secondary questions about RTÉ’s long-term digital strategy and how they intend to integrate it with their public-service commitments.

Already there are hints that after flirting with DRM they are returning to the – surely clearly obsolete – DAB standard. DAB has attractions for networks seeking to maintain central control and lock out newcomers to broadcasting (due to its reliance on centralized multiplexes rather than distributed transmitters), but I’m very concerned if this is the approach RTÉ is taking to the future of its public service mission. RTÉ has often had a troubled history when it comes to welcoming democratic and participatory approaches to broadcasting and media creation, but one would hope that they would by now be seeing the potential of such approaches. Being central to facilitating active public engagement – over the airwaves and elsewhere – may be the best hope public service broadcasters in Europe have of not being slowly made irrelevant.

Now, to be fair, RTÉ will continue to offer service on Long Wave – most people will have missed the fact that RTÉ took over the 252 frequency a number of years ago, and is broadcasting the Radio One service on it – which will cover some of the areas being missed on FM. However, LW is not present on most domestic receivers at this stage, so it will be a difficult transition for some people. Thus, in a certain sense, the burden is being moved from RTÉ (who were spending large sums maintaining and operating a MW network) to individual listeners. As a public service operator, RTÉ have, in general, a responsibility to provide universal service, but whether that responsibility can be accurately given a financial value in calculating public service audits/reports, and where the burden becomes an unreasonable drain, depriving other possible public service activities, is a tricky question.

I wonder if this move will mean, however, that RTÉ will concentrate more investment on LW – which could be good news for Enda O’Kane’s campaign to have them introduce Digital Radio Mondiale (DRM) on that band.

(Link thanks to fluffy.)