The Association wishes to point towards the multitude of new services that will be delivered via digital broadcasting platforms. These will include traditional public, private and community services as well as new niche broadcast services, data services, interactive services as well as integrated multimedia services.The digital platforms will also allow for dynamic  re-configuration of services. This will mean that the capacity used for a public service during one period of the day could be used for data or any other service at a different time of the broadcast day.
It may be inappropriate to rigidly apply the current categories in future. A more flexible approach that can accommodate optimal frequency use, regardless of the specific definition of the service type or nature may even provide  advantages in the analogue broadcast world today.

SADIBA herewith wishes to encourage the regulator to take decisive steps towards the fast tracked introduction of digital broadcasting in South Africa as this offers the best avenue to promote increased diversity of services  and will alleviate the pressure associated with the demand for frequencies.

The introduction of digital broadcasting will instantly create more capacity to carry services within the available radio frequency spectrum. Digital broadcasting technologies (DVB-T and DAB (Eureka 147)) are significantly more spectrum efficient than analogue broadcasting technologies. The introduction of digital terrestrial television (DVB-T) will allow for a 20-fold increase in the number of television services that may be accommodated. Five or more radio services can be accommodated in the spectrum currently required for a single FM radio service. Depending on the networks size and the multiplex configuration, digital single frequency networks can make up to 200 times more efficient use of the broadcast spectrum than analogue networks can.
 
The fast tracked introduction of digital broadcast services coupled with an innovative marketing strategy for receiving equipment will ensure increased diversity of services and cheaper as well as easier access to broadcast capacity as opposed to access to a frequency.

 

The introduction of digital broadcasting will allow for the introduction of new services within the geographical areas in which it is currently not  possible to allocate further analogue broadcasting frequencies. While new frequency allocations in Band III  and in the L-Band would be required for the introduction of Digital Radio (DAB Eureka 147), the digital terrestrial television services may with careful  planning be accommodated within the existing UHF band.

(See the comments of the frequency allocations proposed by ICASA in section 6)

In the interest of protecting national and regional identify, character and culture, it is critical that the regulator fast track the introduction of terrestrial digital broadcasting.
Terrestrial radio broadcasters are currently awaiting the licensing opportunities that will empower them to provide a local national and regional voice that  may compete with the foreign influences delivered via a Satellite Radio system already in the market.
While it may not be possible to regulate or influence the content on an international satellite radio platform, the regulator can protect the national and regional identity, character and culture by enabling the local industry to compete on a terrestrial digital platform. A fast track digital terrestrial radio licensing process as well as licensing incentives will be required in order to protect the national and regional identity character and culture.

Digital Terrestrial Television (DVB-T) will allow for an increased number of services that will enable the inclusion of new national services as well  as local and regional services.The commercial feasibility and networks structure for networks carrying local and regional services need however to be carefully analysed.

      

New stakeholders wishing to enter the South African radio market find the current regulatory structures restrictive and unable todeal with their  requirements.For example: The new service that is to be provided may not be accommodated within the current  licensing categories E.g. a national  community station for a religious community. Other examples relate to the limited number of private licenses available as well as the natural limitations  brought about buy a congested spectrum in the key market areas and therefore the inability to license new services.New stakeholders therefore find the satellite radio option quite attractive. It allows the establishment of new services without elaborate time-consuming processes of applications and hearings. In addition the coverage desired is achieved without any restrictions or obligations. New entrants are free to  continue the business of broadcasting. Local broadcasters are currently expanding their services on to satellite radio and new broadcasters targeting specifically the South Africa radio audience are entering the market. The current limited choice of services on FM and AM is leading to the uptake of digital satellite radio receivers.
This could be growing an unfair competition situation where local broadcasters are required to adhere to license conditions and local content quotas whilst having to compete with services from other local as well as international broadcasters that operate into the same market  without any licensing restrictions or obligations. As the number of satellite radio listeners grows, the potential for uncertainty, instability and disillusionment  with the local regulatory system increases. While it may not be possible to influence the satellite services through local regulation, the regulator can ensure stability and fairness by empowering the local industry to compete with the satellite services by licensing digital terrestrial radio services (existing and new) and providing incentives that will ensure investments in such networks.A favourable digital terrestrial licensing regime may furthermore encourage growth and investments in the local industry thus enabling new entrants and ensuring the stimulation of the local economy and  not payments for satellite capacity in foreign currency.

 

SADIBA acknowledges the contribution made to date by the regulator in facilitating and licensing the pilot transmissions for both DAB (Eureka 147) and DTT (DVB-T). It is expected that the Digital Broadcasting Advisory Body (DBAB) will  make formal recommendations on all relevant digital broadcasting issues including the systems and standards. SADIBA supports
this process and is eager to contribute where appropriate. In light of the ongoing DBAB work, it may be inappropriate to include in this submission detailed system performance comparisons and recommendations. The following will thus not be elaborate. Further information as well as international test results may be provided upon request.

 

SADIBA supports the comments made in the draft frequency plan on the Eureka 147 system. Digital Radio according to Eureka 147 delivers the multimedia radio of the future.The technology is mature and is being introduced across the world. The system is based on an open standard and will ensure  fair and free competition in its introduction. The recent developments in the international consumer market have led to the increase in receiver sales and lower receiver prices.In order to benefit from economies of scale and thus lower receiver costs and service levels of international quality, South Africa will have to embrace that digital radio standard that is most widely introduced and that delivers the broadband audio and data services that will be demand in future. Digital Radio according to Eureka 147 is the only system that is widely introduced and that delivers the radio of the future.In addition to choosing the most widely used system, South Africa would also by allocating frequencies in accordance with the international planning and allocation processes, ensure that standard receivers will operate in the country. Large area Digital Radio (DAB Eureka 147) Single Frequency Networks (SFN) have been deployed in VHF (Band III)Local and regional multiplexes are also accommodated in Band III (UK example)L-Band allocations have been made for smaller coverage areas around cities Only where Band III frequencies are unavailable are network providers pursuing L-Band for larger area coverage. (Canada and  France)In France the 5 additional L-Band blocks  previously allocated for satellite DAB have been re-allocated for terrestrial DAB (DAB Eureka 147).It is expected that this will be expanded throughout  Europe in future frequency planning meetings. Receivers and antennas are capable of receiving transmissions in both the L-Band and Band III L-Band is widely used for niche service networks that are designed with a limited and specific coverage area such as the live  video and data service for public transport systems in SADIBA supports the proposal to deploy Digital Radio (Eureka 147) in Band III as well as in the L-Band. Band III networks will ensure that services may be provided at the lowest possible cost.L-Band networks may be 4 to 5 times more expensive to deploy for the same coverage area.The L-Band allocations provide an attractive low cost solution for niche broadcasts, community radio services as well as data service broadcasts in smaller geographical areas as well as densely populated areas.

Channel Number	Number of Potential DAB Blocks (Wiesbaden Plan) (BPN 003)	Number of transmitters in operation (Sentech data base)	Number of High-power transmitters in operation (Sentech Data Base
CH 5	5	10	6
CH 11	5	11	2
CH 7	5	12	6
CH 4	5	14	6
CH 9	5	15	3
CH 8	4	10	5
CH 10	4	12	3
CH 6	4	14	2
CH 12	1	0	0
CH 13	0	11	5

Table 1:                      DAB Blocks in South African VHF Channels

The table above summarises the collation between the internationally allocated DAB blocks (Wiesbaden Plan) and the South African Band III television channel  allocations referring also to the services in operation.Vacating channel 11 as proposed by the regulator would result in the smallest impact on the existing services whilst rendering the same yield in new DAB blocks. The regulator’s proposal in this regard in supported. Although vacating channel 5 would also yield  5 potential DAB blocks and there are only 10 operational transmitters on this frequency, there are significantly less high power transmitters in operation in Channel 11. Channel 12 is not used for television in South Africa. Vacating the band  above 240MHz would not yield any further DAB blocks as the international frequency allocations for DAB in Band III do not extend above 240 MHz.The current block 13F used in the Sentech Pilot transmissions, is the highest Band III DAB frequency allocated. Sufficient UHF allocations are available and the services on channel 11 could be migrated to the UHF frequencies. In many of the metrople areas where the CH 11 migration to UHF would be required, the general public would already be equipped with UHF antennas (used for e.tv.Viewers would only have to re-tune their receiving equipment.The cost to migrate would thus not be significant to the viewing public. It is recommended that L-Band allocations be made available for broadcast as soon as possible.The L-Band had been earmarked for Digital Radio broadcasting in Project SABRE.As was pointed out above international demand for more spectrum for Digital Radio broadcasting (Eureka 147) has lead to the re-allocation of the L-Band capacity reserved for satellite to terrestrial.  In South Africa the WorldSpace satellite transmissions may require formal recognition in order to ensure that terrestrial transmissions in adjacent  channels do not interfere with the satellite signal.International allocations for Digital Radio (DAB Eureka 147) do not include the FM or AM frequency bands. It is therefor unlikely that these will be used for Digital Radio (DAB Eureka 147) in South Africa.

The Digital Radio Mondiale (or DRM) consortium will offer a system for Digital AM in the frequencies 30 kHz to 30 MHz. One of the design criterion of the DRM system is that it will allow for the introduction of digital transmissions within the band with the digital signals not affecting the existing analogue broadcasts more than any analogue  signal on the same frequency would. DRM transmissions could thus be accommodated within the existing frequency plan. Regular DRM transmissions are expected in Europe from 2003.In future, once the technology is well established and analogue transmissions are migrated from the band, the 9 kHz allocation for DRM could be increased to 18 kHz in order to allow higher quality audio.

The European DVB-T standard has been widely tested and has been implemented in countries outside of Europe.The  ATSC system has met with significant criticism and opposition and has been referred to as significantly flawed.The  ISDB system is slow in getting off the ground. Although it may offer more  flexibility, it will be more expensive to implement as chipsets would be produced at lower volumes than would be the case with DVB-T chipsets. SADIBA would like to recommend the following on frequency allocations for Digital Terrestrial Television (DTT) within the UHF television band: Provision is to be made in the UHF Band for the analogue television service to be migrated from Channel 11 VHF DTT allocations should consider the number of services to be accommodated on the platform All existing as well as new services are to be accommodated on DTT Digital allocations should as far as possible be made within the existing analogue allocations ensuring minimal disruption to operational services. Where possible the new digital allocations  should fall within the channel groups allocated in order to allow use of existing  transmit and receive antenna systems.

SADIBA wishes to thank ICASA for the opportunity to make this written representation. Should there be an opportunity to make oral representation, SADIBA would welcome an opportunity to address the Authority.