21 submissions received for ACMA's Future of Radio consultation: Analysis | radioinfo

21 submissions received for ACMA's Future of Radio consultation: Analysis

Saturday 05 October, 2019

Earlier this year the ACMA released an issues paper  and opened consultation on the future delivery of radio services in Australia.

 
The ACMA received 21 submissions and/or comments to the consultation (three in-confidence). The public submissions have been made available on the ACMA website and are now under consideration by the regulator.
 
radioinfo reviews some of the key submissions.
 
Links to each of the public submissions are at the end of this article.
 
The ABC and SBS both made direct submissions, and other sectors made submissions through their representative bodies: CRA (Commercial Radio), the CBAA (Community Radio), ANRA (Narrowcasters) and First Nations Media (Indigenous).
 
Transmission provider Broadcast Australia, which operates the digital radio multiplexes and provides transmission services for the national broadcasters, also made a submission, as did the Digital Radio Mondiale project office and car maker Ford Australia.
 
Individual operators, including Chinese and Arabic language narrowcasters, a music narrowcaster and the Super Radio Network, made submissions, as did a range of interested individuals. Radioinfo also made a submission, highlighting coverage of transmission and policy issues over the past 20 years of our radio industry trade publication.
 
 

The Ford Motor Company supports DAB+ and wants migration off the AM dial to happen as a priority. The company says “vehicles are an important place for listeners to access the current and future range of radio services in Australia.”

Australia’s geography and sparsely populated rural regions pose a challenge for all listeners accessing these services in vehicles.
 
Based on the diverse range of listener use cases, Ford Australia envisages a combination of the scenarios outlined in the ACMA consultation document. Within large cities and regional centres, DAB+ digital radio could continue to offer an effective migration path from the current AM and FM services. Migrating AM services would be viewed as a priority.
 
Starting in 2013, Ford Australia introduced DAB+ on selected vehicles, and this feature is now included on all new Ford Australia vehicles. As vehicles becomes increasingly connected to the mobile network, listeners will have the choice to embrace the internet services as coverage permits.
 
Ford Australia welcomes the ACMA exploring alternative solutions, but would see more listener benefit by migrating to DAB+ digital radio services. While FM broadcast offers some advantages to AM, it also continues to present challenges with mobile reception in a vehicle.
 
Ford Australia believes AM broadcast remains the viable option for sparsely populated rural/regional areas in Australia. Ford Australia notes the lack of broad international interest in DRM.

 
The ABC “foresees significant challenges for radio broadcasting, particularly in respect of analog medium-wave (AM) radio” and benefits in digitising transmission, but also sounds alarm bells about wide area digital transmission in regional Australia.
 
“AM is in decline… a replacement technology will be required,” says the submission.

The Corporation sees a range of benefits for audiences and broadcasters in the digitisation of audio delivery, including greater choice and quality, improved efficiency and reduced energy consumption.
 
The radio policy settings adopted in Australia to date have created a plausible trajectory for the digitisation of audio services in metropolitan areas, based on a combination of DAB+ radio broadcasting and IP streaming.
 
By comparison, there is no similar trajectory in regional Australia, as neither of these technologies can provide the wide-area coverage required to serve regional and remote audiences… None of the three scenarios outlined in the issues paper adequately address the wide-area coverage needs of Australia.
 
Currently some 33% of the ABC’s Local Radio transmitters broadcast in AM, including eleven high- powered (50kW) transmitters serving the mainland state capital cities and providing wide-area coverage of central Victoria, central NSW and southern Queensland, northern Queensland and southern Western Australia. AM is used for Local Radio services in all capital cities other than Darwin, and in Newcastle and 71 other regional locations. In addition, roughly 10% of RN and ABC News radio transmitters use AM.
 
Where television is steadily migrating to IP delivery around the world, the trend in relation to radio is less clear…
 
Much as the challenges of delivering services to regional and remote areas are unique to Australia, so are the likely solutions. In the US, which has a similar land area to Australia, but a much larger and more evenly-spread population, satellite radio has proven an effective and economically viable supplement to analog radio transmissions. Europe, whence Australian customarily seeks broadcasting technology solutions, comprises a large number of countries separated by short distances and with relatively high population densities. Its radiofrequency planners actively constrain coverage to minimise cross-border interference and confine services to local markets. Europe, therefore, does not have wide-area problems of the kind experienced in Australia.

 
SBS proposes consideration of DRM and Satellite as a viable possibility for regional Australia and agrees with most other submissions that delivery of radio services over the internet is not viable. If DRM is adopted, SBS flags that it will need more money from government to implement it.
 

Currently, SBS relies heavily on AM radio. By virtue of the spectrum it uses, AM has the best reach across Australia given the geographical scale of the country and the dispersed Australian population. However, the audio quality of AM radio is sub-optimal, and it is susceptible to more interference than other technologies.
A successor technology will need to have similar reach and provide better audio quality. High speed internet access does not currently have sufficient reach across Australia to make online-only audio delivery practicable on a national basis, nor is this likely in the short-medium term.
While there is no obvious successor technology available to be immediately deployed, SBS recommends further consideration be given to a number of options to replace AM, with a focus on:
 

  • Digital Radio Mondiale (DRM); and
  • emerging satellite technologies.

 
Until a few years ago, there had been no wide-area or large-population adoption of DRM internationally to drive mass produced, low price-point DRM receivers for domestic listening. This has changed since the adoption of DRM30 by All India Radio for nationwide broadcasting in the MF Band and the increasing integration of software defined receivers (SDR) by the automotive industry in India and Europe.

SBS therefore recommends that the ACMA further consider DRM as a successor to analogue radio broadcasting in Australia in the medium- to long-term…
SBS acknowledges that the introduction of DRM technology would have cost implications for reception equipment and network upgrades. Government funding would be required.
In our broad continent, satellite delivery is likely to be cost-prohibitive in the current environment for mass audience consumption, but is worthy of review if emerging satellite technologies reduce cost. In particular, SBS recommends the ACMA monitor opportunities using Low Earth Orbiting satellites.

SBS quotes a radioinfo report showing that the majority of listeners still tune in to terrestrial radio.
 

ANRA, the Australian Narrowcast Radio Association, is the peak industry body representing Low Power Open Narrowcast (LPON) Radio Services and High Power Open Narrowcast (HPON) Radio Services. ANRA’s position on the evolution of radio is to let the market decide.
 

The association’s membership includes the major Narrowcast radio program providers such as the TAB agencies and organisations, foreign language groups, fringe music services, tourist services and religious services, as well as many other independently owned and operated services. Narrowcast Radio in Australia now has 2,370 LPON and 240 HPON licences.
 
In general, ANRA feels that the market will decide which platform/s they prefer in the car, at work, at home, or away. In most cases we believe it will be a combination of platforms. Additionally, for the safety and security of Australia and its citizens, we should not be reliant on one delivery method to communicate important messages and information.

 
One narrowcaster, World Media, which operates off band Chinese languages services, made its own submission, asking for more power and access to new frequencies.

World Media, who transmits it’s AM service in Sydney on 1620kHz, would like the ACMA to consider its service in any review of the future of radio services in Australia. In particular we ask the ACMA to consider:

  1. a power increase from 400W to 1000W for the NAS services in the MF Band. This is needed to help overcome the increasing man-made noise which degrades the AM signal.
  2. a technology migration path for the AM services currently operating in the 1606.5kHz to 1705kHz to either the FM band and/or to DAB+, making additional spectrum available for 2) above by extending the FM band and utilising the spare VHF spectrum in Band 3 currently reserved for the 6th TV channel for DAB+

 
Another narrowcaster, Noise FM, wants the FM band extended.

Noise FM has operated a number of narrowcast radio services since 1993, providing a range of niche music services to audiences across Australia via multiple radio platforms.
 
Our organization fully supports extending the FM Band (as long as spectrum is made available for Low Power Open Narrowcasting LPON services). The benefits of an expanded FM band could include more services available, ability for AM services to transition to the expanded FM band, ability for more narrowcasting services using the expanded band.
 
Expanding the FM band would be much more cost effective than implementing a new broadcasting standard (such as DAB+) with only minor modifications required to standard FM transmitters, antennas and receivers to allow them to operate across the extended FM band. Furthermore the spectrum that the extended and standard FM band (70 Mhz to 108 Mhz) occupies is very well suited for a range of Australian terrain for both short and long range coverage – current DAB+ technologies just cannot compete with the reliability and flexibility of FM. FM radio band is a wonderful solution for accessing radio services.

 
 
Commercial Radio Australia’s submission reinforces the importance of allocating spectrum for DAB+, discusses the opportunities and threats of online services and takes aim at community stations and Temporary Community Broadcasting Licences (TCBLs) for overstepping their boundaries.

The commercial radio industry currently communicates with listeners using a range of platforms – terrestrial analog (AM/FM), DAB+ and online… The industry urges the ACMA to maintain this availability of platform choice for consumers in its future planning for radio, supported by regulation designed to safeguard the longevity of Australian radio…
 
The future for commercial radio lies not in choosing a single platform and sticking to it while other technologies advance apace. Rather, commercial radio seeks to find ways of continuing to extend its reach by strengthening its existing communication platforms and linking such platforms with those of the future… radio has survived for a century by constantly adapting and using each technological leap, to continually find new ways to deliver its core promise – live, local, reliable and free content…
 
CRA encourages the ACMA to continue to support conversion of AM to FM in regional radio markets.
 
The industry supports the continued roll out of DAB+ infrastructure, including into regional markets. Spectrum should be retained and, where feasible, increased to enable the broader roll out of DAB+ in regional areas… The Issues Paper notes the existence of an alternative digital technology, DRM. This is not a viable technological option in Australia...

CRA urges the ACMA to strongly support the commercial radio industry’s requests for simplification of the DAB+ roll-out process under the Radiocommunications Act 1992, to facilitate the adoption of DAB+ technology by regional markets.

The opportunities offered by online platforms and technologies are accompanied by certain threats, primarily because of the dominance of huge, US based technology companies, such as Google, Amazon, Facebook and Apple. It is vital that these platforms, which occupy dominant market positions, allow non-discriminatory access for Australian commercial radio content.

CRA wants the regulator to “take steps to preserve the distinction between commercial and community radio broadcasters.”

Currently, some community broadcasters provide programs of general appeal without sanction. This should be stopped, as it has the potential to threaten diversity, listener choice and the value of commercial radio licences.

CRA requests that the ACMA also considers halting the proliferation of community and narrowcast licences which take up spectrum for relatively small audiences, especially when providing content already supplied by commercial and national broadcasters. Commercial radio broadcasters would like the ACMA to review its grant and renewal of Temporary Community Broadcasting Licences to ensure that long term planning and consultation processes are not circumvented by established community broadcasters…
 
CRA’s view is that the BSA should be interpreted to restrict the content broadcast by community stations so that such stations serve an audience not already served by existing commercial or national stations.

  CRA also criticises narrowcast services which it says are “increasingly being used to offer commercial format services.”

CRA requests that the ACMA also considers halting the proliferation of narrowcast licences which take up spectrum for relatively small audiences, especially when providing content already supplied by commercial and national broadcasters.

 
Bill Caralis’ Super Radio Network has 38 commercial licences and many transmitters and translators. SRN supports CRA’s submission and gives further clarification and expansion from its point of view.

SuperRadioNetwork reinforces the CRA position to free up spectrum in regional areas to allow full conversion to FM, especially by allowing some frequenceis reserved for SBS and ABC to be  used for commercial station conversion. Also use single frequency networks for ABC national networks using  new technology called Synchronous FM.
 
The submission also says that planning for conversion is “time consuming and expensive,” and expresses concern about some community radio services, especially TCBLs, which “seem to be  issued without consideration of the impact on other services in the area.”

 
 
The Community Broadcasting Association (CBAA) submission reinforces research that underlines “the continued strength of live free-to-air radio broadcasting.”

Recently published industry figures follow an enduring and consistent pattern, showing that listening to live radio accounts for the overwhelming majority (over 62%) of all listening to audio in any from… free-to-air radio is an enduring, significant public good…
 
In the mainland capital cities, where it is available, listening to community radio via DAB+ digital radio accounts for 30.5% of all listening to community radio, in line with the broader industry pattern… The impact of change, particularly over the last decade or so, on the access and distribution of media content has shifted social and cultural ‘connection points’…

 
The CBAA’s submission emphasises the importance of localism and discusses income for the sector.

Community radio stations provide tangible community support and engender social cohesion in ways that online audio services and social media do not. While fundamentally local in focus, stations have embraced emerging technologies to share content to supplement their terrestrial delivery capacities and improve community service outcomes.
 
Community broadcasting raises 75% of total station revenues from fundraising, sponsorship, membership/subscription fees, training, airtime fees and production services. The remaining 25% of revenue derives from grants from federal, state and local government sources as well as from philanthropic and educational institutions. Sale of on-air sponsorship provides about 40% of total sector income and donor fundraising/gifts accounts for a little over 21%.
 
A viable and sustainable community broadcasting sector is essential to the realisation of four of the key objects of the Broadcasting Services Act.

 
The CBAA supports DAB+, given the positive progress of DAB+ digital radio implementation to date, but doesn’t rule out the use of DRM.

The CBAA supports the use of DAB+ digital radio as the mainstay technology to deliver free-to-air digital radio services, supported and augmented by other technologies working in a complementary and hybrid manner.
 
The CBAA does not rule out use of alternative digital technologies such as Digital Radio Mondiale (DRM) operating on MF spectrum that would otherwise be used for AM services. DRM technology potentially offers better service outcomes than analogue AM services in terms of audio quality, area coverage and spectrum efficiency…
 
There is little to no merit in further exploring extending the VHF-FM band… there is little merit in exploring a wholesale re-stack of channel planning and assignments with the existing VHF-FM band…
 
Mobile broadband is not suited to radio station audience sizes. It is suited to on-demand and boutique scale live delivery.

 
The CBAA has other long-standing concerns in relation to the detail of DAB+ digital radio legislation, which it says are matters for consideration with the Department of Communications and the Arts. It raises them in the submission.

Current spectrum allocations for analogue VHF-FM and MF-AM remain necessary over a five to ten year window. Yet these analogue technologies are heading towards legacy status.
 
There is merit in the ACMA, with industry, exploring the factors leading to sunset of (some) MF-AM services in metropolitan areas. This would logically be in favour of digital transmission, with VHF-DAB+ being the mainstay, augmented in a complementary fashion, in hybrid mode, using online/mobile.
 
Given the positive progress of VHF-DAB+ digital radio implementation to date, the wider circumstances and recognising the need for investment stability, common receiver availability and timeframes, the CBAA supports the use of VHF-DAB+ digital radio as the mainstay technology to deliver free-to-air digital radio services, supported and augmented by other technologies working in a complementary and hybrid manner.

 
Another ongoing issue for the CBAA is that small sub-metro community station cannot currently be accommodated on the city wide multiplexes. The CBAA explores new ways to deliver these services in DAB+.

There is merit in exploring ways to deliver extra service outcomes to VHF-DAB+ digital radio. Now that there is a clear national channel plan for DAB+ digital radio based on commercial Licence Areas, there is scope to explore, on a case-by-case basis, where that may be augmented with an overlay for small-scale DAB+ services. The CBAA supports the ACMA facilitating exploration and trial of small-scale DAB+ free-to-air digital radio services. There is a significant availability of VHF-DAB+ receivers that will facilitate positive outcomes for listeners

 
 
Some individual community sector stations and aspirants also made submissions.
 
Living Arts Canberra, operated by Barbie Robinson and Richard Scherer, “is a home-based, not-for-profit arts media organisation which gives exposure to visual and performing artists, and authors from the Canberra region and beyond. It includes a website, a continuous internet audio stream, and podcasts of interviews. The organisation “believes strongly that the internet is playing an increasingly important role in the delivery of radio and other audio services.”
 
Golden Days Radio, a community station for senior citizens, encourages the ACMA to begin small-scale DAB testing in order to give stations such as 3GDR an equal playing field in a radio setting such as Melbourne where digital radio listening is widespread.

We note that the ACMA released findings in 2016 from both ABS and Roy Morgan figures show that although the number of people 65+ who have access to the internet is rapidly rising the frequency of use diminishes with age. As 3GDR is licensed to serve older Australians 3GDR would be at a distinct disadvantage broadcasting solely online.

 
 
First Nations Media Australia is the peak body for Indigenous media and communications. It’s submissioin gives background on the number of indigenous services operating and discusses the “drivers for change” in the radio broadcasting industry.

Radio remains a key communication tool for First Nations communities. Although significant technological advancements have been made to supplement the radio medium, none have surpassed it for accessibility, immediacy, affordability, and geographic reach. Continued access to radio is an essential service to communities across the country… Radio, particularly independently produced radio, contributes significantly to a functioning Australian democracy.

 
 
The First Nations radio sector has 35 licensed radio stations servicing 230 communities, including 5 metropolitan services, 18 regional stations and 8 Remote Indigenous Media Organisations (RIMOs) serving as hubs for Remote Indigenous Broadcasting Services (RIBS).  Collectively, First Nations radio services reaches around 320,000 First Nations people, including around 100,000 very hard to reach people in remote Indigenous communities.

There are a number of drivers of change impacting the delivery of First Nations radio services across Australia in different ways. Changes in audience behavior is one motivating factor for stations to respond to the proliferation of delivery platforms available to them…
 
Audiences can now access a broad range of screen content on-demand, which has significantly shifted the television landscape in Australia and with it, audience expectations of engagement with radio content. While a significant amount of radio listening still takes place in the car, audiences are increasingly utilizing on-demand web services to access their favourite programs online, to listen back to previous programs and to hear podcast series. In areas with strong, reliable internet service radio audiences are following contemporary audience trends in accessing information via both terrestrial broadcasting and online delivery platforms.
 
New avenues for listening to First Nations radio and other community radio services has not reduced the amount of time spent listening to terrestrial services, rather it has added listening time through maintaining connection with audiences across a range of delivery mechanisms… Particularly in remote communities, AM and FM broadcast services are a primary means of receiving information, especially where internet and mobile phone coverage is unavailable or unreliable…

 
Since the ABC shut down its inland short wave transmitters, First Nations Media says it it is more important than ever for emergency service information. It also says the the impact of DAB+ services on audience growth for First Nations radio services is “as yet unknown,” but that it will be expensive.

There is heightened reliance on First Nations radio stations to provide emergency and local news services due to the withdrawal of commercial and ABC services from regional and remote areas. This is due to a number of factors- the shutdown of ABC shortwave radio services in the Northern Territory, the decline in maintenance of self-help retransmission sites, the impact of media reform and closure of regional media outlets, and the increased amount of content on regional stations that is rebroadcast from metropolitan cities.
 
Such was the impact of switching off ABC shortwave services across a large cross-section of the Northern Territory community, that the Australia Labor Party committed to providing funding to switch them back on in its election campaign. However, since the federal election, those frequencies have been taken over by a Chinese radio station to broadcast into the Pacific region. The ACMA risks a much bigger backlash in regional areas should AM and/or FM services be switched off…

 
The international DRM Consortium made a submission to the regulator, correcting a few points in the discussion paper and making the case for DRM in Australia, especially in regional areas.
 
The consortium commented on two points made by ACMA: “One is that there is no standard covering both AM and FM. Such a standard exists, is ITU recommended, thrives in the Asia-Pacific region and is called DRM. The other point is about the existence of DRM receivers,” which have  recently been increasing.

There are over 1.5million cars with DRM receivers on the roads of India. The DRM/AM Chinese made receiver Gospell is on sale and has sold well in Australia even if the price is relatively high. Moreover, a DAB+ DRM receiver is a reality and even for cars this is not a big issue any longer.
 
According to the largest chipset manufacturer for cars NXP, carmakers already offer radios with DAB support for Europe and also have radios which are supporting DRM for India. Both are based on the NXP’s SAF360x family (Saturn) - the market leading chip for digital radio in cars. And as a software defined radio solution this can be programmed to multiple standards, including DAB+, DRM, as well as others…
 
The most economical, flexible option for replacing AM is now DRM, as the most technologically advanced and newest global digital radio standard. It is internationally standardized by ITU and ETSI for digitising terrestrial radio broadcasts in all frequency bands (both AM and FM bands). Digital Radio Mondiale, DRM, is the newest, most complete, open standard for digitising radio in all frequency bands (both AM and VHF DRM can serve all the coverage needs of any country, without any gaps..
 
The beauty of going to a digital standard or a combination of DRM for large coverage (“DRM30”), DAB+ for key cities and DRM for local coverage (DRM+) and community stations, for example, is that a lot of the network planning and the infrastructure exist. What is needed is a national plan incorporating all service levels for all types of coverage. A network plan would have then to be devised or revisited and amended. Unlike DAB+, DRM can use the current channelization delivering clear spectrum savings (three digital programmes per current analogue channel).

 
Transmission technologist Alan Hughes also made a submission in support of digital radio, discussing the success of DAB+ and also exploring DRM.

Australia was the first country to commence full time high powered DAB+ broadcasts anywhere in the world. At the time there were no receivers in the hands of the general public and the only possible receivers were of a modified UK design.
 
At the time the USA’s HDradio had also started but had been tested in Australia and found to have poor digital coverage and big interference issues, which are keeping USA lawyers busy. DAB was in use in Europe had got a bad name because there were too many programs on a single transmitter causing most programs to be in poor quality mono. DAB+ has a far greater capacity to carry programs so all of our programs are in good quality stereo and the improved error correction makes reception in marginal areas better than DAB.
 
DAB+ through the use of 2 or 3 transmitters in each capital city are able to carry all existing metro wide AM & FM programs Using Sydney as an example two DAB+ digital transmitters carry 17 existing AM/FM commercial programs along with 8 existing community transmitters. The third transmitter carries the 6 existing ABC & SBS AM and FM programs all with additional unique to digital programs.
 
If the existing AM and FM transmitters were switched off there is a large drop in program distribution costs. To make the considerable savings the following is necessary

  • Install DAB+ repeaters into all black spots as indicated in my main submission
  • Start transmitting the AFS – Automatic Frequency Checking & Switching which is a table containing all the alternative transmitters radiating the same program.

 
For regional areas a newer technology is required to cover larger areas. It is called DRM. DRM+ can use the frequencies vacated by analog TV’s channels 0 - 2 creating 168 DRM+ channels. With so many channels the ABC/SBS can transmit all the programs for metro areas in regional area on a single transmitter per TV site, substituting the local radio for the region. Commercial stations have dual programs can transmit their signal from their current FM site on a single DRM+ transmitter.
 
For remote areas HF or Short Wave is commonly used for communications… DRM will also operate at HF as well with a crystal clear stereo sound just like the city people are used to. As an example, Radio New Zealand received in Spain https://youtu.be/kkD01FuXOsg, a distance of 20,000 km. comparing HF DRM and HF AM. Australia is 4,000 x 3000 km in size. The ABC state program, Grandstand and News radio along with encrypted commercial broadcasting should be available to the 470,000 remote Australians. These signals will also fill in blackspots. After all, Radio New Zealand has been transmitting HF DRM to the Pacific for 14 years…
 
Radio is much more effective & reliable than mobile phone and NBN in the event of an emergency. All new receiver must be able to respond to the Emergency Warning System including displaying the maps and detailed instructions.

 
Broadcast Australia (BA) is the radio transmission services provider to the ABC and SBS. It “believes there is value in looking to digitize the analog radio services over time, whilst keeping them free to air for Australian audiences.” Its submission explors DAB+ and DRM and notes that there are an increasing number of receivers that do not receive AM radio signals. It also comments that “there is no mandated receiver standard in Australia which would require a minimum level of functionality in radio receivers.”

The national broadcaster MF-AM services provide in-home, mobile and portable reception to a vast area of Australia. Whilst VHF-FM and VHF-DAB+ cannot provide similar coverage to the MF-AM radio service, two existing technologies have the ability to provide similar reach – satellite and Digital Radio Mondiale (DRM) in the MF band…
 
Satellite delivered radio is unlikely to be commercially viable in the Australian environment. DRM in the MF band does, however, warrant further detailed investigation and BA would be willing to engage with industry parties on this investigation, including conducting system trials.
 
Whilst the use of small scale DAB+ in VHF Band III and DRM in the VHF-Band II spectrum may provide ways for existing analog services to transition to digital, further work is required to determine the feasibility of these technologies and, in the case of DRM, the availability of receivers capable of working in this spectrum.
 
Wireless broadband services are complementary to rather than a viable replacement for existing free to air, wide area coverage MF-AM radio services. Wireless broadband services cannot replicate the coverage of these radio services, require payment to access the services and rely on more expensive receivers. Any future reliance on these IP delivered services also introduces the risk of multiple intermediaries between broadcasters and their audiences.

 
In analysing the submissions above, we have picked out a range of key points from various submissions and linked them together by topic. There is repetition and agreement on many topics in the submissions, we have not repeated points where there is general agreement, we have instead taken examples from as many submissions as possible so that all the key points are covered.

As usual, if we missed something, or you disagree with our analysis or summary, please feel free to email us at editor@radioinfo.com.au or post your comments below (You need to be logged in to comment. There is no cost to register and login.)

Two issues that require more exploration are DRM for regional Australia and the issue of TCBLs. Look for our follow up reports on these topics in the next few days.
 
The full list of submissions is below, with direct links to each document.
 
ABC - IFC 13 2019 pdf .PDF3694 KB
Alan Hughes - IFC 13 2019 docx .DOCX3053 KB
Alan Hughes 2 - IFC 13 2019 docx .DOCX2542 KB
Brendon Agpasa - IFC 13 2019 pdf .PDF90 KB
Broadcast Australia - IFC 13 2019 pdf .PDF177 KB
CBAA - IFC 13 2019 pdf .PDF4463 KB
CRA - IFC 13 2019 pdf .PDF214 KB
DRM Project Office - IFC 13 2019 pdf .PDF514 KB
First Nations Media - IFC 13 2019 docx .docx631 KB
Ford Australia - IFC 13 2019 pdf .PDF157 KB
GDR - IFC 13 2019 pdf .PDF837 KB
Living Arts Canberra - IFC 13 2019 docx .DOCX18 KB
Noise FM - IFC 13 2019 pdf .PDF610 KB
Radioinfo - IFC 13 2019 pdf .PDF168 KB
SBS - IFC 13 2019 pdf .PDF1315 KB
Super Radio Network - IFC 13 2019 pdf .PDF3857 KB
World Media - IFC 13 2019 docx .DOCX873 KB
ANRA - IFC 13 2019 pdf .pdf391 KB
 

 
 
 

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