Broadcasting Carriage Policy Section

14 October 2018

The Manager

Broadcasting Carriage Policy Section

Spectrum Management Policy Branch

Australian Communications and Media Authority

PO Box 78

Belconnen ACT 2616

IFC 38/2016

Re: Proposed variation to the Radiocommunications (Digital Radio Channels Queensland) Plan 2007 – Brisbane

Dear Sir

Comments in this submission relate to the proposal to vary the technical specifications for the three Brisbane digital radio multiplex transmitter (DRMT) licences to vary the output radiation pattern to allow greater ERP levels and improve coverage within the Brisbane RA1 licence area.

Introduction

Sunshine Coast Media holds two of the three commercial radio licences in the NambourRA1licence area which overlaps and adjoins the Brisbane commercial radio licence area.

The overspill of signal from metropolitan areas into regional markets has been a longstanding issue in the analogue environment and any proposal that accentuates that situation, for example in a DAB+ scenario, cannot be accepted.

Background

Sunshine Coast Media holds, as mentioned, two commercial radio licences in the NambourRA1licence area (Sea 91.9 and 92.7 MIX FM) and is, like other neighbouring Brisbane commercial radio licensees directly affected by any change to the current configuration of the antenna patterns for the Brisbane DAB+ services – perhaps more so.

There are both licence area overlap and signal overspill issues between the NambourRA1licence area and the Brisbane RA1Licence Area. For the record, according to the Section 30 Schedule there are 153,318 people in the overlap area – this equates to 33% of the NambourRA1licence area or 7.68% of the Brisbane RA1licence area.

We accept that a licensee is entitled to service their licence area. However, if the numbers mentioned earlier are a starting point every possible resistance must be brought to bear to resist any further spill of Brisbane services into Nambour.

Apart from there being significant numbers the extent of the overspill and the impact on the NambourRA1 lead the Group to take no other position than reject the proposal to vary the Brisbane DRMT. I will address our reasons throughout the submission.

The position the Group are adopting is not a new one in relation to the DAB+ proposal – it is consistent with the position we have had throughout the pre DCP variation discussion process. Because of the overlap issues mentioned earlier and the overspill issues identified in the proposal document the Group cannot stand by and allow further access to the NambourRA1 market from a major metropolitan market to proceed without objection.

That overspill situation I refer to applies to analogue radio and also with the existing DAB+ services operating from Brisbane under the specifications proposed. I will deal with this matter in more detail under “issues” below.

Whilst there are no DAB+ services planned for the NambourRA1licence area at this point in time due to the status of DAB regional planning – no proposal that provides additional services in a neighbouringlicence area can be supported.

Issues

There are a number of issues that, in my view, are unique to the position of this Group and they need attention.

The two immediate issues are:

Overspill into NambourRA1licence area

From the Engineering Report – Digital Radio Channel Plan (DRCP): Queensland document dated January 2017 a detailed analysis of overspill issues is presented and documented with the following stated in relation to the NambourRA1licence area:

“Television field strengths were measured at 138 locations solely in the NambourRA1licence area. As the current antenna has a large null to the north none of these 138 locations were estimated to have overspill with the current antenna and the current or revised thresholds. With the proposed antenna, two of the three measurement locations in Maleny were categorised as having overspill with the current threshold and a further five locations were categorised as having overspill with the revised thresholds. Maleny is similar to the Mount Tamborine region in that it is relatively high and any location with line of sight to Mt Coot-tha is likely to receive high field strengths irrespective of the transmission ERP.

The further five sites categorised as having overspill with the revised threshold and proposed antenna are in areas where multiple television measurements were made

with most measurement locations remaining below the overspill threshold. Two of the locations were also in areas which don’t have a current DRCP limit.

The proposed antenna will increase the ERP transmitted toward the NambourRA1licence area by between 10.5 dB and 13.7 dB. Even with this large power increase the estimation analysis at 138 measurement locations does not predict any overspill other than at two high locations. This is not particularly unexpected given that the Sunshine Coast region requires multiple additional television repeaters to address the poor television field strengths in the region.”

There seems a general acceptance that overspill into a smaller market is to be accepted.

The above ACMA comments acknowledge a further level of overspill into the NambourRA1 area and seems to expect the neighbouring licensees will accept the changes with no apparent recourse. There are over 30 DAB+ radio services operating in Brisbane offering many different genres of services and more importantly offering products and services to an audience in the NambourRA1 that that licence area cannot compete with.

The ACMA engineering report and maps clearly depict overspill in both the overlap area and beyond i.e. in the NambourRA1 (non-overlap) area. In other words it is clear and stated that the Brisbane DAB+ signals will propagate into NambourRA1 once implemented. An area of major concern to this group is the growth area around the new city of Aura just south of Caloundra. This is a city anticipated to reach the size of Gladstone, but wholly within the Nambour commercial licence area with a population in the vicinity of 50,000 within 20 years.

Under no circumstances should Brisbane licensees be given access to this group before a local Nambour commercial provider as, over time, that group will become vital to the long term future of the commercial stations in this market.

I have argued continually that the closeness of the Brisbane and Sunshine Coast markets presents unique issues in terms of radio listenership – allowing an overspill of the nature proposed only exacerbates an existing imbalance in the analog and digital environment.

Steps must be taken to revisit the overspill issue and reduce power to the areas I have mention in the preceding paragraphs.

Amount of mobile overspill

A second issue is mobile overspill.

Overspill attributable to mobile into the NambourRA1licence area has not seemingly been a major factor from an ACMA planning perspective. It is however significant from an impact on licence area perspective and was a major discussion point in the work undertaken pre-planning. Overspill of the mobile nature has a major impact on the viability and sustainability of the Nambour market, particularly when one considers the fact that there is no competitive signal from the NambourRA1 area.

Mobile overspill is a significant factor because of the increasing number of motor vehicles fitted with DAB+ tuners, coupled with the increased amount of vehicular traffic between areas within the Nambourlicence area and Brisbane and returning on a daily basis.

The tables below shows the impacts and why we are expressing concern and why the mobile impact cannot be ignored in considerations.

Within the NambourRA1 overlap area with Brisbane RA1

Population above threshold within NambourRA1Licence Area / Mobile Current
(63 dBμV/m) / Mobile Proposed
(60 dBμV/m)
Current Pattern / 82,720 / 118,878
Proposed Pattern / 146,001 / 146,982
Increase / 63,281 / 28,104

Table 1: Population based comparison of current and proposed Brisbane DAB antenna pattern signal within the NambourRA1 and Brisbane RA1 overlap area.

Population above threshold within NambourRA1Licence Area (km²) / Mobile Current
(63dBμV/m) / Mobile Proposed
(60dBμV/m) / Suburban Current
(70 dBμV/m) / Suburban Proposed
(64 dBμV/m)
Current Pattern / 270 / 409 / 49 / 230
Proposed Pattern / 714 / 767 / 488 / 690
Increase / 444 / 358 / 439 / 460

Table 2: Area based comparison of current and proposed Brisbane DAB antenna pattern signal within the NambourRA1 and Brisbane RA1 overlap area.

Outside the NambourRA1 overlap area with Brisbane RA1

Population above threshold within NambourRA1Licence Area (km²)
outside the overlap / Mobile Current
(63dBμV/m) / Mobile Proposed
(60dBμV/m) / Suburban Current
(70 dBμV/m) / Suburban Proposed
(64 dBμV/m)
Current Pattern / 1,369 / 6,770 / 0 / 435
Proposed Pattern / 29,455 / 50,625 / 8,618 / 24,014
Increase / 28,086 / 43,855 / 8,618 / 23,579

Table 3: Population based comparison of current and proposed Brisbane DAB antenna pattern signal levels within the NambourRA1 and outside the overlap with Brisbane RA1.

I mentioned earlier there were many radio services operating in Brisbane offering many different genres of services and more importantly offering products and services to an audience in the Nambourlicence area that that licence area cannot compete with. While I have mentioned the signal overspill issues previously when mobile is taken into account the figures as per the above tables speak for themselves. These are planned “overspills” and not what might be termed “unreasonable overspills”. They purposely make the overspill situation worse when steps could have been taken to reduce, or eliminate the problem by addressing signal strength levels in the direction of Nambour. We don’t believe that ACMA can facilitate in making this situation worse by endorsing the proposed technical changes.

Timing of any implementation

The issue of timing or implementation of any proposed Brisbane DAB+ services raises an interesting question. In regional areas that overlap metropolitan areas to the extent of Brisbane/Nambour no change to the Brisbane service (in this case) should be permitted to be implemented until the neighbouring regional area has had the opportunity to implement its own DAB+ service.

I believe to action or implement the Brisbane DRMT change before neighbouring licensees have had an opportunity to establish their own DAB+ services must, in the interests of retaining a metropolitan/regional balance between the markets, be resisted at all costs.

I note that the Gold Coast RA1 have the option to establish a DAB+ service – it seems rather odd that an area which is so hamstrung by overlapping licence areas is not afforded the same opportunity.

Conclusion

In its present configuration the change to the Brisbane DRMT cannot be supported – the specification of the proposed service must have no additional overspill into the NambourRA1licence area than achieving service of its own licence area. I accept there is a licence area overlap but overspill beyond that boundary point will be resisted strenuously.

Should you have any questions in relation to the issues raised in this correspondence please contact on 07 5443 8444 in the first instance.

Yours Sincerely

John Williams
General Manager

Sunshine Coast Broadcasters Pty Limited