CHAPTER 1 - INTRODUCTION Background Radio. A personal medium. A local medium.

Messages broadcast over radio are directed personally to each individual listener. Its intense level of connection with the audience is such that for many years now, the first medium that an individual tunes in to every morning is radio. Also, it could be said that it is the last broadcast medium that an individual tunes in to before he goes to bed. This creates a form of emotional bond between the individual listener and the broadcaster. Such emotional bond can be tapped for purposes of persuasion, as applied, for instance, in radio advertising. Radio is a local medium. It broadcasts messages that significantly concern its target

audience. It encourages and sometimes requires the participation of listeners living within a certain locality. This aspect works in correlation with the personal characteristic and importance of radio. It is not an intrusive medium, as it allows the listener to do his routine work, such as household chores among other things, without getting in the way. It is an inexpensive medium and requires very little technological resources. It is

inexpensive in the sense that transistor radios are easily accessible and very affordable these days. Even personal FM radio tuners that come with headphones could be

purchased for less than one hundred pesos (PHP 100). Listeners in remote areas where electricity is absent can still tune in through the use of battery-operated transistor radios. It is a portable and readily available medium. Even people who travel can tune in to radio in their cars or on most public utility vehicles. Listeners may also choose to bring their own portable stereos, transistors, or even walkmans. These qualities of broadcast radio give it immense influence over a vast range and sizeable number of

1|Page

audiences. Another more important attribute of radio is its power to make listeners use their imagination. As in radio dramas, it encourages the audience to imagine the setting, the characters, everything. It is the theater of the mind. If we look at it closely, it

encourages the listeners to think.

Thus, it enhances and sharpens the listeners It is an

thinking skills if exposed to a certain format for a certain period of time.

intellectual medium. That is, the only way to process the information is to listen. And being a cold medium, it requires the listener to participate to enjoy the content. It allows for experience, which is fundamental to learning. If radio would be used to exploit these characteristics, our society would be in for a world of progress. Developmental broadcast format what is it? Briefly, it is a format established following the concepts of development communication that can be applied to either of the two broadcast media, radio or television. It is a theme aimed at finding solutions to present problems of development and modernization of a particular locality or country. Wikipedia, The Free Encyclopedia, an online resource library that is communityoperated and moderated, defines development communication as:
A spectrum of communication processes, strategies and principles within the field of international development, aimed at improving the conditions and quality of life of people struggling with underdevelopment and marginalization. Reflective of the fields historical evolution, Development communication is characterized by conceptual flexibility and diversity in the application of communication techniques used to address the problems of development. Some approaches in the tool kit of the field include: information dissemination and education, behavior change, social marketing, social mobilization, media advocacy, communication for social

2|Page

change, and participatory communication. Communication for informed decision. Development communication is for the betterment of the society though raised from a particular group but affect the whole mass for better.

The term "Development Communication" was coined by Nora C. Quebral, a professor at the University of Philippines at Los Baos (UPLB).

Given radios exceptional power, reach, and influence, a developmental broadcast format specifically-designed for the medium could do a lot of good for our society. This is not hypothetical at all, as development campaigns have been launched in the poorest of countries, and the United Nations help put up more campaigns in more countries. The Development Communication section on The Museum of Broadcast Communications states,
The United Nations provides multi-lateral aid to governments. Non-profit nongovernmental organizations (NGO) conduct development projects worldwide using U.N., government, or private funding. And government agencies, such as the U.S. Agency for International Development (USAID) provide assistance to developing countries, but with political strings attached.

The United Nations and USAID help conduct development projects worldwide. Naturally, this must be some form of testament to the efficiency of development-oriented programs. The Museum of Broadcast Communications states more,
There are three common types of development campaigns: Persuasion, changing what people do; Education, changing social values; and Informing, empowering people to change by increasing knowledge. This third approach is

3|Page

now perceived as the most useful. Instead of attempting to modernize people, contemporary efforts attempt to reduce inequality by targeting the poorest segments of society, involving people in their own development, giving them independence from central authority, and employing "small" and "appropriate" technologies. The emphasis has shifted from economic growth to meeting basic needs.

If such a paradigm of communication, especially the third type of development campaigns earlier mentioned proves to be so useful and important, then why are we not employing it here in our own country? We have the required technologies to use to target our people. We are a member of the U.N. and we could ask for their help. We have made ties with the United States and we could ask help from experts from USAID. We have numerous intellectuals of our own who could help formulate a format and tailor-make it to suit the Philippine context to address our own problems and issues. And most importantly, as stated, our society has enough predicaments to garner enough attention from the said authorities. So, the question is, why not? (Patterson, 2005) Due to limited real estate and tower locations the FM broadcast plant, especially in urban centers, can house several transmitters each producing its own carrier frequency. These signals are usually combined at the base of the tower in order to have a single feeder line to the antenna. The combining technique employed can vary but usually utilizes bandpass or bandstop filters to provide the necessary isolation between the carrier signals. It is the presence of these filters that adds undesired frequency response and variances to group delay in the transmission path. The 4|Page

traditional FM channel bandwidth is 800kHz but that has now been increased with the addition of HD Radio. Systems that use a common radiating element (antenna) for both the analog and digital portions of the signal now require a channel bandwidth of 400KHz placing even a greater strain on the channel combiners to provide an adequate response. The mathematical relationship between frequency response, group delay and the degradation to the FM hybrid signal is beyond the scope of this paper but can be observed by three figures of merit: stereo separation; AM synchronous noise; and spectral analysis of the HD carriers to verify proper amplitude. Note as well, the iBiquity requirements from SY_SSS_1026s states total gain flatness of the transmission signal path to be flat within 0.5dB while differential group delay variation of the entire transmission path to be within 600nS from Fc- 200kHz to Fc+ 200kHz.

Statement of the Problem Is using lowering traditional bandwidth of 800kHz to 400kHz possible? If probable, what are the things to consider when implementing this proposal? If unattainable, what are the hindrances that made it unfeasible?

5|Page

Objectives of the Study General: To determine the factors that will make 400khz bandwidth possible for implention in fm broadcasting. To ascertain if there are any effects (beneficial or detrimental) of the format on the execution using lower bandwidth of 400khz compare to the traditional spacing of 800khz. Specific: To propose formulation of a new broadcast format that utilizes the existing theories of development communication to aid in transforming radio into a valuable and beneficial medium to its audience.

Scopes and Limitations One of the major limitations of this study is lack of equipments and other resources needed to examine the feasibility of lowering the spacing between fm radio stations. Also, this project is time constraint.

Definition of Terms Bandwidth. It is the difference between the upper and lower frequencies in a contiguous set of frequencies. It is typically measured in hertz, and may sometimes refer to passband bandwidth, sometimes to baseband bandwidth, depending on context.

6|Page

FM.

Frequency Modulation band.

It is a broadcast technology invented by Edwin

Howard Armstrong that uses frequency modulation to provide high-fidelity sound over broadcast radio. FM radio is distributed primarily through broadcast reception of FM radio signals. Examples of FM stations in Manila are Monster Radio RX 93.1, Campus Radio 97.1, and Love Radio 90.7.

7|Page

CHAPTER 2 - REVIEW OF RELATED LITERATURE The proposal of 400 KHz FM spacing in the Philippines are similar to the proposal in other countries however the 400 KHz FM spacing are now applying in other countries and not like the other countries they can minimize the FM spacing up to 200 KHz like the article below:

Center frequencies While all countries use FM channel center frequencies ending in 0.1, 0.3, 0.5, 0.7, and 0.9 MHz, some countries also use center frequencies ending in 0.0, 0.2, 0.4, 0.6, and 0.8 MHz A few others also use 0.05, 0.15, 0.25, 0.35, 0.45, 0.55, 0.65, 0.75, 0.85, and 0.95 MHz An ITU conference in Geneva, Switzerland, on December 7, 1984, resolved to discontinue the use of 50 kHz channel spacings throughout Europe.

Most countries have used 100 KHz or 200 kHz channel spacings for FM broadcasting since this ITU conference in 1984.

Some digitally-tuned FM radios are unable to tune using 50 kHz increments. Therefore when traveling abroad, stations that broadcast on certain frequencies using such increments may not be heard clearly. This problem will not affect reception on an analog-tuned radio.

A few countries, such as Italy, which have heavily-congested FM bands, still allow a station on any multiple of 50 kHz wherever one can be squeezed in.

8|Page

The 50 kHz channel spacings help prevent co-channel interference, and these take advantage of FM's capture effect and receiver selectivity. Thats why we reviewing this are to make sure that our proposal is possible, and to

see that we can do what the other country did by getting some information. And to make the technology of our country updated of what the latest technology is.

According to http://en.wikipedia.org: In the United States, frequency-modulated broadcasting stations operate in a frequency band extending from 87.8 MHz to 108.0 MHz, for a total of 20.2 MHz. It is divided into 101 channels, each 0.2 MHz wide, designated "channel 200" through "channel 300." In actual practice, no one (except the FCC) uses these channel numbers; the frequencies are used instead. To receive a station, an FM receiver is tuned to the center frequency of the station's channel. The lowest channel, channel 200, extends from 87.8 MHz to 88.0 MHz; thus its center frequency is 87.9 MHz. Channel 201 has a center frequency of 88.1 MHz, and so on, up to channel 300, which extends from 107.8 to 108.0 MHz and has a center frequency of 107.9 MHz. Because each channel is 0.2 MHz wide, the center frequencies of adjacent channels differ by 0.2 MHz. Because the lowest channel is centered on 87.9 MHz, the tenths digit (in MHz) of the center frequency of any FM station in the United States is always an odd number. FM audio for television channel 6 is broadcast at a carrier frequency of 87.75 MHz, and many radios can tune down this low; a few low-power television stations licensed for channel 6 are operated solely for their right to use this 9|Page

frequency and broadcast only nominal video programming. For the same reason, assignment restrictions between TV stations on channel 6 and nearby FM stations are stringent: there are only two stations in the United States

(KSFH and translator K200AA) licensed to operate on 87.9 MHz, both due to being forced off of another channel. Therefore, in effect, the FM broadcast band comprises only FM channels 201 (88.1 MHz) through 300 (107.9 MHz). Originally, FM stations in a market were generally spaced four channels (800 kHz) apart. This spacing was developed in response to problems perceived on the original FM band, mostly due to deficiencies in receiver technology of the time. With modern equipment, this is widely understood to be unnecessary, and in many countries shorter spacings are used. Other spacing restrictions relate to mixing products with nearby television, air-traffic control, and two-way radio systems as well as other FM broadcast stations. The most significant such taboo restricts the allocation of stations 10.6 and 10.8 MHz apart, to protect against mixing products which will interfere with an FM receiver's standard 10.7 MHz intermediate frequency stage. Commercial broadcasting is licensed only on channels 221 through 300 (the upper 80 channels, frequencies between 92 and 108 MHz), with 200 through 220 (the lower 21 channels, frequencies between 88 and 92 MHz) being reserved for noncommercial educational (NCE) broadcasting. In some "Twin city" markets close to the Canadian or Mexican border, such as Detroit, Michigan andWindsor, Ontario,

or San Diego, California and Tijuana, Baja California, commercial stations operating from those countries target U.S. audiences on "reserved band" channels, as neither Canada nor Mexico has such a reservation. Because of this necessary sharing, the 10 | P a g e

FCC reserves a few other channels for such NCE stations. FM stations in the U.S. are now assigned based on a table of separation distance values from currently licensed stations, based on station "class" (power output, antenna height, and geographical location). These regulations (see Docket 80-90) have resulted in approximately double the number of possible stations, and increases in allowable power levels, over the original bandplan scheme described above. All powers are specified as effective radiated power (ERP), which takes into account the magnifying effect (gain) of multiple antenna elements.

FM broadcast zones in the U.S. The U.S. is divided into Zone I (roughly the northeastern quarter of the U.S. mainland, excluding the far northern areas), Zone I-A (Californiasouth of 40 degrees latitude, U.S. Virgin Islands, Puerto Rico), and Zone II (all other locations). The highest-power stations are class C in zone II, and class B in the others. There are no B stations in zone II, nor any C stations in the others. (See the list of broadcast station classes.) Canada is also divided in this manner, based on the most highly-populated regions. 11 | P a g e

High power is useful in penetrating buildings, diffracting around hills, and refracting for some distance beyond the horizon. 100,000 watt FM stations can regularly be heard up to 100 miles (160 km) away, and farther (e.g., 150 miles, 240 km) if there are no competing signals. A few old "grandfathered" stations do not conform to these power rules. WBCT (93.7) in Grand Rapids, Michigan, runs 320,000 watts ERP, and can increase to 500,000 watts ERP by the terms of its original license. This huge power level does not usually help to increase range as much as one might expect, because VHF frequencies travel in nearly straight lines over the horizon and off into space. Nevertheless, when there were fewer FM stations competing, this station could be heard near Bloomington, Illinois, almost 300 miles (480 km) distant. According to: http://frequencyfinder.org.uk This article descibes the technical criteria for planning new FM stations in the UK and then discusses how the number of stations could be increased by relaxing the division into sub-bands and using transmitter synchronisation.

Technical planning criteria The required field strength to provide a good stereo signal is 54 dBV/m in rural areas, 66 dBV/m in suburban areas and 74 dBV/m in city areas. For good mono reception, the required field strengths are 6 dB lower. However, most popular music stations use lots of dynamic range compression, providing a listenable signal at lower field strengths. However, for good reception, the signal must also be significantly stronger than other signals on the same and adjacent frequencies. The following 12 | P a g e

margins are needed:

Co-channel: 100 200 300 kHz kHz kHz

45 separation: separation: separation: 33 7 -7

dB dB dB dB

400 kHz separation: -20 dB

A negative value indicates that the interfering signal can be stronger. To meet these margins, transmitters on the same and adjacent channels must be some distance apart or heavily screened by hills. Stations 200 kHz apart of similar field strength may be receivable in the same location with different aerial positions. However, official coverage areas can not overlap. If there are hills separating the two coverage areas, 200 kHz spacing can be used for adjacent stations; otherwise there must be a small buffer region. With stations 300 kHz apart, the margin is -7 dB, so it will always be possible to pick up one station or the other, but not always both. This spacing is suited to transmitters broadcasting the same programme to overlapping areas, provided the stonger signal is not subject to multipath interference. It can sometimes be used for different stations serving neighbouring areas, depending on the geography of the overlap region.

A 400 kHz spacing is always suitable for transmitters with overlapping coverage areas, whether they carry the same programme or not, provided reception of each station near the other's transmitter is not required. If both stations are transmitted from

13 | P a g e

the same mast or nearby masts, a 400 kHz spacing is OK. For example, a local station on 97.5 in Nottingham would interfere with Radio 1 from Sutton Coldfield on 97.9, but the same frequency could be used from the Sutton Coldfield mast without disrupting Radio 1. However, if a network radio filler was introduced for Nottingham, it would then be possible to use 97.5 for local radio from the same mast as the network filler as reception of the 97.9 signal would no longer need to be protected.

The final issue to consider in planning FM transmitters is intermodulation products. There are two types: intermediate frequency and cross station. FM radios use a superheterodyne circuit to reduce the mean carrier frequency of the selected FM station down to 10.7 MHz prior to demodulation. As a consequence, intermodulation products within the receiver can prevent reception on a frequency 10.7 MHz below a strong local station. In practice, this only happens very close to the transmitter. In addition, radio receivers transmit a weak signal on a frequency 10.7 MHz higher than they are tuned to - you can demonstrate this yourself using a pair of radios. Consequently, stations serving the same area are never spaced 10.7 MHz apart in the UK. 10.6 and 10.8 MHz spacings are usually

avoided as well as cheaper receivers sometimes have off- centre intermediate frequencies, though 10.8 MHz spacing has been used in Bradford and Kettering. Very close to the transmitter or with a poor receiver, intermodulation products of stations on frequencies x and y can be received on frequencies 2x - y and 2y - x, blocking out weaker stations on those frequencies. The use of regular station spacing reduces the impact of intermodulation products and a station covering the same area from a

14 | P a g e

different mast can usually operate 100 kHz apart from a cross station intermodulation product.

More efficient use of the sub-bands

In the UK, the FM band is currently divided into 11 sub-bands as follows: 87.6-88.0: Temporary and very low power stations 88.1-90.2: Radio 2 90.3-92.4: Radio 3 92.5-94.6: Radio 4 and BBC regional radio 94.7-96.1: BBC local radio and Radio 4 96.2-97.6: Independent local radio 97.7-99.8: Radio 1 99.9-101.9: Classic FM and Independent local radio 102.0-103.4: Independent local radio 103.5-104.9: BBC local and regional radio and Radio 4 105.0-107.9: Independent local radio

With a handful of exceptions, every transmitter operates within the appropriate sub-band for the station it carries. As a consequence of this, many towns and cities have run out of space for local radio, while spare capacity remains in the national subbands. By placing BBC and independent local radio transmitters throughout the FM band, much more efficient use could be made of the spectrum available. Space is available in the national sub-bands in some parts of the country, but not others. However, by moving existing local radio transmitters to the national sub-bands where 15 | P a g e

possible, the local sub-bands could be re-planned, making space available everywhere. In many cases, moving a local radio transmitter to the national sub- bands will increase incoming interference, particularly during temperature inversions when high powered FM transmitters carry much further due to ionospheric reflection. Because of this, lower power transmitters are more suitable for relocation because their powers can be increased to compensate without outgoing interference becoming a problem. A number of case studies are presented on other pages on Frequency Finder - see the side bar.

Synchronisation

Normally, a spacing of 200 kHz is too close to avoid interference. However, if the two transmitters carry the same programme and are time synchronised to within 25 s, then both carriers will always be on the same side of the centre frequency, preventing the receiver being captured by the unwanted signal (the stereo difference signal is always of equal or less magnitude than the sum signal). Consequently, if the difference in the signal path to the two transmitters does not vary by more than 15 km over the area where they might otherwise interfere, they can be synchronised and operate at 200 kHz spacing. Thus, within the UK, there is scope to move a number of low powered fillers to new frequencies 200 kHz away from the corresponding main transmitters, freeing up space. However, this will increase the transmission cost as a separate feed will be needed instead of simply using the main transmitter's FM signal to feed the relay. This technique has already been implemented for a number of commercial stations in the Netherlands. According to: stationplaylist.com

16 | P a g e

I have previously owned a high power license here in Tauranga (99.0 FM). I am also the creator and moderator of the Yahoo LPFM New Zealand discussion group mailing list. This group has grown to over 200 members since founded in 2001. This group has attracted a variety of members from around the country with differing skills, including a lawyer, and an employee of BCL who has provided technical engineering advice for several years. Over this time we have discussed many ideas and I have gained technical knowledge of the many aspects of radio transmission. I currently run a software development company (www.stationplaylist.com) which specializes in the development of software for running radio stations. I havegained technical FM transmission experience from contacts in this line of work also. I wish to use this knowledge to discuss your proposals C, D and E.Proposal C - The Ministry seeks comments on the provision of infill coverage through licences separated by 400 kHz from the main coverage service, or synchronous systems, initially in Wellington but later in other centres following technical proving. As you mention in your discussion paper, it has been proven over time that 400Khz spacing between transmissions is quite adequate for most radio receivers. Tauranga receives signals from Mt. Te Aroha and Kopukairua at 400khz spacing and both can be received fine on all modern radios. However, some badly designed clock/alarm radios may have difficultly with this separation, but I do not believe the specifications should revolve around poorly designed radios. Technical issues aside, there is a very real need for local community radio stations which the current licensing regime does not provide for. The multinational networks can and will out bid any local organisation when tendering for local frequencies. No doubt this has a short term benefit to the ministries treasury but it does

17 | P a g e

not provide for the best use of the spectrum or the benefit to the community and New Zealand as a whole. With this in mind, any additional frequencies made available from an official change to 400khz separation should be reserved solely for local community stations with suitable restrictions to either deter or remove national networks from the tendering process.The restrictions that I and others have discussed include the following: a. The studio or programming source should be within the same geographical area as the transmission site. Perhaps a specific radius could be imposed, say 50km. This means no networking from studios in other geographical areas. b. Only one frequency should be allocated to one organisation. Without this restriction, a large company in one city could end up with all the available frequencies. Any organization currently holding a license anywhere in the country should not be eligible to tender for a community frequency.Proposal D - The Ministry seeks comments on the proposal to plan and implement VHF-FM broadcasting services between 87.5 MHz and 88 MHz. This would require the present Land Mobile use to be compressed into the band below 87.5 MHz. If the proposal is adopted, what time frame should apply to the transition? It is an international standard for 88-108FM radio receivers to support down to 87.5Mhz. Many services occupy these frequencies in other countries. All members of the LPFM discussion group believe the current number of frequencies available for LPFM should not be reduced. The Land Mobile frequencies up to 87.5Mhz should be moved as soon as possible to 87.4 and below, Once this area is available, the lower LPFM band could consist of the frequencies 87.5 through 88.1, utilizing the same

18 | P a g e

600khz of band currently available for LPFM. New community licensed frequencies could be allocated from 88.4 through 88.9. As mentioned earlier, this newly created licensed area should be available for community frequency licensing only. Proposal E - Comments are sought on the proposal to allow a greater power for low power FM broadcasters under the general licence in the 88.0 MHz to 88.4 MHz range. Is an eirp limit of 5 watts suitable? Should the method of measurement be changed to specify, say, 5 watts at the transmitter output and allow any antenna to be used? There is no need to restrict any of the current LPFM guard bands to less than 5 watts eirp. Providing transmitters are conforming to the requirements for spurious emissions, etc, 5 watts will not interfere with any existing service. I propose 5 watts eirp be implemented for 88.1 through 88.7 (88.4 in the Auckland area), and 106.7 through 107.7Mhz. The discussion papers suggestion that 5 watts at 107.7 will be potentially harmful to aeronautical services is unfounded. NZ uses the same standard aviation band from 108 to 117 MHz as used in most other countries, and in most of these countries, many high-powered FM transmissions exist on 107.9 and 108.0Mhz. This includes Australia, the US and the UK. There is nothing different in NZ that would require a larger separation, particularly at the low power of 5 watts. What appears to have been overlooked is that the aviation band has a self imposed guard band from 108.0 to 109.0Mhz. No services use any frequencies between these 2 frequencies. This is designed for protection from highpower transmissions on the FMBC band up to 108.0Mhz, and therefore there is no need to provide a guard band for a guard band. An engineer acquaintance of mine has established that a 5 watt eirp transmission

19 | P a g e

at 108Mhz would not affect aviation services. The engineer established that an aviation receiver within 1km of a several kilowatt 108.0Mhz broadcast would not cause any issues. The selectivity of an aviation receiver is several times better than a high quality FMBC domestic receiver, and the self imposed guard band is more than ample protection. At 5 watts LPFM, an aviation receiver could be within just a few metres of the transmission without any effect, so there is no reason to restrict the upper LPFM band to 0.5 watts. I propose the increase to 5 watts occur immediately across all current LPFM frequencies. There is no need to wait for greater separation from the land mobile services. The receivers in these radios are also very selective and will easily disgard 5 watts at 100khz separation at close range. The current LPFM guard band up to 107.7 could in fact be used for high-power broadcasting licences, but to be overly cautious, I recommend leaving this space reserved for a 5 watt LPFM guard band.The current suggestion that only 88.1 to 88.4Mhz be increased to 5 watts is not a necessary restriction, and will likely cause other problems. Most LPFM operators will want to use 5 watts as apposed to 0.5 watts and this will lead to massive over-crowding within this small 400khz area. Using the same power level across all LPFM frequencies will make for much easier compliance and policing. With an increase to 5 watts, I for one will be much more motivated to spend more time on my own LPFM station to produce better programming. I know that many others feel the same way. The additional coverage and penetration into more homes will reduce the many complaints I receive where listeners can receive the station in the car but not inside their homes. Overall, the increase will be

20 | P a g e

most beneficial for the listeners, most of whom struggle to receive the current 0.5 watts signal. The coverage made available from the increase in power to 5 watts will be suitable for existing stations to relay into small pockets where their main signal cannot reach. There are various areas around NZ where 5 watts would be all that is required to service these small areas. One example is around Rotoruas many lakes of which some are behind elevated hills. This would simplify the process for stations to extend their coverage into areas where no other signals can reach, without the need to engineer a commercial license.Summary and Benefits There is technically no reason why the changes I have proposed cannot be implemented. Existing services will not be affected. In an attempt to prevent any possible indentation to their advertising revenue with competition, I'm sure there will be the usual negative feedback from the commercial networks regarding 400Khz spacing, community frequencies, and 5 watt LPFM. I and many others believe that 5 watt LPFM is not going to impact very much at all on the revenue of these companies. Most LPFM operators are not operating for profit, but as a service to the community. Many are offering alternative styles of music that many listeners desire, but since this format will not provide massive profits to shareholders in other countries, it is not currently available on the radio. I and many other operators, LPFM listeners, and the general public, believe it is the benefit to the community that should be considered above all else. The current commercial networks provide a very limited range of music, and little or no community presence. LPFM operators are providing an essential service with alternative programming, servicing localized suburban areas with formats that are often niche and not commercially viable. Licensed community frequencies will also greatly influence what is offered to local communities.

21 | P a g e

These services along with LPFM can make a real positive difference to what is available on the radio. The commercial networks have taken over the airwaves to the detriment of the NZ public. The Government needs to stand up to these money hungry networks and provide New Zealand with some alternative programming and spectrum. Restricted community licenses are the most logical step, and these need to be made available in good numbers, before all the spectrum is lost to foreign companies. This may require reserving all lower band in-between frequencies for community licences, in addition to some upper band frequencies. According to: maraa.i.com Issues Related to Prescribing Minimum Channel Spacing, within a License Service Area, in FM Radio Sector in India. The Community Radio Forum is a registered society working in the interests of community radio stations in India. This document, has been in consultation with community radio stations operating on the FM Band, and we request TRAI to consider these comments as a stakeholder in the FM Radio Sector in India. Background: The Supreme Court of India saw a landmark case in 1995, in Ministry of Information and Broadcasting Vs Cricket Association of Bengal, presided over by a bench of three judges P.B Sawant, Jeevan Reddy and S. Mohan. The landmark judgment airwaves are public property has been, in many ways the foundation of the community radio movement, a unique combined effort of grassroots communities from all over the country and community media advocates, civil society actors and academicians.

22 | P a g e

After nearly a decade, the Ministry of Information and Broadcasting released community radio guidelines, but limited the definition of community to educational institutions. It was only eleven and a half years after the airwaves judgment that, on November 16th 2006, the government of India released community radio guidelines which recognized the legitimacy of communities to broadcast on FM through the third tier of broadcasting community radio. Today, there are 150 operational community radio stations, and an equal number awaiting license. Most of the community radio stations fall under three key categories nonprofit, educational institution and agricultural centre (Krishi Vigyan Kendra). More than 80% of the licenses have been awarded to educational institutions since they have had a policy almost two years earlier, and also because of a single window licensing process for campusbased CR stations. Further, in 2006, there have been various presentations by engineers and officials from Wireless Planning & Coordination (WPC) wing of the Ministry of Communications who have stated explicitly that there would be six (6) frequencies allotted to community radio in a given license service area or a circle. Over the next five years, the number of available frequencies for CR were whittled down to three (3) for all practical purposes. As grassroots communities are poised to finally gain access to media ownership, they are indeed showing potential to not only realize the vision of freedom of speech and expression as constituted in Article 19(1)(a), but also become powerful vehicles for communities to address their own social, economic, political and cultural issues.

23 | P a g e

There is a need from the Ministry of Information & Broadcasting and the Ministry of Communication & Information Technology and the broadcast regulator (TRAI) to give priority to this sector as it is explicitly using the airwaves to serve community and public interests in the spirit of the 1995 judgment referred to earlier. Overall Comments Community Radio Forum would like to place some overall comments on the record in the context of the consultation paper issued by TRAI , No. 7/2011 (Issues Relating to prescribing Minimum Channel Spacing, within a License Service Area, in FM Radio Sector in India). 1.) India has since early 2004, a three tiered radiobroadcasting structure Public Service (All India Radio), Commercial (private FM radio stations) and Community (Community Radio Stations). Since there are over 150 community radio stations in the country on the FM band, and their numbers are steadily increasing, TRAI is requested to kindly consider Community Radio in their future consultations and recommendations regarding FM. 2.) The current consultation paper suggests reduction of channel spacing to 400 KHz from the existing spacing of 800 KHz. Although the rationale is primarily for the growth of commercial FM radio in A+ and A category cities, the final recommendation could be for FM licensing across India including rural areas. Therefore it is critical to look at the issue from a larger perspective. 3.) While commercial FM radio licenses are obtained through an auction, CR stations are mandated to be notforprofit, and hence have an entirely different licensing process.

24 | P a g e

4.) Unlike private FM, community radio stations are allotted licenses by MoIB and frequencies allotted by WPC, with stations only paying approx. 20,000 INR for spectrum usage. However, since licensing is an internal government process, there is no transparency in how a given license service area is defined for community radio; how many frequencies are reserved/allotted for community radio in a given service area; and on what basis the frequencies are divided between public radio, commercial radio and community radio. 5.) Until there is transparency from DoT on a systematic frequency allocation plan within the FM band for a given service area, it is very difficult to decide or comment on how channel spacing reduction will impact all three tiers of the FM Radio Sector in India 6) We also would like to mention here that while private FM radio stations can transmit on power from 3 kW (3000 watts) upwards, community radio stations are transmitting at 50 to 100 watts ERP. Therefore it may be possible for a 3KW station to overpower a 100 W station if the channel spacing between them is insufficient. 7.) While this is possibly speculative, it does underline the need for wider consultation and field based research on how much interference is faced by the lowpower community radio stations, especially in urban areas.

25 | P a g e

Specific Comments On the specific questions posed in the Consultation Paper, the CR Forum would like to submit the following responses: 1.) What should be the minimum channel spacing within a license service area for the FM radio channels? Should it be reduced from the current level of 800 KHz, if so, what should be the appropriate minimum channel spacing? Please justify your response with appropriate reasoning. While giving the response, the issues such as the viability and desirability of having more number of channels in the interest of the stakeholders, selectivity of FM receivers available with the consumers (such as mobile handsets, car radios, and other receivers), transmission from a single or multiple transmission setups may please be factored in The Minimum Channel spacing within a license service area should be reduced from the current level of 800 KHz. This will create more opportunities for community radio to address the urban poor who often get left out of developmental initiatives, which are rural centered. Arriving at a specific and mutually convenient and feasible channel spacing level should be through wider consultation with all stakeholders including community radio. Further, it is accepted that in A+ and A category cities, the vast majority of radio listeners use their mobile phones as listening devices which can handle even 200 KHz channel separation. However, the quality of transmission from transmitters of community radio as well as private FM stations can lead to increasing interference amongst FM radio stations, especially in urban areas. This issue can be looked at in more detail through some field level data whether interference is or is not occurring between private FM stations or between private and community radio stations. There also needs to be some field level research to see from

26 | P a g e

listeners of A+ and A category cities, especially listeners of community radio stations, if they are facing interference from private FM stations. 2.) What are the implications of reducing/notreducing the minimum channel spacing within a license service area? The implication of reducing the minimum channel spacing within a license area has huge potential for the FM radio sector in India, especially in larger metros and A category cities. It could encourage the growth of the private FM Radio sector in India, through more private radio stations. It could also create more FM frequencies for community radio stations since there could be more allocated for them with reduced channel spacing. However, more in urban areas than others, it is critical to have a concrete FM band management plan, where there are clear indicators on reservation for different sectors public, private and community and how much spectrum each sector can access. This planning needs to equitably cater to each sector and needs to be done in a public, transparent and consultative manner. 3.) In the event of reduction of minimum channel spacing, from the current level of 800 KHz, should the minimum channel spacing be reduced only in A+ and A category cities or should it be reduced across the country? The minimum channel spacing from current level of 800 KHz could be reduced in phases A+ and A category cities; smaller urban centers, and lastly across the country. Each phase should consult with stakeholders and existing practitioners who might be able to give valuable field level experiences, which can be considered in shaping recommendations. 4.) Any other relevant issue that you may like to raise or comment upon

27 | P a g e

We reiterate that FM radio sector planning should accommodate the needs of community radio stations as well. Therefore we urge TRAI to recommend that the priority is to have a coherent FM frequency planning which caters to all three sectors in an equitable way. Community Radio stations, especially, need clarity on the size of the circles within which frequencies are allotted and on what basis this size is defined; and further, how many frequencies are allotted within each circle, and on what basis these frequencies are allotted. Depending on this information, it would be possible to assess supply and demand and subsequently, assess scientifically the positive and negative consequences of issues like reduced channel spacing. Community Radio Forum of India D302, 2nd Floor, Defence Colony New Delhi 110024

28 | P a g e

Methodology 1. Frequency Selection a. GQ-AAS extracted the relevant data from the SMART service which contains the database of current and planned FMBC services. The data from the Ministrys database was converted into an Excel spreadsheet format which could be used for investigating the potential frequency availabilities. b. Frequencies spaced at 400 kHz which could potentially be used for the proposed service were investigated. As a first pass, the frequencies identified for

detailed analysis were based on current and planned co-channel or adjacent services within 400 km. c. Current (or planned) co-channel and adjacent services which could potentially interfere with (or be subject to interference from) the proposed frequency(s) were identified and all relevant details of the services, such as the transmitting antenna heights, EIRPs, horizontal radiation patterns, etc. were further obtained from the database. d. The proposed service and existing (and planned) co-channel and adjacent services were then analysed for interference to each other as detailed in the next section. 2. Interference Analysis a. The predicted coverage/interference plots for the proposed service and the potential interfering services were produced using the Planet EV radio prediction programme (produced and supported by Ericsson Wireless) and the SRTM 3 second digital terrain data.

29 | P a g e

b. Planet EV supports a number of propagation models including: Free space Okumura-Hata Longley-Rice ITU 370-Recommendation CRC-Predict GQ-AAS primarily uses the CRC (Communications Research Centre) of Canada Predict models, as they are the most sophisticated model in the Planet EV suite and allow (50,50), (50,10) and (50,1) predictions. Stage One c. The predicted coverage plots of the proposed and current (or planned)

services were mathematically compared at the relevant protection locations. Initially, the protection locations of the proposed service were assessed for interference from current and planned services. c-1. In cases where significant interference is predicted at one or more of the protection locations, the relevant frequency was considered to be unavailable400 kHz Channelling FM Radio Planning for Auckland c-2. In cases where significant interference is not predicted at any of the protection locations, the frequency was then assessed for interference from the proposed service back to the other services protection locations. c-3. Where the significant interference is predicted at one or more of the protection locations for current (or planned) services, the relevant frequency was considered to be unavailable.

30 | P a g e

The following criteria were used for the first stage of interference analysis. Case
1

Result
The predicted RPR margin was greater (better) than or equal to -6 dB at the protection location The predicted RPR margin was less (worse) than -6 dB at the protection location.

Action
Frequency may potentially be available. Further investigation required. Frequency unlikely to be available. It was assumed that interference would exist.

Table 9: Criteria used for the first stage of interference analysis d. The frequency assessments that predicted -6 dB or higher margins relative to the RPR at all protection locations for both the proposed and current (or planned) services were analysed in greater detail in the second stage. Stage Two e. Each frequency that passed the first stage of interference analysis was analysed further by plotting the margin relative to the RPR between each wanted and unwanted service and overlaid with the 66 dBuV/m coverage contour for the wanted service. This produced a figure which identifies any areas of predicted interference within the 66 dBuV/m contour of the wanted service. f. Where significant interference is predicted to occur within the 66 dBuV/m contour of the wanted service the frequency was considered unavailable. interference plots are appended to the report for the Ministrys consideration. g. Where no or minor interference is predicted within the 66 dBuV/m contour of the proposed service and current (or planned) services, the frequency was considered to be available. The

31 | P a g e

32 | P a g e