[cr-india] FM Commission recommendations

[Vickram Crishna]

I filed this note at the proper address on Jan 19 in response to the
Commission report on revamping FM licensing. I hope that others have
also used the opportunity to voice their feelings and opinions on
this (terribly shortsighted) policy recommendation.

If you recall, we had a proposal to set up a specific website to deal
with issues pertaining to the growth of community media, mainly
radio. Sarai had very kindly offered to do the tech work for us.
Unfortunately so far we have not had any serious interest in taking
this further. The government is acting already. Are we going to?

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Kindly note the following response to the Commission Report of FM.
There is a problem with the policy discussion following the report of
the Commission asked to look into licensing issues for radio. The
problem begins right from the preliminary opening of the Report : see
the sections taken from the *abbreviations* below.
                                                   ABBREVIATIONS
7.	FM			Frequency Modulation
11	LOI			Letter of Intent for Operating FM Radio Station
12  	License Agreement	License Agreement for Operating FM
Radio Broadcasting Service
14.	MW 			Medium Wave
15.	Phase I			Issue of FM broadcast licenses in the
first phase of privatization of FM broadcasting in India
16.	Phase II		Proposed issue of FM broadcast
licenses in the second phase of privatization of FM broadcasting in
India
17.	SAFCA		Standing Advisory Committee on radio
frequency allocation
19.	SW 			Short Wave
20.	Tender Documents	Tender Documents for FM Broadcasting
Through Private Agencies (no. 212/2/99-B(D))
In reference after reference, it is automatically assumed that
activities associated with the use of the radio spectrum, can be
clubbed together under the head of *broadcasting* and dealt with in a
neat and tidy manner.
There must be a serious recognition given to the utility of low power
radio, in diverse applications: from emergency services to
entertainment. This technology can be used in museums and areas of
national and international attraction, such as heritage sites and
wildlife sanctuaries. All these applications fall within the ambit of
broadcasting as defined in the official literature, which needs to be
addressed.
Low power radio needs to be treated separately because applying it is
cheap and it focuses on the small and micro-sized community. Most
importantly, it is the most inclusive medium of modern communication,
involving with equal facility people who are stricken by poverty,
illiteracy or physical disabilities such as blindness.
1	Licenses
The question of licensing needs to be reviewed completely. As
presently constituted, the SACFA is not able to study fine grained
needs of rural and poverty stricken urban communities that can best
benefit from this inexpensive medium. The process of bidding for
licenses is not scalable to the issue of community owned and operated
village level communication centers. It is also not applicable to the
management of small powered radio communication applications in
museums, heritage and tourist sites, wildlife sanctuaries and so on.
The viewpoint of the Commission on licensing, including the bidding
process, the fees and the payment methodologies needs to be
re-examined. The question of scaling paymernts of licenses to the
revenue model may not be at all applicable, as broadcast stations can
be funded by public subscription, and public service communications
at places like wildlife sanctuaries may pay for themselves in terms
of increased safety and better sharing of information.
The licensing period seems reasonable, except that it may be
administered far more effectively at the local, perhaps, district
level, rather than with centralised management as presently described
in the report.
For the record, spacing of radio stations at 400KHz is twice the
protection than that given in major metropolises such as New York,
which has 72 broadcasting stations currently between 87.5 and 108 Mhz.
With 200 Khz separation, the total number of stations possible in any
location go up mathematically over 100, in the available bandwidth.
Unless the policy is made much more user friendly, it is very
unlikely that the spectrum will be effectively or productively used.
The reserve price for some cities appears to have been decided. This
should not apply to low power radio used within urban spaces for
public use, whether or not it needs to be supported by any revenue
model.
2	Allocation and use of frequencies
In clause 11 of the Summary, reference is made to “the spectrum being
a scarce resource has to be used rationally, efficiently and
optimally by all.”
In fact, used effectively, the spectrum is not as scarce as this
statement may imply. The frequency at which FM is used for public
audio signal transmission allows for over 100 channels to be used in
a single location. This is far higher than can be envisaged if the
policy as recommended in the report will be used for popularising
radio in India.
With reasonable coverage of the landmass of India, it is possible to
calculate the potential of over 1.25 million channels in use
simultaneously, which should not be considered a scarcity.
3	Use of spectrum by IGNOU vis-a-vis private broadcasting
An attempt is made to divide the use of radio between MW and FM,
suggesting that IGNOU (and by extension, all educational radio?) use
MW for its educational radio. In reality, FM delivers better sound
quality, and there is no reason to believe that good educational
radio should not be the minimum standard, including the availability
of better sound quality.
4	Support of non-commercial channels
The suggestion that the collection of funds by licensing of
commercial channels be made available to non-commercial stations may
prove quite unworkable in the light of the actual potential for rural
radio. It may be better to manage such funding through local
discussion and sourcing, while avoiding practices that lead to
concentration of ownership.
5	Import duties and policies
Low power radio is very much possible to engineer locally, without
drawing extensively on imports. With the potential to implement large
numbers of stations through more radio friendly policies, the Indian
manufacturing sector will get a fillip. This should fall in line with
other proposals to maintain and encourage Indian industry.
6	Broadcast Regulator
While an autonomous regulatory process is welcome, it should work at
creating a local character to assist the creation of this medium at
the village level, by ensuring participation at the village, block
and district level in every local regulator's office.

--
Vickram