Digital switchover of television and radio in the United Kingdom - Communications Committee Contents


CHAPTER 4: Where have we reached on digital radio?

83.  In this chapter we consider the current state of UK radio, the case for switchover[33] to digital radio, and the views of the radio industry and the consumer on radio switchover.

THE STATE OF THE UK RADIO SECTOR

84.  Despite the growth of alternative media, radio remains a highly-valued medium with particular attractions. Tim Davie, Director of Audio and Music for the BBC, said that its in-built advantages were that it was live, mobile and allowed its listeners to do other things at the same time—making it a companion (Q 358). In 2009, around 90 per cent of the population[34] listened to the radio every week, for an average of 22 hours. The BBC dominates radio listening in the UK. Tim Davie said that the BBC's share of the radio audience was steady at between 54 and 56 per cent, with two thirds of the population spending more than 16 hours a week listening to the BBC, an achievement which he attributed to the quality of the BBC's output (Q 354).

85.  According to Ofcom's latest research, 63 per cent of radio listening takes place in the home, whilst in-car listening accounts for 18 per cent of all listening[35]. Almost all in-car listening is still on analogue FM as the vast majority of cars in the UK have analogue only radios (see Chapter 5).

86.  Between 2003 and 2008, total hours of radio listening has fallen among most age groups, with all adults' (15+) listening time down by 5 per cent. This fall in total hours was more pronounced among younger listeners aged between 15 and 34, whose listening was down by around 12 per cent. One of the main reasons may be "the iPod effect": younger listeners prefer their own choice of music on an MP3 player rather than what is available on the radio[36]. Nevertheless, radio listening by the over-55s remains particularly strong. They make up a disproportionate number of BBC radio listeners. They accounted for 70 per cent of hours on BBC local/national radio and 35 per cent of national commercial radio listening[37].

87.  In 2009, 66 per cent of all radio listening was on analogue, 21 per cent on digital and 13 per cent unspecified. Of digital listening, the majority (13 per cent) was on DAB, with the remainder on other platforms, including digital television and the internet[38]. In June 2009, the Government said that digital listening was unlikely to reach 50 per cent of all listening by 2013 by organic growth: "a concerted drive"[39] would be required to achieve this. Although the figure for unspecified listening complicates matters, it is likely that the digital share of total listening in 2009 was below the 26 per cent required if the Government's "drive to digital" projection was to be on track to meet the 50 per cent target by 2013. The projections are shown in Figure 3.

FIGURE 3

Projected total digital share of listening

Source: Digital Britain

88.  An analysis of digital versus analogue radios sold in 2009 shows that, in the category of standalone radios (also known as 'kitchen' radios) digital sets accounted for 63 per cent of all sales (p 32-33). Whilst this statistic for 'kitchen' radios suggests a major shift in listening habits, Grant Goddard, an independent radio analyst, has pointed out that, if other types of radio are taken into account—for example, portable handheld radios, clock radios, mobile phones and hi-fi systems—the picture is very different. In 2009, sales of digital radios made up only 28 per cent of total radio sales (p 94 and blog[40]). The sales figures for digital radios include radios which have both digital and analogue tuners. Most DAB radios now on sale incorporate an FM tuner.

THE RADIO ECONOMY

89.  In economic terms, radio is relatively small having a total sector value of £1.1bn a year, compared to £11.2bn for television[41]. BBC Radio accounts for only 17 per cent of the licence fee but was described by Caroline Thomson, Chief Operating Officer of the BBC, as "the jewel in the crown of the BBC", carrying good, distinctive content to a variety of audiences (Q 354). In the last financial year, the BBC spent £588m directly on radio services, of which £463m was on content.

90.  Commercial radio, on the other hand, faces serious challenges. RadioCentre, the industry body for commercial radio, summarised these as "a difficult financial situation due to a combination of structural change in the industry ... compounded by the current advertising recession" (p 211). The structural changes arise from "the growth of on-line advertising at the expense of traditional media; consistently high costs due to regulation; and the need to make many millions of pounds worth of investment in dual transmission costs (for both FM and digital), with little if any additional revenue generated as a result" (p 211).

91.  These wider problems are reflected in listening and revenue figures. Andrew Harrison, Chief Executive of RadioCentre told us that the total revenue of the commercial radio sector in 2009 will be about £500m, down from a peak of £620m [in 2004] (QQ 262-3). Table 1 shows that commercial listening share has been falling steadily, whilst the number of commercial radio stations has been rising over the same period.

TABLE 1

Number of radio station licences awarded and radio audience share
UK Radio Industry 2002 20032004 2005 20062007 2008
Number of analogue radio station licences awarded*
315
322
326
342
364
369
371
Commercial share of listening
45.5%
45.2%
44.6%
43.5%
43.1%
42.8%
41.1%
BBC share of listening
52.6%
52.8%
55.5%
54.5%
54.7%
55%
55.7%

Source: Ofcom Communications Market Reports 2005-2009

* Most of the licences were awarded to local and regional commercial stations

Note: Commercial share of listening stood at its lowest in 2008 since 1993, and down from its peak in 1998 at 51 per cent. In 1993, there were only 126 commercial stations whereas now there are over 300 stations. (Source: Enders Analysis, August 2009).

92.  RadioCentre also notes that small local stations have been hardest hit by the combination of high fixed costs, structural change and recession (p 211). John Myers, who conducted a review of localness in radio for the Department for Culture, Media and Sport[42], told us that 70 to 80 per cent of radio stations broadcasting to a population of less than 700,000 potential listeners were unprofitable or making less than £100,000 a year. He went on to say that "too many radio stations were licensed in areas that were never going to be successful and profitable and that caused problems ... In summary, the commercial radio sector ... is in crisis" (Q 307).

93.  Tim Gardam, in an independent review of digital radio in 2004, commented that the decision of commercial radio to go digital was based more on "visionary conviction than on obvious commercial calculation" since "it was by no means obvious that the investment in digital radio would successfully establish the platform to the point at which consumer demand would justify an expansion of radio stations"[43]. This remains the case. Although digital broadcasting was successfully launched and digital listening is increasing, the commercial radio sector has had difficulty in making digital radio economically viable. Grant Goddard said that the majority of digital-only radio stations have closed, due to lack of listening and low revenues. "After ten years of DAB in the UK, no digital radio station yet generates an operating profit" (p 75).

94.  A further problem is transmission costs. Ofcom's financial analysis suggests that, compared to television, the radio industry has high operating costs relative to revenue. A relatively high proportion of these costs—around 10 per cent—are transmission costs (p 41). This has been exacerbated by dual transmission[44]- broadcasting in both analogue and digital - which gives commercial radio an early interest in switching to digital only. RadioCentre told us that total transmission costs have risen from £50m a year, five years ago to £70m, of which £40m is for analogue transmission (FM and AM), £20m for DAB transmission and £10m for other forms of transmission, such as DTT and satellite. They say that "transmission costs have begun to exceed annual industry profitability" (p 213). This was confirmed by Michael Betton, Chief Executive of Lincs FM Group, which holds nine licences in the Midlands, broadcasting in analogue and digital, who told us that moving to one transmission platform would shift his company from loss to profit (Q 270).

COMMUNITY RADIO

95.  A further tier in the UK radio sector, which has emerged in the last five years, is local community radio, broadcasting on FM on a non-profit making basis. According to Jaqui Devereux, Director of the Community Media Association, about 160 community radio stations are currently broadcasting, with up to 40 more holding licences and yet to launch (Q 661). There are no official audience figures, but Ofcom estimates that community radio broadcasts can be received by around 15m listeners. Jaqui Devereux told us that their audience may be ten per cent of this figure, 1.5m (Q 672).

96.  Jaqui Devereux went on to say that community radio sees itself as part of the voluntary sector, with more than half of its funding coming from public body funding, including, local authorities, service level agreements with public authorities and the DCMS Community Radio fund. Advertising, sponsorship, and donations account for another third of funding. This revenue is supplemented by voluntary staffing amounting to about 150,000 hours a month (Q 663). She said that, because it was competing for public funding, community radio's finances were always under pressure. She said that, if the BBC were to cease broadcasting its local services on FM, and therefore cease to maintain the local FM infrastructure, this could lead to financial difficulties for community radio.

THE CASE FOR SWITCHOVER TO DIGITAL RADIO

97.  The Government acknowledges that analogue radio in the UK is "a medium which is highly valued by listeners today"[45]. But it went on to say that if radio is to compete with other media, it must have greater flexibility to grow, innovate and engage with its audience; and that, compared to analogue radio, digital radio offers possibilities to grow through the delivery of new content and functionality[46]. The case for switchover put to us consisted of the following main arguments.

(i)  Increased choice and capability

Ford Ennals, Chief Executive of Digital Radio UK, the industry body formed in December 2009 to promote digital radio in the UK, said that a digital future for radio would bring about "innovation, competition and choice" (Q 78) and that those who have digital radios "love the listening experience and the functionality" (Q 79). Siôn Simon, then Minister of State for Creative Industries, also mentioned the practical and technical advantages of "extra functionality and interactivity" of digital radio (Q 484) and "more stations more clearly defined" (Q 517). The extra functionality includes scrolling text, one-to-one traffic information and "listen again"[47].

RadioCentre also argued that the listening public will benefit from the increase in station choice. Although Ofcom's latest research suggests that customer satisfaction with choice of radio stations is high and rising[48], RadioCentre said that this argument was deployed by incumbent operators in television prior to the launch of additional channels and that a reversion to three television channels would be inconceivable: "we do not believe that radio will be any different" (p 210).

(ii)  Ageing infrastructure

Siôn Simon MP told us that the FM infrastructure is ageing and the likelihood is that it would not be economic to renew it. "What you would be faced with ... would be a piecemeal disintegration of the FM infrastructure in a disorderly way and an inevitable move by the market to digital. What the Government is, therefore, doing is trying to help manage this move in an orderly and efficient way" (Q 484). Arqiva told us that "while we would not agree that analogue radio infrastructure is 'decaying', it is true that some of it will soon require significant investment" (p 186). Digital Britain stated that the analogue infrastructure would require up to £200m of capital expenditure over the next 20 years to maintain a full national network[49].

(iii)  Radio industry support

The radio industry generally supports the policy of a move to digital as the main delivery platform. The industry body, RadioCentre, makes the case strongly. Andrew Harrison, Chief Executive, told us that the "whole industry is broadly aligned on the direction of ... travel. It is not just RadioCentre and its members, which is the majority of commercial radio; it is also the BBC and also community radio. All of us are keen to get radio to have its place in a digital future and to interact with consumers on that platform as all of competitive media, be that television, music and so on, which are all distributed digitally" (Q 274).

The BBC, in its response to the Digital Britain interim report[50], supported the Government's plan for Digital Radio Upgrade. It argued that digital radio offered the radio industry a proven means of improving the audience experience and increasing the breadth and quality of radio listening, citing wider choice of stations, improved sound quality, ease of tuning, an Electronic Service Guide and live text services. "The BBC believes that digital radio adoption is therefore critical for the medium to continue to play its central role in the social and cultural life of the UK"[51]. The BBC also supported the Government's recognition of the importance of new and innovative content in bringing consumers to digital radio and said it would continue to explore ways of doing so. Its main concern was—and remains—the funding of build-out of the multiplex system to create the required digital coverage. This is dealt with in the next chapter.

(iv)  Consumer investment in digital

A further argument advanced in favour of switchover is the investment in 10m DAB radios made by British consumers. In 2009, around one third of UK households owned a DAB radio at home[52]. Since the average retail price of a DAB radio was as high as £85 in early 2009[53], this represents an investment of over £800m.

Digital Radio UK also pointed to evidence of consumer satisfaction among those who have bought digital radios. In a poll of 7,000 DAB radio owners in July 2009, 76 per cent thought the sound quality was as good, or better, than FM and 79 per cent thought the choice of stations as good or better (p 16). The recent announcement by the BBC, proposing closure of its digital-only station, 6 Music, provoked an on-line campaign to save the station[54].

CONCERNS OF THE SCEPTICS

98.  Against the views of the proponents of switchover to digital radio, a number of counter-arguments and concerns have been expressed.

(i)  Public benefits

From the perspective of the general public, the case for switchover to digital radio is much less clear than for television. Although there are problems of reception quality in some areas, there is a high degree of listener satisfaction with the FM and AM services currently available. There is no polling evidence on whether consumers wish to receive national radio services in digital only. Ofcom's latest research found 94 per cent satisfaction among radio listeners with the radio content they receive[55]. We received written submissions to this inquiry from over 120 members of the public, many of whom are unable to see how a switchover of the national radio channels to digital only would benefit listeners. This included a number who already had bought and listened to digital radios and think that reception, particularly of music channels, is better on FM.

Unlike television, the spectrum which will be released by the majority of stations ceasing to broadcast in analogue has little alternative use or value. Siôn Simon MP confirmed that the Government was not aware of "anybody being likely to want [the released spectrum] and certainly to want to pay anything in order to use it for anything else" (Q 508). Grant Goddard explained that, "... there is no value to the Treasury of the FM waveband. Unlike the analogue television spectrum, which is going to be re-used for other things, there is no other purpose for FM; it is ideally suited for radio" (Q 338).

(ii)  Cost of replacement and conversion

The investment by consumers in digital radios has to be balanced against the accumulated investment in analogue radios, much of which would be lost by switchover to digital radio. It is much more difficult to assess the residual economic value of these, since estimates of the existing stock of analogue radios vary considerably. Siôn Simon MP thought that there might be 50m analogue sets in use (Q 516). Although some estimates put the total number of analogue radios in existence as high as 100m. Unlike television, most of these sets are likely to be disposed of after switchover.

Many of the comments we received focused on the cost of throwing away FM radios and buying DAB radios, and the outdated technology and poor reception quality of DAB radios. A letter from a member of the public, Richard Hellawell, covered both points: "Why should all FM radio owners incur the expense of switching to DAB radios only to endure poorer quality"[56]. Consumer concerns are beginning to receive press coverage, for example a recent article in the Daily Mirror entitled "Why DO we have to throw away our old radios in 2015?" [57]

A particular problem is radios in vehicles, almost all of which are analogue at present. Although the motor manufacturers are working towards putting digital radios in all new vehicles, they expect that 20m older vehicles still in service at time of digital switchover will have to have their radios converted to receive digital broadcasts (Q 564). This will involve inconvenience and cost for all owners of older cars.

(iii)  Which digital standard?

A further complication in assessing the case for digital radio is the continuing debate over the digital standard that the UK should be adopting. Because the UK was one of the earliest adopters of digital radio, it launched mainstream digital broadcasting, using the then-current DAB standard. Other digital standards within the same group as DAB (known as the 'Eureka 147' family), include DAB+ and DMB (Digital Multimedia Broadcasting), which has video/multimedia capabilities. The recently-introduced DAB+ uses the same amount of spectrum as DAB, but the coding techniques used for DAB+ are twice as efficient. DAB+ can therefore offer more services in the same amount of spectrum space or better sound quality for the same range of services.

Some commentators and members of the public continue to suggest that DAB is out-of-date technology and that the UK should opt for DAB+. Since DAB+ offers more capacity on the multiplex, it could permit more commercial stations to migrate onto digital: a point made by William Rogers, Chief Executive of UKRD[58] (Q 348). The better sound quality could meet the concerns of those who consider that current digital broadcasts on DAB have failed to produce high sound quality. Notwithstanding the evidence of satisfaction with DAB sound quality mentioned in paragraph 96(iv), we have received letters from members of the public, arguing that DAB sound quality is inferior to FM, particularly for music broadcasts[59]. In the trade-off between choice of stations and quality of sound, broadcasters have so far prioritised greater station choice over fewer stations with higher quality sound.

(iv)  The alternative industry view

Two members of RadioCentre, UTV Radio and UKRD, have recently resigned their membership because of concerns over digital radio policy. Scott Taunton, Chief Executive of UTV Radio, told us that, while he thought digital radio had a big part to play in the future of radio, he did not "understand the logic of seeking to turn off or to switch over the bulk of services from Medium Wave and FM" (Q 324). He said that the Government's policy would create a two tier system, which would "leave local radio behind to a large extent, and for the bulk of consumers the benefits are not as perhaps some of us are led to believe. The average consumer in the UK has 14 radio services available to them currently" (Q 325). William Rogers told us that he considered the digital switchover strategy to be "ill-considered, ill-thought through, poorly executed; the wrong platform has been chosen; it will restrict choice and damage radio stations at the smaller end and completely and radically change the nature of local commercial radio as to how it services its community ... To us, that is something that is not necessary and indeed we do not believe there is any public demand for it" (Q 311).

(v)  A disincentive to localness

The Digital Economy Bill[60] provides for the changes to the digital infrastructure necessary to facilitate the delivery of the Digital Radio Upgrade programme, and empowers Ofcom to approve areas within which local analogue stations may co-locate to share premises and administrative costs. Without these changes some stations may be forced to close as their business models will not be able to adapt to broadcasting on digital. John Myers told us that these changes are necessary, but that localness must be preserved (Q 313).

However, localness may be threatened by digital broadcasting. Local radio stations broadcasting, via a local digital multiplex, could reach a larger area and number of listeners than by broadcasting on FM. Jaqui Devereux described the effect: "If you are a radio station in St Albans, you are broadcasting at the moment to most of St Albans. If you go on the local multiplex you are broadcasting to Herts, Beds and Bucks" (Q 673). This wider reach offers a potentially greater listenership to local stations, but it also encourages stations to reduce the amount of local information they carry, in order to avoid causing their new, wider audience to switch off.

The Government plans to leave ultra-local and community radio stations on FM at present, so the issue has not yet become critical. But it will be an important factor to consider if it is planned to close the FM broadcasting network. Although in favour of the move to digital, Jacqui Devereux said that the wider reach of digital made it difficult to maintain accountability to the local community. She would have liked to see some guarantee for the long term future of FM in the Digital Economy Bill (Q 673, Q 670).

(vi)  Environmental concerns

Switchover to digital radio will potentially have an adverse environmental impact through disposal of a large number of analogue radios and through greater power consumption of digital equipment. However, the impact of radio disposal will be reduced through the operation of the Waste Electrical and Electronic Equipment (WEEE) Directive, which requires householders to ensure that WEEE waste, which would include discarded radios, are passed to a registered waste carrier or other approved person. Retailers are required to accept WEEE waste on a one-for-one basis (which is to say that when one radio is purchased one old radio must be accepted for recycling) but we heard from the electronic retailers association, RETRA, that retailers would accept more than one-for-one (Q 611).

The first digital radios consumed significantly more power than their analogue equivalents. However, we were assured by Laurence Harrison, Director of Consumer Electronics at Intellect, the body representing the UK technology sector, that the difference is now only marginal (about one per cent) and that the industry is confident of further efficiency gains (Q 588). The Government will be conducting research to examine the impact of disposal and recycling of old radios, as well as energy consumption of digital receivers as opposed to their analogue equivalent. Siôn Simon MP was not able to give us any indications as to the emerging outcomes of this research (Q 548).

ASSESSING THE ARGUMENTS

99.  We had expected that these arguments would have been closely analysed and subjected to a rigorous cost benefit analysis before now. However, the only cost benefit analysis of digital radio switchover so far carried out[61] suggested that a balance of benefit would be achieved only after 2026. Siôn Simon MP told us that the study was commissioned on the basis of the recommendations of the Digital Radio Working Group, made in December 2008, which are not exactly the same as those in the final policy, as set out in Digital Britain, so the assumptions were not strictly comparable (Q 486). It is only as a result of our enquiries that this analysis has recently been published, albeit with some of the key financial figures excluded. We strongly regret that the cost benefit analysis carried out by PriceWaterhouseCoopers was not published at the time it was delivered to Ofcom and the Department for Culture Media and Sport in February 2009.

100.  The question now is whether a fresh analysis should be carried out? The Government promised in Digital Britain that a Full Impact Assessment, including a new Cost Benefit Analysis of Digital Radio, would be conducted. Peter Davies, Director of Radio Policy and Broadcast Licensing at Ofcom, told us that the Impact Assessment had not yet been requested (Q 228). Although the Government is committed to its Digital Radio Upgrade programme, a new cost benefit analysis could provide valuable information to inform Government investment decisions and to gauge accurately the impact on consumers. We recommend that the full impact assessment, including the cost benefit analysis of digital radio, be commissioned by the Government and carried out as soon as practicable and that the results be published.

DIGITAL RADIO ELSEWHERE

101.  There is no global consensus on radio broadcasting standards: some countries are remaining with analogue radio, some adhere to DAB, and others have dropped DAB in favour of later standards such as DAB+ and DMB. At the time of writing, it appears that most European countries are committed to or will commit to the same family of digital radio standards—Eureka 147. A multi-standard, Eureka 147, chip therefore will also ensure the interoperability of digital radios across these European countries, including the UK. France will roll out digital radio services using DMB from 2010. The French government is supporting the rapid roll-out of digital radio with a law requiring that electronic products containing a radio must include a digital compatible receiver. All products including cars must have digital radio as standard before 2014. Germany will relaunch its digital services in 2010. The 16 German regional governments have agreed to start the roll out of nationwide digital radio services, using DAB+, at the beginning of 2010. The USA and Japan have opted for standards outside the Eureka 147 family.

RADIO SWITCHOVER: SHOULD WE GO AHEAD?

102.  The case for switchover of the UK's main radio services to digital is not widely known outside of the Government and the radio industry. For consumers, it does not have the clear attractions of television switchover. Given the parlous financial state of commercial radio, we are not convinced that digital switchover will necessarily give the consumer a wider choice of radio stations. Indeed, at the local level, it seems that some consolidation of existing stations is likely[62]. Neither is it clear that the consumer wants a wider choice of stations. We do not accept the argument, from the example of television, that there is pent-up demand for more choice. The success of cable and satellite television channels, prior to digital switchover, showed there to be a demand for more television choice. There is no such evidence for radio. The gradual rate of take-up of digital radio services does not suggest that consumers are enticed by the reception quality, extra functionality or the digital-only content so far available.

103.  Nevertheless, we have to accept that the path to digital has already been taken. The Government say that, with competing media moving to digital, it makes no sense for radio to remain an island of analogue. John Myers added that "The whole world is going digital. To assume that radio remains in an analogue world I do not think is viable" (Q 313). The Digital Economy Bill—broadly accepted by all political parties—is on the verge of becoming an Act, subject to negotiations in the run-up to the General Election. The radio industry has already invested on the basis of the guidance they have been given that digital radio switchover is Government policy. The motor manufacturers are planning to go over entirely to digital radios as standard by 2013. Consumers have already invested heavily in DAB radios. More generally, we accept that, to go back on this policy now would risk turning confusion into an utter shambles. However, if we are to go ahead, certain requirements must be met. The next chapter sets out what these should be.


33   As mentioned in chapter two, the move to digital radio is variously described as switchover, migration and upgrade. We have used the word switchover in this report. When we refer specifically to the Government's radio switchover programme, we have used its full name, Digital Radio Upgrade, or Upgrade. Back

34   90 per cent of the population over five years old Back

35   Ofcom Communications Market Report, 2009, p 193 Back

36   Enders Analysis, October 2009 Back

37   Ofcom Communications Market Report, 2009, p.183-184 Back

38   Figures, from RAJAR / Ipsos MORI / RSMB, are reproduced in Ofcom written evidence (page 15)  Back

39   Digital Britain, June 2009, p 93 Back

40   Grant Goddard blog 3 March 2010. http://grantgoddardradioblog.blogspot.com/ Back

41   Ofcom Communications Market Report, 2009, p 16; these figures are for total radio and television revenue, including the BBC. Back

42   An Independent Review of the Rules Governing Local Content on Commercial Radio, April 2009 Back

43   Tim Gardam: Independent Review of the BBC's Digital Radio Services, 2004, p 15 Back

44   Dual transmission is also known as simulcasting or dual illumination Back

45   Digital Britain, June 2009, p 92 Back

46   Ibid, p 92 Back

47   Ibid, p 92 Back

48   Ofcom Communications Market Report, August 2009. According to Ofcom research in Q1 2009, 61 per cent of listeners were very satisfied and 30 per cent fairly satisfied with their choice of radio stations. The total of 91 per cent satisfaction was up from 88 per cent the previous year. Back

49   Digital Britain, June 2009, p 92 Back

50   Digital Britain: the BBC's role; The BBC Executive's response to Digital Britain-the interim report, March 2009, p 35 Back

51   Ibid Back

52   Ofcom Communications Market Report, 2009, p 150 Back

53   Ibid, p.190 Back

54   The BBC's proposal appeared in the press the week before its official publication on 2 March. According to the Guardian Media of 3 March, there were already over 100,000 signatories to the on-line petition. The Guardian Media of 12 March reported that the BBC had received nearly 8,000 complaints about the proposed closure. Back

55   Ofcom Communications Market Report, August 2009. According to Ofcom research in Q1 2009, 53 per cent of listeners were very satisfied and 41 per cent were fairly satisfied with the content of what they listened to on the radio. Back

56   Letters received from members of the public are not published in this report but are available to read on the Communications Committee page of the Parliament website http://www.parliament.uk/parliamentary_committees/communications/wehlcommunications.cfm. Back

57   Daily Mirror, 1 March 2010, p10 Back

58   UKRD, which wholly owns and operates 15 local commercial radio stations, is the fourth largest radio group in the UK Back

59   Letters received from members of the public are not published in this report but are available to read on the Communications Committee page of the Parliament website http://www.parliament.uk/parliamentary_committees/communications/wehlcommunications.cfm Back

60   Digital Economy Bill, 19 November 2009, section 34 Back

61   Cost Benefit Analysis of Digital Radio Migration: Report prepared for Ofcom by PriceWaterhouseCoopers, 6 February 2009 Back

62   Digital Britain, June 2009, p.101 Back


 
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