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					Rebel Media
P O Box 332 Beaudesert Q 4285
T: 07 5541 4222 F: 07 5541 4444 E: aaron.jowitt@rebelfm.com.au M: 0418 752 200



Gavin Oakes
Sector Analysis and Reporting Section
ACMA
PO Box Q500
Queen Victoria Building NSW 1230

Wednesday 29 March 2006



Dear Gavin,

    Variation of Programming Within RCRS License Areas –
                ACMA Issues Paper March 2006

Rebel Media operates commercial radio services Rebel (4RBL) and Breeze (4BRZ)
which are licensed to serve parts of regional, rural and remote Queensland/NSW.
Rebel FM is currently provided via 32 FM transmitters, Breeze FM via 4 FM
transmitters. Both services, including 3 regional variations of the Rebel FM
service are available in near CD quality digital stereo via satellite across Australia.

Rebel Media supports changes to legislation to allow complete freedom to carry
separate programming on transmitters within its license area, without limitation.


The Rebel Media Market
The market is easily the largest and most diverse of any commercial radio
broadcaster on the eastern seaboard. It includes over half the land mass of
Queensland and stretches from the coast line of Papua New Guinea 2,500
kilometres down to Wilcannia near Broken Hill in western NSW. Yet it is typically
sparsely populated with no large population centers or cities within it.

It includes the town with the coolest climate in southern Queensland and the
town with the hottest climate in North Queensland. It stretches from world
renowned tropical island tourist resorts, rain forest, coral reefs through to mines,
desert and vast dry cattle properties in the west. It spans two states and time
zones. There are many parts of the license area that have no common
geographic, economic, social or industry ties with another part of the license
area, apart from the fact they are in Eastern Australia and in our license area.

These geographic differences drive a push for Rebel Media, where and if viable, to
provide different content on its transmitters to better reflect the local/regional
needs of the market, as localism is one of the strengths of regional commercial
radio. To help cater for those needs, currently Rebel FM provides four different
regional variations of its service within Queensland, Breeze FM provides two
regional variations of its service.

Additionally there are now significant differences in the number of radio services
available to residents within different parts of the Rebel Media license. For
example, many rural Queensland towns served by the Rebel FM service (such as
Alpha) can only receive two other radio stations; ABC Radio Regional and ABC
Radio National. Alpha has 3 free to air analog TV channels.

In another completely different part of the Rebel Media license area, Beaudesert
township has 10 licensed commercial radio services (11 if high grade overspill
from Ipswich River 949 is included), 7 community radio services, 4 ABC radio
services, 1 SBS radio service and 1 narrowcast radio service. It has 8 free to air
analog/digital TV channels.


The Need For Complete Programming Flexibility on
Transmitters
Commercial radio stations operating in a highly competitive well serviced market
would typically be driven to have a program format that is tightly targeted to an
opening in the market, rather a broader 'all things to all people' format of a
remote solus/duopoly market. Rebel Media operates services in both those
environments, yet across its vast market it is restricted to a 'regional variation' of
its main service forcing it to carry a similar program format. The legal boundary
of 'regional variations' we are currently permitted has never been clearly defined
by ACMA, leading us to err on the side of caution rather than risk breaching the
act by providing too much localism in part of our license area. This limits the
relevance of the services we can provide.

The Rebel Media license area neighbors or overlaps 45 commercial radio markets
in Queensland/NSW. 44 of those markets are relativity small geographically and
therefore they are currently typically able to provide a regionally relevant service
across their entire license area. Where those signal and/or license areas overlap
with the larger adjacent Rebel Media license area, it places Rebel Media at a
disadvantage, as the neighboring broadcasters that service or overspill into our
market have the potential to be more regionally relevant to towns near our
license area boundary than we ourselves are permitted to provide.

Complete programming freedom would allow us to finally operate on a level
playing field with neighboring market stations by choosing a format and content
that best suits the market. It's our view that CRA and IRB oppose these changes
as it's in the commercial interests of a number their member stations to continue
to have an unfair advantage over Rebel Media in those situations. It makes it
easier for them to take advantage of fortuitous signal overspill and/or licence
area overlap with the Rebel Media license area.

ACMA and DCITA would be aware that there has been escalating community
concern voiced since 1992 at the increasing trend of networking regional/rural
commercial radio at the expense of localism. It's hard to imagine that the current
restriction on programming variations within our license area was ever intended,
but rather is a result of legislation that was developed at a time when there was
far less commercial radio competition within parts of the Rebel License Area.

For example, Tamborine Mountain was the largest duopoly population center
within our license area, with Rebel Media the only licensed commercial (or
community) station on the mountain. ACMA (ABA) recently permitted significant
additional competition to enter that market and Mount Tamborine now has 5
licensed commercial radio services (and 4 community radio stations that can
carry 'promotional sponsorship)'. There could well be further dramatic license
area changes down the track, so it's important that legislative changes allow the
flexibility for Rebel Media to immediately respond to those changes if and when
they happen. Rebel Media ideally should have the freedom to completely change
formats in any part of its license area, while retaining the flexibility to provide
different services to a less competitive part of its license area.

While we have no immediate plans to have 100% different formats under the one
license within our licence area, future market growth and/or competitive changes
in a select part of our license may compel us to do so. That may involve branding
a 4RBL or 4BRZ service in a part of our market under a completely new format
and different name to another part of the market.

At the moment, both our stations formats are primarily driven by the larger more
competitive parts of our license area that generate the bulk of our broadcast
revenue, which at times does compromise the format of choice for solus/duopoly
parts of our license area.

With our current license area, there is negligible immediate commercial benefit in
having any greater programming flexibility, as any extra revenue generated in
providing a different service to the smaller regional/rural duopoly areas is likely to
be no greater than the additional cost of providing the separate programming
feed given the limited commercial size of the market we operate in. But where
viable, it would allow us to consider providing services more suited to each area
without any risk of breaching the act.

The freedom should extend to each transmitter, given that efficient ACMA
spectrum planning has ensured that there is minimal overlap, if any, in the
primary coverage area of each transmitter attached to the same license.

This is similar to the approach ACMA take to overlap in terrestrial commercial
radio license areas, where license area population overlaps of under 30% are not
considered to be directly competitive.

Another example is the operational model of ABC radio, which operates four radio
networks nationally. One of those national networks is known as ABC Local
Radio. ABC Local Radio network in Brisbane is branded as ABC 612 (4QR) and
carries markedly different programming to the ABC Local Radio network outlet in
the neighboring market of the Sunshine Coast, which is separately branded as
ABC Coast FM.

Rebel Media would still only operate two networks within its license area, but like
the ABC, would have the complete freedom to choose what content to provide on
each transmitter it operates. It is desirable that any new legislation is not
platform dependent, to allow greater flexibility for future DAB services in the
same coverage area.
Should Changes Extend Beyond RCRS Licenses?
We have no concern if legislative changes were to include the terrestrial only
commercial radio stations. We support changes that allow Rebel Media services
and terrestrial only services to operate on a level playing field. We would be
wary about changes that create a new and different class of license in the act for
RCRS licenses.

Non-BSB licenses should ideally not be included, as anyone seeking to provide a
different service in a different region can easily apply to ACMA for a new and
separate Section 40 license for that area. To include section 40 licenses has no
real benefit and risks allowing further exploitation of the loophole that allowed
AM-NAS operators to establish commercial radio services under a section 40
license.

Regards




Aaron Jowitt
DIRECTOR

				
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