Response to DCITA Issues Paper
“INTRODUCTION OF DIGITAL RADIO”
AsiaSpace submission to DCITA “Introduction of Digital Radio” paper page: 1
The key points of the AsiaSpace submission to DCITA’s issues paper entitled
“Introduction of Digital Radio” can be summarized as follows:
1. all of Australia, particularly rural and remote areas (including our national off
the mainland island territories), should have access to the benefits of digital
radio and not only terrestrial but also satellite radio can deliver these benefits
2. the success of satellite-DSB has demonstrated that this is a viable new
technology that has had a rapid take-up by radio consumers. In contrast,
terrestrial digital radio has struggled in most markets
3. satellite and terrestrial broadcasting can co-exist and it should be left to the
market place to determine what radio platforms are appropriate
4. the introduction of digital radio should be an opportunity to reduce barriers to
entry for new broadcast service providers
5. the DCITA policy principles should be extended to include satellite radio
6. a light handed regulatory and technology neutral approach should be adopted
7. satellite radio has certain wide area coverage and rapid roll-out advantages
for a large country like Australia
8. ITU-R radio broadcasting spectrum planning and technical recommendations
should be adopted
Future Work Program
9. a Technical Implementation Group with wide radio industry participation
should be established to assist the ABA and ACA on both terrestrial and
10. in addition to major metropolitan markets, the program should also address
timely provision of services to regional, rural and remote markets
Threshold Issues for Digital Radio (Part A)
11. the focus on terrestrial platforms and Eureka 147 issues should be broadened
to include other issues including satellite radio
12. Eureka 147 is now a very old (terrestrial only) technology that uses relatively
inefficient audio compression, and has not been particularly successful in any
13. different technology platforms (or combinations of platforms) might be
appropriate for urban, rural and remote areas
14. all digital radio technologies should use up to date spectrally efficient
encoding to facilitate more channels and innovative services
15. satellite radio also provides a robust infrastructure that is relatively immune
from the effects of cyclones, floods and bush fires that afflict regional and
16. the planned five year moratorium for incumbent commercial broadcasters
disadvantages new entrants, and should be reviewed and not be extended
17. it is possible to develop a suitable L band channel plan that accomodates
channels for both terrestrial and satellite radio services
Regulatory Issues (Part B)
AsiaSpace submission to DCITA “Introduction of Digital Radio” paper page: 2
18. the regulatory policy should provide equitable conditions for both incumbents
and new entrants and encourage investment in up to date digital radio
19. overseas experience with digital radio has shown that the key drivers are
competition between service providers, affordable receivers, more content
choice, new multimedia services, extensive coverage, appropriate regulatory
20. a channel plan should be developed for the shared use of the 1452 – 1492
MHz L band segment for terrestrial and satellite digital radio
21. access to L band spectrum should be regulated by relevant ITU coordination
and notification procedures, coupled with national licensing mechanisms. If,
after a given period of time (e.g., 5 - 10 years), the segment remains unused
by S-DSB systems, then the segment could be reassigned for use by other
Digital Audio Services (Part C)
22. An L band satellite digital radio service for Australia could be provided using a
single beam to provide coverage to all of Australia and its island territories,
with 40 - 80 channels of high quality audio and multimedia services that can
accommodate new entrants, national broadcasters and emergency services
23. a hybrid satellite/terrestrial digital radio system would require approximately
12 MHz of L band spectrum (6 for satellite plus 6 for terrestrial augmentation)
24. in the USA satellite radio has succeeded in the market place by clearly
differentiating itself from existing radio services, firstly by introducing content
not previously available, and secondly by reducing or eliminating advertising
by becoming a pay type service
Additional confidential information is provided in a separate supplementary
For clarification of any issue in this submission please contact:
Mr Les Davey VP-Regulatory and Operations
phone: 03 9693 8403
AsiaSpace submission to DCITA “Introduction of Digital Radio” paper page: 3
2. Response to the Issues Paper
2.1 Policy Principles
2.2 Future Work Program
2.3 Threshold Issues for Digital Radio (Part A)
2.3.1 Technology Platform
2.3.2 Regional and Remote Area Coverage
2.3.3 Appropriate Implementation Model
2.3.4 Availability and Performance of Spectrum
2.4 Regulatory Issues (Part B)
2.4.1 Key Drivers to support take-up
2.4.2 Data-only Services
2.4.3 Use of L band for Satellite Radio
2.5 Digital Audio Services (Part C)
2.5.1 Role of Satellite Radio
2.5.2 Coexistence of Terrestrial and Satellite services
AsiaSpace contact information
AsiaSpace submission to DCITA “Introduction of Digital Radio” paper page: 4
AsiaSpace Ltd. (“AsiaSpace”) is pleased to submit its comments to DCITA’s
issues paper entitled “Introduction of Digital Radio”, issued in December 2004.
AsiaSpace is a subsidiary of WorldSpace Inc. (“WorldSpace”), presently a privately
owned company incorporated in the state of Delaware (USA) and headquartered in
Washington, DC. Founded in 1990, WorldSpace owns and operates the AfriStar and
AsiaStar satellite radio networks, which currently provide a Satellite Digital Sound
Broadcasting (S-DSB) service to markets in Asia, Africa, Europe and the Middle
AsiaSpace was established in 1995 and operates and controls the Australian notified
ASIABSS (AsiaStar, 105.0E) satellite network from its Regional Operations Centre in
Melbourne. This network was brought into service in July 2000 and provides S-DSB
audio and multimedia services to the Asian region including South Asia (India,
Pakistan, Sri Lanka), East Asia (China, Japan), all of the ASEAN countries and
nearby countries in each of those three beam areas. The service utilizes the
international designated 1452 – 1492 MHz L band spectrum allocated for BSS (S)
and complementary terrestrial services (WARC-92). Australian territory is not in the
primary service area of AsiaStar, however there is some fortuitous coverage to the
far north-west of Western Australia and Northern Territory, where there are some
users of the current services.
The WorldSpace service is currently delivered via satellite to fixed and portable
receivers. The service currently does not include “mobile” (in-vehicle) reception,
which requires the deployment of a complementary terrestrial component.
WorldSpace is currently planning to deploy terrestrial low powered repeaters to offer
S-DSB (DARS like) services to fixed, portable and vehicular receivers in Asia,
commencing with India in late 2005 and for which trial transmissions have been
carried out from the Melbourne ROC.
The global success of satellite-DSB commencing with WorldSpace in 1999, XM
Satellite Radio in 2002 (which deploys WorldSpace technology), Sirius Satellite
Radio (2003), TU Media/Mobile Broadcasting Corporation (2004) and other planned
services has demonstrated that this is a viable new digital radio technology that has
had a rapid take-up by radio consumers. In contrast, terrestrial digital radio has
struggled in most markets.
AsiaSpace has previously made a submission to the Australian Parliament inquiry
into regional radio , and is responding to the DCITA issues paper because it
considers it important that in the development of a policy for the introduction of digital
radio the role and benefits of satellite-DSB to deliver crystal clear radio and ancillary
services for all members of the community in such a large country like Australia are
It would seem a reasonable policy formulation requirement to at least require that
services be developed within a reasonable time frame, and that provision is made
for L band satellite radio in the only frequency band designated for global satellite
AsiaSpace submission to DCITA “Introduction of Digital Radio” paper page: 5
AsiaSpace has followed up on recommendation 19 of the report of the Parliamentary
inquiry into regional radio and has recently established a trial of the WorldSpace
digital radio technology in Darwin  to focus groups in that area, working with an
existing Australian terrestrial broadcast network (World Audio Group).
AsiaSpace considers it important that:
a. all of Australia, particularly for rural and remote areas including our national
offshore island communities and areas, has access to the benefits of digital
b. Australia harmonise its national use of the L band with ITU-R international L
band frequency allocations for BSS (S) satellite and complementary terrestrial
broadcasting (1452 – 1492 MHz)
c. satellite and terrestrial radio can co-exist (i.e. are not mutually exclusive) and
it should be left to the radio industry and the market place to determine what
technologies are appropriate for Australia
d. the introduction of digital radio should be an opportunity to reduce barriers to
entry for new broadcasters and other interests
2. RESPONSE TO THE ISSUES PAPER
DCITA published its issues paper on the introduction of digital radio in
December 2004. The issues paper contains a set of policy principles to guide
consideration of digital radio issues, future work program, and three parts (Part A-C)
covering, “Threshold Issues for Digital Radio”, “Regulatory Issues”, and “Digital
The following comments address each of these sections.
2.1 POLICY PRINCIPLES
AsiaSpace generally supports the DCITA policy principles, however we
suggest that the introduction of digital radio should be an opportunity to lower the
barriers to entry for new broadcasters and other interests (e.g for education, health,
agriculture, environment and even emergecy needs), not to raise the existing
barriers by special commercial conditions to protect particular incumbents.
Also, AsiaSpace suggests other important policy principles are:
a. a light handed technology neutral regulatory approach that leaves it to the
radio industry and commercial market to decide on appropriate technologies
and services (different technologies might be appropriate for urban, rural and
b. that satellite has certain wide area coverage and rapid roll-out advantages for
a large country like Australia
c. national spectrum planning should be based on ITU-R spectrum planning and
technical recommendations and accommodate both terrestrial and satellite
2.2 FUTURE WORK PROGRAM
AsiaSpace submission to DCITA “Introduction of Digital Radio” paper page: 6
AsiaSpace considers that the future work program should also have
participation by the radio broadcasting industry, and in addition to major metropolitan
markets should also address regional, rural and remote markets.
A Technical Implementation Group, with wide radio industry representation, should
be established to assist the ABA and ACA with this work.
2.3 THRESHOLD ISSUES FOR DIGITAL RADIO (Part A)
AsiaSpace notes that the DCITA threshold issues only concern terrestrial
platforms, and concentrate on Eureka 147 issues. We consider that a broader
perspective is required that also considers satellite platform issues.
Comments on the threshold issues raised by DCITA follow.
2.3.1 Technology Platform
AsiaSpace considers that the radio market and commercial market should
decide on appropriate technology platform/s, and that different technology platforms
(or combinations of platforms) might be appropriate for delivery of digital radio to
urban, rural and remote areas.
It is important that DCITA should ensure that all digital radio technologies implement
up to date spectrally efficient audio encoding to promote spectrum efficiency and to
facilitate more channels and innovative services.
Different satellite radio platforms are available that have certain wide area coverage
and rapid roll-out advantages for a large country like Australia. These systems use
up to date spectrally efficient audio encoding (eg AAC+), and have been successful
in the market place, especially in USA.
Eureka 147 is now a very old (terrestrial only) technology that uses relatively
inefficient audio encoding and occupies more RF spectrum, and has not been
particularly successful in any market.
2.3.2 Regional and Remote area coverage
The timely provision of national, commercial and community digital radio
coverage to regional and remote areas is an important issue to ensure that all
Australians have rapid access to the benefits of digital radio.
The cost, limited coverage and long construction time for terrestrial only digital radio
will disadvantage access by Australians in regional and remote areas.
As for the provision of telecommunications services to these areas, satellite has
certain advantages including wide area coverage and rapid roll-out.
Satellite broadcasting also provides a robust infrastructure that is relatively immune
from the effects of cyclones, floods and bush fires that afflict these areas. This is
important for providing disaster warning and relief services, as has been shown for
the recent Asian tsunami. AsiaSpace been able to provide through Melbourne,
emergency radio services to support the Indian Disaster Management and Mitigation
AsiaSpace submission to DCITA “Introduction of Digital Radio” paper page: 7
relief operations at Chennai to provide guidance , health and sanitation, stress
management counselling to those in distress at the coastal centres. Later similar
relief services, including the above as well as news and childrens programmes in
local languages, were also delivered to the Aceh disaster area.
Also, in cooperation with the Australian Meterological Bureau and NOAA (USA)
AsiaSpace has been delivering hourly and half hourly weather forecasts and
information to the Asia Pacific Region.
The expected upgrading of the Australian Early Warning system adds a new
opportunity to the unique capability that satellite radio may offer for Australia,
recalling the earlier devastation of Darwin, and the recent concerns post Tsunami
and Cyclone Ingrid.
2.3.3 Appropriate Implementation Model
AsiaSpace supports a Market-based approach, based on equitable conditions
(ie level playing field) and a light handed regulatory approach, and one that lowers
rather than raises existing barriers to entry for new broadcasters.
Commercial broadcasters will then be able to make commercially based risk and
reward business decisions on the feasibility of investing in digital radio broadcasting
It is noted that the Government has already committed to a five year moratorium for
incumbent commercial broadcasters. AsiaSpace considers that this seriously
disadvantages other potential entrants, and that any move to increase the
moratorium period should be rejected by the Government, and allow market forces to
2.3.4 Availability and Performance of Spectrum
AsiaSpace considers that it is important for Australia to make the international
L band allocation of spectrum for BSS(S) and complementary terrestrial (1452 –
1492 MHz) available for S-DSB services in Australia. This spectrum was originally
allocated by the ITU-R at its 1992 World Radiocommunications Conference (WARC-
92) to facilitate the introduction of global S-DSB services.
WorldSpace the Global Pioneer in radio broadcasting by satellite, has utilised this L
band spectrum segment to establish its AfriStar satellite network in 1999 serving
Africa, Middle East, and part of Europe, and its AsiaStar satellite network in 2000
serving all of Asia.
It is possible to develop a suitable national L band channel plan that accomodates
channels for both terrestrial and satellite digital radio services. Such a plan has been
adopted in Europe.
2.4 REGULATORY ISSUES (Part B)
AsiaSpace considers that the working assumption of adoption of only a
Eureka 147 platform is inappropriate for Australia for the reasons previously stated in
sect 2.3, and that the decisions on technology platforms should be left to the radio
industry and commercial market place.
AsiaSpace submission to DCITA “Introduction of Digital Radio” paper page: 8
Accordingly, the AsiaSpace response to Part B will not address issues raised in the
issues paper that are specific to Eureka 147.
Also, as AsiaSpace is a broadcast infrastructure provider and not a broadcaster the
AsiaSpace response will not comment on the role of national and community
broadcasters other than to reiterate that the benefits of digital radio should be
available to all Australians.
Instead the AsiaSpace comments will focus on more fundamental regulatory issues.
The regulatory policy should concentrate on providing a light handed regulatory
framework that provides equitable conditions for both incumbents and new entrants
and encourages investment in up to date digital radio technology to provide the
benefits of quality and new services to all Australians.
The key regulatory issues are considered to be:
a. lowering barriers to market entry for new broadcasters
b. use of spectrally efficient audio encoding to promote RF spectrum efficiency
to facilitate more channels and innovative services
c. harmonising national use of the L band with ITU-R L band frequency
allocations for BSS (S) satellite and complementary terrestrial broadcasting
(1452 – 1492 MHz)
d. providing equitable access to spectrum
e. equitable radio licence conditions
2.4.1 Key drivers to support take-up
Overseas experience with digital radio has shown that the key drivers to
support take-up of digital radio are:
a. competive service providers
b. affordable receivers
c. new and innovative content with more choice
d. new data and multimedia services
e. extensive coverage
f. appropriate regulatory framework
S-DSB (DARS) has been very successful in the USA because it has focussed on the
key drivers. There are two competing service providers, the receivers are affordable,
there are approximately 100 channels to choose from, traffic and weather data
channels provide up to date information, and the service is available throughout the
USA. Also the FCC provided sufficient spectrum and a regulatory framework to
encourage 2 satellite operators, and promote competition.
It should be noted that the satellite radio system used by the most successful USA
S-DSB operator (XM Satellite Radio) uses the WorldSpace hybrid satellite radio
system, but operates in the S band (L band not available for BSS(S) in USA.
The requirement for new and innovative content that provides more choice should be
used as an opportunity to encourage new content providers and broadcasters to
enter the market and stimulate competition. Conversely, radio consumers will not
AsiaSpace submission to DCITA “Introduction of Digital Radio” paper page: 9
support digital radio if the choice of content is similar to the limited range of content
on existing analog FM radio.
2.4.2 Data-only Services
The capability to provide new data-only services is an important feature of
digital radio platforms and should be left to the commercial market to decide on its
viability, not tightly regulated, and not be the subject of a new restrictive licence type.
WorldSpace has developed a number of new applications that utilise the data
capability of satellite radio to provide new and innovative services including
affordable distance education, government health agricultural and other information,
real time stock prices, newspaper and magazine distribution , and web browsing.
This capability when used with satellite radio broadcasting provides a robust and
affordable emergency warning infrastructure that is relatively immune from the
effects of cyclones, floods and bush fires that can afflict urban, regional and remote
2.4.3 Use of L band for Satellite Radio
In considering how L band spectrum should be allocated in Australia for digital
radio it is important to understand that in 1992 the International Telecommunication
Union (ITU) allocated the band 1452-1492 MHz to the Broadcasting-Satellite Service
(Sound) [BSS(S)], in all regions limiting immediate use to the upper 25 MHz of this
allocation (Resolution 528 (Rev. WRC-03)).
WorldSpace pioneered the use of this band for S-DSB with its AfriStar satellite
(1999) and its AsiaStar satellite (2000). There are also a number of other BSS(S)
satellite filings, from a number of administrations and satellite operators, being
processed by the ITU. This means that there is an existing world-wide market
served by a number of receiving equipment manufacturers of affordable L band
equipment. The large market and competition between manufacturers has seen a
continuing reduction in the cost of L band satellite radio receivers.
Also, note that in Europe the European Conference of Postal and
Telecommunications Administrations (CEPT) has made provision for S-DSB systems
in the segment 1467-1479.5 MHz of the L band BSS(S) allocation.
An important task for a broadcasting industry Technical Implementation Group
should be the development of a channel plan for the shared use of the 1452 – 1492
MHz L band segment for terrestrial and satellite digital radio, so that the existing
embargo on this band can be removed.
Accordingly, AsiaSpace respectfully requests that the L band segment 1467-1492
MHz be retained in Australia for S-DSB and complementary terrestrial services,
pursuant to Res. 528 (Rev. WRC-03). Access to this band should be regulated
pursuant to relevant ITU coordination and notification procedures coupled with
national licensing mechanisms. If, after a given period of time (e.g., 5 - 10 years),
the segment remains unused by S-DSB systems, then the segment could be
reassigned for use by other radiocommunications services.
AsiaSpace submission to DCITA “Introduction of Digital Radio” paper page: 10
2.5 DIGITAL AUDIO SERVICES (Part C)
The following AsiaSpace comments focus on the role that satellite digital radio
can fulfill, its benefits for Australia, and how satellite and terrestrial radio can co-
2.5.1 Role of Satellite Radio
The successful business model for satellite digital radio in the USA has been
based on a subscription service, rather than the traditional free-to-air business model
used for terrestrial radio.
The rapid take-up by satellite radio subscribers in USA (approx 5 million )
indicates that there is a mass market for a service that provides more choice, high
quality audio, and wide area coverage. The predictions are that there will be a total
of more than 20 million satellite radio subscribers in the USA by the end of 2010 .
The success of this subscription based business model means that most new
satellite radio operators will adopt the subscription based business model.
An L band satellite digital radio service for Australia could be provided using a single
beam to provide coverage to all of Australia and its island territories, with 40 - 80
channels of high quality audio and multimedia services. The service would be mainly
based on a subscription model, can facilitate new entrants, and also make provision
for free-to air channels for national broadcasters and emergency services.
For mobile operation, in urban areas where urban infrastructure (buildings etc) can
interrupt or block the direct satellite signal reliable mobile reception can be provided
by the use of low-power terrestrial repeaters (arranged as an SFN).
Based on the WorldSpace Digital System Dh, a hybrid satellite/terrestrial digital radio
system to provide the service outlined above would require approximately 12 MHz of
L band spectrum (6 for satellite plus 6 for terrestrial augmentation) of the ITU-R
BSS(S) allocation of 40 MHz. This can be accommodated within a channel plan
shared with terrestrial services, and harmonized with ITU and CEPT allocations.
The use of S band ITU footnote frequency allocations for DARS in the USA and for
S-DMB by Japan and Korea was a consequence of national planning considerations
that have no relevance for Australia.
2.5.2 Coexistence of Terrestrial and Satellite services
The recent experience in the USA has shown that satellite and terrestrial radio
can coexist, and that competition and market forces will determine business
The USA satellite DARS service has succeeded in the market place by clearly
differentiating itself from existing radio services, firstly by introducing content not
previously available, and secondly by reducing or eliminating advertising by
becoming a pay type service.
Rather than competing directly with existing radio services, the USA satellite DARS
service has added a new type of service to extend and grow the radio business.
AsiaSpace submission to DCITA “Introduction of Digital Radio” paper page: 11
The same business considerations should be left to the Australian market place to
determine the viability of a satellite DARS like service.
AsiaSpace appreciates the opportunity to comment on the DCITA issues
paper and to contribute to the development of an appropriate policy for the
introduction of digital radio that will benefit all Australians.
The main concern of AsiaSpace is the need to ensure that the policy for the
introduction of digital radio makes a balanced provision for satellite delivery, not only
terrestrial, and to provide the opportunity for nation wide high quality radio and
ancillary services, within a reasonable time frame.
We urge DCITA to quickly establish a radio broadcasting industry based Technical
Implementation Group to advise it on key policy issues including:
1. modern and spectrally efficient digital radio technologies, including satellite
radio, suitable for urban, regional and remote areas
2. development of a national L band channel plan that accommodates both
terrestrial and satellite radio
AsiaSpace submission to DCITA “Introduction of Digital Radio” paper page: 12
AsiaSpace Contact Information
For any clarification, or additional information, regarding this submission please
Level 5, 6 Riverside Quay
South Bank, Melbourne
Attn: Mr Les Davey VP-Regulatory and Operations
ph: 03 9693 8403 fax: 03 9693 8535 email: email@example.com
 AsiaSpace submission to Parliamentary Committee Radio Industry Inquiry
into Regional Radio, November 2000
 “Local Voices: Inquiry into Regional Radio”, House of Representatives
Standing Committee on Communications, Transport and the Arts, September
 ”DARS and DBS”, Via Satellite, March 2005
 “Advantage DARS”, Satellite Magazine, March 2005
AsiaSpace submission to DCITA “Introduction of Digital Radio” paper page: 13