My comments on some of the submissions:
Sport FM - It would be fair that the commercial service moving onto that frequency shares some/all of their costs of moving them off that frequency, and a contribution towards helping their promotion of their shift.
SEN - Interesting that they have taken the approach of arguing that they should also be on FM, rather than instead trying to leverage a commercial AM license out of the situation. I think itâs a bit much trying to claim itâs unfair that a narrowcast license is treated differently to a commercial or national license.
Mollo - The FM band extension is something Iâve advocated for in the past on here - thereâs no alternate usage proposed for it, so would be very good for expanded DRM+ trials or LPONs and HPONS. Indeed if SEN want to switch from AM, it should be into the top end of an expanded FM band.
SCA - well what would you expect. If they canât operate economically having one of a tiny number of commercial radio licenses in one of the biggest cities in the country - sell it to someone who can. Thereâs no âcurrent economic climateâ that theyâd ever say âsure, more licenses are fineâ.
6IX - I like the exactly one mention of DAB in the whole document. That bad AM or the tiny FM translators are their listeners only choice. Should they get a conversion just because they are bad at communicating the benefits of Digital to their listener base?
Nova - I like that their argument in favour of not expanding FM contains a table showing that of the 4 FM commercial stations, thereâs only two unique formats in their eyes, âGreatest Hitsâ and âRock Musicâ. Unlike SCA, they donât even consider the minimal change option for the ABC getting 1 conversion as okay. I somewhat agree 6PR/6IX should have to pay a fee to convert - perhaps this could be suspended for 10 years and only triggered by a change of ownership?
6PR - I like that they concede that the ABC needs to be converted and object to the options that leave the ABC on AM. I suppose itâs enemy of my enemy stuff.
KCR - I like that theyâve asked for access to DAB as an alternative/supplement. They make a good point.
CBAA - It is absurd how low the bitrates are for cramming in the community stations, they are right to ask for a second DAB+ frequency to fix that.