OPEN LETTER ON DIGITAL RADIO - Brazil
30.04.2010
- Brazil 
On the last day March 30 the Ministry of Communications published Ordinance No 290, establishing the Brazilian System of Digital Radio (SBRD), setting the same goals. Although the text of the Ordinance does not advance far beyond what was already included in the text of Public Call last year, we understand that we are entering another stage in the standard-definition of digital radio to be adopted in Brazil. Since this is an issue of great public interest, the undersigned entities launch this open letter as a warning to the authorities and a call to Brazilian society. We understand that the digitalization of broadcasting is an essential factor for the sustainability of the radio environment of media convergence. The change represents an improvement in sound quality, especially in relation to AM, new uses and functions for the receiver, including the provision of data and value-added complementary services, and technological devices which also use the same digital languague. While radio is already present on the Internet and cellular, we believe that the digitization of transmission can integrate it with media convergence. However, for this to happen consistently, it is essential that the technological definition is preceded by the definition of service models and business, since the current impasses of radio are located in the lack of these models. We have clarified the social importance of radio for its strong presence in the everyday life of most of the population. It is a means of information and entertainment par excellence, especially for those in transit in cities and those living in the countryside, small towns in rural and particularly in macro-regions like the Amazon. Integrating the communication system of the country significantly. There are more than eight thousand stations in operation supporting business, education and community. The business offers more than 300 000 direct and indirect jobs, and earn $ 1,673 per year million (FGV research and IBRE 2007). We also have awareness of the slow process of migration to digital transmission recorded in much of the world. The difficulty is related to technological characteristics of available systems that hamper their adaptation to the broadcast model, the regulatory framework and market rules in each country. In some European countries, the digital signal system DAB (Digital Audio Broadcasting), for example, has good reception inside buildings, especially those situated in streets with high density of buildings and traffic. We know that the American system HD Radio (IBOC) presents similar problems: the signal is low compared to station analog signal. In addition, HD Radio receivers are incompatible with DAB and DRM. We recognize that the Ministry of Communications has promoted testing in search of a pattern that may be suitable for the broadcasting system in Brazil. We tested only two rules for digital radio: HD Radio (also known as IBOC) standard owner of the United States, whose test results do not seem to have been as expected, and they deserve even greater dissemination and publicity, and DRM (Digital Radio Mondiale), of European origin, whose tests are being conducted on a scale far below the IBOC and not even been completed. We argue that this testing process should broaden and deepen, and should be a lot more transparent and public. We also recognize that the Decree No. 290/2010 of March 31, 2010 the Ministry of Communications establishing the Brazilian System of Digital Radio - SBRD is positive because it signals to the fundamental values that should guide the choice of technological solutions, are highlighted and are: a) providing efficient use of radio spectrum b) permit the participation of institutions of higher education and research in the adjustment and improvement of the system according to the needs of the country, c) solutions to enable low-power transmissions, with reduced costs; d) facilitate the creation of network of distance education, e) encourage local and regional industry in the production of digital tools and services f) to foster technology transfer for the Brazilian industry of transmitters and receivers, guaranteed, where applicable, the exemption of royalties. While these and other guidelines are essential, we believe that the ordinance did not end the debate about the model to be followed, not even the set, and thus indicates the need for openness and time for society to appropriate more of the issues related to digitization the radio. It should be ensured along this next step, greater transparency and public control in this process. There was recently a debate at the First National Conference on Communication, that called for the urgent opening of deep and consistent debate involving the society in a broad process of consultations and public hearings with the sectors of broadcasting (public, private and community), industry equipment, and technicians from the Ministry of Communications of Brazilian universities and research centers. Accordingly, the undersigned institutions and entities are asking the Ministry of Communications to set up a Working Group (WG) that has the objective to design a common strategy on policy for the deployment of digital radio in Brazil as well as enable monitoring by entities on next steps in the consolidation of public officials that policy. Initially the group will discuss the policy guidelines (diversity, plurality, universality and gratuity) and technical guidelines (royalties, coverage, spectrum use, bundled services, among others) presented in Ordinance No. 290/2010 in the light of the results of tests already performed with HD Radio and DRM. Besides advocating comparative international experiences with other systems such as DAB and his family (DAB +), DMB, DRM and ISDB-TSB FMeXtra. We argue, therefore, a thorough evaluation and comparison of these models relating them to the tests of efficiency already achieved. We believe that the SBRD be transformed into its own law, to be approved by Congress. But before this improvements from the discussions to be held by the WG should also be included. Remember that an early decision, without proper assessment of its impact on our broadcasting system, may result in low service penetration, prejudice to the broadcasting industry, reduced interest of the population, not expansion of jobs and lack of public policies to maximize the digital inclusion and public services. We are aware that the adoption of any system without rigorous debate and reflection, or automatically and without technological improvements may lead to serious problems and do not meet the Brazilian reality. Therefore, we can not rule out the future possibility of Brazil come to opt for a genuine national SBRD with technology, with the guarantee of due financial and structural incentives for their achievement. We know that regardless of the model to be adopted, adjustments may be made necessary. And it becomes strategic to know what are our demands for improvement and how we can involve all sectors can contribute to the improvement and adaptation of the system. This debate, we insist, must be preceded by debate on the service models and business, since without democratic models and accessible to the Brazilian radio continuity is not assured. On the possible changes, remember what happened to Digital TV, where the Japanese ISDB has been developed further, going to use the MPEG-4 encoding and interactivity Ginga, developed in Brazil by universities and UFPB PUC-Rio. As with any transition it will be necessary to understand the process of building public policy for digital radio needs to be based on some criteria such as: a) ensuring the maintenance of free access to radio, by the listener, b) transmission audio quality of reception in any situation, c) adaptability of the technical standard to the park installed d) coevolution and coexistence with standard analog, e) low-cost receivers, f) adoption of a non-proprietary technology and the potential to interconnectivity with other media, g) real-time interactivity, h) multiprogramming i) democratization of the use of spectrum, with the increase in the number of grants available and the large presence of public radio and community j) guarantee equal conditions for the process transition to standard procedures, including the radios coimunitárias. The criteria that preserve in some way, experience social, historical and cultural environment. Integrated into a way of life, the radio is linked to the cultural identities of place, the daily knowledge, the sharing of common assets such as language, music, work, sports, festivals, among others. It is a place of public recognition as belonging to a cultural dynamic site. So to make sense and be useful, the interventions of public policy in the structures are guided and justified by objectives related to the content. Means for highlighting not only the relations between economy and politics, but also the size of consumption. That implies to consider culture as an inherent component of the formulation of public policies for transition to digital radio. The migration of Brazilian radio standard analog to digital and the integration in technological convergence is a public policy interest of the whole of Brazilian society in the interest of entrepreneurs, professional communicators, listeners, public managers, technicians and general public. Therefore, this public policy should be constructed broadly democratic, listening to the whole of society and ensuring popular participation tools and public control. Brasília, 23 de abril de 2010 Assinam esta carta aberta as seguintes entidades: ABRAÇO – Associação Brasileira de Rádiodifusão Comunitária ANEATE – Associação Nacional das Entidades de Artistas e Técnicos em Espetáculos de Diversão AMARC – Associação Mundial das Rádios Comunitárias ARPUB – Associação das Rádios Públicas do Brasil CUT – Central Única dos Trabalhadores CFP – Conselho Federal de Psicologia FENAJ – Federação Nacional dos Jornalistas FITERT – Federação Interestadual dos Trabalhadores em Empresas de Radiodifusão e Televisão FNDC – Fórum Nacional pela Democratização da Comunicação INTERCOM – Sociedade Brasileira de Estudos Interdisciplinares da Comunicação INTERVOZES – Coletivo Brasil de Comunicação Social