They (WPC) have an active link list scrolling down, and one of the items is
"Last date for comments NFAP 2008" (not the exact wording) which downloads a
.doc file (I have protested to the Wireless Adviser at the consultation in
Ahmedabad the continued use of proprietary format downloads where a simple html
page serves the purpose). The link is prominently marked "New", so I clicked on
it, to receive a tiny little document whose entire text I copy here:
" A meeting of NFAP review committee was held under the chairmanship of
Wireless Advisor to the Government of India on 29 April 2008 at 1500 hours at
Sanchar Bhawan, New Delhi to discuss the draft India remarks based on comments
received from various stake holders in NFAP-2008. The summary record of the
meeting has already been placed in web site. The last date of comments on draft
NFAP received by various stake holders is 12 May 2008.
If no comments are received by late evening of 12 May 2008, it would be
presumed that that concerned organization/ stake holders have no comments to
offer."
Continuing the spirit of Sajan's remarks, about the achievements of the I&B
ministry, with this irrelevant document (at least on 25 Dec, it seems to me to
have long since expired from any state of relevance) being highlighted as "New"
seems to reflect a singular lack of understanding of 'achievement' at WPC as
well. There may be a mention of the 1-month extension somewhere else, but I
don't really see how that matters six months later.
Anyway, an extract from the Draft NFAP document that Ram mentioned, for the FM
band, reads as follows:
IND11 The requirement of broadcast
services will be considered in the frequency band 87-91.5 MHz and 95-100 MHz on
case-by-case basis.
IND12 The frequency band 91.5-95
MHz is earmarked for FM broadcasting.
IND13 Frequency spots in the
frequency bands 88-100 MHz and 103.8-108 MHz for private FM broadcast have been
specifically identified.
I think the following observations are in order:
1. A geospatial map of the country and frequency usage, updated frequently
(following changes and specific allocations), will go a long way in making the
provisions of IND11, 12 and 13 (which deal with the 'FM broadcast' bands)
practical and proactive.
2. With IND12 specifying the earmarking of 91.5-95 MHz for FM broadcasting, it
makes sense for the WPC to routinely assign frequencies from this band to low
power community radio broadcasting stations, which by their very nature do not
pose a significant interefence problem for the typical private (commercial) FM
broadcaster (ref the Mitre study commissioned by the US FCC, establishing this
relationship through field research, report available as pdf from
http://www.mitre.org/work/tech_transfer/technologies.html*). This may replace
the current practice of allocating only 3 specific frequencies to such stations
in the whole country. As specific frequencies have been already allotted
between 88-100 MHz to private broadcasters, cf IND13, the de facto allocations
in the past may be treated as exceptions and the practice discontinued
henceforth, following the spirit in which public broadcasting stations set up
by PB in earlier years continue to occupy
freqeuncies in the 103.8-108 MHz band.
3. Unlike the reserved analogue and data communication bands, which are of
direct interest to a relatively small number of discrete organisations, the
treatment of these 'FM broadcast' bands are important to entire communities of
population in many parts of the country. The consultation process around
planning the usage of these bands should be made inclusive, through the use of
available open RFC technologies applied on the WPC website, in order to enable
and facilitate comments from different sectors of the people, as also to
address issues raised through what becomes in effect an open forum.
*Very low power broadcasting, (compared to the kind of stations being set up in
the US in large numbers, under 100W EIRP was considered low power, unlike here
in India, where the I&B ministry proposes the same value as the upper limit
necessary for community radio stations), was shown as effectively
non-interfering with powerful broadcast stations in the same geographical area.
In fact, the organisation actually recommended that the expensive followup
study originally planned, in order to understand the kinds of interference
being experienced, be dispensed with entirely with, as there was effectively no
interference. This makes the encouragement of all kinds of stations an
attractive proposition - from the very inexpensive micropowered community radio
stations, up to 100W EIRP, which is what the community radio policy considers
suitable at the upper limit on power, through open licensing - as they directly
address the capabilities and potential of
communities that are economically poor and/or unsupported by external agencies.
The main findings of the report are:
"1. Reduction or elimination of existing third-adjacent channel** LPFM minimum
distance separation requirements is possible without increasing the potential
for third-adjacent channel LPFM interference to existing stations.
2. Adoption of a more stringent third-adjacent channel LPFM emissions mask
would mitigate LPFM interference potential because most LPFM transmitters
achieve spurious emission suppression in excess of the current mask value.
3. Third-adjacent channel LPFM stations will have little or no effect on the
transition to terrestrial digital radio since third-adjacent channel LPFM
interference to digital receivers is unlikely to occur beyond 130 meters from
the LPFM transmitter.
4. Due to the lack of measurable interference produced by third-adjacent
channel LPFM stations during testing, the listener tests and economic analysis
scheduled for Phase II of the LPFM field tests and experimental program should
not be done."
**in 2000, the US Congress passed a bill, somewhat of a kind as the bills being
rushed through Parliament in the last few days, to restrict LPFM to 3 channels
away from the nearest powerful broadcaster. This effectively eliminated most of
the LPFM. Later, Congress ordered the Mitre study, published in 2003, but so
far has not acted to counter the 2000 bill. So much for US leadership of the
democratic process worldwide, just in case anyone on this list still
entertained doubts.
I could not find Mr Sharma's email address, although I did find his telephone
and fax numbers here: http://www.wpc.dot.gov.in/Static/wpcofficerdirectory.asp.
If anyone is able to assist faxing him the above, or forwarding it by email,
please do go ahead. However, it might be better to collect further observations
and present them jointly.
Actually, I find IND12 curious, and mystifying at the same time. If it is
deemed necessary to specify this allocation now, what was the band being used
for earlier, or at any time, that calls for such a detailed note? Does anyone
know? I seem to recall that the ITU recommends the band 88-108 for FM
broadcasting, but allowing member countries (India is a leading signatory) some
leeway at the fringes, hence our using 87 for the lower cut-off. I checked the
ITU site, and although many of the working paper titles are quite enlightening,
the documents themselves are all locked. I could not find the specific
description of the allocation of frequencies for this purpose.
Vickram
http://communicall.wordpress.com
http://vvcrishna.wordpress.com
________________________________
From: Ram <[email protected]>
To: [email protected]
Sent: Thursday, 25 December, 2008 13:42:48
Subject: [cr-india] New Frequency Allocation Plan- India remarks
Hi All,
Please check the WPC website (www.wpc.dot.gov.in), as the latest inputs
for the frequency allocation plan have been submitted by various parties
involved, like telecom, private broadcasters, army etc.. (The file is
called Draft NFAP 2008 - Draft IND EMARK
although a new player, community radio is conspicuously absent. Can we
have someone from the cr circle put out a recommendation in the document...
i believe the last date for comments is over, but all the people who
have contributed to the document have asked for a one month extension to
understand the document better...
Recommendations may be sent to Mr. S M Sharma (from WPC) in writing or
email...
We have also heard from "reliable sources" :) that a percentage kind of
comment won't work... (discussions have veered towards asking for 20% of
spectrum reserved for community broadcasting)
As others have asked, I believe it is much better if we ask for specific
number of frequencies (we have currently been allotted 3) or ask for a
certain amount of frequency (like 1 MHz, or 2 MHz or whatever)
Can anyone who has experience/expertise in these things come up with
some concrete recommendations for community radio?
Best Wishes,
Team@ Maraa
--
Ram
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