Government admits: no assessment of impact on small FM commercial radio stations of Digital Economy Bill

House of Commons
21 January 2010
Written Answers to Questions

Digital Broadcasting: Radio

Mr. Alistair Carmichael (Orkney and Shetland): To ask the Secretary of State for Culture, Media and Sport what assessment he has made of the likely effects of digital switchover under the provisions of the Digital Economy Bill on the ability of local commercial radio stations without a digital path to continue to broadcast on the analogue spectrum.

The Parliamentary Under-Secretary of State for Culture, Media and Sport (Mr. Siôn Simon): No specific assessment has been made of the impact of the radio provisions set out in the draft Digital Economy Bill on local commercial stations remaining on FM after the digital radio switchover. However, these provisions, and the proposals in the Digital Britain White Paper, were made following 18 months of consultation with the radio industry, which included representatives of small local commercial stations.

I am continuing this dialogue with the industry with the specific purpose of ensuring that local radio can continue to thrive on FM after the digital radio switchover.

Digital Broadcasting: Scotland

Mr. Carmichael: To ask the Secretary of State for Culture, Media and Sport what percentage of Scottish households are able to receive digital radio services; what plans his Department has to increase coverage for digital radio in Scotland before 2015; what the cost of implementing those plans will be; and who will pay for the implementation.

Mr. Simon: The Spectrum Planning Group, which formed part of the Digital Radio Working Group, reported in November 2008 that 77.8 per cent. of the population in Scotland had access to indoor Digital Audio Broadcasting (DAB).

Coverage of digital radio broadcasting in the UK continues to increase and both the commercial and the BBC’s national multiplexes now reach about 90 per cent. of the UK population. The Digital Radio Upgrade programme will require new investment in building and improving DAB coverage and reception. To this end we will be working with the BBC and commercial operators to ensure coverage of DAB is comparable to FM by the end of 2014.

The Digital Britain White Paper was clear that the investment need to increase coverage will need to come from both commercial operators and the BBC.

Mr. Carmichael: To ask the Secretary of State for Culture, Media and Sport what percentage of households in Scotland receive (a) digital commercial radio and (b) BBC digital radio services.

Mr. Simon: The Spectrum Planning Group, which formed part of the Digital Radio Working Group, reported in November 2008 that 76.2 per cent. of the population in Scotland had access to digital commercial radio services, while 77.8 per cent. of the population in Scotland has access to BBC digital radio services. Figures are based on indoor coverage.

GERMANY: “FM is and will continue to be the most important means of transmission for radio,” say commercial broadcasters

Commercial radio broadcasters in Germany have published a policy paper emphasising that FM will continue to be the main broadcast platform for radio. The VPRT, a trade association of 160 commercial broadcasters (70 of whom are active in radio), this week responded to the draft Work Programme for 2010 set out by the Radio Spectrum Group [RSPG] of the European Commission. One of its proposed work streams had been “to discuss the pros and cons of indicating a target date for analogue radio broadcasting (FM) switch-off.”

The formal response from VPRT sets out powerful arguments why current FM spectrum (referred to as ‘Band II’) will continue to be radio’s most important platform for broadcasting:

The future development in the different frequency bands (especially Band II) is of utmost importance to our radio service members. Therefore, we are seriously concerned about the fact that RSPG is considering a target date for analogue radio broadcasting (FM) switch-off.

Nevertheless, we see the need to think about future developments and possible usages of Band II which comply with the provisions of the GE84 [Geneva radio conference of 1984] agreement and ensure FM services which are able to operate free of any interference. At the same time, we would like to stress the necessity of adapting and developing those GE84 provisions to ensure the continuity of Frequency Modulation (FM) and the future usages in Band II. However, this needs to be achieved without further co-ordination at international level.

1. Band II with FM is and will continue to be the most important means of transmission for radio
Band II with FM is the most important means of transmission for VPRT’s radio service members. Also, in the foreseeable future, Band II with FM will remain the basis of commercial activities for private radio stations. This is grounded by two reasons: firstly, the heavy usage by listeners and, secondly, the very high market penetration of FM receivers. Currently, more and more new Band II FM receivers are establishing in the market. As a consequence, the receiver basis is modernised constantly. Modern communication devices, such as mobile phones, smart phones and media players, integrate Band II FM receivers and ensure an even wider availability of FM. Switching off FM transmission is therefore neither realistic, nor can it be crowned with success.

2. FM in Band II is of utmost importance in the case of catastrophe
Due to the extremely high penetration of FM devices in Europe and its heavy usage, Band II is the only reliable way to inform the public in the case of catastrophe or need of contacting citizens in an emergency. This was recently proven when a blizzard hit Germany at the beginning of January. This is also valid in case of a regional power cut, as many devices are powered by batteries. For the time being, no digital receiver (DAB, etc.) has been developed for the operation with battery.

3. Band II is a small but efficiently used frequency range
The so-called Band II is the frequency range between 87.5 and 108 MHz and only represents 20.5 MHz. Nearly every single frequency is used in this bandwidth. Together with the broad receiver penetration and very high usage by the listeners, this small bandwidth is very efficiently used. In the last few years, receivers have been significantly developed which today results in an enormous improvement of their reception quality. Millions of listeners are convinced by the characteristics of FM. Even under very difficult circumstances for receiving a signal, a very good reception is possible. On the other hand, other (digital) systems are disconnected in a very early stage, which is rather disadvantageous. The usage of Band II is still “state of the art”.

4. No migration or partial migration of the services in other frequency spectrum
VPRT rejects any proposals which include the shifting of the current usage from Band II to other frequencies. This would bring the intensive and effective use of Band II to an end. Due to the lack of digital receivers, as well as of the absence of consumer demand for change and migration, a restart of a digital system would mean inefficiency and un-sustainability for a very long period of time. In other bands, there is enough space to introduce new systems. Band III (174 to 230 MHz, channels 5 to 12) and therewith corresponds to 56 MHz – is available.

5. Consideration of future developments of FM transmission after GE84
Since the Geneva conference of 1984 (GE84), different parameters of the FM usage in Band II have changed. In the meanwhile, different and changed sources of signals are available (music), the signal processing was adapted and a compression of the signals was introduced. The processing of the FM signals in the receivers is completely digital. 25 years after G84, the provision from the Geneva plan should be adapted and developed according to recent technical developments.

6. There is a chance for new standards with unlimited parallel FM operation
In the medium term, there are different options to develop the use of Band II. The use of FM has to remain, due to the heavy use described in point 1.4. An unlimited parallel FM operation offers the opportunity of financing additional engagements from the remaining FM transmission. Further developments with new standards based, on additional unlimited parallel operation of FM, is a chance for economical efficiency. Therefore, it is necessary to adapt the ETSI spectrum mask ITU-BS.412-9, as well as other ITU-R recommendations, by keeping the guidelines for aeronautical services (VOR and ILS). In this way, the “envelope concept” which was already used in the GE06 plan could be kept. Therewith, new standards under an adapted ETSI spectrum mask would be possible without interfering with the existing FM transmission and conditions. In this case, a new planning conference would not be necessary.

We support a conversion to digital assignments if the FM transmission can be maintained without any limitation. In this case, a switch from single FM transmission into a digital transmission would be possible, without discriminating other FM transmissions.

We do not see a future for technologies which are linked to a switch-off of the FM transmission.

7. Interference with FM through new standards have to be avoided
As already mentioned in point 6, it must be avoided that future technology developments cause any interference to the existing FM transmissions. A reduction of the current coverage caused by future developments is not acceptable for VPRT members. Some aspects of the technical developments are promising but, due to a lack of information, a full evaluation is not possible.

8. No international re-planning of Band II or of parts of it
Due to the very intensive and effective use of Band II, we do not see any need for a long and very costly international re-planning. The GE84 plan should be supported in its principles and adapted as mentioned in point 6. Even a re-planning of certain parts of the Band II would not lead to any benefit, as the complete Band II is used and needed in the future.

9. Re-adjustment of Band II at national level is necessary
However, we always have been calling for a re-adjustment of Band II at national level in order to balance the relation between public broadcasters and private broadcasters. At the moment, we face an imbalance with regard to the amount of frequencies, as well as the frequency capacity, held by public broadcasters on the one hand and by private broadcasters on the other hand. We therefore ask for a readjustment which takes the actual demands into account. The introduction of new standards would carry forward the current imbalance.

10. Further research and economical comparison are necessary
Next to the research and comparison, with respect to the technical characteristics and parameters of the available standards, further research is needed to complete a substantial evaluation. For the time being, an evaluation of the economical and financial factors is still missing. We therefore ask to also take those aspects into consideration.

Summary of VPRT comments
• Band II with FM is and will continue to be the most important means of transmission for radio
• FM in Band II is of utmost importance in the case of catastrophe
• Band II is a small but efficiently used frequency range
• No migration or partial migration of the services in other frequency spectrum
• Consideration of future developments of FM transmission after GE84
• There is a chance for new standards with unlimited parallel FM operation
• Interference with FM through new standards have to be avoided
• No international re-planning of Band II or of parts of it
• Re-adjustment of Band II at national level is necessary
• Further research and economical comparison are necessary

Berlin, January 2010

[this is VPRT’s own English translation]

Labour MP says government's analogue radio switch-off "is absolutely potty”

House of Commons
18 January 2010
Oral Answers to Questions

Rob Marris (Wolverhampton, South-West) (Labour): My understanding is that the Government currently propose that analogue radio be switched off in 2013. If that is the case, it is absolutely potty. Will the Government reconsider?

The Parliamentary Under-Secretary of State for Culture, Media and Sport (Mr. Siôn Simon): My hon. Friend is, for once, slightly wrong on the detail. The policy is that we move to digital in 2015, but not that analogue radio be switched off. Most big radio stations will move to digital, but smaller commercial and community radio stations will stay on FM and will be, as I have said, on the same dial as the big digital stations.

House of Commons
18 January 2010
Written Answers to Questions

Theresa Villiers (Chipping Barnet) (Conservative): To ask the Minister of State, Department for Transport with reference to the answer to the right hon. Member for East Yorkshire of 23 June 2009, Official Report, column 768W, on motorways, what assessment he has made of the effects on the level of motorway congestion of the DAB radio service Traffic Radio since its introduction.

The Parliamentary Under-Secretary, Department for Transport (Chris Mole, Ipswich) (Labour): Traffic Radio is one of a suite of Highways Agency information services designed to provide road users with access to the very latest traffic information.
Research has shown that awareness and usage of information services can influence levels of motorway congestion. It is not possible to directly correlate the impact of Traffic Radio to motorway congestion due to the complexity of assessing one information service in isolation from the others. In addition, information is only one of a series of measures that can contribute towards congestion reduction.
The Highways Agency is undertaking a piece of research to evaluate whether the anticipated benefits of Traffic Radio, as outlined in its original specification, have been realised. This work is due to be completed by April 2010 and will be supplemented by information from the agency’s annual Measuring Improvements in Network Information Services survey.

Parliamentary debate on local radio: Minister reads from the government DAB script

“The Future Of Local Radio” [excerpts]
Private Members’ Debate
Westminster Hall, House of Commons
12 January 2010 @ 1330

The Parliamentary Under-Secretary of State for Culture, Media and Sport (Mr. Siôn Simon): Local radio is, without question, important to the Government and to communities, playing an important role in binding together the social fabric. We take it very seriously.

Dan Rogerson (North Cornwall) (Liberal Democrat): On the point about the importance the Government place on local radio, it seems that local radio stations, and certainly those in my constituency, Pirate FM and Atlantic FM, do not necessarily feel that they have had the opportunity to get their points across at an early stage. That is why they are now contacting local Members to look at some of the issues when the Digital Economy Bill is debated on the Floor of the House. What sort of consultations are taking place with local radio stations?

Mr. Simon: The hon. Gentleman is quite right; there is undoubtedly some concern in the industry. There has been a bit of a campaign, led by UTV. I recently met, at RadioCentre, representatives of many local commercial local radio stations from across the country, and some of them will have been those he mentioned from his constituency. There was extensive consultation when the Bill was drafted, so we do take it seriously. During my remarks, I hope to allay some of the fears which may have emerged through misunderstanding.

Bob Spink (Castle Point) (Independent): There are genuine fears that the Bill will lead to a two-tier system, so would the Minister address a couple of those fears? Will Clause 34 genuinely lead to deregulation for smaller local radio? Will digital be affordable for smaller local radio, and how can we achieve that? Will smaller local radio get more access to higher-quality FM while it is still around?

Mr. Simon: I am pretty confident that I shall address all those points in my brief remarks. Let me make some progress before I take any more questions. Digital switchover provides new opportunities and increases functionality. It is an essential part of securing the long-term future. The total revenue of the commercial sector has fallen from £750 million in 2000 to £560 million now. At the same time, transmission costs have gone up, with stations now bearing the cost of carriage on FM, DAB, online and digital TV. A market facing such rising costs and falling revenue is unsustainable and puts the health of the entire sector under threat. Although the path to digital may not be easy, we are convinced that it is the only route for securing the long-term future of radio, and that is a view shared by the vast majority of the sector, notwithstanding some of the reservations raised by hon. Members. Therefore, rather than a catalyst for decline, the changes set out in the Digital Economy Bill are essential to secure the survival of local radio. For the first time, we will have three distinct tiers. First, there will be a tier of national services, both commercial and BBC, with a wide range of content. It will allow the commercial sector to compete more effectively with the BBC, employ high-profile presenters and attract high value national advertising and sponsorship. Secondly, a regional or large local tier, again comprising commercial and BBC services, will provide a wide range of programmes, including regional news, traffic and travel. The tier will increase the coverage size and potential revenue of many large local stations which, in turn, will increase the opportunity for linked advertising between regions so that regional commercial operators can benefit from quasi-national advertising. The hon. Member for Orkney and Shetland mentioned the issue of advertising being badly commissioned by the Scottish Government, which I understand. None the less, the benefits of linked advertising for regional radio can be very great if commissioned sensitively. Most important in the context of today’s debate, there will be a tier of local and community radio stations with the specific focus of informing and reflecting the communities they serve. They will be distinct from the national and regional tiers because of the very local nature of their content and they will benefit from less competition for local advertising funding.

Mr. Oliver Letwin (West Dorset) (Conservative): People in my constituency and elsewhere who depend on radios will not be able to get local radio if it is purely digitised.

Mr. Simon: Local radio will not be purely digitised. That tier will stay on FM for the foreseeable future, but it will not be an FM ghetto; it will be an accessible FM, as I shall explain.

Mr. Brian H. Donohoe (Central Ayrshire) (Labour): Given the time constraints, will the Minister agree to meet Members who are interested in the subject?

Mr. Simon: Yes, I am happy to meet Members who are interested. I have another meeting scheduled with local radio operators from all over the country, which will be under the same auspices as my recent meeting with them. (I am not sure whether I have enough time to continue. I do.) So, let me be clear: we see a digital future for all radio eventually. However, with more than 50 BBC services, nearly 350 commercial stations, 200 licensed community stations, the current infrastructure will not support a move to digital for everybody. For small commercial and community stations, the coverage area and the cost of carriage of a digital multiplex are too great. That is one reason why, for the time being, we believe that those stations are best served by continuing to broadcast on FM.

Malcolm Bruce (Gordon) (Liberal Democrat) rose —

Mr. Simon: I am nearly coming to my point, but I give way to the right hon. Gentleman.

Malcolm Bruce: Some of the small stations have already invested in being on digital. Are they not in danger of being kicked off to FM, having made that investment, and would that be a fair outcome?

Mr. Simon: No, small stations are not in such danger. Stations that are already on digital are not in danger of being kicked off digital, but they are suffering the extra cost of running on two platforms. That is one of the reasons why we need an orderly, managed and reasonably speedy transition to an affordable single platform for as many people as can afford to be on it. The idea of stations on more than one platform is not new, which moves us to a key point that has not been widely understood — it is really important. Listeners have for decades moved between FM and Medium Wave, and historically also to Long Wave. The current generation of DAB sets has tended to make that move a rather sharp distinction, which has led to the fear that FM will end up being a second-class ghetto tier. To avoid that, we are committed to ensuring the implementation of a combined station guide, which is similar to an electronic programme guide, that will allow listeners to access all sets will simply have a list of station names. The listener will not distinguish between FM and digital stations, but will simply select the station by name. We are already working with the industry on that system and encouraging its development and introduction as quickly as possible. That is a crucial difference that has not been widely promulgated or understood. It means that people can stay on FM and the new sets can service the same market. Only 5 per cent of the digital radio receivers currently on sale cannot receive FM. It is our intention that all digital receivers should be able to receive FM as well as complying with the World DMB profile, which will ensure that they can support other technologies to accommodate future changes. That crucial distinction has not been widely understood. When I explained it to people in the industry, it made a big difference. The hon. Member for Orkney and Shetland asked whether we could upgrade to DAB+ from the beginning. I understand why he says that, but we are not right at the beginning. There are 10 million DAB sets out there for which people have laid out large amounts of money. The BBC completed a study into the issue last year, and concluded that, on balance, it was not worth writing off that technology because of the impact on the 10 million people who had bought DAB sets. We have said that all new technology should be DAB+ and future compatible so that further change is future-proofed and DAB+ is not excluded. As for the switchover date of 2015, the hon. Gentleman asked whether it was the only way we would get things moving. The Government believe that 2015 is an achievable date. The actual date that switchover happens will depend on the criteria for listenership and coverage being satisfied. We think it can be done by 2015, and that it is important to set a challenging target. The issue of £20 sets was raised. There are already some £30 sets. We have five years to go until 2015, so we remain confident that we will have £20 sets by then.

Miss Anne Begg (Aberdeen, South) (Labour): I am interested to hear what my hon. Friend says about the 2015 date. Can I take it from what he said this morning that 2015 is an aspiration to encourage the industry to move towards digital — to put their house in order and get things ready? However, if the coverage is not there in places such as the constituencies of the hon. Member for Orkney and Shetland (Mr. Carmichael) and the right hon. Member for Gordon (Malcolm Bruce) where there are a lot of hills, will the Government look at the date again? That date is not already fixed.

Mr. Simon: As I said, we believe it is an achievable date. If more than 50 per cent of listeners are not on digital by then, and if coverage is not similar to FM — 98.5 per cent — it will not happen on that date. If for any other unforeseen reason, we are not, as a nation, in good shape to do it by then, we will not do it. We will not switch over at an inappropriate time, but we believe that it can and should be done in 2015. As time ticks on, let me say that a relatively small and cheap piece of hardware will be available to convert in-car sets to something that works in the future as well as the present.

[Sitting adjourned without Question put (Standing Order No. 10(11)).]

Kiss FM: it's the same old songs

London dance music radio station Kiss FM has re-scheduled its specialist shows to slots after midnight, according to The Guardian, and has cut their duration from two hours to one hour. Almost nobody listens to radio on a weekday after midnight, RAJAR audience data show, so the policy change condemns these shows to a radio graveyard that is very close to extinction.

According to Kiss FM specialist DJ Logan Sama: “The shift of focus away from upfront specialist music to more playlisted hours is one which the management feel will enable the station to compete with the likes of Capital and Galaxy FM. All of the genre-specific late-night shows took the brunt of the hit.”

When Kiss FM was launched in 1990, its specialist music shows started at 7.30pm on weekdays, and the preceding half-hour magazine show ‘The Word’ created a watershed between the daytime mainstream playlist and the more radical evening shows. There was a specific commitment in the station’s licence to broadcast these shows so that Kiss FM would give airplay to music unheard anywhere else on the radio in London.

In the intervening years, through attrition, Kiss FM’s owner (EMAP then, Bauer now) has succeeded in ‘persuading’ the regulator to loosen these licence requirements for the station to broadcast specialist music shows. To its discredit, the regulator has seemed happy to go along with such proposals, permitting Kiss FM to be turned into a much more mainstream hit-orientated station than it was ever intended to be.

What the regulator and some radio owners seem to fail to grasp is that, in a crowded radio market such as London, one station can attract a significant (and loyal) audience by doing something deliberately different both from its competitors and from its own daytime mass-market output. This works both commercially and altruistically. In the case of Kiss FM, advertisers can reach a niche audience that daytime shows do not deliver (if I organise a reggae concert, the best place to advertise it is in a reggae radio show); citizens are offered a genuine extension to the ‘listener choice’ that the regulator loves to cite.

This is not just a theory – there is plenty of empirical evidence to demonstrate how it works. Look at Helen Mayhew’s evening ‘Dinner Jazz’ show on the original London Jazz FM, which was almost the only show on the station that delivered 100% jazz music, but also had higher ratings than any of the daytime playlisted output.

Kiss FM itself provides a good example of what can be achieved. In the graph above, the red line shows the current audience of Kiss FM London (RAJAR, Q3 2009) peaking at 147,000 adults at breakfast between 8 and 8.30am, then falling to a minimum of 1,000 adults by the early hours of the next morning. This is the normal pattern of listening for a mainstream music radio station in the UK.

The blue line shows the Kiss FM London audience a decade earlier in 1999 when specialist music shows still occupied the weekday evening hours. Note that, in the evening, during most of the hours from 7pm to midnight, the audience was bigger a decade ago than it is now. Has the subsequent replacement of specialist music shows with mainstream music in the evening improved Kiss FM’s audience at those times? Apparently not.

After the station launched in 1990, the daytime audience was lower than it is now, but the evening specialist music programmes generated huge audiences. Some of the Kiss FM evening shows attracted more listeners than any other London station in these evening timeslots, ranking them #1 in that daypart.

This was not an accident. Kiss FM’s original schedule was deliberately designed to attract significant audiences to each of a wide range of specialist music shows broadcast on weekday evenings. Listeners loved them – individual shows were promoted heavily on-air and in specialist music magazines. Advertisers loved them – the rates were cheaper than daytime and the spots regularly sold out.

Doing something different on-air can reap rewards, if you satisfy genuine listener demand and promote the hell out of it, so that people know the programmes are there. But, if you simply do the same in the evening that you are doing during daytime, your station is going to have much the same declining listening pattern as any other radio station.

If you compare Kiss FM’s current listening pattern to that of its competitors, you can see from the graph above that it delivers much the same weekday shape – a continuous decline from a peak at breakfast. The exception amongst the London commercial stations is Magic’s unusual peak between 10 and 11pm. Why? Because it schedules ‘The Mellow Ten At Ten’ each weekday evening from 10pm, a one-hour feature that breaks from its playlist.

Also noteworthy in the graph is the unusually high evening audiences achieved by Choice, with more listeners than the station attracts during the afternoon. Why? Because Choice schedules specialist music shows during weekday evenings (mixes, reggae, hip hop). Again, being different can pay off for both audiences and advertisers.

This concept – that individual radio stations often struggle to sound the same, even though ‘daring to be different’ pays dividends – has been understood since the earliest days of media theory. American economist Peter Steiner wrote:

“…. the existence of [different] program types and [different] audiences therefor is assumed by the broadcasting industry and forms the basis for [station] program decisions. In this case, it is the assumed size and distribution of listeners’ preferences that is decisive in determining the amount of [programme] duplication that will result. If, as is often suspected, broadcasters exaggerate the homogeneity of audiences and their preferences for certain program stereotypes, the tendencies towards [programme] duplication will be increased.”

Writing in 1951, Steiner already recognised that radio station owners will tend to duplicate each others’ formats and programme scheduling, rather than offering their audiences something different or unique. He wrote:

“The problem, of course, is that a series of competing firms, each striving to maximize its number of listeners, will fail to achieve either the industry or the social good. Here, then, competition is providing a less than desirable result.”

In the UK, our government created a broadcast regulator to intervene in the market to ensure that commercial radio station formats maximise the ‘social good’, as Steiner refers to it. The UK is in a very different situation from the US, where the regulator (FCC) does not interfere in the formats of radio stations. But the UK system will only work if the regulator understands the economic and social imperatives for market intervention and exercises those powers appropriately.

The increasing marginalisation over the years of Kiss FM’s specialist music programmes demonstrates that the regulator is oblivious to the economic and social imperatives to regulate. Instead, it is simply conspiring to deny both listeners and advertisers the programme diversity they should be entitled to. The fact is that ‘light touch’ radio regulation is not regulation at all, any more than driving a car with no hands on the steering wheel would be considered by a court to be ‘driving’.

A regulator that simply allows market forces, in Steiner’s words, to produce “a less than desirable result” is not regulating. The Independent was quick to blame Kiss FM’s owner:

“Once the king of pirate radio, the legendary station Kiss is being dragged into the mainstream by owners Bauer Media, which will today cut back a number of the Kiss specialist music shows and axe several presenters in order to reposition the network to take on Global Radio operations such as Galaxy. Shame.”

However, the blame should fall squarely on the regulator for allowing a station owner to pursue an objective that further restricts consumer and advertiser choice. There is no ‘free market’ for radio in London – the gap in the market created by Kiss FM’s marginalisation of specialist music genres and DJs will not be filled by another licensed radio station …… only by London pirate stations.

Pirate radio stations seem to be the only ones that implicitly understand Steiner’s competition theories perfectly, and they risk the consequences for putting them into action. Pirate radio’s popularity is no accident – it is a direct outcome of the failure of the regulator to regulate.

FRANCE: de-localising RFM and Virgin Radio

Like the UK, commercial radio in France is delivered both nationally and locally. Category ‘C’ stations have local studios, employ local staff and are permitted by the regulator to sell local advertising and use a national brand name, as long as they produce a minimum of 3 hours per day of local programmes. Category ‘D’ stations are broadcast nationally from one central studio, have no local offices and are only allowed by the regulator to sell national advertising.

Now it seems as if some of the local radio operations of European media conglomerate Lagardere, branded RFM and Virgin Radio in France, might have to be closed. “We are in the process of looking at some of them,” said Lagardere Active chairman Didier Quillot. The objective, he told Le Monde, is to know “whether they are all profitable”. The newspaper commented: “the future looks bleak for those that are not.”

Monday 14 December 2009 was a busy day for Lagardere. In the morning, it made a detailed presentation to the CSA, France’s media regulator, about “the economic and financial situation” of its RFM and Virgin Radio local operations. In the afternoon, it repeated the presentation to the IRTS public body, trade unions and staff representatives of the two networks.

RFM is presently available from 192 transmitters across France, of which 55 are local Category ‘C’ stations. Virgin Radio is available from 228 transmitters, of which 146 are local Category ‘C’ stations. Each of the local stations employs at least one journalist and one producer (as required by the regulator) plus advertising sales staff. Lagardere insists that, for the moment, “no decision has been taken and no request has been filed with the regulator”.

A few weeks ago, the programme director of RFM and Virgin Radio, Jean Isnard, produced a study on the future of local radio. Its conclusion was that it would be more profitable to close down some local stations and centralise them in Paris. Such closures, converting Category ‘C’ to Category ‘D’ stations, are unlikely to be implemented until February or March 2010, once the regulator has approved. Lagardere has referred to this strategy as “drastic economic measures” although it has reiterated its “determination to maintain a significant local presence”.

One insider told Le Monde: “For Didier Quillot and Alexandre Bompard, CEO of Europe 1, the crisis impacting the radio sector is not cyclical but structural.” Lagardere is also trying to sell its Paris sports news station, Europe 1 Sport, which is losing 1.2m Euros per annum. It had acquired the station two years ago, intending to transform it into a national station on T-DMB digital radio. However, as Le Monde commented: it is “too expensive, too late!”

The journalist union, SNJ, has denounced Lagardere’s proposed re-structuring of RFM and Virgin Radio “in the strongest terms”. It suspects that 25 local offices would be closed and 40 jobs are threatened. It accused Lagardere of using the economic crisis and competition from new media as pretexts for a purge of local journalists.

Meanwhile, competing national radio station RTL (owned by Bertelsmann) has seen advertising revenues fall 10% year-on-year, despite being ranked #1 station in France for the last three years. On Thursday 17 December 2009, management requested 30 voluntary redundancies from the station’s 300 staff. Chief executive Christopher Baldelii told Le Figaro: “Being market leader is good, but we must not rest on our laurels. RTL has to be modernised to increase its competitiveness”. The objective is to save 20m Euros over the next three years.

GERMANY: government proposes to re-launch DAB in 2011, if sufficient interest

In Germany, the Commission for the Approval & Supervision of State Media Authorities, ZAK, has published a new directive today that attempts to stir interest in resuscitating the country’s DAB radio system. It requires the media authority of each German state to issue a common tender by 22 January 2010, calling for applications by 12 March 2010 from those who want to provide national radio services on DAB.

This new plan involves re-launching DAB radio in Germany in early 2011, but only “if sufficient qualified commercial applicants” show interest in acquiring licences, according to ZAK. Two-thirds of national DAB multiplex capacity has been allocated by the government to commercial radio, with the remainder for state broadcaster Deutschlandradio.

ZAK says it is seeking proposals for new digital stations that “strengthen the diversity of viewpoints in Germany” by offering information, business, sport, religion and specialist music formats. However, this suggestion flies in the face of evidence from other countries where it has not proven commercially viable to offer specialist radio formats on a national DAB platform, even after many years of consumer hardware take-up. For example, in the UK, many radio formats have come and gone on the DAB platform over the last ten years, including:

• news (ITN News 2000-2002)
• business (Talkmoney 2000-2003)
• 50s/60s music (PrimeTime 2000-2006)
• country music (3C 2000-2007)
• teenagers (Capital Disney 2002-2007)
• contemporary pop music (Core 1999-2008)
• soul music oldies (Virgin Groove (2000-2008)
• pop music for young women (Capital Life 1999-2008)
• book readings & talk (OneWord 2000-2008)
• jazz music (TheJazz 2006-2008)
• extreme rock music (Absolute Xtreme 2005-2009)

The worst thing a nascent or potential business can do is fail to learn from the experiences of those who have attempted the same proposition previously and failed. Continually re-inventing the wheel is a waste of human and financial capital. The agencies that are charged with promoting DAB broadcasting could do the global broadcast industry a massive favour by analysing and documenting why each of these stations, and others like them in other countries, failed. There is much more to be learnt from the 95% of business failures than from the 5% of successes.

Propagating the notion globally that DAB radio has been nothing other than a huge success in the UK is horribly irresponsible. More than £600m has been sunk into DAB in the UK over the last decade, but not one content provider has yet generated an operating profit from the platform. Actively encouraging and promoting implementation of DAB radio overseas as a means for broadcast entrepreneurs to emulate the ‘success’ achieved in the UK is as immoral an export as selling cigarettes to developing countries as a ‘luxury’ good.

Judged by their previous rejections of the DAB platform (see my July 2009 blog), radio stakeholders in Germany have demonstrated that they are not so easily duped.

Radio in the Digital Economy Bill: three more amendments tabled

The following amendments to the Digital Economy Bill will be considered at Committee Stage in the House Of Lords, scheduled for 20 December 2009 and 6, 12 , 18 January 2010.

CLAUSE 30: DIGITAL [RADIO] SWITCHOVER

What does Clause 30 do? According to the government’s Explanatory Notes:

“Clause 30 allows the Secretary of State to give notice to OFCOM of a date by which digital switchover must occur for services specified in the notice. In making a decision to nominate a switchover date, the Secretary of State must take account of any reports by the BBC and OFCOM about the future of analogue broadcasting.
The date for digital switchover is the date after which it will no longer be appropriate for the service in question to be broadcast in analogue form.
The Secretary of State may nominate different switchover dates for different types of radio services and may withdraw a nomination of a switchover date.
After a switchover date has been set, OFCOM are required to vary the licence periods of all licences for the services specified by the Secretary of State so that they end on or before that date. However, OFCOM cannot shorten the duration of a licence so that it would end less than 2 years from the date on which OFCOM give notice of the variation, unless the licence-holder consents.
OFCOM may not vary a licence period so that it ends after the switchover date.”

A.      Lord Clement-Jones and Lord Razzall have proposed an amendment to Clause 30:

Page 33, line 19, at end insert—
“(2A) The Secretary of State may not nominate a date for switchover—
(a) unless it can be established that all local commercial radio stations will have the opportunity to move to digital audio broadcasting,
(b) until the proportion of homes in each of the four nations of the UK able to receive—
(i) national BBC services,
(ii) national commercial radio services,
(iii) local BBC services, and
(iv) local commercial radio radio services [sic],
via digital audio broadcasting is equal to the proportion able to receive them via analogue broadcasting.
(c) until digital audio broadcasting accounts for at least 67 per cent of all radio listening, and
(d) until digital audio broadcasting receivers are installed in 50 per cent of private and commercial vehicles.”

Page 33, leave out line 21 and insert—
“(a) must ensure that all commercial and BBC radio services broadcasting in the UK have the opportunity to switchover on the same date,”

Page 34, line 1, leave out “2” and insert “4”

In (my) plain English, this amendment would prevent the government from announcing a single digital radio switchover date until:
• Listening via DAB accounts for two-thirds of all radio listening
• DAB radios are installed in 50% of cars
• 50% of households in each nation have access to a DAB radio
• All BBC and commercial stations, large and small, have been offered the opportunity to migrate from analogue to DAB.
In practice, none of these criteria could possibly be met within the next decade, which would effectively scupper the notion of a digital switchover date. Additionally, a four-year termination notice period would be inserted into renewed commercial radio licences (instead of the government’s proposed two-year period).

B.      Lord Cotter has proposed a separate amendment to Clause 30:

Page 33, line 33, at end insert—
“97AA Disposal and recycling of domestic analogue radios
(1) Following a decision to give notice to OFCOM under section 97A of a date for digital switchover, the Secretary of State must devise a scheme for the disposal and recycling of domestically owned analogue radios.
(2) The scheme must include provision for a financial incentive for domestic owners of analogue radios to purchase a radio suitable for digital audio broadcasting following disposal and recycling of their analogue radios.
(3) The financial incentive must be based on any profit made from the disposal and recycling of analogue radios and must not be derived from public funds.”

In plain English, consumers will have to be paid something for all those analogue radios they will be expected to no longer use.

CLAUSE 31: RENEWAL OF NATIONAL RADIO LICENCES

What does Clause 31 do? According to the government’s Explanatory Notes:

“Clause 31 allows the further renewal of national analogue licences for a period of up to seven years. All of these licences have already been granted a renewal of 12 years under the powers in section 103A of the Broadcasting Act 1990 (“the 1990 Act”). ……”

Lord Clement-Jones and Lord Razzall have proposed an amendment to Clause 31:

“The above-named Lords give notice of their intention to oppose the Question that Clause 31 stand part of the Bill.”

In plain English, this amendment would delete the proposal in the Bill to automatically renew the three national commercial radio licences for a further seven years. Instead, the licences would have to be auctioned individually to the highest bidder, as required by existing legislation. The greatest impact would be on Classic FM, whose licence would have to be advertised by Ofcom in 2010, if this amendment were passed. Its owner, Global Radio, would be faced with Hobson’s choice – either to bid a significantly higher amount (maybe £10m+ per annum rather than the present £2m+ per annum) to win/retain the licence, thus diminishing its ‘cash cow’ status, or to lose the single most profitable licence in commercial radio. Either option might seriously undermine Global Radio’s ability to trade profitably and to service its debt.

Internet radio: denigrate it, ignore it, marginalise it … consumers will still listen

It was a surprise to find that the entire front page of the most recent issue of the World DMB Forum’s global newsletter (‘Eureka!’) was filled with an article that did not extol the virtues of the DAB/DMB platform, but instead tackled the online radio platform and drew the conclusion that the internet “will NOT replace traditional broadcasting”. The article, entitled “The Future Of Radio”, sought to debunk the assertion that “the internet is the future of radio”.

It stated that the BBC iPlayer “allows the UK public to access almost all of its radio and TV programmes broadcast during the previous seven days”. This is inaccurate. The iPlayer offers nothing like “almost all” the BBC’s radio and TV output. Indeed, for some of the BBC’s radio and TV networks, the selection of content remains remarkably thin (mostly due to rights issues).

The article continued: “Given the outstanding success of the BBC’s iPlayer, it is surprising to learn from RAJAR’s latest audience figures that ‘radio via the Internet’ (in all its forms: live streaming; on-demand services and podcasting) accounts for only 2.2% of radio listening in the UK.

This is untrue. The RAJAR 2.2% share figure ONLY includes simulcast live streams of the BBC and UK commercial broadcasters. It does not include on-demand services; it does not include podcasts; it does not include listening to online radio services such as Last.fm, Spotify and Rhapsody; and it does not include listening to audio from overseas broadcasters. There is a detailed section on the RAJAR web site that explains these facts. RAJAR has never claimed that its data for ‘internet’ listening includes anything other than simulcast live streams of BBC and UK commercial radio stations.

The article then drew the conclusion: “Taking these differences in penetration into account shows that DAB listening in the UK is 10 times more popular than listening via digital TV or via the internet.” However, it is unclear what the phrase “10 times more popular” is trying to imply. Is that ‘10 times more listening’? Or maybe ‘10 times more reach’?

Interestingly, exploring the latter metric, RAJAR’s own research (as part of its MIDAS survey, rather than the main diary survey) found in December 2008 that the weekly reach of all internet-delivered radio content in the UK was 14%, compared to the DAB platform’s weekly reach of 17.8% during the same quarter (see graph below). Ten times more popular? The platforms were almost neck-and-neck in the ‘reach’ metric. I wrote about this research a year ago. It is the closest we have for now to a like-for-like comparison that includes all forms of audio delivered by the internet.

  

The most recent reach data for the internet platform in the above graph derives from Q3 2008 because RAJAR has not publicly released comparative data derived from its two subsequent MIDAS surveys (which are now only available on subscription).

RAJAR was keen to stress in its press release accompanying this week’s latest MIDAS 5 survey that:

74% of those Listen Again http://on-demand listeners said the service has no impact on the amount of live radio to which they listen, while half said they are now listening to radio programmes to which they did not listen previously”.

Somehow, the Daily Mail managed to mangle this factual statement into something that, yet again, portrayed the internet platform as an aggressor against DAB:

Rajar says the figures do not mean people are abandoning traditional or DAB radio sets but that more Britons are trying and using online stations as well.”

  

The problem the radio industry faces with the RAJAR audience metric is that it cannot have its cake and eat it. Either it chooses:

• to restrict RAJAR to measuring ‘traditional’, live radio and accepts that, as a result, the data will inevitably show that listening to ‘traditional’ radio is in continuing decline (which is RAJAR today, see graph above); or

• to expand the RAJAR metric to measure ‘audio’ consumption that includes on-demand and podcast content, as well as non-traditional radio such as Spotify and Last.fm, thus demonstrating that total listening is not at all in decline but, on the contrary, has been enhanced by audio content increasingly consumed via non-broadcast platforms and ‘on the go’.

For the BBC, Director of Audio & Music Tim Davie hinted at the last RadioCentre conference that he would be interested to see RAJAR extended to encompass time-shifted and downloaded audio, both of which account for an increasing proportion of BBC radio listening.

For its part, commercial radio has shown no interest in advocating such a re-definition of the RAJAR metric. Not only do its offerings of time-shifted and downloadable audio remain miniscule compared to the BBC, but it is locked into a strategy to maintain its ‘walled garden’. Understandably, it has no desire to demonstrate to the world that it is losing listening to competitors’ time-shifted audio and online ‘radio’. UK commercial radio has enjoyed a nice little over-the-air duopoly from 1973 until recently – best just to pretend that it remains one of only two games in town.

The paradox here is that commercial radio is busy presenting advertising agencies and potential advertisers with RAJAR data that only tell part of the story of how and what audio people are listening to in 2009. However, once their meetings with commercial radio people are over, those same advertisers and agencies will inevitably be busy booking advertising with all sorts of online media, including Last.fm and Spotify. They know precisely what opportunities are out there in the wide world beyond traditional broadcasting.

Simply ignoring new businesses that are competing for your listeners’ attentions is not going to make them go away. Sticking your head in the sand can only have the effect of devaluing RAJAR as a useful and accurate metric in the long term.

Remember King Canute.

UK Commercial Radio Revenues Q3 2009

Commercial radio revenue figures for 2009’s third quarter have been published.

Q3 2009 DATA
£120.2m total revenues
£35.7m local revenues
£59.8m national revenues – lowest quarter since Q1 1998
£24.8m branded content

YEAR-ON-YEAR
Total revenues – down 12.5%
Local revenues – down 3.8%
National revenues – down 16.5%
Branded content – down 13.3%

QUARTER-ON-QUARTER
Total revenues – up 0.4%
Local revenues – up 2.6%
National revenues – down 0.3%
Branded content – no change

FOUR-QUARTER MOVING AVERAGE DATA
£497.5m total revenues – lowest since Q1 2000
Down 14.6% year-on-year (last quarter: down 13.4% year-on-year)

Have we hit the bottom yet? That is the thorny question. The answer is not easy. Yes, this most recent quarter’s revenues have halted their recent terrifying decline, demonstrating a tiny 0.4% improvement over the previous quarter. But one ‘okay’ quarter does not necessarily signal a turnaround. You would be risking your shirt to announce that the radio advertising market is going to improve from now on.

The one bright spot was local advertising, which accounts for 30% of total radio revenues. It improved quarter-on-quarter by 2.6%, although it was still down 3.8% year-on-year. Nevertheless, it is local advertising which has held up better during this recession, exhibiting only single digit percentage declines year-on-year. If you are looking for ‘grass shoots’, you might find them here.

By contrast, national advertising (50% of total radio revenues) continues to be an unmitigated disaster. This was the sixth quarter in succession to record double-digit percentage declines year-on-year. National radio advertising in Q3 2009 was at its lowest point for eleven years (longer, if you factor in inflation). Neither is this a purely cyclical phenomenon – out of the last 20 quarters, only six have exhibited year-on-year growth. In aggregate, during three and a half out of the last five years, radio has suffered declining national revenues.

Where does that leave the UK commercial radio industry? Well, for the small local stations that have continued to fulfil the remit of their original licences by serving local listeners and local businesses, if they have survived this far, they might yet live to see another day. It is impossible to predict that ‘the worst is over’, but it might be that ‘the worst of the worst is over’. Local advertising is never going to migrate wholesale to digital TV or to the internet, and the yields that a successful local radio station can extract remain high.

The outlook is not so good for group owners of local stations who started to spend less on the shoe-leather necessary to secure local advertising contracts in the 1990s, dazzled by the lucrative opportunities presented by big-name national brands. Unfortunately, the national advertising market is fickle and media buyers now have a longer list of options than ever before, at more competitive prices than ever before. It’s all very well for some current owners to be busy ‘transforming’ local radio licences into national brands, but the market for national radio advertising has shrunk by 40% over the last six years. Now, a much smaller cake has to be divided by a greater number of national radio brands.

The revenue data also contradicts the message repeatedly broadcast by Ofcom in recent years that national radio brands represented ‘the future of radio’. Betraying a lack of understanding of the radio advertising market, Ofcom ignored double-digit declines in national advertising revenues that were evident as early as 2005, instead insisting that national brands on digital platforms were what listeners and advertisers wanted. To date, not one commercial digital radio station broadcast on DAB has produced an operating profit, and consumers’ preferred source for national radio remains the BBC. Commercial radio used to be good at genuinely local radio, so deliberately giving it up was never a sensible idea.

One characteristic that too much of UK commercial radio presently lacks is ‘excitement’, for both listeners and advertisers. More so than ever in these days of media overload, you have to create a distinct ‘buzz’ around your product to attract attention. Being in the marketplace is simply not enough. I only realised how much I have missed that kind of radio excitement when I stumbled across a local commercial station this week that entertained me enough to make me stop what I was doing and listen intently. It even played three of my all-time favourite songs in a single hour.

Unfortunately for the financial health of the UK radio industry, that station serves Lafayette, Louisiana – metro population 257,000. Deservedly, it ranks #2 in the market.