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.

BBC radio: endangering commercial radio's 'heartland audience'

Dear David Liddiment

I was interested to see your article in The Guardian, on behalf of the BBC Trust, defending Radio Two from accusations made by the commercial radio sector that the station has deliberately sought a younger audience. You say:

“What about the challenge that Radio 2 is getting younger? We found that Radio 2’s under-35 audience did grow significantly between 1999/00 and 2004/5 (albeit from a low base). However, over the past five years, the age profile of the station has remained stable and there’s been no increase in reach to under-35s.”

Your analysis here focuses on two specific metrics – under 35’s and Radio 2’s ‘reach’ – whereas the important issues raised by commercial radio rightly concentrate on:
• Commercial radio’s ‘heartland audience’ of 15 to 44 year olds, which it has pursued for many years as a result of advertiser demand to reach this segment of the population;
• ‘Share of listening’ as the appropriate metric because there is a direct correlation between this figure (how many hours are listened to commercial radio) and how much revenue the sector generates.

The graph below, taken from RAJAR data, shows the ‘share of listening’ attracted by BBC radio stations amongst 15-44 year olds since 1999.

It is evident that the listening share of most BBC stations has remained relatively static over this period. The exception is Radio Two, whose share of listening amongst 15-44 year olds has more than doubled from 4.9% to 10.5% over the last decade. It is true that this growth has started to level out in recent years, as your article asserts, but there is no denying that the damage has already been done.

The graph shows clearly that this significant increase in listening has not been achieved by migration from competing BBC radio services to Radio 2. On the contrary, the BBC’s overall share of listening amongst 15-44 year olds has increased from 36.5% to 44.7% during the last decade and, most importantly for commercial radio, is continuing to grow year-on-year.

The graph below demonstrates clearly that it is commercial radio which has lost listening share, from both its local and national stations, that has migrated to the BBC. As a result, commercial radio’s listening share amongst 15-44 year olds has fallen from 61.7% to 52.1% over the last decade.

 
The danger for the commercial radio sector is that, if its market share falls below 50%, potential advertisers might no longer consider radio to be the ‘powerhouse’ delivery platform amongst 15-44 year olds that it used to be. The impact will not simply be a proportional loss in advertising revenues, but a significant loss of confidence in radio as an advertising medium to reach 15-44 year olds.

This is why, inside the BBC and Radio Two, a change in strategic policy might look as if it only results in an increase in BBC market share of a percentage point or two. For the commercial sector, not only does that single percentage point lead directly to a proportional loss of revenue but, sustained in the longer term, it can potentially undermine the medium’s ability to convince advertisers to use radio rather than, say, digital TV or the internet.

This is why the promise you make that “Radio 2 listeners won’t get any younger” is little comfort to a sector that has already been damaged by BBC strategic policies and which is continuing to lose market share year-on-year amongst its ‘heartland audience’ to BBC radio as a whole.

Of course, some of this listening loss can be attributed to commercial radio’s own competitive (in)ability to compete with the BBC – I would be first in line to argue that case – but unless its downward spiral of diminishing listening and diminishing revenues can be reversed, commercial radio could be decimated to the point where it can no longer be a financially viable business.

I write to you not to criticise Radio Two, which is a remarkable station, nor to apologise for the commercial radio sector, which has to shoulder considerable blame for losing touch with its audience. I write to illustrate that the industry’s own data clearly shows the BBC continuing to eat away at commercial radio’s ‘heartland audience’, and I write so that the BBC Trust might understand the consequences if the migration of radio listening to the BBC continues at its current rate.

Yours,
Grant Goddard

30 November 2009

UK Commercial radio revenues Q2 2009

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

Q1 2009 DATA
£119.7m total revenues – lowest since Q3 1999
£34.8m local revenues – lowest since Q1 2001
£60.0m national revenues – lowest since Q1 1998
£24.8m branded content

YEAR-ON-YEAR
Total revenues – down 10.8%
Local revenues – down 6.0%
National revenues – down 16.1%
Branded content – down 3.7%

QUARTER-ON-QUARTER
Total revenues – down 6.9%
Local revenues – down 5.4%
National revenues – down 12.3%
Branded content – up 6.0%


FOUR-QUARTER MOVING AVERAGE DATA
£514.6m total revenues
Down 13.4% year-on-year (last quarter: down 13.1% year-on-year)


Whatever may be going on elsewhere in the economy, it is hard to see any green shoots of recovery in the UK commercial radio …. yet. Total revenues in Q2 2009 fell by 10.8% year-on-year to £119.7m. Initially, this might look mildly positive compared to the 19.5% year-on-year fall experienced last quarter. But remember that the downturn in UK radio first hit in Q2 2008 and had already reduced that quarter’s revenues 10.1% year-on-year. As a result, Q2 revenues in 2009 are now 20% below what they had been two years ago, a decline so significant that it will prove difficult to recapture even when the economy does improve.

National advertisers remain the weak spot for UK commercial radio, with revenues in Q2 2009 down 16.1% year-on-year. But once again, Q2 in 2008 was the start of the downturn and that quarter showed a 15.9% fall year-on-year. National revenues in Q2 2009 are now 29% below what they had been two years ago. It will be a mighty challenge to recoup such losses.

The notion that UK commercial radio is merely experiencing a cyclical blip and will quickly show recovery once the overall economy improves is a great feelgood story, but one that is not supported by the industry’s own data. Long before the ‘credit crunch’ hit us all, UK commercial radio revenues were already showing structural decline, a trend that the current economic cycle has merely exacerbated.

Nothing demonstrates the long-term trend more starkly than a glance at the year-on-year changes to commercial radio’s total revenues in recent quarters. Of the last 20 quarters, only 7 have demonstrated year-on-year revenue growth (one quarter in 2004, one quarter in 2005, one quarter in 2006, three quarters in 2007 and one quarter in 2008). The most recent quarter’s total revenues were 29% below the peak achieved as long ago as Q4 2003. If these comparisons were adjusted for the effects of inflation, the decline would look even more stark.


For the commercial radio industry, business will never be the same again. The ‘goldrush’ 1990s are never going to happen again, at least not without some kind of radio revolution (such as the BBC wilfully destroying Radio Two’s popularity, as they did with Radio One in the early 1990s). As a result, the commercial radio industry will need to change its modus operandi more substantially than ever before, not to thrive, but in order simply to survive. If it doesn’t change, we won’t have much of a commercial radio industry left at all.

The seemingly widely held belief that commercial radio MUST continue to exist in its present form because it is a highly regulated and licensed industry is simply false. If there was one lesson that should have been learnt from the implementation of DAB radio in the UK, it was that ensuring that a small group of commercial interests control a technology and the access to it counts for nothing if there is almost no demand for it. With DAB, radio broadcasting groups got what they wanted – their cartel became the licensed gatekeeper and owner of DAB. But if nobody wants your DAB, you are left being gatekeeper to a field of nothing.

It’s the same with commercial radio. If advertisers and listeners don’t want your product, there is no reason for it to exist, regardless of you waving around your scarce Ofcom licence. Not so long ago, station owners could still foist crappy radio content on the public because listeners were starved of alternatives, but digital audio and the internet have changed that FOREVER. No longer is there any market for second-rate radio. And, in commercial radio, if unwanted or irrelevant content doesn’t attract listeners, it won’t last long.

In this context, the latest Ofcom radio

consultation (“Radio: the implications of Digital Britain for localness regulation”) is a remarkably disappointing document. At a time when commercial radio is at a crossroads in so many senses (profitability, consolidation, platforms, localness, public service, interactivity, CPM, etc), this latest chapter in Ofcom’s many attempts to map out “The Future Of Radio” is no more than tinkering at the edges of existing radio regulation.

What was needed was a full-blown, courageous effort to overhaul the radio regulatory system in order to ensure that commercial radio continues to exist financially and that the diminishing number of licensees genuinely serves the public’s articulated radio needs. Instead, we have an Ofcom consultation that is no more than a grudging reaction to Lord Carter’s Digital Britain proposals, some of which are now adopted as if they were Ofcom’s own, some of which are watered down, and some of which have been ignored altogether.

The reluctance drips from every page. There are 81 uses of the word ‘if’ in this 82-page document. Almost every one of its proposals is tainted with uncertainty – “if and when new legislation is passed” or “if Parliament decides not to take forward”. Rather than seizing the opportunities that arise from the painful ‘crossroads’ when change is an inevitable necessity rather than a nicety, Ofcom seems happy to sit in the back seat and respond “whatever!” to ideas it receives, rather than grabbing at innovation and pushing it forward. It reads very much as if written by nobody who has ever themselves run a commercial business where painful life and death decisions have to be made, sometimes at breakneck speed and often without the aid of a parachute.

Ofcom continues to treat the commercial radio industry like a naughty child who, although 36 years of age now, cannot be trusted with more than a five pound note. Every Ofcom proposal continues to keep its centralised, London-based decision making about local commercial radio firmly within its own control, without trusting licensees to co-regulate in any meaningful way. For example:
· Proposal 1 requires stations to submit a request every occasion they seek a change
· Proposal 2 will lead to “a short consultation upon receipt of such a request”
· Proposal 3 requires stations to submit a request every occasion they seek a change
· Proposal 4 will lead to “a short consultation in most cases”
· Proposal 5 will lead to “short consultations in most cases”.

Only one thing is certain – Ofcom will be drowning in consultations for the foreseeable future. These five proposals alone (out of eight) multiplied by 300 stations plus DAB multiplexes yields a potential 1,000+ new consultations or requests. And yet the document claims that these Ofcom proposals are “broadly deregulatory”.

Sadly, more than anything else, the Ofcom document completely lacks any kind of vision as to what the commercial radio landscape might look like in the future, the antithesis of what the Digital Britain consultation exercise was trying to achieve. This is a missed opportunity for Ofcom. Not just this latest document, but in 2009 when the whole “what is the future of radio?” debate is probably at the most critical point in commercial radio’s history. It appears to many in the industry that Ofcom has simply disengaged from radio. This is a particular irony for an industry that prides itself on its success in one-to-one communication.

It may seem a stupid question……. If Ofcom still sees itself as the party with the skills necessary to make 1,000 potential individual decisions on the future of individual commercial radio stations, how is commercial radio presently in such a sad state of affairs as a result (partly) of previous regulatory decisions? We tend to respect and trust people who can demonstrate a positive track record. Why would I let a doctor operate on me who had killed almost every patient he had ever consulted?

Predicting the radio present, twenty years ago

Whilst looking for some information about the changes wrought by the Broadcasting Act 1990, I happened to find some old press cuttings from that time. What follows are some predictions for the 1990s UK radio industry that I had written in the February 1990 edition of “For The Record” magazine:

RADIO ONE continues to feel the winds of change instituted by the new Head of Music Roger Lewis and a team of younger presenters. It promotes and programmes itself more aggressively now and will continue to lead the way where commercial stations only follow. In the 1990s, it will sever entirely the relationship between its playlist and the current Top 75, thus sounding the death knell for the single as a commercial proposition.

NEEDLETIME RESTRICTIONS, which have held back developments in music radio for so long, will be legislated away, though not without a spirited fight by the record companies. As a result, all-music stations will become the norm in the commercial sector, leaving the BBC as the only producer of serious speech programmes.

MORE STATIONS will fracture the radio market into lots of small pieces, losing forever the kind of huge audiences attracted by the Sunday chart show or “Our Tune”. Record retailers will have to react by stocking a wider range of album releases and developing their specialist sections (a reversal of the 80s trend towards narrower stock). The album chart will increasingly reflect the sum of different sets of fans’ interests, rather than a common pop denominator.

OWNERSHIP of radio will narrow to a handful of large companies, despite the increased number of stations. The 80s saw radio shares treated as profitable propositions for the first time. The existing big boys (Capital Radio, Crown Communications, Trans World Communications) will continue to buy up anything and everything. Publishers (Associated Press, EMAP) will enter the fray, and TV companies will seek lateral integration with radio as a hedge against loss of their franchises. For the first time, radio shares will become an essential part of a media portfolio and change hands rapidly at inflated prices.

FM RADIO will reign supreme. Listeners will remember “medium wave” with the quaint fondness our grandparents reserve for “cats’ whiskers”. Push-button, auto-locate receivers become standard, timeshift recorders are introduced, knob-twiddling disappears, and listeners channel hop endlessly in search of the perfect beat.

SYNDICATED PROGRAMMES already enable David Hamilton to sound as if he works for your very own local station when he is really sat in a London studio. The development of whole syndicated networks in the 1990s means that your favourite rock station in Leeds is actually originated in New York and plays exactly the same records as WLUP Philadelphia.

DISC JOCKEYS will lose their aura as media stars and lose lucrative careers opening supermarkets, hosting TV shows or making their own hit records. Being a radio presenter will carry as much kudos as being a tax inspector.

SHOCK RADIO develops a huge cult following amongst young people, whilst deplored by their parents. The Radio Authority is belatedly forced to curb the phenomenon by introducing a largely ignored “Code of Presentation Conduct”. James Whale makes a film of his life story.

In the December 1989 edition of “For The Record”, I had written:

Asked whether the public service obligations in commercial radio would be abandoned completely, Lord Chalfont [newly appointed chairman of the newly created Radio Authority] has expressed hope that the Broadcasting Act would allow stations to continue with such commitments if they so wished. He added that, in his recent discussions with various MDs of local stations, they had expressed their avowed intent to maintain public service elements. This is a little like a headmaster hearing his class of fourth-formers promise never to drop litter, to always help old ladies across busy roads, and to keep their school uniforms on until they get home.

The issue of public service commitments in radio is important not just from a theoretical point of view, but because it directly affects the listener’s choice. We’re talking about the very things that should differentiate stations from each other.

At the bottom line, commercial radio does not exist to “satisfy” its listeners. It exists to deliver the largest targeted audience possible to the advertisers who pay money to do so. Listeners’ broadcasting needs are irrelevant to the stations’ profitability.

The cheapest form of radio programming is the continual play of well-known pop records linked by young local DJs who aspire to be Tony Blackburn – anything more fanciful than that costs more money and reduces the profit margin. So, in the brave new world where commercial radio is regulated by a “lighter touch”, the cheapest programming appealing to the lowest denominator audience wins hands down. Out go the rock shows, the folk shows, the local band slots and the ethnic language programmes that were necessary to comply with the IBA’s policy of serving all sections of the audience. Out goes anything but a token commitment to local news coverage, information services, off-air activities and social action broadcasting.

Independent Local Radio will increasingly have little that is either “independent” or “local” about it. If a bomb drops on your town at two in the morning, the one place you won’t hear about it is on your local station (unless the story makes the national news). They’ll simply carry on soothing you through the night – probably with a service beamed by satellite from London. ….

We’ll all get to hear more radio in the 1990s. But there are no guarantees to be seen so far that it will be any better for the consumer in its content.

"Above all else, Durham FM will be local" …. a promise is a comfort to a fool

Durham must be unique in Britain in that it once had its own local radio station and then had it taken away. BBC Radio Durham closed down in 1973 when the BBC, then limited to just twenty local radio services around the country moved the station in its entirety to Carlisle. It was reasoned that Durham could be adequately served from the north by Radio Newcastle and from the south by the then Radio Teesside. The same arguments can be heard today when, despite the proliferation of electronic media over the past thirty years, all the mass media serving the Durham area are based on Tyneside, on Teesside, in Darlington or in London. Our research and consultations confirm an almost universal desire for Durham to have its own radio station – for Durham and from Durham.

These words are taken from the winning licence
application submitted to Ofcom by The Local Radio Company in January 2005 for the new Durham FM licence. The application continued:

There is an unduly low level of contact between the City of Durham and the many towns and villages which surround it. Those representing the towns and villages in the Districts away from the City also point to a reluctance to travel between those towns and villages. Local people feel marginalised by the existing media. When most local news and information comes from media dominated by out-of-area conurbations is it surprising that local awareness and pride starts to suffer? We see this as a major opportunity for Durham FM to provide an entertaining and informative local radio service which will have wide appeal…..

Durham FM will broaden the range of local commercial radio services by offering the only programming to focus exclusively on Durham City and the surrounding districts. In addition to the full range of national services, the proposed TSA is served by local radio stations based around Tyneside and Teesside. From the BBC there are BBC Radio Newcastle and BBC Radio Cleveland, while from commercial radio Metro Radio, Magic 1152, Century FM and Galaxy 105-106 all broadcast from Tyneside with TFM and Magic 1170 having their studios in Stockton-on-Tees…..

Only 8% of total news time on Metro Radio was devoted to stories drawn
from the proposed Durham FM editorial area…. With slightly more time devoted to news bulletins than on Metro, local news [on Magic 1152] about the Durham area featured a little more frequently, but still only 10% of news bulletin time was devoted to material directly relevant to the Durham FM TSA…. [On Century FM] our independent monitoring agency failed to identify a single reference to anywhere within the proposed Durham FM TSA…. There was no locally relevant news [on Galaxy FM] for the Durham FM area….

Durham FM will focus entirely on Durham and the districts surrounding it. Our programmes will be locally produced and presented from studios in Durham by people who know and understand the area. This independent monitoring of the existing services shows that no other ILR station in the area provides anything approaching the level of relevant local news and information which are demanded by the local population and will be offered by Durham FM. During the period monitored very few local news stories were included and there were very few locally relevant programme items on any of the four ILR services. Durham FM will become established as the only dependable, independent and up-to-the-minute source of information about what’s happening in the towns and villages of the Durham area….

Local material is vitally important to the success of Durham FM. Our detailed quantitative research, detailed later in this application, confirms that a gap exists in the Durham radio market for a greater quantity of Durham city and county news and local information. Whether expressed in terms of speech items that listeners would like to hear or those that they consider ‘essential’ listening it is local Durham and North East regional news, along with local weather forecasts and traffic and travel news for the Durham county area, that head the list of requirements….

All programmes on Durham FM will be locally produced and presented with the exception of a nationally networked chart show during three hours on a Sunday afternoon/evening and one latenight ‘phone-in of three hours duration each week. A limited further amount of appropriate network programming may be added outside weekday daytime once our local audience is established, after the second year on-air, but a minimum of 18 hours per day will always be locally produced and presented.

Following up this written application, Ofcom asked The Local Radio Company explicitly:
Are there any cost-saving sharing of resources planned arising from Durham FM’s close geographical proximity to both Alpha 103.2 and Sun FM?

The written answer from The Local Radio Company was:
It is our intention to operate Durham FM as a separate radio station with its own facilities, staff and objectives.

At its meeting on 7 April 2005, Ofcom’s Radio Licensing Committee [RLC] considered
three competing applications for the new Durham FM licence and decided to award it to The Local Radio Company. Ofcom explained that this decision was made because:

…the speech commitments contained in Durham FM’s Format (such as a seven-day local news service) would improve Durham-specific news and information provision in the area, and that the overall programming proposals contained in the Format were both deliverable and would cater for local tastes and interests, as demonstrated by the group’s research. The RLC considered that, in relation to Section 314 of the Communications Act 2003, Durham FM’s programming proposals contained a suitable proportion of local material and locally-made programmes. The station will offer locally-made output for 18 hours per day, and the Format includes commitments to delivering a range of local material. The Committee noted that, after two years on air, the station’s Format gives it the ability to air networked programming at off-peak times, if it so chooses. [emphasis added]


Durham FM launched on 5 December 2005. The station failed to come anywhere close to the audience forecasts made in its licence application (see table). A radio station’s revenues are closely proportionate to the total hours listened to it. On that assumption, Durham FM must have been around 74% below its revenue target for Year Three – a catastrophic performance for a business that is operated on largely fixed costs. So how come The Local Radio Company’s forecasts in its licence application were so wildly optimistic? The application had said:

We have no doubt that these audience projections are realistic and achievable in the light of our experience of comparable services throughout Britain…. We have every confidence that Durham FM’s locally focussed programming, backed by a significant launch budget, will establish a substantial audience within a relatively short period of time.

And how come Ofcom was so confident that the Local Radio Company could meet these targets? Ofcom said:

Durham FM’s audience and revenue forecasts were considered to be achievable, and in this context RLC members noted the excellent ratings performance and track record of both Sun and Alpha in nearby areas which have a line-up of competitor stations very similar to that which the new Durham service will face.

So just how “excellent” were the performances of the neighbouring Sun and Alpha stations owned by the same applicant?


When Ofcom’s Radio Licensing Committee met in April 2005 to consider the Durham licence, it was becoming evident that Sun and Alpha were losing listening at an alarming rate, both stations having peaked in 2002 under previous owner Radio Investments Ltd. Similar audience losses were experienced across most stations owned by The Local Radio Company, following its disastrous decision in 2004 to homogenise the branding and content of its portfolio under the slogan “music:fun:life”. Essentially, the group sucked the quirky ‘localness’ out of its local stations and, unsurprisingly, listeners subsequently turned off in droves.

The end result? Durham FM presently has a 4.0% share of listening in its local market of 201,100 adults. By comparison, Galaxy has a 9.5% share, Magic 6.4%, Century/Real 6.5% and Smooth 4.8%. Metro FM and TFM together probably take 7.5% (Durham FM chooses not to itemise these two stations in its RAJAR report). BBC local radio takes a significant 8.8% share, even though Durham is only on the periphery of both BBC Radio Newcastle and BBC Radio Tees. [RAJAR Q1 2009]

In December 2008, The Local Radio Company submitted an application to Ofcom to move Durham FM’s studios to Sunderland, effectively closing the Durham location, but continuing to provide ‘local’ programmes for Durham from Sun FM in Sunderland. It argued that “the losses for Durham FM are significant”, the details of which had “been provided, in confidence, to Ofcom”. It argued that “this co-location will allow the station to build its audience on a more stable and secure financial basis” because “it has a poor financial history” and that “the proposals will be imperceptible to listeners in the local market place”.

At its meeting on 23 February 2009, following a five-week public consultation, Ofcom’s Radio Licensing Committee refused this request to move Durham FM to Sunderland because it decided that “the case for the existence of exceptional circumstances had not been made”. However, Ofcom did suggest that it could reconsider this request “later in the year” following publication of the Digital Britain final report. Interestingly, Ofcom noted that a previously approved request in March 2008 to allow the Durham station to share programming with Alpha FM in Darlington “has been scrapped by the licensee [so as] to secure all-local programming output on Durham FM”.

With an immediate move to Sunderland now off the agenda, The Local Radio Company moved on to Plan B. Next, it applied to Ofcom to effectively merge the output of Durham FM and Alpha in Darlington into one station to be called “Alpha”. So what would remain of the promised local programming for Durham? “Weekday breakfast programming and four-hour daytime shows on Saturday and Sunday will remain separately and locally produced in Durham….”, said the application. “At all other times, local programming will originate from Darlington”. Boldly, the application argued that “the character of the [radio] services will remain substantially unchanged” and “the essentially local nature of the [radio] services will remain”.

Suddenly, Durham and Darlington were to become a single local radio market:
We believe there is considerable editorial justification in combining much of the local programming of Durham FM and Alpha, and in originating the shared programmes from Darlington. Until 1997, when it became a unitary authority, Darlington was part of County Durham and still very much leans culturally towards the county. Equally, for listeners and advertisers in the county, the attraction of a local radio service focusing on Durham is greatest for those more remote from the Tyneside conurbation, particularly those in the towns nearer to Darlington. The general public, listeners and advertisers are accustomed to the County Durham local press being substantially based in Darlington.

Am I the only one who finds this line of argument totally unbelievable? Firstly, it directly contradicts the opposite assertions made in The Local Radio Company’s application for the licence four years earlier that Durham was not well served by other media in the region. Secondly, the licence application had demonstrated there were few community links between Durham and either Tyneside or Teesside. Thirdly, my personal experience is that, having lived in Durham for seven years, I never visited Darlington (which is 19 miles away by road), though I did go to Newcastle (16 miles) and Sunderland (13 miles) regularly. However, Ofcom barely blinked at the contradictions and was so eager to go along with the story that it approved this proposal without any kind of public consultation, stating:

Durham has already regionalised four of those hours, and the request sets out clearly the affinities between the two areas [Durham and Darlington]…. This is not seen a major change to the stations’ output, and the request is granted.

So, for the second time, Durham has effectively lost its local radio station and now retains only a local breakfast show hanging by the barest thread. I am not trying to argue that Durham must have a local commercial radio station, regardless of how much money it might lose. But, once again, the outcome for radio listeners in Durham seems to raise questions about the robustness of our system of local radio licensing:
· Before advertising the Durham licence in 2004, did Ofcom properly evaluate the potential for local radio advertising revenues in the market?
· How carefully did Ofcom scrutinise the application by The Local Radio Company, before awarding it the licence, in order to separate the ‘spin’ from the reality?
· Did Ofcom monitor and assess the Durham station to ensure that the promises made in its licence application were executed on the ground?
· Why is a ‘promise’ explicitly made in a radio licence application not a contractual promise? Or are the proposals promised in an application simply disregarded by Ofcom once an applicant has been awarded the licence?

The local station in Durham must have failed because either/and:
· It was licensed to fail – no commercial radio station could survive in too small and too poor a local market – in which case Ofcom should never have advertised the Durham licence
· The Local Radio Company did not paint a truthful picture in its licence application of the economics of opening a Durham station, and Ofcom did not critique it sufficiently
· The Local Radio Company’s execution of its business plan for the Durham radio station was badly flawed

In any of these cases, somebody needs to put up their hand and simply admit ‘we got it wrong’. What galls is that both The Local Radio Company and Ofcom appear to have almost connived to come up with a ridiculous new storyline – Durham is a lot closer to Darlington than we realised – which simply contradicts everything that had been said previously, but conveniently glosses over any notion that the present predicament was the result of poor judgement.

To be fair to The Local Radio Company, its latest submission to Ofcom did reiterate:
The present proposal to simply add two further hours of daily weekday sharing is made in the light of the difficult financial situation facing all stations such as these. Relevant financial information has been supplied to Ofcom in confidence.

It might engender much more respect for the parties if, instead of these economic vagaries cloaked in confidentiality, the application to Ofcom to request deconstruction of the Durham station had simply said:
We screwed up as a station owner, you screwed up too as a regulator, and all we can do now is the two of us try and salvage the situation to ensure that the citizens of Durham can at least retain the shell of a local radio service, even if not the substance. Between us, we recognise that all we have done is add insult to injury, repeating the BBC’s unwarranted removal of a local radio service for Durham in 1973. Our sincere apologies to the people of Durham. All we can hope is that, by both of us learning from our mistakes, this travesty will not be repeated either for a third time here in Durham or elsewhere.


What Northeast England now has in the enlarged ‘Alpha’ is the makings of yet another regional radio station that could (if Sun FM were included) cover the huge area stretching from Tyneside down to Yorkshire. It would then become the fifth regional station in the area, adding to Galaxy, Smooth, Magic and Real. As for genuinely local radio serving the Durham area, The Local Radio Company’s licence application already demonstrated very clearly that neither Metro Radio nor TFM cover Durham editorially. This leaves Durham, whose population seriously lacks economic mobility, back out in the local radio wilderness once again. If that isn’t public policy failure, then what is?

Durham must be unique in Britain in that it once had its own local radio station and then had it taken away. ….

Once is an accident, twice is a ……..?

Digital Radio Switchover: Parliamentary Question

20 July 2009 : Column 561
House of Commons
Monday 20 July 2009
The House met at half-past Two o’clock
Prayers
[Mr. Speaker in the Chair]
Oral Answers to Questions
Culture, Media and Sport
The Secretary of State was asked—
Digital Radio Switchover

1. Sir Nicholas Winterton (Macclesfield) (Con): What his most recent assessment is of progress on digital radio switchover; and if he will make a statement. [287437]

The Parliamentary Under-Secretary of State for Culture, Media and Sport (Mr. Siôn Simon): The “Digital Britain” White Paper set out the Government’s vision for the delivery of the digital radio upgrade by the end of 2015. We have committed to a review of the progress towards that timetable in spring 2010, and we have also asked Ofcom to review and publish progress against the upgrade criteria at least once a year, starting next year.

Sir Nicholas Winterton: Is the Minister not aware that “Digital Britain” has in fact failed to address the inadequacies of digital radio broadcasting coverage? I am sure that he will agree with that comment. Representations made to me so far suggest that the idea of a switchover is currently very unpopular. Instead of rushing ahead with the switchover, will he take positive action to allow people to see some tangible benefits?

Mr. Simon: I am disappointed that the hon. Gentleman thinks that we are rushing ahead. We have said that we will move Britain to digital by 2015. That gives consumers and the industry six years to make the upgrade, which we are doing because we are committed to radio, we believe in radio and we love radio, and radio will not have a future unless it goes digital. We are not switching off FM, and we are putting new services on the FM spectrum that is vacated by the services which move to digital audio broadcasting, because we want to see radio prosper and grow in the digital age.

Mr. Barry Sheerman (Huddersfield) (Lab/Co-op): Is my hon. Friend aware that switchover is affecting valued services on both radio and television? I have been lobbied by Teachers TV, which fears that it will lose an enormous part of its audience because the Department for Children, Schools and Families is stipulating that it must switch over totally to digital.

Mr. Simon: We are ensuring with radio switchover that community organisations and small community radio stations, which might currently be able to broadcast for only two weeks a year, will inherit the FM spectrum currently taken up by big regional and national FM broadcasters. Precisely such small, commercial, local community organisations will be able to flourish in the digital future in a way that they are technologically constrained from doing now.

Adam Price (Carmarthen, East and Dinefwr) (PC): The Minister is a Welsh speaker, so is he aware of the fears for the future of Radio Cymru, the BBC’s Welsh language national service? It is not currently available on digital and will not be available in large swathes of western Wales for reasons of topography.

Mr. Simon: I have, with personal regret, to tell the hon. Gentleman that I am not really a Welsh speaker. [Hon. Members: “Ah!”] Dwi’n dysgu, ’de? I should have been a Welsh speaker. We are alive to the particular problems of Wales. There are serious problems with coverage, not just with respect to Radio Cymru but with digital coverage throughout Wales. We have made it clear that the nations and regions that are furthest behind in digital coverage will be the first priority for the most serious intervention, to ensure that they are not left behind when we move to digital. We have made it clear also that we will not move to digital unless 90 per cent. coverage at the very least is achieved.

Mr. Jeremy Hunt (South-West Surrey) (Con): I start by welcoming you to your post, Mr. Speaker—an elevation that was only marginally more likely than man walking on the moon, which happened 40 years ago today. I offer you my congratulations. I am sure that you will want to join me in offering the congratulations of the whole House to the England cricket team, which won an historic victory today—their first victory over the Australians at Lord’s for 75 years. We would also like to congratulate the Minister on taking up his post in the DCMS team. The Government’s own figures state that there are 65 million analogue radios in circulation, and they hope that the cost of digital radios will fall to £20 a set. That means that the cost of upgrading the nation’s analogue radio stock will surpass £1 billion. Who will pay that £1 billion? Will it be the Government, or will it be consumers?

Mr. Simon: Mr. Speaker, I should apologise for having forgotten to congratulate you; I thought that we were taking your position for granted by now, but it is my first time speaking under your chairmanship. I offer my very sincere congratulations. I never thought that your elevation was unlikely.

Mr. Edward Vaizey (Wantage) (Con): What about cricket?

Mr. Simon: The hon. Gentleman shouts “cricket” from a sedentary position. I can tell him that the Under-Secretary of State for Culture, Media and Sport, my hon. Friend the Member for Bradford, South (Mr. Sutcliffe), was at the cricket, which almost certainly accounts for the first English victory at Lord’s since, I believe, 1934. In response to what we might call the “Tory sums” of the hon. Member for South-West Surrey (Mr. Hunt)— [Interruption.] No, Tory sums. We do not know how many analogue radios are in circulation; it may be 65 million. The first point to make is that those sets will not become redundant. The FM spectrum will be well used for new services that are currently squeezed out. We are working with industry to come up with sets that are consistently priced at £20 or less. That will enable consumers to add to the 9 million digital sets—

Mr. Speaker: Order. May I gently say to the hon. Gentleman, who has been extremely generous in his remarks, that I do not want to have to press the switch-off button, but I am a bit alarmed that he has a second point in mind? It might be better if he kept it for the long winter evenings.

Mr. Hunt: The point is that if people use their analogue sets, they will be able to listen to new radio stations, but not the radio stations that they have been listening to for a very long time. Was it not the height of irresponsibility to announce the phasing out of analogue spectrum without announcing any details or any funding for a help scheme, similar to the one that was in place for TV switchover? Will that not cause widespread concern among millions of radio listeners, who will feel that they are faced with the unenviable choice of either paying up or switching off?

Mr. Simon: I shall try to squeeze in my answer at the end of that extraordinarily long question. We will do exactly the same with radio as we did with television: we will carry out a full cost-benefit analysis of exactly what kind of help scheme might or might not be required, and we will proceed accordingly. There are 9 million digital sets in use already. Consumers have six years to decide how much they want to pay, for what equipment, to receive which services.

http://www.publications.parliament.uk/pa/cm200809/cmhansrd/cm090720/debtext/90720-0001.htm

Digital Radio Upgrade: everyone's a winner?

For every winner, there is inevitably a loser (or three). The ‘Digital Radio Upgrade’ proposals contained in the Digital Britain Final Report are no exception. It is relatively easy to see who the winners will be from its proposals, as some of these are made explicit in the accompanying Impact Assessment:
• “the beneficiaries of these proposals are primarily [DAB] multiplex operators” (p.12)
• “benefits of £38.9m per annum [to broadcasters] for each year after dual transmission on analogue and DAB ceases” (p.12)
• “cost savings to [commercial radio] national broadcasters of licence extensions approximately £10m” (p.12)
• “cost savings [to local commercial radio stations] of co-location and increased networking £23m” (p.12)

However, the losers are made far less explicit in the fine print of the Impact Assessment:
• “merging [DAB] multiplexes will reduce the overall capacity available for DAB services, therefore reducing the potential for new services” (p.117)
• “reduced capacity on local multiplexes might result in some services losing their current carriage on DAB” (p.117)
• “extending the licence period of existing analogue services would reduce the opportunities for new entrants” (p.119)

There would appear to be a degree of contradiction here. Digital Britain also insisted that:
• “DAB should deliver new niche services, such as a dedicated jazz station …. The radio industry has already begun to agree a pan-industry approach to new digital content …” (p.98 main report)

However, the Impact Assessment admits that amalgamation of existing local DAB multiplexes will reduce their capacity, “therefore reducing the potential for new services”. Worse, it states that some existing stations broadcasting on DAB will have to be bumped off as a result of local multiplex amalgamation.

So the potential losers from Digital Radio Upgrade would seem to be:
• commercial stations presently carried on local DAB multiplexes who might have to be bumped because there is no longer the capacity after amalgamation
• local commercial stations presently carried on their local DAB multiplex who will have to quit DAB because they do not wish to serve the enlarged geographical area after amalgamation of multiplexes (for example, the cost of DAB carriage for Kent/Sussex/Surrey is likely to be considerably higher than Kent alone)
• new entrants

The local commercial radio stations bumped from DAB will fall into two types:
• digital-only stations (such as Yorkshire Radio) whose current regional multiplex will be transformed into a national (or quasi-national) multiplex under Digital Britain proposals – such stations have no analogue broadcast licence and could lose their radio broadcast platform altogether
• analogue local stations who were simulcasting on DAB, but whose multiplex has either bumped them post-amalgamation, or who are not in the market to pay more for increased coverage across a much larger area – many of these stations have had their Ofcom analogue licences renewed on condition that they simulcast on DAB. If they are now forced off DAB, will Ofcom take their licences away?

In the rush to frame proposals in Digital Britain that respond to the circumstances of the large radio players with substantial investments in DAB infrastructure, it might appear that the voices of the smaller local commercial radio stations have got lost in the stampede of lobbying. These stations might be small in number but many of them remain standalone, so they will not benefit financially from the relaxation of co-location rules. Digital Britain is condemning many of them to remain on FM (or AM), leaving the large radio groups to dominate the DAB platform.

Although the proposals in Digital Britain have been framed to ‘help’ local commercial radio, overwhelmingly they will reduce the financial burden of group radio owners with local station operations in adjacent areas, and of group owners who have invested in DAB infrastructure. There is little in the way of financial benefits for independent local commercial stations, or for potential new entrants, both of whom face being crowded out of the DAB platform.

UK Commercial Radio In Numbers: Q1 2009

Click here for my latest presentation containing data for the UK commercial radio industry’s key performance metrics in Q1 2009 for revenues, audiences and radio receiver hardware.

Revenues

Q1 2009 radio revenues were down 19.5% year-on-year, eclipsing the previous quarter’s 14.5% decline (although Q1 2008 had been an exceptionally strong quarter). National advertising continues to weaken, the last four quarters having declined by 15.9%, 12.2%, 21.2% and 28.8% respectively year-on-year. By comparison, local revenues have proven more resilient, down 6.4% in Q1 2009 year-on-year.

The gravity of the downturn is demonstrated by the fact that Q1 2009 was the lowest quarter for revenues since 1999 (at face value – if inflation were factored, the situation would be worse). The size of the industry is likely to continue to contract throughout 2009 and it will have to make further, significant cuts to overheads simply to ensure its survival. Public and parliamentary debate to date has focused upon the economic plight of local newspapers, but local commercial radio is just as endangered.

John Myers’ local radio report for Digital Britain suggested a number of regulatory and legislative changes that would potentially ease the financial burden on the commercial radio sector, but these still remain proposals at present. Until the government’s Digital Britain final report and Ofcom’s consultation exercises potentially turn these recommendations into action, the worsening economic pressures on commercial radio are likely to continue to produce further casualties.

Although some voices are already talking up a future bounce back of revenues after the recession (whenever that might be), it is important to recognise that the recent advertising downturn has only exacerbated a downward trend in radio revenues that was already established. In real terms (removing the impact of inflation), radio revenues peaked in 2000 and had already declined by 25% between 2000 and 2008. The current economic cycle is merely aggravating the structural decline that was already evident.

Audiences

At the root of commercial radio’s structural problem is the public’s declining consumption of its output – hours listened during the last four quarters were down 2.3% year-on-year. Radio as a medium continues to attract significant amounts of listening (22.4 hours per week per listener) and reaches 90% of the population weekly. Within those impressive totals, commercial radio is maintaining most of its reach but is losing listener hours. In Q1 2009, the average commercial radio listener consumed 13.5 hours per week, compared with 15.6 hours per week five years earlier.

It would be easy to lay the blame for this loss of listening at the door of increasingly promiscuous 15-24 year olds spending increasing amounts of time using mobile phone applications, social networking websites and streamed video. Whilst it is true that 15-24 year olds’ average time spent with commercial radio has fallen to 12.4 hours per week in Q1 2009 from 15.2 hours per week eight years ago, blame must also be shouldered by the other constituent demographics within commercial radio’s ‘heartland’ 15-44 year old audience.

Reductions in time spent listening to commercial radio have been almost as substantial amongst 25-34 year olds (12.7 hours per week in Q1 2009, down from 15.5 hours eight years earlier) and 35-44 year olds (14.2 hours per week in Q1 2009, down from 16.6 hours eight years ago). Commercial radio’s share of listening amongst both these demographics fell to 49% in Q1 2009, so that BBC radio listening now dominates all age groups except for 15-24 year olds, in which commercial radio still has a 59% share. Only two quarters ago, commercial radio’s share had been above 50% in all three constituent demographics of its 15-44 ‘heartland’ audience whilst, back in 1999, it had been above 60% in all three. These changes represent the crux of commercial radio’s long-term problem.

Additionally, people under the age of 40 are evidently listening to more ‘audio’ then ever before, assisted by the take-up of portable audio players and the blossoming integration of audio applications into mobile phones. However, listening on these new platforms is not being reflected in the audience data quoted above because the RAJAR radio ratings metric continues to define ‘radio’ listening in the traditional linear way, excluding time-shifted consumption (listen again, podcasts) and non-broadcasters (Last.fm, Spotify). Sooner or later, the industry will have to decide whether RAJAR is to remain merely a marketing tool to demonstrate the two traditional broadcasters’ (BBC and commercial radio) continuing dominance of the shrinking market for linear radio; or whether it is more important for RAJAR to demonstrate that ‘audio’ is a growing consumer medium now shared amongst a widening group of content providers. Comments made recently by the BBC’s Tim Davie at the RadioCentre conference offer encouragement in this respect.

Transactions, Openings & Closures

In May 2009, Global Radio finally sold its eight Midlands stations (an OFT requirement of its acquisition of GCap Media) to former Chrysalis Radio chief executive Phil Riley in a deal reported to be worth £30m and backed by Lloyds TSB. Global’s rival Bauer Radio was long anticipated to be the successful buyer, causing some to comment that the transaction has the hallmarks of a ‘warehousing’ deal that would satisfy current competition issues until media ownership rules are amended by legislation to allow further radio consolidation and cross-ownership.

In May 2009, UKRD succeeded in its acquisition of The Local Radio Company [TLRC] in a deal that valued the latter at £2.88m. UKRD owned six local stations, having closed one and sold three stations during the last year. TLRC owned 20 stations, having sold eight during the last year. Since the acquisition, two further TLRC stations have been sold – Bournemouth’s Fire FM to Westward Broadcasting for £40,001, and Macclesfield’s Silk FM to neighbouring Dee 106.3 for a nominal amount. In the seven months to April 2009, Fire’s operating loss was £129k on revenues of £216k, implying an annual cost base of almost £600k, considerable for a station with a weekly reach of 28,000 adults.

In April 2009, TLRC also sold digital station Jazz FM for £1 to former TLRC chief executive Richard Wheatly and former finance director Alistair Mackenzie, the station having lost £733k in the six months to March 2009. In May 2009, the new owners announced a £500k national poster campaign for the station which broadcasts on Sky, Freesat and regional DAB multiplexes. To date, no digital radio station has generated an operating profit.

Forward Media finally exited the radio business by selling its last remaining stations, Connect FM in Kettering and Lite FM in Peterborough, to Adventure Radio (which owns Chelmsford Radio, Herts Mercury and Southend Radio) for undisclosed amounts.

In March 2009, Midwest Radio sold its two stations, MidWest Shaftesbury and MidWest Yeovil, to South West Radio Ltd, the company that had purchased five stations in the West Country from the administrators last year, following the failure of Laser Broadcasting. Another former Laser station, Fresh Radio in Skipton, was sold in March 2009 by administrators to Utopia Broadcasting which includes some station management.

In April 2009, CN Radio sold Touch FM in Banbury to a management buyout team for an undisclosed amount and the station was relaunched as Banbury Sound. In November 2008, CN had said it would close its Touch FM stations in both Banbury and Coventry if it did not find buyers.

April and May 2009 saw the closure of seven local analogue commercial stations, a greater number than in the previous three years. Ofcom revoked the licence of KCR FM in Knowsley from owner Polaris Media, following failure to comply with its format. Sunrise Radio closed two London stations, Time 106.8 in Thamesmead and South London Radio in Lewisham, which had been up for sale since last year. Pennine FM, purchased by John Harding from TLRC last year, closed in Huddersfield. UTV closed Valleys Radio in South Wales after Ofcom had rejected a co-location request. Jason Bryant closed Radio Hampshire in Southampton and Winchester, stations which he had acquired from Southampton Football Club in 2007 and from Tindle Radio in 2008 respectively.

However, Pennine FM has since been acquired from administration by former station staff Adam Smith and Steve Buck and relaunched in May 2009. Similarly, internet broadcaster Play Radio has expressed interest in acquiring the two Radio Hampshire stations from administration, and a creditors’ meeting is due on 24 June.

On digital platforms, local Stafford station Focal Radio closed in May 2009 with the loss of 23 jobs after local businessman Mo Chaudry, who had invested £80,000 to ‘save’ the station, withdrew his support after being arrested on corruption charges involving Stoke City Council. London DAB station Zee Radio (simulcast on Spectrum AM) closed in April 2009 after a year on-air.

The national DAB multiplex Digital One has three new additions, two temporary. On 20 April 2009, forces radio station BFBS launched a simulcast on the platform, following its earlier trial. On 1 June 2009, Amazing Radio launched a six-month trial service showcasing unsigned UK bands as an extension of its Amazing Tunes website. From 27 June 2009, Folder Media’s Fun Kids station will be simulcasting a 14-week trial, extending its present availability on DAB in London.

In London, black talk/music station Colourful Radio launched on DAB on 2 March 2009, and music station NME Radio added DAB on 13 May 2009.

In the coming months, UKRD/TLRC is likely to divest further local stations from its portfolio. At the top end of the commercial radio business, consolidation has created huge groups of large local stations whilst, at the bottom end of the market, an increasing number of small local stations are now being divested from groups to local owners (or closed down). In a small way, this is returning local commercial radio to its 1970s roots, when it was expected that each station would be owned by local entrepreneurs. It will be instructive to see how each of these divergent strategies succeeds in such tough economic times.

Radio in Digital Britain – sense and sensibleness

In the 13-page radio section of the Digital Britain Final Report published yesterday, there was not one mention of the word ‘switchover’ in the context of ‘digital radio switchover’. Neither was there a single mention of the word ‘switch-off’, as in ‘FM radio switch-off’. Throughout the document’s radio section, the new buzz phrase is ‘Digital Radio Upgrade’, meaning a drive to make DAB radio better and improve its consumer take-up. In Digital Britain, the notion of switching off FM radio broadcasting, notably for local stations, has been buried for good.

Not that you would have realised this fundamental policy shift by reading some of the press reports. “FM radio switched off by 2015”, said the headline in The Telegraph. “Government sets 2015 as digital radio switchover date”, said the headline in Media Week. “Digital radio switchover set for 2015”, said the headline in Broadcast. “Analogue radio switch-off set for 2015”, said the headline in The Guardian. These bold press assertions are contradicted by the Report’s recommendations that “FM spectrum is to be re-planned to accommodate the current MW services” (paragraph 43) and that “a new tier of ultra-local radio [which] will occupy the FM spectrum” (paragraph 39). The report is perfectly clear that FM is not to be switched off (at least, not in my lifetime).

It was almost as if the lobbyists for FM switch-off – the large commercial radio groups, most notably Global Radio – had written the press headlines the way they had wanted the outcome, regardless of the actuality. This was reinforced by an article that appeared in Media Week yesterday morning – only hours before Digital Britain was published – in which “a well-placed source” predicted “a schedule for the shutdown of FM radio” under the headline “Digital Britain to give radio licensees guaranteed protection”. That source proved not to be so well-placed.

The Media Week headline referred to the owners of the three national commercial stations who had been lobbying to have their licences extended by another term in order to avoid the impending auction of their frequencies, as required by existing legislation. I have written previously about Global Radio’s determination to seek an automatic renewal of its Classic FM licence, which otherwise expires in September 2011. So did Digital Britain give Global, TIML and UTV the renewals that they wanted?

The answer appears to be both ‘yes’ and ‘no’. Digital Britain will:
· extend all commercial radio licences, national and local, “up to a further seven years” for stations that simulcast on DAB
· insert a two-year termination clause into all new licences
· review all licences in future and determine whether the Digital Radio Upgrade is likely to be achieved by the end of 2013
· terminate licences if the Digital Radio Upgrade is not achieved
· then re-advertise the national licences under the existing auction scheme.

Not only does this add considerable strings to licence extensions of “up to” seven years, not only does it allow those extended licences to be terminated at two years’ notice, but it also puts the onus squarely on the licensees to make sure that the DAB platform succeeds (something which has not been achieved in the last decade). If the Digital Radio Upgrade does not hit its targets, the licensees lose their stations. This is a poker game that, whilst offering national stations a potential second life, also threatens to take that life away not so far down the line. For an owner trying desperately to convince its bank lender of the long-term value of its national commercial radio licence, Digital Britain has not offered anything in the way of future guaranteed revenue streams. As a result, indebted radio owners now have two guns pointed at their head – one from their bank manager and the other from Lord Carter.

Worse, even the licence renewals proposed by Digital Britain require new legislation to be enacted. If there is renewed turbulence in government, and with the ever-present threat of a snap general election, it is looking doubtful whether media legislation will be a priority in a Parliamentary timetable that will be rushing to legislate more significant political issues during this government’s final days. If new legislation doesn’t happen soon, then Ofcom will have to rush to advertise the Classic FM licence in an auction by early 2010 at the latest.

Furthermore, even if digital platforms do succeed in accounting for more than 50% of radio listening by the end of 2013, which station owner (either commercial or BBC) is going to be prepared to switch off their analogue signal and lose 50% of their listening at a stroke? In the case of a commercial station, losing 50% of listening would mean losing 50% of revenues, an idea that nobody will entertain. In this way, regardless of the speed with which the 50% criterion is reached, the outcome is the same – stations will have to simulcast on both analogue and digital broadcast spectrum for many years to come, a necessity that is almost doubling transmission costs during a period when sector revenues are falling precipitously.

For smaller local analogue radio stations, the future remains rather unclear. Another Digital Britain proposal (paragraph 26) to amalgamate local DAB multiplexes into bigger geographical units makes sense in order to bring economies of scale to multiplex owners, but unequivocally transforms DAB into a large-scale broadcast platform for national or regional operators. A local analogue station in Bridlington, for example, will find it even more expensive and inefficient to be on a ‘Yorkshire’ multiplex, thus restricting that local station’s future distribution platforms to FM broadcast and online. Neither will such a local station benefit from the automatic analogue licence renewal promised only to stations simulcasting on DAB. If anything, such stations’ predicament will ensure that FM continues to be the consumer platform for local radio, which still accounts for 40.7% of all radio listening [RAJAR Q1 2009].

Digital Britain’s acceptance of the important citizen benefits of local radio broadcasting is underlined by its (unexpected) proposal to license “a new tier of ultra-local radio” on FM and to re-plan the FM waveband if existing stations (ever) migrate from FM to DAB. Although the report is at pains to explain that it does not intend to “blur the lines between commercial and community stations”, it makes sense in the long run to consolidate a third tier of radio with the flowering of a whole new set of radio stations that genuinely want to serve local communities. With many small local commercial stations now barely breaking even, it might make sense to turn some of them into companies limited by guarantee and thus let them seek public subsidy from local councils and regeneration schemes.

Such an expansion of radio content in local markets could potentially invigorate the entire radio medium, making ‘local radio’ more of a ‘must have’, particularly following cutbacks in local news provision by local newspapers and regional television. It is also a potential antidote to the continuing transformation of many of our former local commercial radio stations into regional or quasi-national services (see the example of Radio 210 in my previous article on ‘Heart-ification’). As Digital Britain commented: “Today’s radio industry has been shaped more by the scarcity of the analogue spectrum than by market demand” (paragraph 4).

On the issue of public subsidy, the biggest disappointment for commercial DAB radio owners/operators must be Digital Britain’s insistence that “the investment needed to achieve the Digital Radio Upgrade timetable will, on the whole, be made by the existing radio companies” (paragraph 44). The report acknowledges that “this will require a significant contribution from the commercial operators” (paragraph 21) but suggests it should be funded by:
· savings from the negotiated 17% reduction in transmission charges as a result of the Arqiva/National Grid Wireless merger (paragraph 22)
· future savings from the ending of simulcast analogue and DAB transmission (paragraph 22)
· cost savings from the anticipated relaxation of co-location rules and the automatic extension of analogue licences (paragraph 25).

Although there is a brief mention of “residual access” to some of the funds left over from the BBC’s Digital Switchover Help Scheme being used to support DAB infrastructure build-out, the overwhelming message is ‘you guys are on your own to make DAB work’. The worry is that, when times were relatively good in the late 1990s/early 2000s, commercial radio did not manage to develop sufficient traction for the DAB platform. How is it ever going to succeed now in an environment where sector revenues are falling so rapidly?

So the conundrum continues, same as it ever was. Everybody wants DAB to work. Nobody except the BBC wants to pay for it. Commercial radio simply isn’t making a profit anymore. We can argue about how/why it got to that desperate situation, but nothing changes the fact that there is no surplus cash slopping around ready to invest in either DAB infrastructure or exclusive digital content. Without an ongoing commitment to both, even the limited migration of national radio services from analogue to digital transmission proposed in Digital Britain is unlikely to ever happen. Consumers follow content, not platforms (or, as Digital Britain says: “consumers will adopt new technologies when they are affordable and the benefits are clear” (paragraph 8)).

This is not at all to imply that Digital Britain does not offer a lot of sensible recommendations. Whereas the outcome of the Digital Radio Working Group in December 2008 was a remarkably theoretical report that appeared to bypass the harsh economic realities of the radio sector, the Digital Britain document is realistic and pragmatic, telling the radio sector that much of what it needs to do to make the DAB platform a success is in its own hands. How the radio sector moves forward with these issues in the coming weeks will determine how much further we continue to plod along the long DAB road. There is an increasingly stark choice for commercial radio – to give up now and accede the DAB platform to the BBC and Arqiva, or to press on and further endanger the viability of the entire commercial radio sector.

Lord Carter proffered a lot of home truths in Digital Britain and he threw down this gauntlet: “Any good business will invest in its future if it understands that future and the potential returns from its investment” (paragraph 8). What he did not do was throw commercial radio a map to get it to the buried treasure.

——————————-
On a purely personal level, I was pleased to see Digital Britain embracing several policies I had advocated for the radio sector:
· the two-year pilot scheme for an output focused radio regulatory regime takes up the idea of the Local Impact Test I proposed in November 2007
· the proposal to use the surplus from the Digital Switchover Help Scheme and the savings from the Arqiva/NGW merger for DAB infrastructure build-out was a strategy I
suggested in October 2008
· the notion that ‘localness’ will prove a commercial radio station’s Unique Selling Point in the future global media village is a scenario I have included in client briefings and conference presentations for several years.

For the purpose of transparency, I contributed radio sector analysis to two documents that were part of the Digital Britain process – a pre-consultation overview and the regulation of local radio.

First Love Radio (aka South London Radio) R.I.P.

Two local commercial radio stations in London – South London Radio 107.3 and Time 106.8 FM – closed forever on 3 April 2009 with little fanfare. South London Radio had launched in 1999, initially to serve the Borough of Lewisham, but its roots were in South London’s black music pirate radio stations of the 1980s. Time 106.8 had launched in 1990, serving the Thamesmead area of Southeast London, but it had been part of the cable community radio experiment of the 1970s. The closure of these two stations leaves London with only two local FM/AM radio stations based south of the River Thames (Radio Jackie in Kingston, Spectrum Radio in Battersea). Even Choice FM, launched in 1990 specifically to serve the Afro-Caribbean community in Brixton, is now relocated to Leicester Square, its latest owner having closed the station’s studios that had always been located south of the river in Borough High Street.

At first glance, the closures of South London Radio and Time might seem simply an expected outcome of the current pressures faced by many local media, particularly radio and newspapers, particularly in the UK’s largest and most crowded media marketplace. More local commercial radio stations have gone out of business in the last month than in the previous two years, with the Credit Crunch inevitably blamed for declining local advertising revenues. However, if you scratch a little deeper, the recent closures of these two stations were horribly inevitable, almost from the day they opened. What surprises me is that they managed to last this long, having struggled with a succession of owners who failed to turn them into successful businesses, and under a radio regulatory system that failed to ensure that South London’s population was offered the local radio services it had been promised.

I must declare a personal (non-financial) interest in both stations. I live within the coverage area of South London Radio and listened to it on the last occasion only days before it suddenly closed; and I had worked a one-year contract at Time’s forerunner, Radio Thamesmead, as Head of Programmes in 1986 when it was still a community cable radio station. Before they closed this month, each of these two stations was losing more than £100,000 per annum. Their accumulated losses since launch ran into millions. Yet, only five years ago, their combined market value was over £1m. How does that make sense? Their closures speak volumes about the UK commercial radio system and its inability to satisfy consumer demand for radio content via a regulated licensing system that seems to fail listeners again …. and again …. and again. Although these two legal local commercial stations are truly dead and buried, the FM airwaves of South London nevertheless remain alive with the sound of dozens of unlicensed ‘pirate’ radio stations, many of which seem to know exactly what content their audiences want and know how to give it to them.

‘Pirate radio’ had been the starting point of South London Radio, though it might have been hard to believe if you had listened to the station in its final years. Between 1986 and 1990, a pirate station named Rock 2 Rock had broadcast from the roof of the three 24-story tower blocks behind New Cross station. Its programmes of soul, reggae and community information attracted a loyal following in South London and, although the station might not have been as well known as competitors such as LWR, Horizon or Solar, its signal reached across the capital, and its DJ roster exhibited a love of the music they played at a time when legal radio continued to shun black music almost totally. “Most of the people who were involved in [Rock 2 Rock] lived or worked in the Lewisham Borough,” DJ Inspector Scratch-It told me in 1992. “I don’t even really know what the secret [of our success] was. It was just something [indefinable].”

In the late 1980s, local resident Stella Headley had walked into her local reggae record shop, Sound City in Deptford, and asked if she could present a show on pirate radio. Despite having no radio experience, but armed with a passion for jazz music, Stella was offered a show on Rock 2 Rock where she called herself Lady X. The station quickly became ubiquitous in the area. “The way that we had broadcast was so down-to-earth and friendly,” Stella recalled when I interviewed her in 1992 [Radio Scan, City Limits #562, 16 July 1992]. “It was something that everyone could relate to.”

In late 1990, the government of the day introduced draconian laws that made it a criminal offence to be involved in the promotion or broadcast of pirate radio, with the possibility of a prison sentence even just for wearing a pirate station T-shirt or having a pirate radio sticker on your car. Rock 2 Rock, along with dozens of other pirate stations of the time, decided voluntarily to close down. “It was pressure,” explained Inspector Scratch-It, “realising that things could really start getting bad if we did get caught”. Some of the station’s twenty DJs moved on to work at new, legal ‘incremental’ stations that had just been licensed to satisfy previously unfilled gaps in the radio market – Mistri, one of the most popular club DJs of the era, joined short-lived WNK in North London; and I recruited Angie Dee to the launch of the legalised London ex-pirate KISS FM. Ten others, including Stella, started a new venture called First Love Radio which went on to campaign for Southeast London to be given its own commercial radio station.

A £5,000 grant from South Thames TEC enabled the group to organise formal radio training for local residents. A temporary, one-month FM licence (under the Radio Authority’s Restricted Service Licence scheme) showcased to residents of the Borough of Lewisham the content which the station wanted to be able to broadcast legally. Inspector Scratch-It explained: “We’ll be doing things we would have liked to have done when we were a pirate. Now we can plan ahead and use more people from the community, without fear of being arrested. I know how hard it was to maintain the [Rock 2 Rock] station. Every time there was a knock on the door, your heart was going thump, thump, thump”.

First Love Radio completed several, successful one-month local broadcasts, and by 1997 the Radio Authority was sufficiently impressed to advertise a small-scale commercial radio licence for Southeast London. To be sure of winning the licence, Stella involved commercial radio group UKRD as a partner and majority shareholder who, in turn, recruited community radio consultant Des Shepherd to write the licence application. In January 1998, the Radio Authority announced that it had selected First Love Radio as the winner from amongst eight applicants. The Authority noted proudly that “this is the 22nd ILR [Independent Local Radio] service to be awarded covering Greater London or parts of the capital”.

However, the station’s winning licence application promised, somewhat surprisingly, that its output would “represent the diverse tastes and interests of its target audience by providing a dynamic music mix from the 60s through to the 90s with high quality local news and information for the Borough of Lewisham”. Gone was any specific commitment to serving the substantial Afro-Caribbean community within the Borough. Gone was any specific commitment to playing soul and reggae music. It seemed that, while the Radio Authority was busy congratulating itself that it had licensed its 22nd station in London, it had condemned First Love Radio to become simply another tiny little station in the UK’s biggest radio market that would be playing the same pop music hits that everyone else was. The eventual fate of First Love was sealed there and then.

Whereas Rock 2 Rock had embodied a quite Unique Selling Point in its music format, First Love Radio was destined to be ‘all things to all people’. As one writer noted of its music policy, “this is perhaps as diverse as a radio station can get”. Owner UKRD was not really interested in the business of operating a black music station for Lewisham. UKRD was in the business of collecting local radio licences. A London licence held intrinsic value, whatever you did with it, and the cost of a licence application was probably no more than the low tens of thousands of pounds, while the scarcity value of any London licence made it worth millions. UKRD was an investment machine, turning paper licence applications into valuable licences, rather than a turnaround specialist turning poorly performing radio stations into success stories.

First Love Radio launched as a full-time station in 1999 but achieved dismal ratings so, in 2000, UKRD sold it to Fusion Radio Holdings, a new company established by radio salesman Nigel Reeve to acquire local radio licences. Stella Headley tendered her resignation from the Board little more than a year after her station had launched, abruptly bringing to an end her decade of hard work to secure a local station for Lewisham. The ideals of First Love Radio were already dead. Veteran radio presenter Roger Day was appointed Programme Controller of the station, whose name was quickly changed to Fusion 107.3. Reeve said: “We are delighted to have acquired two radio stations [Lewisham and Oxford] with huge growth potential. Plans are in place to build revenue and increase audience figures….”

In 2001, Fusion Radio Holdings and its three stations (Lewisham, Thamesmead and Oxford) were acquired in a deal worth £4.1m by another corporate collector of local licences, the Milestone Radio Company, which was run by former radio presenter Andy Craig. Media Business reported that the deal “puts an end to industry speculation concerning the demise of Fusion Radio [Holdings], following the move from its West End location to Lewisham”.

In 2002, Fusion 107.3 was instructed by the Advertising Standards Authority to withdraw a poster campaign that featured “a photograph of the naked torso of a woman” whose “nipples were airbrushed out and radio dials were positioned at the bottom right-hand side of her breasts”. Complainants had objected that the poster was “sexist and demeaning to women”, though the station’s owner argued that “the poster was designed as a high-impact campaign to attract new listeners” and that the model’s “radio dials [were] pointing south east to emphasize the geographical range of their broadcast”.

Three owners in three years were still failing to make First Love Radio/Fusion 107.3 a success. In 2003, Milestone raised £8m from an AIM share listing, despite admitting that it had “limited revenues to date and … accumulated net losses”. The pre-AIM company had suffered pre-taxes losses of £5m in 2001 and £4m in 2002, on turnover of £0.6m and £1.7m respectively. By 2003, Fusion 107.3 was still only attracting 6,000 listeners per week in a local market of 322,000 adults. The station was already losing more than £300,000 per annum, so Milestone put it up for sale.

In February 2004, after a year on the market, Sunrise Radio acquired both the Lewisham and Thamesmead stations for £1.2m. Sunrise (coincidentally an ex-pirate station) had run a successful, legal Asian radio station in London since 1989 and wanted to diversify into mainstream radio formats. In January 2004, former Radio Authority finance director Neil Romain had been recruited to head new Sunrise subsidiary London Media Company which would manage these stations.

Once again, the station’s new owner appeared to miss the opportunity to imbue the station with a Unique Selling Point to differentiate it from its many competitors in the London market. The station was renamed South London Radio and its web site was branded “All Time Favourites”, a radio format similar to that already offered in London by Heart FM, Magic FM, Gold London and Smooth Radio, amongst others. As a result, in 2006, the station was given a ‘Yellow Card’ sanction by Ofcom because it was found to be failing its mandated music format. Ofcom said the station “should have a distinct musical sound” whereas “over 50% of the daytime output fell within the Hits/Pop genre”.

As well as the change in station name, the new owner asked Ofcom’s approval in 2006 to temporarily move the station’s studio out of its Lewisham service area to share premises with co-owned Time 106.8 in Thamesmead. There was a subsequent period when the station operated from a business centre in Croydon. At the same time, it appears that improvements to the station’s transmitter were granted that enabled the station to be heard across a wider area that included parts of the Croydon and Bexley boroughs for the first time, extending the potential audience to 645,000 adults. Eventually, the station returned to co-location in Thamesmead.

During this whole period, the station’s music policy continued to be a bizarre mish-mash of current hits and the oddest selection of ‘black music’ that seemed scheduled purely to satisfy Ofcom’s prescribed Format requirement to appeal to “listeners with a preference for soul/Motown, R’n’B, reggae and dance hits”. So the daytime output might make transitions straight from Nat King Cole to Lily Allen, or from Dionne Warwick to the Pussycat Dolls. Whilst I personally like eclectic mixes of music styles, South London Radio ended up sounding particularly schizophrenic. Five years under the same owner should have provided plenty of time to make the station at least sound consistent and instil it with a sense of purpose. Neither Romain, without prior radio management experience, nor Sunrise, without experience in black music formats, achieved a successful turnaround of the Lewisham station.

In 2008, a notice appeared on the consumer-facing homepages of the Lewisham and Thamesmead stations, informing interested parties that both were up for sale and inviting bids. Sunrise Radio’s Avtar Lit explained: “They are good local businesses but they do not fit in with our portfolio. Traditionally these stations have always made losses but we have reduced those losses dramatically. The days of large companies running a number of local radio stations are gone, simply because the decision-making process is too far removed.” There was at least one bid lodged for South London Radio, but the offer deadline passed and no transactions were reported. Precisely what happened next is open to interpretation…………

The official web site of South London Radio includes a message which explains (in part):
“Both stations were sold on 22 February [2009] to an individual who, after seven days of ownership, informed staff that he could not afford to fund the stations and would need to sell one station to fund the other. At this point, staff had already not been paid for the month of February. Since the announcement, staff have been working at the station free of charge in the hopes a new buyer would be found. After a lot of work, a potential buyer was found who was very keen to acquire the stations and take them forward. Several obstacles were put into their way which saw the sale of both stations put on hold……”

The Radio Today web site initially reported on 4 April 2009 that both stations had closed because they had been “up for sale but no suitable buyer was found”, though its storyline was later amended to match the explanation on the stations’ web sites.

According to the Company Register, on 22 February 2009, Sunrise Radio’s Avtar Lit, London Media Company’s Neil Romain and Company Secretary Sonia Daggar resigned as directors of South London Radio. On the same date, Arvind Kumar Audit was appointed sole director of South London Radio, and a loan to the value of £1,029,704.61 was made from Sunrise Radio to South London Radio which gave Sunrise first call on the station’s assets. Staff at the stations have suggested that a relative of Lit was brought in to manage the Thamesmead operation, though this allegation remains unsubstantiated. For the brief period the two stations remained on-air, Audit was listed in their Public Files as Station Manager. However, Ofcom did not publish a Change of Control review for these transactions.

In legal terms, it would appear that Sunrise Radio/London Media Company sold the stations weeks before they closed, though why someone would decide to purchase a loss-making station that had a £1m loan outstanding to its previous owner remains a mystery. Nevertheless, the circumstances make it impossible to suggest that Sunrise Radio/London Media Company themselves closed these stations (as Radio Today had initially stated) because the stations were not officially under their control when the plugs were pulled. This subtlety might hold some importance to Sunrise or Ofcom, but it remains wholly irrelevant to the local people of South London who no longer have a local commercial radio station, whatever did or did not happen.

Admittedly, listeners to South London Radio were few in number as a result of the station’s consistent failure to connect with an audience. Its market share only surpassed 1% during two quarters of its decade on-air, though most of the time it registered less than 0.5%. In the station’s launch year, its listeners numbered less than 1,000 adults per week although, by the time it closed, that number had risen to 19,000 within its significantly enlarged coverage area. These numbers would still prove too low to adequately finance a local radio business in London. The station had never stood a chance from the time that UKRD saddled it with a pop music format in its licence application.

South London Radio never made an operating profit from airtime sales, not even in its earliest days. The only period of positive cashflow occurred in 2004 and 2005 when £1.7m compensation was received from its landlord when the station was forced to vacate its premises, presumably before its tenancy had expired. Ironically, this windfall was twice the size of the advertising revenues received by the station during its entire lifetime. Although, in recent years, its owner had managed to substantially reduce the station’s overheads, revenues had fallen to as little as £1,000 per week by then. There are pirate stations in South London that earn more money than that.

South London Radio’s final owner (or ‘penultimate’ owner legally) seemed to know where the blame lied for the station’s failure. In one set of Annual Accounts, its directors said:
“Despite significant investment by the management, the station has continued to perform below expectations. The impact of illegal broadcasters compromising the transmissions of this station is the main reason for the poor financial performance. The Directors are continuing to lobby the regulators in an attempt to find a solution”.

It was this lobbying by Sunrise Radio (a former pirate) of Ofcom which led to the transmitter power increase that significantly extended the station’s coverage area. Its owner then increased the survey area for the station’s RAJAR audience ratings from 304,000 to 1,472,000 adults, but the station’s weekly reach stubbornly remained at around 1%. Perhaps the owner thought that a station which claimed to reach 1.5m people across South London was more likely to find a buyer than a station that served only the relatively poor Borough of Lewisham. Whatever, South London Radio eventually closed with accumulated losses estimated at almost £2m, a figure that would have been twice the size, had it not been for the windfall settlement the station received from its previous landlord.

So it’s all over now, a sad end to Stella Headley’s dreams and also the death of what was supposed to be my local radio station. Hopefully, some lessons can be learned from this sorry tale. Some of these ‘lessons’ seem so glaringly obvious that it is almost embarrassing to point them out, but the 36-year history of commercial radio in the UK is so littered with repeated failures that it is worth spelling out some of the things that evidently went wrong. First Love Radio is just one of many local stations that have failed with both audiences and advertisers because of structural and procedural faults within the UK’s commercial radio system.

POSSIBLE LESSONS

1. CAN A DESIGNATED LOCAL MARKET SUPPORT AN ADVERTISING-FUNDED COMMERCIAL RADIO STATION?
Before advertising a new licence for a specific geographical area, the radio regulator did not evaluate whether there were sufficient local advertising revenues to support a commercial radio station for that area. This was true of Lewisham when the Radio Authority advertised this licence in 1997. A decade later, it was probably just as true of Ofcom when it awarded new licences for a talk station in Edinburgh (now closed), a rock music station in Plymouth (never opened), a station serving a population of 65,000 adults in Barrow (now closed), or a station serving a population of 30,000 adults in Northallerton (now annexed). Whether it was the Radio Authority or Ofcom, the regulator was issuing ‘licences to fail’ that never stood a chance of being successful, standalone businesses.

2. LOCAL RADIO GROUPS ARE FODDER FOR THE AMBITIONS OF COMMERCIAL RADIO GROUPS
First Love Radio is not the first local radio group to have organised short-term broadcasts in their area, organised training, raised public funds and raised local awareness of it campaign for a local station. Then, when it comes to writing the licence application, many such groups jump into bed with a commercial radio group that has no understanding of the group’s aims, the proposed station’s format, or the local marketplace. The radio group is interested in the licence, and the local group believe that such an alliance will ensure that licence will be won. An outside ‘consultant’ is brought in to write an application that is likely to win the licence, rather than an application that tells the truth.

3. NEW LOCAL COMMERCIAL RADIO LICENCES ARE AWARDED TO APPLICANTS THAT ALREADY HAVE COMMERCIAL RADIO LICENCES
To those that already have shall be given …. again and again and again. How many of Ofcom’s 39 new local radio licences between 2004 and today were awarded to applicants that did not already own a radio station? Ony one. It’s a regulatory gravy train of licence awards, which works great for those lucky few who already have a seat on the train. For those genuinely local radio groups who simply have a desire to run a radio station in their local area, the message is – you don’t stand a chance of winning a licence on your own.

4. MOST LOCAL RADIO GROUPS’ EXPERTISE IS IN COLLECTING LICENCES, NOT IN TURNING AROUND LOCAL RADIO STATIONS
As noted previously, the cost of making a licence application is usually a five-figure amount, whereas the balance sheet value of a radio licence is either a six- or seven-figure sum. The ‘business’ skill of most local radio groups has been based upon turning paper radio licence applications into valuable intangible assets to add to their balance sheets. Sadly, it has not been based upon launching successful local radio stations (‘successful’ meaning profitable), or upon turning around unsuccessful stations.

5. RADIO LICENCE APPLICATIONS ARE GENERALLY NOT GROUNDED IN REALITY
The promises made in most licence applications are mostly over-optimistic ‘waffle’. The lavish programming, the potential profitability, the audience targets – most of these are written purely to fit what the applicant radio group thinks the regulator wants to hear. Almost every licence applicant promises that its business will break-even within three years, despite evidence that there are very, very few newly-launched stations that have achieved such a performance in the last 20 years. Rule Number One of licence applications – never let the facts get in the way of a good story. As a result, the performance of most start-up stations is more than dismal. The graph below shows the percentage plus/minus achieved in hours listened versus the forecast hours listened in the station’s licence application for new local stations licensed during the last five years. Only four stations managed to beat their targets. (The crosses represent stations that have closed.)

Because of the untruthfulness of most licence applications, if you were to submit a more realistic assessment of your business plan within a licence application, it would look very gloomy compared to your competitors. Do you get any credit for being realistic (i.e. honest)? No, you are unlikely to be awarded the licence.

6. THE REGULATOR DOES NOT ‘POST MORTEM’ ITS LICENSING DECISIONS
When the Independent Broadcasting Authority licensed the ‘incremental’ stations, did it publish a report to show why so many of them went out of business within their first year? No, it didn’t. When the Radio Authority licensed the ‘regional’ stations, did it publish a report to show why these stations had no impact on enabling commercial radio to be more competitive for audiences against the BBC? No, it didn’t (I did my own research). Now that Ofcom has licensed so many new local stations, has it published research to show why so many are already proving unviable and whether awarding new licences to existing licensees had proven the appropriate regulatory policy? No, it hasn’t (see research in John Myers report). In all these cases, there seems to have been no attempt to learn from past experience, and thus no attempt to assess the positives and negatives of regulatory policy. To an observer, the attitude might look remarkably like ‘OK, that didn’t really work, so let’s try something different now’.

7. A LOCAL RADIO LICENCE ONLY ACQUIRES INTRINSIC VALUE IF YOU DO SOMETHING CONSTRUCTIVE WITH IT
Local radio groups can play the game of putting inflated values for their local radio licences on their balance sheets. But unless you can actually find someone who is willing to pay that inflated price, your licence in reality is worth nothing at all. After an era of crazy acquisition prices during the 1990s, we are now in a period where there have never been so many station sellers, but almost no buyers for the majority of small local radio licences. The ‘house of cards’ that was carefully constructed over the last two decades is already falling down. The radio licence gravy train bears some similarities to the vulnerability of a Ponzi scheme. Now that Ofcom is no longer offering new local radio licences, the ability of radio groups to continue to improve their balance sheet valuations through more licence wins has ended abruptly. As a result, their existing stations are now revealed to be worth a lot on paper, but worth almost nothing in reality because there are no buyers (i.e. other local radio groups with similarly over-inflated balance sheets). The underlying fallacy of the licence award system is now revealed.

8. THE TRACK RECORD OF MOST SMALL LOCAL RADIO GROUPS IS NOT GOOD
There is simply no money to be made from owning a number of small local radio licences, unless you have proven turnaround skills. Plenty of companies have raised millions of shareholder funds, promising to return them a profit from a cluster of loss-making local radio stations. The profits never arrived. Laser Broadcasting went bust. Forever Broadcasting went bust. The Wireless Group sold out. Golden Rose sold out. Milestone sold out. The Local Radio Company is on its knees financially. You might think that this history of failures would be sufficient warning to future investors that adding X number of loss-making local commercial radio stations to Y number of loss-making local commercial radio stations does not equal profits. Apparently not.

9. THERE IS A WIDENING ‘REALITY GAP’ BETWEEN WHAT THE REGULATOR IS REGULATING ON PAPER, AND WHAT IS ACTUALLY HAPPENING IN LOCAL RADIO MARKETS
On paper, each of the UK’s 300 commercial radio stations has a distinct ‘Format’ it has to follow, theoretically offering it a unique position in its local market. In this highly regulated system, Ofcom is supposedly ensuring that a diverse range of consumer demands for radio content are being simultaneously satisfied in each market. Even a casual radio listener realises that this system is a fiction. London has a large number of local commercial stations, and many of them sound remarkably similar, despite on paper them being meant to be different from their competitors. If South London Radio had offered different content and satisfied local demand for content, it might have thrived. Despite its Yellow Card sanction, Ofcom failed to ensure that South London Radio was satisfying the demand in South London for a local, black music station.

10. THE CLOSURE OF A LOCAL STATION IS THE FAULT OF BOTH ITS OWNER AND THE REGULATOR
It is very easy for the regulator to step back and say that the commercial failure of a specific local radio station is not its responsibility because it does not interfere in the business operations of its licensees. Frankly, this is a cop-out. Eight applicants applied for the Lewisham licence awarded to South London Radio. Seven were never even given the opportunity by the regulator to create a successful local radio station. Our public servants in the regulator were supposed to use their knowledge and expertise to select the applicant that was most likely to ‘win’. Ofcom even has a web page where it explains why it selected one applicant above the others for each licence. If the regulator’s choice was misguided, mistaken or ill-informed, it should have to explain what went wrong (a bit like this blog entry?). Surely, the regulator owes such an explanation to the listeners the station was supposed to serve and also to the unsuccessful licence applicants who, as a result of the regulator’s judgement, have no ‘second chance’ to put their own proposals for a radio station into action.

11. RADIO STATION OWNERS ARE NOT REQUIRED TO SELL STATIONS, RATHER THAN CLOSE THEM
I have heard several radio group executives say that they would rather close down one of their loss-making stations than sell it for £1. There are several issues at play here. Firstly, closing a company creates an opportunity to move some liabilities from elsewhere in the group before the station is made insolvent. Secondly, radio owners don’t want the embarrassment of someone else successfully turning around a station that they had not managed to make profitable over several years. Thirdly, if an owner paid £1m for a station, it is embarrassing for the CEO to have to tell their Board that it had to be sold for £1. The end result, as in South London, is that listeners no longer have a local radio station at all, rather than the baton being passed on to someone else to try and make the business work. Again, it is the listeners and the unsuccessful licence applicants who lose out.

12. THE SCARCITY OF LOCAL RADIO LICENCES HAS TURNED THEM INTO TROPHY ASSETS
If you want to start a local newspaper, you simply start it. You don’t need a licence. If you want to start a local radio station, you cannot. You have to wait for Ofcom to decide to offer a licence for your area, then you have to apply for it, and then you have to win it. In this case, Ofcom is unlikely to offer another South London FM licence to replace South London Radio. That opportunity came and went in 1997. As a result, there are far too many owners coveting local radio licences because of their scarcity, hoping that at some point in the future a ‘white knight’ will still ride over the horizon and pay an outrageous sum for it, regardless of the fact it is losing money every year and has accumulated losses of millions. After the Communications Bill opened up UK radio ownership to non-European Union stakeholders, there were several radio owners who were waiting for a global media company such as Clear Channel to ride into town and offer them a small fortune for their failing businesses. It never happened, and sadly there was no ‘Plan B’.

13. THE LACK OF CREATIVITY IN COMMERCIAL RADIO
There is a terrible lack of creativity within the commercial radio sector that is severely holding back its ability to compete with the BBC, let alone to compete with the flood of audio content available via the internet. It is far easier for radio companies to simply do either the type of content that they have always done and/or the content that everybody else is doing, rather than to be innovative or creative. In the case of South London Radio, I understand that its owner was approached last year by at least one radio consultant (not me) with a plan to resuscitate the station by returning it to its original roots as a black music outlet. That proposal was rejected.

14. THE REGULATOR PRETENDS TO ADOPT A ‘LIGHT TOUCH’ APPROACH TO COMMERCIAL RADIO REGULATION
If the regulation of commercial radio in the UK were genuinely ‘light touch’, then it would be appropriate that the regulator makes no attempt to intervene in the failure of individual stations. However, the system of radio regulation (even under Ofcom) intervenes heavily in almost every aspect of the commercial radio landscape, down to such detail as whether a particular station can play a specific song within its output. In such a highly regulated market where Ofcom exercises such a high degree of control, the regulator should surely have a responsibility to the citizen/consumer to ensure that the relatively small number of stations it selects to license (compared to the total number of applicants) continue to exist in some shape or form. It is not consistent to intervene at every moment of a station’s existence, except when it is finally threatened with closure as a direct/indirect result of the regulatory system.

15. NO CONSULTATION WITH LOCAL STAKEHOLDERS
Ofcom makes a big noise about its consultation system and its willingness to listen to the opinions of a wide range of stakeholders. However, when a station is threatened with closure, has the regulator ever consulted with local advertisers to consider the impact on them, with local community organisations who used the station to inform the local population of their activities, or with the local population itself? Would it not be useful to talk to Stella Headley now and canvas her opinion of what precisely had gone wrong with First Love Radio since 1990 (I tried to locate her for this blog entry but failed)?

The irony of South London Radio’s closure is that, over a ten-year period, things have already gone full circle. South London Radio was born from the experiences of pirate radio in the Borough of Lewisham, and now it is the pirate stations once again that are carrying the torch for those of us living in this area of South London. There is presently a great pirate station in Lewisham that sounds like the natural successor to1980s pirate Rock 2 Rock, playing reggae and soul music for ‘big people’. I can listen to this station on FM or via the internet (telling you its name would break the law) and it entertains me in a way that the latter day South London Radio never achieved. I used to listen to Rock 2 Rock in the 1980s, and now I am listening to its successor.

First Love Radio R.I.P.

It appears that our highly regulated and interventionist commercial radio system has:
* completely failed the people who originally put the idea together for First Love Radio
* completely wasted the public money invested in training people from the local community in Lewisham to make radio programmes
* has completely failed the population of Lewisham and beyond who should have their own radio service.

These failures in public policy will continue to have to be filled (though not fully because of the threat to those involved of criminal prosecution) by the efforts of unlicensed radio stations in Lewisham. A document published by the publicly funded Creative Lewisham Agency lamented that “television and radio is a very small Creative Industries sub-sector” in the north of the Borough ….. but then it noted that pirate radio is “a contributor to the Creative economy” and “is certainly vital for networking and showcasing”. When you find public bodies extolling the citizen value of pirate radio, you know for sure that something in our radio licensing system has gone very badly wrong.

As Inspector Scratch-It recalled of his Rock 2 Rock days: “We even had links with the police and [Lewisham] Council. They used to send us information that was relevant to read out, even though we were a pirate.” Twenty years on, it is still pirate radio filling that gap.