Is this the end of BBC local radio? As we commemorate the 50th anniversary of Frank Gillard's dream, is its future in peril?
Ofcom's draft new pan-BBC licence appears to permit a BBC local service which is largely networked - with sparse local news bulletins and a few
local features; targeting anybody the BBC wishes, playing the music anyone fancies, with very little by way of genuine, passionate, championing local
content.
The service licence under the ancien régime, the BBC Trust, was considerably more insistent about the character of its local network, as cited below. Now, that detailed and specific local radio Service Licence is to be replaced by provisions contained within an Ofcom licence of broader scope, covering all BBC services.
What's changed?
The requirement that
BBC local radio serves the 50+ generation is gone. Ofcom believes it appropriate to stipulate that Radio 1 should serve 'younger audiences', but not than any other service should explicitly serve grown ups - despite 50+ audiences being wholly unattractive to commercial broadcasters. Whilst the BBC must report to Ofcom on how it addresses diverse audiences, that analysis pertains to the BBC's output as a whole, not to particular services - let alone individual local radio services. Such scrutiny will come as little comfort to the 31% of BBC local listeners who consume no other BBC radio*.
The requirement that
BBC local radio plays a certain sort of music is gone. There is no longer any restriction on how much music may be current or otherwise.
The requirement for
specialist music has gone.
The requirement for encouraging local new and
emerging musicians is gone.
The requirement for
local passion is gone. Your BBC local radio station is no longer necessarily expected to ‘champion’ your area; nor hold decision-makers to account; nor play a part in 'a shared sense of civic responsibility'.
The requirement for news is depleted: The BBC must now only ensure that a station "provides news and information of particular relevance to the area and
communities it serves on local radio at intervals throughout the day"; and that it "provides other
content of particular relevance to the area and communities it serves".
Why should BBC local radio be allowed to do news only when it can be bothered, when its commercial neighbour must broadcast hourly bulletins? Ofcom appears not to have read the Trust's review into BBC local radio (March 2016): "...given the deep concerns regarding the potential impact of the BBC on local news markets, we are clear that there is a need for ongoing regulatory oversight of BBC’s scope in local news."
Why should BBC local radio be allowed to do news only when it can be bothered, when its commercial neighbour must broadcast hourly bulletins? Ofcom appears not to have read the Trust's review into BBC local radio (March 2016): "...given the deep concerns regarding the potential impact of the BBC on local news markets, we are clear that there is a need for ongoing regulatory oversight of BBC’s scope in local news."
Interactivity is no longer a pre-requisite.
Religious programming and programming on minority
sports or for minority audiences is no longer required.
Stations can share a
huge amount of programming with ease. Whilst the time allocated on each BBC
Local Radio station to original,
locally-made programming must not be less than 95 hours (was 85), “original,
locally-made programming” includes
programming shared with neighbouring stations. There is no limit on such sharing.
One could,
accordingly, merge station X with Y, provided both patches were covered adequately as part of a broader editorial agenda. Indeed, mega-regions or the whole network might be merged,
provided inserts of local news and features were injected throughout the day.
Whilst,
arguably, the old Trust licence enabled more programme-sharing than had been implemented,
this new licence seems to facilitate more sharing thanks to diminished content
requirements which can be dispensed with ease in programmes serving a larger patch
The 60% speech across 0600-1900 - and an all-speech breakfast is retained. There is little indication what this speech might comprise.
Regulation
Ofcom has been selective about which areas of all services should be regulated in its new regime. Unlike the BBC’s former governing body, it feels it should lay out 'high level objectives' and has thus removed "the extensive qualitative requirements" which "served more of a governance or strategic function than a regulatory function". They suggest that the requirements are a minimum level benchmark - and that performance will be appraised more generally across the range of BBC services.
I imagine there will be insistence that my analysis above is over-dramatic. I’m not suggesting the BBC has in mind that it would take maximum advantage of this flexibility, but it seems to me to be possible. Under the proposals, BBC local radio could be depleted in the way I have suggested without breaking the conditions of its its licence. Months ago, that was not the case.
Demographic focus
The only BBC station currently targeting the huge over 50s generation is BBC local radio. In the future, the service can target whomsoever it wishes. As I have outlined previously, I have serious reservations about how that even the extant remit
has been tackled in recent years. A poor focus has resulted in a listening share decline amongst those aged 50-70 of 28% in the last five years, vs a drop of 17% amongst adults**. The absence of any focus will result in further deterioration.
If no radio service is dedicated to 50+, the BBC will, on no service, look through life through the
spectacles of those who’ve lived a bit. I cannot countenance that this is what
Ofcom wishes. Whilst the regulator's weasel words suggest it will ensure diverse communities are represented, it troubles to make no specific provision for those over 50, or over 65, who feel that much other radio is not aimed at their tastes.
BBC radio overall does appear, statistically, to serve older audiences well currently in terms of audience volume, principally because that generation loves its radio habit. Indeed, it is because it adores its radio that its stations must be protected.
Regional approach
Regional radio cannot serve the purpose of local radio. Regional identities, in many cases, frequently live only in the minds of bureaucrats and media organisations. You can have as little in common with the City next door as the one right across the Country - and there may be destructive rivalries. In some 'regions', if you are not local, you may as well be national.
It is already the case that the larger stations tend to have a smaller % reach; and there is clear correlation between TSA size and % reach***. Furthermore, in any regional plan, it is the smaller communities which miss out most, as content naturally emerges from the populous areas.
As more regionalisation or networking is permitted, off-peak and weekend programming will likely suffer first - such times when programming has been able to be beautifully specific and distinctive in its appeal and its audience share maximised. The evening programming, networked since 2013 and replacing dedicated local programming, has diminished audiences. If this is the trial, can we declare the matter proven?
BBC local radio seems to matter little to London's Ofcom. In its 'distinctiveness' research summary (March 2017), BBC local radio is mentioned but once, despite the existing service being hugely distinctive
from its commercial competitors. BBC
national radio was commended but the report conceded,” a few participants suggested
that BBC Radio could be more distinctive by showcasing even more non-mainstream
music, or by more coverage to local issues and music”. So, despite the fact
that this was cited as the only adverse radio comment in the research summary, Ofcom
chose to diminish the importance attached to these areas in its proposed licensing regime.
Regionalisation is the route commercial radio has adopted. Surely, however, this is part of why publicly funded radio exists: to provide services which are not
sustainable on a commercial basis. The
justification for BBC local radio is greater now it may well be the only
locally-driven service in the market. What's more, as commercial radio has its news provision regulation hardened by the regulator, that of BBC local radio is lessened.
At a time when local press is under threat, money is injected into puzzling BBC ‘local democracy’ schemes even though Ofcom allows the atrophy of platforms on which such reporting might be carried.
If it thinks that funnelling reports into windows in networked
programmes achieves what BBC local stations have hitherto, it is mistaken.
BBC local radio attracts an audience for the company it provides.
In the absence of that company, any news bulletins will be served to a
diminishing audience. I would suggest that a ‘serves all’ local service’ will not generate a meaningful audience; and the lack of focus on a target audience hitherto has been responsible in part for the network’s decline.
Economic
BBC local radio has its challenges. As an expensive multi-site operation, it will
logically cause some head-scratching as budgets are reduced. It simply cannot afford to carry on as it is. But, as many have pointed out, a proud, solid and
popular locally-tailored news, chat and music service can be delivered at a
considerably lower budget than is currently being spent.
There are alternatives to demolition. Gifted leadership, capable management, and a small committed and agile staff, together with judicious use of technology and reduced central overheads and intrusion, can deliver an even
richer local service than now, at half the price - without leaning lazily on unwarranted regionalisation. It's time for change - but not this change. Give me the money and I'll show you.
Local value
May I suggest other options are tried first, before this atavistic destruction. Let us examine more closely the inputs before we reduce the outputs required. Local radio was Frank Gillard’s dream - and, as he would confirm were he still with us, BBC Head
Office never really understood it. Not least because in London, for a
host of reasons, local radio has never been a powerful force.
Hopefully I’m wrong. Maybe I am missing something. Maybe this document was printed just as
the Ofcom printer ran out of ink - and it’s missing a few pages.
If I am correct, however, then Ofcom is failing in its duty to protect the purposes of the BBC as delivered by its Charter. Judging by the paucity of licensing conditions, it has failed to recognise the value listeners attach to BBC local radio - an audience approaching the size of Radio 1's in England.
The draft sits ill at ease with all published insight:
"Overall, audiences are pleased and satisfied with BBC Local services. There was a lot of warmth for the BBC Local offer in the six case study regions visited. Audiences felt it was important that they “had a voice” via regional BBC media and that their local news and information was being presented and delivered to them by people who live in, and understand, the region. BBC Local Radio was particularly valued, especially by older listeners (60+) who found it gave them companionship. Audiences like how BBC Local Radio keeps them informed about local news and events, whilst the debates and phone-ins help listeners feel involved in their community" (MTM Research summary for the BBC Trust, 2015)
"Audiences have very positive perceptions of BBC Local Radio regarding its quality, accessibility and ability to engage them. Our evidence has shown that BBC Local Radio is not just distinctive, but unique in many respects – the BBC’s local stations are often the only ones in their area offering local content across the daytime schedule. The stations are distinctive in other respects too: their focus on serving older listeners, their high level of news and speech, and their provision of many opportunities for listeners to have their say." (BBC Trust Service Review BBC Local Radio and Local News and Current Affairs in England - March 2016)
Let’s not celebrate BBC Local Radio's 50th anniversary by closing it down.
You have until 17th July to bang on Ofcom's door with your thoughts.
You have until 17th July to bang on Ofcom's door with your thoughts.
Existing BBC Trust Service Licence for BBC local radio:
The target audience should be listeners aged 50 and over, who are not well-served elsewhere, although the service may appeal to all those interested in local issues. There should be a strong emphasis on interactivity and audience involvement.
The output should be relevant and act as a trusted guide to local and other issues for its audiences. BBC Local Radio stations should champion the local area and call to account decision makers.
It should encourage a shared sense of civic responsibility among its listeners by providing constantly updated, accurate, impartial and independent news and information on local, national and international matters.
It should host wide-ranging discussions on matters of local concern and hold elected and unelected decision makers to account, and frequently offer listeners opportunities to contribute to the output and take an active part in their local communities.
Sustaining citizenship and civil society BBC Local Radio should make a very important contribution to this purpose amongst its audience.
It should encourage a shared sense of civic responsibility among its listeners by providing constantly updated, accurate, impartial and independent news and information on local, national and international matters.
It should provide opportunities for new and emerging musicians from the local area and support local arts and music events by providing event information
Music output should be mainstream in peaktime and include specialist in off-peak hours. Specialist music should be appropriate to the area.
Current and recent chart hits should represent no more than 15% of weekly music output.
All stations should mount regular outside broadcasts at events across the local area and report on local sports teams, including minority sports when appropriate to the local area.
All stations should aim to serve local minority audiences.
Each BBC Local Radio station should: Broadcast at least 85 hours of original, locally-made programming each week (Programming shared with neighbouring stations broadcast between 06:00 and 19:00 can be included in the total.)
In addition to local programming, each station may also share some programming with local BBC stations in nearby areas and there may be a single network programme each weekday. They may also simulcast BBC network radio overnight
During the networked programme, each station should retain the ability to cover local emergency situations where necessary.
*** Rajar BBC Local Radio W4 2017