Wednesday, 19 April 2017

Goodbye from BBC Local Radio?

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 rĂ©gime, 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."

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.



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 12 month figures up to Dec 2016
***Rajar BBC Local Radio 12 month figures up to Dec 2016 share Dec W4 2011 v  W4 2016
*** Rajar BBC Local Radio W4 2017


10 comments:

  1. I found BBC LR was at its strongest when they had a strong local competitor. That focussed the minds to be "first with the news" and best for local sport. Having competition that played a diversity of music shows (country, jazz, etc) in the evening also encouraged BBC LR to compete head-on to ensure they stayed in tune with the listeners. Now ILR has become INR with a sprinkling of local adverts (and no local editorial content) the BBC has less competition and, I think, is weaker because of it. I remember when two local stations BOTH competed with each other to do a live football commentary at 2am. These days I don't think that game would attract more than an agency reporter.

    It is difficult to use a broad brush to discuss this issue as all the stations should have their own local priorities but some stations use the 60% speech instruction to cover local issues more effectively while some stations (including one near where I live) just use it as an excuse to witter and pass off trivia as important content while reading yesterday's local newspaper as tomorrow's news.

    As the 7-10pm slot seems to be networked, why not save the money & just re-broadcast another BBC service? As to the question about sharing some programmes in neighbouring areas, this isn't new. In my area 4 of the local services shared afternoons for a few years. If the presenter is strong enough then it will work. Denis McCarthy was an exception host. As was Ed Doolan when he co-hosted on a couple of stations and gave both areas exceptional local output. The key is to find a strong & knowledgeable local presenter. The other trick is too have a manageable editorial area & not one that covers half of South East England (as was tried for a while) to ensure a fair chance for all appropriate stories to be properly analysed.

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  2. I am at a loss to understand why OFCOM are being allowed to determin BBC broadcast policy. Yes, there was a need for it to take on the role of dealing with complaints. But that is all it should have been. The BBC is unique and sometimes has overstepped the mark and lost sight of its core purpose. But no where near to the extent that an outside body should be permitted to stick it's ore in. It would be like Network Rail telling train operators what services to run.

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  3. I am at a loss to understand why OFCOM are being allowed to determin BBC broadcast policy. Yes, there was a need for it to take on the role of dealing with complaints. But that is all it should have been. The BBC is unique and sometimes has overstepped the mark and lost sight of its core purpose. But no where near to the extent that an outside body should be permitted to stick it's ore in. It would be like Network Rail telling train operators what services to run.

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  4. You appear to be making the assumption, on the basis of no evidence that I can see, that just because Ofcom loosens the regulations the BBC will somehow try to shut down Local Radio. You're right, Local Radio faces massive economic challenges, but the BBC continues to value it as a core public service.

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  5. Thanks, James. I think I recognise your name! Rest assured I do recognise the point that the BBC may or may not choose to take advantage of any 'loosening' for BBC local radio; and I expressed that point explicitly. The same is true of other radio networks, but their requirements in the draft licence appear more explicit.

    This, however is a time of consultation for the Ofcom BBC governance, and a time when people should rightly consider what is proposed as a minimum benchmark; and I feel it important to contribute to that debate.

    It does seem to me to be odd that under Purpose (1): To provide impartial news and information to help people understand and engage with the world around them', there are no explicit requirements of BBC local radio, whereas Ofcom does see fit to impose them on  Radios 1, 1Xtra, 2, 3,4, 5Live, 6 Music and the Asian network.

    Under Purpose (2): To support learning for people of all ages, there are no explicit requirements for  BBC local radio, whereas Ofcom does see fit to impose them on 1, 1Xtra, 2, 3,4 and 6 Music.

    Under Purpose (3): To show the most creative, high quality and distinctive output and services (Distinctiveness), there are no explicit requirements for  BBC local radio, whereas Ofcom does see fit to impose them on 1, 2 and 5Live.

    There are some BBC local provisions under Purpose (4): To reflect, represent and serve the diverse communities of all of the United Kingdom’s nations and regions and, in doing so, support the creative economy across the United Kingdom, as I reflected in my blog. The news bulletin requirement for BBC local radio seems Spartan alongside even those of Radio 1 (under Purpose 1) - and whilst there are overall requirements for the quantity of 'locally made programming' , such output may be shared, seemingly without restriction, with (undefined) neighbouring stations - which appears not to bear out the intention of the Purpose.

    Under three of the four BBC Purposes, there are no requirements for BBC local radio to contribute; whereas demands do exist on other radio services.

    I am aware significant changes are proposed to reflect both budget pressures and changing audience habits; and staff are rightly being kept up to date as openly as is possible. There is, as we both know, a need for change.  In this context, it is right to examine closely the base-line draft requirements which will be implemented by your regulator.

    In terms of your observation on evidence:

    a) There is evidence that the focus on the 50+ audience has waned; and the audience figures bear out my own listening experience. The lack of any explicit focus in the draft licence, appears therefore to me to be material.

    b)There is also evidence that the BBC does have an appetite to network or regionalise more programming on BBC local radio as it sought to do that in 2011. The Trust stopped the move on that occasion; next time, it would be the duty of Ofcom.

    As I hope I made clear, I believe that to regionalise/share programmes during the day - and to take away valuable off peak local distinctive programming at weekends and evenings and therefore the ability to champion effectively  - is giving up on the very  tenets which underpin the real friendship value listeners attach to their own local service.  To move in such a direction would indeed be to close down these services which truly belonged to their communities and replace them incrementally with something different.

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  6. I share your worries David and am concerned that for some time BBC local radio has lacked enough friends in high places in the Beeb ( and beyond) to fight a successful battle against creeping regionalisation, which dilutes local identity, loses listeners and contributes to its decline.

    Radio 4 or 5 Live don't GO LOCAL at times of the day when fewer listeners are tuned in and nor should BBC local radio be expected to GO REGIONAL or NATIONAL whenever the budgets 'need' to be cut - which they seem to do regularly.
    Like I said earlier, BBC local does not have enough big hitters fighting for it over an ever-decreasing share of the budget, even though it's needed now arguably more than ever.

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  7. Hi David, I like the comparison you make of reach v. TSA! However, the cost per listener for our local English stations is more than should be afforded, given their narrow focus on the older generation. People of all ages live in these communities and the BBC should be engaging them likewise.

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    1. A station targeting everyone will likely attract lower audiences than one targeting someone. I suggest audiences have already fallen because of a lack of focus.

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  9. And a lack of marketing! I see lots of tv promos for Radios 1,2,3,4 & 5 Live & 6 Music though. Not seen a generic LR trail for years. It's not the only issue but certainly doesn't help

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