Memorandum submitted by GCap Media plc
INTRODUCTION
GCap Media plc is submitting this evidence to
the Culture, Media and Sport Committee Inquiry into Public Service
Media Content as a mark of our commitment to public service commercial
radio. In legislation, the term "Public Service" is
applied only to certain television channels and BBC Radio—but
in the ecology of UK media, commercial radio makes a significant
contribution which is seldom recognised by policy makers. Services
such as Classic FM have opened up the world of classical music
to new audiences, digital radio stations like Planet Rock[1]
and FUN radio[2]
serve listeners who have never before had a station focussing
on their particular tastes and interests, and the local radio
stations in the GCap Media stable and across the commercial radio
network make a major contribution to community cohesion and economic
development.
This submission is structured around the seven
questions posed by the Committee, and draws upon a major evidence-gathering
exercise which maps GCap Media's stations against the Ofcom framework
of the "Purpose and Characteristics of Public Radio"
set out in Phase Two of Ofcom's Radio Review. Significant points
from the data are highlighted in the text of the submission, and
the complete data set is presented as Appendix One (not printed
here).
ABOUT GCAP
MEDIA
GCap Media plc is the UK's largest commercial
radio company, formed in May 2005 following the merger of GWR
Group plc and Capital Radio plc. With 47 locations across the
UK, GCap Media owns 55 analogue and 99 digital radio stations.
Our stations include leading brands such as Classic FM, 95.8 Capital
Radio London and Xfm, and in DAB digital radio we are developing
stations like FUN radio, Planet Rock, Chill and Core. On Christmas
Day 2006, we launched our newest station—theJazz, a sister
station to Classic FM which aims to do for jazz what Classic FM
has done for classical music in making the genre accessible to
a UK-wide audience.
EXECUTIVE SUMMARY
1. The prospects for maintaining plurality
in public service broadcasting in the digital age
The radio ownership rules provide the context
for commercial radio Public Service. Rules which allow owners
to provide a number of stations to the audience encourage diversity
of output as owners operate distinctive stations targeted at discrete
audiences—examples include the diverse range of stations
on the Digital One DAB Digital Radio multiplex, and the BBC's
radio networks, positioned to minimise overlap between stations.
2. The practicality of continuing to impose
PSB obligations on commercial broadcasters
Legislation does not identify commercial radio
as a "PSB broadcaster" despite the significant PSB output
of many such stations. Commercial radio engages in PSB output
because of its understanding of community needs and its sense
of corporate responsibility—commercial stations are acutely
aware of the privilege they have been granted in broadcasting
to their communities. Therefore the question for the Committee
in respect of commercial radio is how to create the right ownership
and licensing context for this voluntary PSB to continue.
3. The viability of existing funding models
for PSB broadcasting
Proposals for spectrum charging threaten to
introduce a new (and, as yet, unquantified) cost into the ecology
of commercial radio. Any additional cost might result in less
money being spent on PSB programme making. GCap Media proposes
a safety mechanism which would reduce the risk of spectrum charging
reducing PSB output. The value to society of certain elements
of PSB programming would be given a monetary value, which would
then be offset against the spectrum charge for each channel. Programme
makers would be incentivised to provide PSB programme ideas, confident
in the knowledge that such output would be recognised for its
public service value through the charging calculation.
4. The case for public funding of broadcasters
in addition to the BBC
The dominance of the BBC in programme creation
and production risks imposing a monoculture on the creativity
of the radio sector. GCap proposes a Programme Assistance Fund,
taken from the Licence Fee. This would allow a thousand creative
flowers to bloom because it would offer as many routes to the
listener as there were ideas—a programme maker would develop
an idea, select the commercial broadcaster with the audience that
would benefit most, and then work with the support of that broadcaster
to secure funding from the Programme Assistance Fund.
5. The future of key areas of PSB content
The future of Classic FM's analogue licence—and
therefore its PSB contribution—is not assured. Under current
legislation, there is a risk of another company bidding for the
analogue licence when it comes up for re-advertisement in 2010[3],
taking over the channel and broadcasting an entirely different
genre of music. This anomaly dates back to the 1990 Broadcasting
Act, which introduced competitive bidding for the three new national
commercial radio channels. As the law currently stands, 2010 will
see the licence being auctioned. GCap Media believes that for
the three INR analogue licences a hypothetical auction, similar
to the process which the INR licensees undertook in 2000-01 and
in 2006, should be established that will deliver a realistic value
to the Treasury for the analogue spectrum utilised.
6. The value of the Public Service Provider
concept as advanced by Ofcom
Commercial radio's voluntary contribution of
Public Service material is impressive (though often unrecognised)
and a more formal system of support for commercial radio PSB would
be valued by the industry and would produce significant benefits
for society in general and communities across the UK in particular.
The PSP concept dovetails into this system of support. GCap Media
believes there should be a Public Service Provider of radio/audio
output, consisting of a channel of PSB output, broadcast on digital
radio but also available for streaming online and as podcasts
for downloading to MP3 players and iPods.
7. The case for Public Service provision
on new media
The Internet allows GCap stations to deliver
extensive PSB content which would not be possible on the air because
of the limitations of time. Audio material is also presented for
download and podcast, allowing listeners to listen whenever they
wish. Public Service content on new media is a rapidly developing
area of PSB. The possibilities for personalisation of content,
for intelligent signposting of material that users would benefit
from, and the rapid building of communities of interest, all add
value to stations' new media offering. GCap Media's experience
in launching the new technology of DAB Digital Radio provides
a valuable insight into the challenges of new media and PSB. Partnerships
between different sections of the industry have been an important
part of the success of DAB, and will be important in building
new media PSB—no one company or organisation has all of
the skills needed for success.
MAIN SUBMISSION
1. The prospects for maintaining plurality
in public service broadcasting in the digital age
Plurality and media ownership rules are inextricably
linked, and the 2003 Communications Act went some way to relaxing
these rules. If the objective is to maintain and improve plurality,
changing the ownership rules is one way to achieve this. Plurality
is usually taken to refer to a combination of two positive public
service aspects:
— Distinctiveness in the sources and
provision of news and information coverage.
— Distinctiveness in the format and
output of different channels.
Ofcom, in its "Review of Media Ownership
Rules" (November 2006) concluded that ownership plurality
does not ensure the first aspect—"two local radio stations
might have different owners and yet obtain all their news from
the same source" (para. 2.13, p. 6) and noted that "journalists,
editors and producers, rather than owners, may have a more direct
impact on the views expressed via a media outlet." (ibid).
The regulator's conclusion is that ownership plurality remains
the best proxy for viewpoint plurality, but GCap Media's view
is that ownership rules are an extremely blunt instrument to use
to achieve the objective expressed in the Communications Act—to
further the interests of citizens by securing "the maintenance
of a sufficient plurality of providers of... services". We
believe a further relaxation of the media ownership rules would
also encourage more public service output by encouraging owners
to differentiate their output and produce distinctive channels
to serve distinct audiences.
In Green Paper submissions in advance of the
2003 Communications Act, we argued that achieving the second public
service objective—distinctiveness between channels—would
be facilitated by allowing owners to control a greater number
of channels. Citing the economic principle of the Hotelling Effect,
the argument was that an owner with a range of channels would
find it in its interest to differentiate them over a wide range
of audiences. Using the example of the BBC (which ensures minimal
overlap between its radio channels to appeal to the widest range
of licence fee payers) and the national digital radio provider
Digital One (which selected distinctive services to appeal to
the largest total audience), the business drivers towards distinctiveness
under common ownership were accepted in the 2003 Communications
Act, indeed the Hotelling Effect was mentioned in the Ministers'
introduction to the Bill.
Since the 2003 Communications Act came into
force, a number of mergers have taken place within the radio industry,
of which the GWR Group/Capital Radio merger, which led to the
formation of GCap Media, was the largest. Ofcom's "Review
of Media Ownership Rules" found "despite the reforms
carried out in 2003, [the rules] remain complex" and "the
rules have not always operated in the public interest" (para.1.6,
p.2). Ofcom then goes on to describe a situation in which the
2003 ownership rules forced Emap to remove its Smash Hits service
from three local digital radio multiplexes because, after Emap's
merger with Scottish Radio Holdings, the new company would have
exceeded the ownership rules. Listeners in Ayr, Aberdeen and Dundee
lost the Smash Hits service, and no alternative provider took
up the spare capacity—hence the ownership rules resulted
in a reduction of listener choice, the exact opposite of the intended
consequence. This effect is likely to be repeated following the
decision by Ofcom to grant a second national digital radio multiplex
to run alongside Digital One. GCap Media welcomes the addition
to listener choice that should result from this, but if the process
is not carefully managed quasi-national services created through
local multiplexes will have the opportunity to move to this new
national channel, leaving "voids"" on local multiplexes
which may then struggle to carry on funding themselves.
On a positive note, the common channel ownership
which has become the hallmark of broadening choice in DAB digital
radio, has led to significant new channel launches. The most recent
is theJazz, a new jazz channel launched by GCap Media on the national
multiplex. theJazz plays a wide range of jazz genres such as bebop,
swing, cool jazz, trad, blues and modern jazz, and features artists
such as Miles Davis, Ray Charles, Oscar Peterson, Weather Report,
Jamie Cullum and Diana Krall. The new station is provided by GCap
Media and—in its early stages—is a pure public service
contribution, generating no advertising or sponsorship income.
By deploying the talents of the team behind Classic FM, GCap Media
can provide the infrastructure, programming expertise and partnerships
to launch theJazz, and because it owns a portfolio of complementary
brands and stations which operate on Digital One[4],
GCap Media is motivated to produce a differentiated new service,
distinctive from its existing stations—there would be no
point in spending money on launching a new station which simply
attracted the same people who were already listening to other
GCap Media stations.
It is interesting to note that the opportunity
to launch theJazz came about through the operation of these economic
principles on a single channel owner, which caused the withdrawal
of a previous jazz service. GMG Radio owned and operated Jazz
FM, as a single service with no sister channels alongside it.
With no opportunity to segment the audience and provide a range
of complementary stations under its ownership, market conditions
led GMG to move Jazz FM into the mainstream, renaming it Smooth
FM and providing the listener market gap for theJazz to launch
as a truly authentic jazz service.
GCap Media's conclusion—and one of the
options in the Ofcom Review (para. 1.12, p. 3)—is that the
radio ownership rules should be further relaxed, or abolished
altogether leaving competition law and cross-media ownership rules
to regulate mergers in future. Ofcom says "the benefits of
allowing further consolidation need to be weighed against the
importance of maintaining plurality... at a local level"
(para. 1.12, p. 4) but this puts consolidation and the public
service objective of diversity in a false opposition to one another.
As our examples have shown, allowing more channels to congregate
under one owner increases diversity and therefore improves the
overall service to the public. Owners of single channels have
little option but to aim for the mainstream, as the Jazz FM/Smooth
FM case shows. Therefore further relaxation of the ownership rules
in digital radio would maintain and increase the key public service
element of diversity of channels in the digital age.
Ofcom's own conclusion is that further deregulation
of the radio ownership rules should be considered as part of its
"Future of Radio Review", which is currently under way.
The conclusions of the Culture, Media and Sport Committee's Inquiry
into PSB will feed into Ofcom's review and would, GCap Media hopes,
encourage the relaxation of the rules we have argued for.
2. The practicality of continuing to impose
PSB obligations on commercial broadcasters
As noted in the introduction, legislation does
not identify commercial radio as a "PSB broadcaster"
despite the significant PSB output of many such stations. Commercial
radio engages in PSB output because of its understanding of community
needs and its sense of corporate responsibility—commercial
stations are acutely aware of the privilege they have been granted
in broadcasting to their communities. Whether the community is
geographical around a local station, or a community of interest,
serving the needs of that community is paramount. For GCap Media,
the aim is to harness the unique role that radio plays in listeners'
lives to improve and take action on issues that matter to them
and their families.
In GCap Media stations, PSB highlights include:
— Xfm's Sony Gold winning Rock School,
which takes kid's rock bands from start-up to star quality—the
2006 competition on Xfm London was won by The Attics from Teddington
School in Middlesex.
— Classic FM's new Music Makers charity,
which transforms the lives of young people by involving them in
classical music for the first time.
— Choice FM's Junior Jams, providing
a safe entertainment environment for under 18s with big-name acts
performing.
— Choice FM's "Peace on the Streets"
initiative to help stop gun crime.
— Choice FM's campaign on Sickle Cell
Anaemia, which had blood and bone marrow donors queuing up outside
the station.
— GCap Media local stations' support
for Child Rescue Alert, the scheme which recruits the public to
help when a child is abducted.
— 95.8 Capital Radio London and Choice
FM's support for the London Youth Games.
— GCap Media's Leicester Square HQ
in London was the hub for UK Radio Aid, which brought 250 commercial
radio stations together to raise £3.3 million for Tsunami
relief.
— GCap Media's contribution of over
£5 million of free advertising time to charitable organisations,
recognised by the Business in the Community Per Cent Standard.
— GCap Media's support for the Media
Literacy advertising campaign organised by the UK Media CSR Forum.
A full account of GCap Media stations' PSB activities
is set out in Appendix One (not printed here).
For commercial local radio, reflecting the passions
and concerns of the local area is the key audience attractant.
All GCap Media local stations maintain a skilled and well-connected
local newsroom, broadcasting local news, weather and traffic information
throughout the day. The Public Service contribution of this output
is clear, and is detailed in Appendix One (not printed here) in
the One Network section. Local news for GCap Media stations is
more than simply a programme element, it is the core of their
existence—rather than simply holding up a mirror and reflecting
what is going on the community, GCap Media's stations roll their
sleeves up and get involved. For example, during the recent Suffolk
Murders, GCap Media station SGR in Ipswich purchased 1,000 personal
safety alarms and distributed them to women in the area, along
with advice leaflets from the police and the Suzy Lamplugh Trust.
The contribution made by commercial radio's
PSB output is distinctive because it is not imposed by Charter
or licence obligations, but springs from commercial radio's deep
understanding of the communities it serves. Whether it is Classic
FM organising a musical instrument amnesty to get people to return
their old school clarinet, or Choice FM sponsoring the African
Caribbean Leukaemia Trust, community service on commercial stations
is voluntary, enthusiastic and rooted in the community. Hence
the question for the Committee in considering commercial radio's
PSB is not how to impose obligations, but how to create the right
context to encourage this voluntary activity to continue and grow.
In part, the context is created by the media
ownership rules, which delimit how a company can use its mainstream
brands to support its more niche offerings. We have shown in section
1 how a revision of the ownership rules will encourage more diversity
of output and cross-subsidy between stations. Context is also
created by the charging system imposed on commercial stations
through their licence fees, and the prospect of spectrum charging.
This is the subject of section 3.
3. The viability of existing funding models
for PSB broadcasting
The funding model for commercial radio is simple:
radio stations are licensed by Ofcom and operated by radio companies,
both large and small. These companies have developed a deep understanding
of listener and community needs, and sophisticated techniques
for discovering what listeners want—the Classic FM Consumer
Panel remains the only stakeholder consultation forum of its type
in commercial radio. GCap Media also maintains a fully staffed
research department to ensure that stations meet listener needs.
Based on this deep understanding of needs, companies
launch and run radio stations which are carefully targeted at
specific audiences. These audiences are attractive to advertisers,
who pay for the privilege of speaking to them through advertising
and sponsorship messages. The advertising income funds the cost
of producing the programmes and running the stations, and society
benefits from entertaining and informative radio output without
having to pay a licence fee for it. Businesses that advertise
also benefit from increased trade—a further community asset.
This account of the ecology of commercial radio
might be taken to mean that only mass-audience, wide-appeal stations
would be launched—but it is clear from even a cursory look
at the commercial radio landscape that a much more complex tapestry
of stations is on air. From very small community commercial stations
to the three national commercial analogue stations, the full range
of geographic scale is covered—and communities of musical
interest from heavy rock to easy listening are all catered for,
especially on the rapidly growing DAB digital radio platform.
This is because radio companies—owning a number of stations—also
wish to serve the broadest range of listeners in order to offer
advertisers a wide choice of target audiences for their products.
One threat to this delicately balanced ecology
is the prospect of spectrum pricing. In July 2006 Ofcom published
a consultation document on "The Future Pricing of Spectrum
Used For Terrestrial Broadcasting" which proposed a system
of Administered Incentive Pricing based on population coverage—the
intention being that broadcasters will be encouraged to take decisions
that promote more efficient use of spectrum.
This is a laudable aim, but spectrum charging
threatens to introduce a new (and, as yet, unquantified) cost
into the ecology of commercial radio. From the outline above,
it is clear that any additional cost must (unless there is an
increase in advertising revenue) result in less money being spent
on programme making. The most expensive elements of programming
are often those with the greatest Public Service element, so spectrum
charging, if misapplied, would threaten stations' ability to fund
PSB output. Advertising revenue is at best flat for commercial
radio at present, so charging for spectrum risks deducting money
from programme budgets.
GCap Media is exploring a safety mechanism which
would reduce the risk of spectrum charging reducing PSB output.
Put simply, the value to society of certain elements of PSB programming
would be given a monetary value, which would then be offset against
the spectrum charge for each channel.
For example, Classic FM's support for UK orchestras
and its broadcasting of their concert recordings would be allocated
a monetary benefit to society of (say) £500,000 per annum.
This sum would be subtracted from the spectrum charge levied on
Classic FM. The total of all PSB contributions from Classic FM
would be taken into account when levying the spectrum charge,
resulting in PSB output being ring-fenced from the negative effect
of spectrum charging—programme makers would be incentivised
to provide PSB programme ideas, confident in the knowledge that
such output would be recognised for its public service value through
the charging calculation.
For large stations such as Classic FM with a
great deal of PSB output, calculating the value of individual
PSB elements would be worthwhile—however, for smaller stations
standard sums could be credited for common PSB programme elements.
Local news output could gain a credit for each minute broadcast,
traffic news would be similarly recognised, and social action
campaigns—raising the awareness of local charitable groups—would
also contribute to the PSB value of the local station.
Indeed, a properly organised system of PSB credits
could dovetail into other elements of the public service ecology.
Section 4 details how a Programme Assistance Fund might work,
and this could be additional to the effect of the PSB credits
proposed here. Section 6 reviews the Ofcom Public Service Provider
concept as applied to radio, and PSB credits could form a foundation
for this—linking together the existing provision on commercial
radio, the additional provision which might come from a Programme
Assistance Fund, and the additional channel of output which could
result from the Public Service Provider concept.
4. The case for public funding of broadcasters
in addition to the BBC
Since the Licence Fee started, the BBC has argued
that it should receive all of the funds generated through the
fee—asserting that all its output is Public Service, and
therefore all its output deserves to be funded from this universal
tax. This argument is now breached on two counts—elements
of the BBC's modern-day output cannot, by any reasonable standard,
be described as Public Service, and other broadcasters are producing
output that is clearly in the Public Service.
Classic FM has succeeded in securing funding
for its initiatives from the Arts Council. If a Programme Assistance
Fund were to be established using some of the income from the
licence fee, it is highly likely that Classic FM would benefit
from that source of funding too.
One example would be Classic FM's support for
orchestras and live concert broadcasts. Classic FM broadcasts
nightly Evening Concerts between 9pm and midnight. These are currently
made up from full-work performances taken from CD. The cost of
broadcasting live orchestral concerts from around the UK is prohibitive
to Classic FM (in terms of technical costs and rights fees). A
PAF fund grant would allow Classic FM to broadcast performances
from partner orchestras such as the Royal Scottish National Orchestra,
the Royal Liverpool Philharmonic Orchestra, the Philharmonia Orchestra,
the London Symphony Orchestra and Welsh National Opera Orchestra.
As well as creating exciting and diverse programming for Classic
FM, this would allow concerts from orchestras who already receive
Arts Council subsidy to reach out to new audiences through the
radio. This would have the added benefit of making those public
funds more efficient in terms of the number of people reached.
It would also create a far greater range of live concert broadcasting
on British radio—complementing what is done by Radio 3,
which has a policy of broadcasting concerts largely from BBC orchestras
and also centring on new commissions and rarely performed works.
This leaves a real gap for concerts of broad appeal from regional
orchestras.
The dominance of the BBC in programme creation
and production risks imposing a monoculture on the creativity
of the radio sector. At present, if a programme maker has a good
PSB idea, he or she must take it to the BBC for the greatest chance
of success, even if the target audience for the idea is available
on a commercial channel. Although the BBC operates independent
production quotas for radio, all ideas have to pass through the
same commissioning process as the Corporation's own productions,
leading to an inevitable standardisation in what comes out of
the loudspeaker: ideas are flexed to fit the system, not to fit
the audience.
A Programme Assistance Fund would allow a thousand
creative flowers to bloom because it would offer as many routes
to the listener as there were ideas—a programme maker would
develop an idea, select the commercial broadcaster with the audience
that would benefit most, and then work with the support of that
broadcaster to secure funding from the Programme Assistance Fund.
PAF funded projects would be clearly identified and branded on
the air, so audiences would become accustomed to expecting high
quality results from these projects, rather as one recognises
a Discovery Channel documentary on television.
The administration of the PAF need be no more
complex than any other tightly-run grant giving body: indeed,
if it was combined (as suggested in section 4) with the PSB credits
system it could be funded from spectrum charging income. The number
of programmes made would depend on how much of the licence fee
was diverted into the PAF, but the commercial sector is much more
efficient in programming costs than the BBC, so the multiplier
effect of diverting funds into the PAF would be significant.
5. The future of key areas of PSB content
such as news and childrens' programming
Classic FM is rightly recognised as the most
important provider of Public Service output in commercial radio.
It has added more than six million classical music radio listeners
to the two million who listened to BBC Radio 3 when the station
launched in 1992, and has been the major cause of classical music
moving into the mainstream of public taste. As Culture Secretary
Tessa Jowell said on the station's tenth birthday in 2002;
"Thanks to consistently high standards,
imaginative scheduling and a complete lack of condescension, it
has become part of the broadcasting furniture: hard to imagine
our radios without it [...] Classic FM has become a glorious rebuttal
to all those who insist that the public will never take to "serious"
music."
However, as the Culture, Media and Sport Committee
is inquiring into the future of PSB content, members should appreciate
that the future of Classic FM's analogue licence—and therefore
its PSB contribution—is not assured. In fact, under current
legislation, there is a risk of another company bidding for the
analogue licence when it comes up for re-advertisement in 2010[5],
taking over the channel and broadcasting an entirely different
genre of music, including non-classical music, consigning Classic
FM's success to history and depriving listeners of the only pure
classical music station in the UK.
This anomaly dates back to the 1990 Broadcasting
Act, which introduced competitive bidding for ITV Channel 3 licences
and for the three new national commercial radio channels. Through
a combination of licence extensions and renewals linked to digital
radio commitments, and through maintaining a consistently high
standard of output, Classic FM has maintained its hold on its
licence—but as the law currently stands, 2010 will see the
licence being auctioned. It is imperative for PSB—and for
classical music—that a more equitable method of licence
renewal is introduced before then. The danger is that another
bidder could decide to broadcast something other than classical
music—the licence conditions simply require that the output
should be "non-pop"—listeners would lose their
station and society would lose a major contributor to cultural
capital.
GCap Media believes that the three INR analogue
licences should not be advertised on a highest bidder basis when
they are advertised by Ofcom over the period 2010-12, but that
a hypothetical auction, similar to the process which the INR licensees
undertook in 2000-01 and in 2006, should be established. Under
such a process, Ofcom will assess the business plans of each licensee
and set additional payments (cash bid and percentage of qualifying
revenue) that deliver a realistic value to the Treasury for the
analogue spectrum utilised. GCap Media believes that such a process
would be the most appropriate at that time, as with DAB digital
penetration and migration, the intrinsic value of the analogue
licences will be low.
A competitive highest bid auction will increase
uncertainty, taking the attention of management from programming
to licence retention and could ultimately reduce the ability of
programmers to deliver PSB content.
As detailed in section 2, news provision—especially
local news for local stations—is a key audience attractant
for GCap Media stations. Local stations weave local news, information
and weather into their output, with comment where appropriate
and a campaigning slant where it is needed—many GCap Media
local stations support car share schemes to reduce rush-hour congestion
and urban pollution, and as this paper is written, Classic FM
is auctioning an electric car to raise funds for charity. Classic
FM produces hourly news bulletins and a daily 30 minute news round-up,
Classic Newsnight, which is now available as a downloadable podcast.
New media launches offering streams of music bring competition
for listeners' attention, but very few of these new choices offer
news, and almost none offer local news—most are nationally
or even internationally distributed, so the local news output
of GCap's local stations is a unique selling point for them. The
outlook for the news content of GCap Media's stations is positive—this
is a programme element that listeners clearly value, and a Public
Service that will continue to have a central place in the output.
DAB Digital Radio has opened up new opportunities
for PSB content. The greatly increased availability of channels,
coupled to new and more cost-effective digital production techniques,
means that genres which once had to compete for airspace within
a general-purpose varied channel can now be granted their own
discrete channel.
The clearest example is childrens' programming.
Where once this output would have been jostling for space alongside
the competing demands of larger audience segments on a single
mainstream channel, DAB Digital Radio enables GCap Media to achieve
a unique offering in UK radio—a dedicated childrens' radio
channel, Fun Radio.
Fun Radio is a joint venture between HIT Entertainment,
children's radio campaigner Susan Stranks and GCap Media. With
stories, famous characters like Bob the Builder and Paddington
Bear, and child focused music, it broadcasts 24 hours a day to
under 10s and their carers in London and across Southern England.
By contrast, the BBC delivers only limited childrens' programmes
for four hours a day on its BBC 7 digital radio service, with
some weekly programming on Radio 4.
PSB output such as Fun Radio is subsidised by
income from GCap Media's other, more mainstream stations. To return
to the points made in section 1, PSB output such as this exists
because radio groups have been allowed to become strong enough
to support new ideas and niche audiences. Therefore appropriate
ownership rules—which allow GCap to own sufficient mainstream
stations to produce the funds to support new PSB opportunities—are
an essential precondition for this type of PSB output.
6. The value of the Public Service Provider
concept as advanced by Ofcom
The Ofcom Public Service Provider idea was first
put forward in 2004, and was aimed principally at providing another
participant in the Public Service Television arena—alongside
the BBC and Channel 4, and to an extent replacing the ITV Channel
3 companies, who were expected to reduce their PSB output over
time.
We commented at the time that the Public Service
Provider concept should also be explored for radio. As Ofcom said
in Phase 3 of its Review of Public Service Television;
"Over time the BBC will become a near-monopoly
provider of PSB. That is not a desirable outcome. Plurality—the
maintenance of a range of different providers—is an important
part of our broadcasting system. It drives competition for quality
and makes sure there are a range of different approaches to PSB
content, with a range of alternative perspectives aired."
If that is true for television in the future,
it is a closer prospect for radio, where the BBC garners around
half of the audience. This submission has argued throughout that
commercial radio's voluntary contribution of Public Service material
is impressive (though often unrecognised) and a more formal system
of support for commercial radio PSB would be valued by the industry
and would produce significant benefits for society in general
and communities across the UK in particular.
As set out in section 3, one approach would
be to create a hierarchy of support for Public Service output
in commercial radio, with three levels;
1. Credit for the value of existing PSB output
being offset against spectrum charges for commercial radio stations.
2. A Programme Assistance Fund (taken from
the licence fee) to support specific PSB initiatives in commercial
radio.
3. A Public Service Provider of radio/audio
output, consisting of a channel of PSB output, perhaps broadcast
on digital radio but also available online.
Since Ofcom's PSP idea was first mooted, technology
has transformed the possibilities for receiving and consuming
audio content. One of the problems with the "PSP channel"
idea in radio is that people would have to make "appointments
to listen" to programmes that caught their interest. Audiences
are increasingly unlikely to do so—now listening is to genre-based
streams of output, rather than individual programmes of the sort
that a PSP might carry. Advances in time-shifting, downloading
and podcasting in the past two years mean that timetabling is
no longer an issue—the PSP channel could still offer a stream
of timetabled programming for those who wished to consume in this
way, but would also make its Public Service programmes available
for streaming online, and package them as podcasts for downloading
to MP3 players and iPods.
In this way, programmes would be available to
listeners where and when they wanted them, greatly increasing
the effectiveness of the PSP concept for radio.
Linking the three "levels" of PSB
radio together as described above would also encourage cross-fertilisation
between levels 2 and 3. Thus specific PSB initiatives thought
worthy of support from the Programme Assistance Fund at level
2 could—in addition to being broadcast on their sponsoring
commercial radio station—be made available on the PSP channel.
This would make them available to a national audience (if the
PAF sponsor had been a local commercial station) and would add
further to the diversity and plurality of input for programmes
on the Public Service Provider channel.
In the other direction, commercial radio stations
which act as sponsors and supporters for PAF submissions could
be given access to Public Service Provider material to rebroadcast,
with permission. This would give PSP output an airing to audiences
which might otherwise not have sought it out.
7. The case for Public Service provision
on new media
For many years, the key skill of radio broadcasters
has been in finding and building communities of listeners. Tapping
in to the things that tie 21st century Brummies together in Birmingham,
or the factors that unite Mancunians or Bristolians has been the
major dynamic in attracting audiences to commercial local radio
stations, and those stations have made a significant public service
contribution to community cohesion in an otherwise fragmenting
world. Since 1992 Classic FM has been doing the same, bringing
the classical music community together and adding new recruits
all the time, while in DAB Digital Radio a wide range of new musical
and subject communities is building.
The place for new media in this public service
of community building is that new media gives the opportunity
to identify with a community to the individual. Rather than relying
on a top-down identification of an individual as a member of the
jazz community (for example), the growth of social networking
software encourages the individual to join the community themselves.
GCap Media's new station, theJazz, encourages its listeners to
join in a conversation about their favourite music, discussing
questions such as "what is jazz?". These techniques
allow a much closer relationship between listener and station,
strengthening the role of the station in the listener's life and
opening the possibility of many more public service interactions.
Radio's function as a parallel consumption medium
is key to its importance in the new media arena. Because one's
hands and eyes are not engaged whilst listening to the radio,
an audio request to link to a website for more information is
more likely to get a response than the same request made on TV
(which would require switching off the TV to pay proper attention
to the website).
The internet also allows stations to deliver
extensive PSB content which would not be possible on the air because
of the limitations of time. Audio material is also presented for
download and podcast, allowing listeners to listen whenever they
wish—for example, the "rodcast" on fishing can
be listened to on the way to the river or the "London What's
On Guide" on the bus into town.
Significant GCap Media internet and new media
PSB activities include;
— Choice FM's "What's on Guide"
downloadable from the website for the community.
— Choice FM's health pages, covering
specific conditions such as prostate cancer, lupus and how to
give up smoking.
— Classic FM's Learning Area, which
includes sections on learning to play, composing workshops and
music education in schools.
— Classic FM's City Guides offering
detailed information from presenter Simon Calder.
— Monthly podcasts from Classic FM
Composer in Residence Patrick Hawes.
— Xfm's Mi-Xfm initiative, which creates
personalized music mixes for Xfm listeners along four themes—Chill,
Loud, Classics, and Hits.
— Xfm's film guide, with reviews targeted
at the station's listener age profile.
— Xfm's podcast sessions, the first
from a major broadcaster to include music in the podcast download.
— GWR-FM Bristol's Radio in Schools
project, which uses website content and DVDs to improve reading
and writing—the winner of the 2006 Arqiva Social Action
Initiative Award.
— Fun Radio's range of fun learning
podcasts aimed at children. These include the "A to Z of
Wildlife" and the "Fun Radio Garden".
Public Service content on new media is a rapidly
developing area of PSB. The possibilities for personalisation
of content, for intelligent signposting of material that users
would benefit from, and the rapid building of communities of interest,
all add value to stations' new media offering, in addition to
the simpler functions such as archiving audio material for listening
later and providing more extensive textual material than would
be possible on air.
GCap Media's experience in launching the new
technology of DAB Digital Radio provides valuable insight into
the challenges of new media and PSB. Partnerships between different
sections of the industry have been an important part of the success
of DAB, and over the last decade GCap Media has teamed up with
several major partners to bring the many possibilities to fruition;
including Imagination Technology to develop a DAB chipset to help
encourage the first sub £100 DAB radio, BT to develop mobile
television through a mobile phone/DAB device, and Roberts Radio
and Pure Radio to develop branded DAB radios. GCap is ideally
positioned to take this partnership experience and use it for
further developments such as new media Public Service content.
January 2007
1 Planet Rock is a national station playing classic
rock music. Back
2
FUN radio is a local network of services for children aged 10
and under and their parents. Back
3
The Classic FM licence expires in September 2011. It will be
advertised during summer 2010 to ensure the Regulator has sufficient
time to advertise and grant a new licence. Back
4
Classic FM, Core (playing new chart hit music), Planet Rock (playing
classic rock), Capital Life (playing easy adult contemporary music)
and theJazz. Back
5
The Classic FM licences expires in September 2011. It will be
advertised during Summer 2010 to ensure the Regulator has sufficient
time to advertise and grant a new licence. Back
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