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Memorandum submitted by Create Publishing Ltd
We are writing to object to the launch later this year of a Lonely Planet-branded magazine by BBC Worldwide, following their acquisition of a majority stake in Lonely Planet last year. We believe that the acquisition of Lonely Planet was contrary to the remit of the BBC, and that launching a magazine using the Lonely Planet brand is compounding this mistake.
In this letter we have set out the basis for our complaint, as well as providing an outline of the travel magazine market, in which we have an interest in with our title Real Travel. We have asked the OFT to launch an investigation into the acquisition of Lonely Planet, and in the meantime halt the development of a Lonely Planet-branded magazine by BBC Worldwide, however they have told us they will be taking no action in this instance.
Our objections to the launch of a Lonely Planet magazine by the BBC are summarised briefly as follows:
Does not fit with PSB purposes In the Government's 2004 Green Paper it was stated that all BBC magazines should have a direct connection with their TV or radio programmes, and while the BBC have produced holiday and travel-related programming in the past, this is not a core area for the BBC, and branding the magazine 'Lonely Planet' means there is no direct connection with any of their programmes. The BBC has previously had to dispose of non-BBC branded titles such as Eve, Your Hair and Cross Stitch Crazy (which they acquired from Origin Publishing) and therefore should not now be launching another non-BBC branded magazine. Our opinion is that the launch of this magazine is not about any extension of BBC programming, but more a case of using the resources and content of the BBC to maximise the Lonely Planet brand and its profitability.
Anti-competitive and distortion of the market We believe that the resources and marketing that a BBC-produced travel magazine could bring to bear would make it impossible for independent magazines in the sector to compete fairly. The BBC has access to a huge resource of travel-related content (photography, news, comment, features) that are not available to or affordable by other travel magazines, not to mention the access to 'personalities' from their programmes which are a strong selling point for magazines in this sector. The marketing of this magazine will also benefit from access to other BBC audiences and again this is something other travel magazines don't have access to and can't compete with.
1. The travel magazine market The magazine market into which the BBC are intending to launch a Lonely Planet-branded magazine can be loosely split into two sectors - 'holiday' based magazines that focus on mainstream, package-based travel, and the specialist travel magazines that concentrate on the more adventurous, independent style of travel.
Magazines that fit into the 'holiday' sector include Conde Naste Traveller and Sunday Times Travel, and these are the biggest selling titles in the market. There are several independently-owned travel magazines that fit into the 'specialist' travel end of the market, and these include Wanderlust, Adventure Travel, and our title Real Travel. As more niche titles, the circulation and advertising revenue of these titles is smaller than the 'holiday' based titles, and therefore their resources are also less.
Our magazine Real Travel was launched in March 2006 in response to the growth in independent and 'authentic' travel, and incorporates a 'user generated' element, where readers own stories and photos appear in every issue alongside the expert editorial from our in-house and freelance writers. The magazine has four full-time staff and as a business Create Publishing has 11 staff working across two magazines.
2. Lonely Planet When looking at the Lonely Planet brand in relation to the travel magazine market, the brand can be more closely aligned with the independent, specialist sector of the market as covered by Wanderlust, Adventure Travel and Real Travel, rather than the 'holiday' end of the market. Travellers buy Lonely Planet guides to find out what hotels to book, what restaurants to eat in, and what activities to do, so by their very nature they are more likely to be independent travellers and not package-holiday tourists.
When Real Travel magazine launched in 2006 we worked very closely with Lonely Planet because our two brands were so closely aligned - we cover mounted a Lonely Planet-branded guide on our first issue as well as running subscription offers where subscribers would receive a free Lonely Planet guide - and we even ran Lonely Planet-branded editorial 'help' pages written by one of their employees Tom Hall. Clearly, Lonely Planet saw our magazine as a good match for their own demographic.
The Lonely Planet magazine therefore will be intended to hit this very same market, rather than the 'holiday' sector, and this is backed up by a recent press release from BBC Worldwide: 'The magazine will appeal to open-minded, inquisitive people who have a real sense of adventure and a desire to learn about and connect with, the people and places they visit.'
3. BBC and travel Travel has never been a core area for the BBC, in the way that gardening, history, food and children's content have been - and their travel programming has traditionally concentrated on the more mainstream, 'package' sector of the market. Programmes such as 'Holiday' could in no way be aligned with the type of adventurous, independent type of travel that Lonely Planet stands for. Indeed, when BBC Enterprises launched Holiday 89 magazine, and later BBC Holidays between 1992 and 1995, these titles reflected the remit of the TV programme by concentrating primarily on family-oriented package travel.
Of course, in many programmes the BBC covers cultural and sporting events from around the world, but this output is so diverse and fragmented that in our opinion it's impossible to argue that a focused travel magazine branded as Lonely Planet has a direct connection with any one BBC programme.
The BBC in response to the Green Paper says itself that 'BBC magazines core editorial remit is to extend readers' appreciation and enjoyment of the BBC's broadcast output and genres in which the BBC has a recognised expertise' - yet there is no one identifiable programme that a Lonely Planet magazine is an 'extension' of, and travel is not an area that many people would consider to be an area of expertise for the BBC.
4. Our objections In the Department of Culture, Media and Sport Green Paper of 2004, it was proposed that each commercial activity of the BBC should be assessed against four criteria:
a. Fit with PSB purposes - does the activity either support or relate to PSB purposes?
b. Commercial efficiency - does BBC ownership offer best value for money for the licence fee payer?
c. BBC brand protection - is it compatible with the BBC's brand and values?
d. Market distortion - are BBC commercial services being sold or structured in a way that might give them an unfair advantage over the competition?
We are opposing the launch of the Lonely Planet magazine on points one and four above.
5. Objection one - it doesn't fit with PSB purposes As outlined previously, travel is not a core area for the BBC. Although in our opinion still tenuous, it could be argued that the BBC could legitimately launch a 'holiday' based magazine much like they did in the 90's with BBC Holidays magazine. However, launching a magazine concentrating on independent, adventurous travel is not consistent with their broadcast output, and launching it with the Lonely Planet branding makes no connection whatsoever with any BBC holiday or travel programme.
In fact, launching the magazine as 'Lonely Planet' magazine is an admission that while Lonely Planet is very much aligned to this sector of the market, the BBC is definitely not - there's no one programme that fits into this sector of the travel market, and the BBC is just not known for it generally.
It is clear in our opinion that a Lonely Planet branded magazine falls into the same category of not fitting with PSB purposes and must therefore not be allowed to launch. It could be argued that there's justification for launching a BBC-branded holiday magazine, but there can be absolutely no argument that a Lonely Planet-branded magazine fulfils the remit of being 'fit for PSB purposes' - it just doesn't have any direct connection to any BBC broadcast output.
6. Objection 2 - market distortion The second point we are objecting on is that a Lonely Planet magazine would gain an unfair advantage on competitors by being produced by the BBC - specifically in having access to content, and in the marketing it would receive by being under the BBC umbrella.
Generating
content is a major cost for magazines, particularly travel magazines where
quality photography and writing are essential. The Lonely Planet magazine will
have access to an enormous amount of content - archive, current and future -
that gives it an unfair advantage over its competitors. Such content would be
either unaffordable, or just not available, to other magazines, and yet this
content will be readily available to (and likely at no cost) to the Lonely
Planet magazine.
Because almost
everyone travels, in theory Lonely Planet could use content, columns and
comment from any BBC presenters or personalities. The use of 'names' is a
massive selling point in magazines, yet competing travel magazines are not able
to get anything like the access to this that the Lonely Planet magazine will
enjoy. The other major area the Lonely Planet gains an unfair advantage over the competition is in terms of marketing and promotion. Although the use of TV trailers no longer happens for its titles, BBC magazines enjoy unrivalled promotional opportunities over its competitors. Recent BBC mag launches (e.g Countryfile) have included promotional adverts in its other titles, including Radio Times which sells over one million copies. This is an opportunity that is just not affordable or available to the travel magazines the Lonely Planet magazine will be competing with.
It's likely too
that experts from Lonely Planet will be featured as 'talking heads' on news and
current affairs programmes - and this has already happened on several occasions
actually - which is extremely valuable promotion of the brand and magazine to
millions of people. The equivalent air-time in the form of paid-for adverts on
commercial TV or radio would be prohibitively expensive for any of the
independent travel magazines.
7. Summary
To summarise, we are objecting to the launch of a Lonely Planet-branded magazine by BBC Worldwide for the following reasons:
1. The Lonely Planet acquisition itself does not fit PSB purposes, and launching a Lonely Planet magazine compounds this mistake.
2. Travel is not a core area for the BBC, and certainly not 'independent, adventurous travel' of the Lonely Planet type.
3. The Lonely Planet magazine will have no direct link to BBC broadcast output and therefore does not fit with PSB purposes.
4. The BBC has previously had to dispose of 'non-BBC branded' magazines such as Your Hair, Eve and Cross Stitch Crazy, and therefore should not be launching a Lonely Planet branded title now.
5. The Lonely Planet magazine will gain unfair commercial advantages through access to BBC content and personalities.
6. The Lonely Planet magazine will gain huge and unfair marketing and promotional opportunities through the BBC that are not affordable or just not available to competing travel magazines.
7. The motives of this magazine launch are not to create an extension of any BBC programme, but to use the resources, content and marketing to maximise the profitability of the Lonely Planet brand and its products.
October 2008
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