I live in Nottingham. I was born here. Don’t get me started on how I feel about my City. It frustrates me. I care almost too much about it.
I lived briefly down in Leicester, but it is not part of who I am. It may be close-ish - but news and chat about Leicester is only as interesting to me as chat about Oxford or Gateshead. The East Midlands region, therefore, does not really figure in my life.
BBC audience levels indicate it struggles already with uniting counties across made-up regions. BBC Three Counties Radio reaches 9% of its 1.4m potential listeners. The existing combined ‘BBC Sussex and Surrey’ region (albeit with separate breakfast shows for the two counties) manages an 8% reach. BBC Radio Solent covers Hampshire, Dorset and the Isle of Wight and reaches 10%.
These are significantly inferior figures to, for example, Cumbria (20%) Merseyside (15%), Shropshire (17%) or Derby (18%).
Larger areas do not fare as well – either because they are large by nature or because they have been thrown together thoughtlessly. Larger regions do not work, even with some opt outs. The evidence is clear. Rhodri Talfan-Davies readily concedes this – but his strategy ignores the facts, fingers in ears. This was a great chance to re-invent local radio/audio for the 21st Century - and you've blown it.
Under the new plans, there will be further station mergers for significant proportions of the day – afternoons and across weekends. Stations will become bigger – and audiences will fall. The USP of those stations - some of which already struggle with making headway in a competitive world – will evaporate through the loss of personalities and station amalgamations.
Whole random areas are thrown together. Not just neighbouring but - following Ofcom’s ‘clarification’ neighbouring-to-neighbouring – and that can take you anywhere you wish really. Ofcom appears to believe that these stations remain in the same 'geographic area'. What planet are they on?
At the weekend and weekday afternoons, Cambridgeshire, Suffolk and Norfolk are as one. Same geographic area? Try asking a resident.
Stoke, Shropshire and Hereford and Worcester are to be soldered together. Do tell me what the fine folk of Leek have in common with the citizens of Ross on Wye? I would ask them for you - but it’d be a four and a half hour round trip.
I sometimes think some BBC strategists don’t spend much time out of London or mix with normal folk – and certainly not BBC local radio’s humble C2DE audiences.
What on earth will the presenters talk about that relates across the patch? They’ll talk about generic stuff – but that’s not the point of all this investment in BBC local radio.
BBC Radio Derby – punching a great 18% reach will virtually not exist at the weekend - with no dedicated local programming save for sport. Its expensive transmitters will largely be pumping out generic material from somewhere else.
Three Counties Radio (Bedfordshire, Hertfordshire and Buckinghamshire) will link with BBC Northants - effectively becoming 4CR and a TSA of almost 2m. Focused Northants currently manages 18% reach; its already amalgamated neighbour has 9%. Guess what’ll happen.
And, under the Licence, of course, some shows, even during daytime, can be broadcast across England: "A single ‘all-England’ programme will be launched and broadcast after 10pm on weekdays and after 2pm on Sundays'.
Why is local programming deemed local by Ofcom when it’s not?
Under the Licence, local stations are required to broadcast 4,954 hours of local programmes per year. (In this post, I’m not even going into the struggle I have even making the BBC’s plans compliant with that provision – but putting that to one side…).
In a smaller font, although it should really have been in Comic Sans, the Licence suggests that programmes remain local, even if they are shared with neighbouring stations: “Original, locally-made programming” includes programming shared with neighbouring stations broadcast between 06:00 and 19:00".
Both the host station and the remote station’s programmes are still deemed to be local – even though the output is self-evidently not as local as it would have been for either station. And the presenter on-air may not have the foggiest idea about the patches they are supposed to be being local to.
It’s a very odd definition of ‘local’. Where’s it come from?
Until 2012, the BBC Trust required BBC Local Radio to: “provide 85 hours per week of original, locally-made programming”. In the May 2012 agreement, however, the Trust recognised a single shared programme between BBC Humberside and Lincolnshire. It was at that stage that the foot-note was added about shared programmes counting as local – presumably to cover off the anomaly.
At that time, of course, there were no plans for major programme sharing. This is also clear in the lower levels of programming explicitly required in some areas – to recognise specific very limited sharing arrangements. It seems therefore that the Licence as originally drafted did not seek to permit what is now planned. Its provisions have been carelessly carried forward without thought until they have bitten the regulator on the bottom.
What about ‘neighbouring’
Ofcom: “clarified that we consider that a station which is in the same geographic area, but which does not necessarily share a geographic border, would constitute a neighbouring station".
So, what is a ‘geographic area’? Yorkshire? England? Europe?
Ofcom suggests that little by way of evidence was supplied by way of justifying what a ‘geographic area’ could be – nor what is an acceptable neighbour and what is not - and the BBC has produced little beyond the truly laughable ‘it works on telly’. Surely the decision on a 'geographic area' must be taken in the context of what is deemed 'local'.
Given such geographic areas must be something less than ‘England’, an evaluation must be made on some basis and the BBC must justify. Ofcom can – tomorrow – say that feedback suggests that many BBC local stations are not “in the same geographic area” – and therefore the sharing can’t proceed. Elementary research would reach the same conclusion. In the commercial sector for music radio, ‘Approved areas’ were stipulated by Ofcom not by the broadcaster – and consulted upon.
I have written to Ofcom and a reply is still awaited on various points (although, to their credit, they are generally a lot more efficient than HMRC!).
Ofcom has said: ‘over the coming year we expect to pay close attention to nations and regions 'provision and local radio.’ We are over a quarter of a way through that year. What has its close attention generated?
Ofcom has said it will: “Monitor the impact of the changes to local radio in the nations – if our research shows that audience needs are not being met, we will consider whether to impose additional Licence conditions”.
Ofcom, this is already happening. Even en-route to regionalisation, as each much loved locally-established presenter leaves tearfully and stations struggle to fill rotas, audience needs are not being met. You must amend the Licence now. You know that’s what Parliament wants – and you know that’s what listeners want. The BBC ‘disagrees’ – well that’s why you are there to regulate it. The BBC is not there to please itself.
When commercial stations were re-licensed for DAB ‘extensions’ there was Ofcom monitoring and reporting – to ensure that whatever had been broadcast was cemented into new licences – even if it exceeded current regulatory commitments. Has Ofcom asked the BBC about all the sport and Faith programming (including weekend cricket inserts into programmes, for example - from operations before and after Covid) - to ensure that its glib promises about retention of distinctive programming are being honoured?
Given the Ofcom statement was months ago, I hope that the results of the research are now available. I’ve done a shed-load of research for my station since then, and they are rather better resourced than we are.
The Ofcom 21-22 report highlighted the BBC's issues with C2DE audiences and pledged a report this year. Rajar indicates that BBC local radio is, by some margin, the best way to reach these audiences.
On the strength of the findings from the above – and the huge concerns from Parliament, listeners and community groups – Ofcom is able now, as it has said, to change the Operating Licence to safeguard the existing levels of local output.
Now is the time to act - before the damage is done. In today's competitive world, recapturing lost audiences is far more challenging than retaining and building.
If the strength and influence of local radio has importance - and the Charter indicates it has - Ofcom must act now to save it. Ofcom - you are not regulating a telecoms provider – you are regulating a public service operating under Charter and paid for. The highest possible standards are expected – and it is your job to make sure this egregious strategy cannot be implemented.
Such Ofcom action would not be ultra vires – and, in any case, I cannot see the BBC taking it to court.
Ofcom action required
Ofcom must state what conclusions on this matter it has reached after its ‘close attention to nations and regions provision and local radio’ over the last three months.
Ofcom must assert that, following feedback and further investigation, it is not persuaded that many BBC local stations are “in the same geographic area” as the BBC plans suggest – and therefore the networking plans must not proceed.
Ofcom must demand full reports on what is broadcast currently on each station – and what was broadcast pre-Covid - with data supplied in confidence from station managers without oversight.
Ofcom must conclude from its research, feedback and the above information that “audience needs are not being met’ and, as it suggested, “consider immediately whether to impose additional Licence conditions”.
Ofcom must embark on a full specific consultation on the local radio/audio sector to inform future plans - and require that the exercise be promoted on-air.