SSDAB Consultation – My Response

My response to the SSDAB Consultation.

The DCMS (Department for Digital, Culture, Media & Sport) have been running a consultation on the licensing of SSDAB (Small Scale DAB – which I have started calling “local DAB” at the recommendation of those involved with the trial, although as it’s a DCMS consultation I will refer to as SSDAB here).

The consultation document can be found here:  https://www.gov.uk/government/consultations/small-scale-dab-licensing-consultation and the consultation documentation here: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/671660/Small_Scale_DAB_Consultation.pdf

The CMA are also doing their own survey that can be found here: https://goo.gl/forms/F6mv0wTNae7WfXqa2

Now I recommend you respond to the CMA survey, but also consider doing your own response, as the more voices there are (and ideally more from the Community sector) the stronger the response.

Feel free to use my response as a starting point of your own, copy & edit as you may like. (although I would love to know if you do)

My response

1. DCMS would welcome views on whether reserving capacity on small-scale radio multiplexes for community radio stations is the best way of securing carriage for these types of services on mini-muxes. Do you agree with the principle?

Answer:

Surely the best way of securing carriage for community radio stations is to make sure that the multiplexes are run by the community or not for profit and finding a way of making sure that the platform is affordable and accessible to community radio stations. However, reserving capacity for community radio stations would be a prudent idea, however maybe consider going stronger and make it a condition of the multiplex operators that they have to carry, and that they can not price the stations out of being on the platform.

2. DCMS welcome views on whether there should be an upper limit placed on the amount of capacity reserved for community radio services. Should this be a single figure applicable across all multiplexes?

Answer:

There shouldn’t be an upper limit no, because each area may have a different amount of community stations, ideally, Ofcom should see how many community stations or possible community stations (based on their current EOI experience), to set how much capacity should be reserved. Also, that capacity needs to be of a reasonable quality and can not simply be set at the lowest possible. They certainly should define a one size fits all approach.

3. Do you agree with the principle that small-scale radio multiplex operators should be able to offer unused capacity reserved for community radio services on a temporary basis?

Answer:

Yes, I have no issue with operators offering the unused capacity to temporary services, and in fact welcome and encourage this opportunity as a form of digital RSL’s, a great opportunity for events, activities or even for communities to trail broadcasting.

4. DCMS would welcome views on these proposals and on the interaction with the existing community radio licensing regime.

Answer:

I welcome the consideration for a C-DSP license, however, the following needs to be considered:

The community radio fund is already oversubscribed and is currently not fit for purpose or as designed when it was originally launched, there is simply not enough in the fund for the current 250 Community Radio stations. IF you are proposing that all these extra stations (which no one has any estimate of how many there could be, but we could be looking at hundreds of digital only stations) suddenly has access to the Community Radio Fund then that fund needs to be double as a minimum, and ideally increased even beyond that, also the fund needs to be future proofed, as there is no guarantee that it will exist from general election to general election, and needs to be increased each year in line with inflation but also as the number of eligible stations increase.

Also, you mention access to “lower fees” in the second but last paragraph before this question, but don’t say fees for what, are we to assume Ofcom fees? Multiplex carriage fees? Or music royalty fees? If the answer is yes to all three, then I can see an advantage to this license.

I would welcome an introduction of a C-DSP license as a way to clearly identify community stations over commercial stations, however I do not feel that the benefits (access to reserved capacity, lower undefined fees and access to an already over subscribed community radio fund) outweigh the negatives of restricting the amount of income you can generate from on air advertising and having to deliver key commitments, one point is I think currently CR stations HAVE to have their studio located within the coverage area, there are already CR stations broadcasting on the trial services outside of their studio area, as a way of reaching new audiences and providing them with additional choice and services. Surely the opportunities for SSDAB are for stations to try and do things differently and innovate in a digital age.

I would welcome a C-DSP license that has the criteria that they must be not for profit and as an organisation meet the current criteria for analog licensed stations, maybe introduce some key commitments that provide opportunities, not limitations on what the station can do, and provide access to the positives as listed above. I feel strongly against any restrictions on income generation, as I feel that could be setting these stations up to fail.

5. DCMS would welcome views on this approach and whether it deals with the concerns raised about access to small-scale DAB radio multiplexes by community radio services

Answer:

I feel strongly that the multiplex operators should be not for profit, and was a “non-commercial” element part of the legislation and debate in parliament. I do not feel that this will restrict the growth of this new platform, as it hasn’t restricted the growth of community radio. There is no reason why current community and commercial broadcasters cannot form separate not for profit organisations (ideally in partnership) to hold and operate the multiplex license.

Whilst reserving capacity for community broadcasters is a good step, how does that actually stop them being priced out of the platform? A commercial operator could set the price too high, wait for the community broadcaster to decline to be on the platform and then petition Ofcom to release that capacity as the community broadcaster isn’t using it.

Equally, whilst transparent pricing is a viable option, what will it actually do? Because if there is only one SSDAB multiplex in the area, it won’t do anything for competition or to balance or drive prices down.

What powers or regulation is Ofcom going to have over the pricing of the license?

Equally, I welcome the consideration that pricing could be submitted as part of the license application, however, I do not think that the application process has been discussed at this point. Will the operators that can offer the lowest pricing be a deciding factor in who might receive the license?

6. DCMS would welcome views on this approach.

Answer:

I am not opposed to organisations holding more than one license, and I agree that it can help with growth and sustainability, however I really only hold that view, If the license is held by a not for profit organisation, as this would help to secure the platform for the benefit of the communities and not just for commercial gain or commercial interest. Its an open secret that the current model of local DAB is not really fit for purpose, and that the carriage fees are quite often extremely high, too high for community broadcasters, and even some commercial licenses, in fact, we have recently seen commercial stations maybe under threat of their FM license because they have come off the local DAB license which was used to secure auto-renewal / long FM license award. Currently, local DAB has a license to charge as much as they can, and almost hold the BBC and local commercial stations to ransom because they have to be on their platform. We do not what to develop an environment in which the same activity and behaviour can happen, as this would only see the platform become unsuitable for community stations.

I do not believe that any current national or local DAB license holder should be able to hold any share in an SSDAB license, but if we must compromise than limit them to 25% share, and not for any license for which they have any share of a local DAB license.

7. Do you agree with this two-step approach to delineating the size of small-scale multiplexes?

Answer:

No, I don’t agree with the two-step approach, I have no issue with the first point, and actually using SSDAB as an opportunity to provide coverage in areas that are not currently served with a local service is fantastic. However, I have issues with the second step concerning coverage in an existing local service, which is answered in question 8.

8. Do you agree with the up to 40% limit in areas already served by a local multiplex; if not, why not and what alternative do you propose?

Answer:

No, as I do not believe that an arbitrary 40% coverage as a one size fits all approach will work, we have seen with the trials that some of the coverage is really problematic and people can struggle with the indoor reception in the towns that they are serving. I believe as part of the application process you should outline what target area you want to cover and show why that works as a proposal, if Ofcom agrees with that proposal then they should be allowed the coverage and power to enable them to be received by all households in that intended area.

Without doing an analysis of all the local DAB licenses its hard to fully map out, but what we do not want to happen, is find that a town or area of a large city cannot get the desired reception because it would take them to 41% coverage of the local multiplex.

I believe that on the whole SSDAB should be setup to cover towns / cities & parts of large cities, as well as a section of rural communities (in part as outlined as the first step), and not really designed to provide a regional or large alternative to the local DAB, and do not feel that a 40% rule which can only be seen to serve as protection against the established local DAB actually does anything to support or develop SSDAB

9. DCMS would be grateful for views on these options or other options along with reasons for your choice.

Answer:

I do not see the need to have small license lengths for SSDAB, and in fact feel that short licenses make SSDAB less sustainable or desirable for operators, surely the longer the license the longer the operator has to cover setup/capital costs as well as overheads with the ability to negotiate better terms for transmitter locations and service contracts. Not to mention the length of the multiplex license has an impact on any radio service looking to launch or develop the be on that platform, services will want the ability to be able to broadcast for as long as possible, again to offset setup and capital costs.

I feel that the minimum license should be at least 12 years with the option of continuous  renewal in line with current government policy, and how national and local multiplex licenses are operated

10. We would also welcome view on the merits of linking license length with underlying demand in an area for a small scale multiplex license.

If this question addresses the point in the narrative that areas with low demand to have a greater license length to provide stability than yes that is a good idea, however, if you are suggesting that in areas of high demand that the license length should be shortened to maybe enable other operators a chance, that produces far too much uncertainty on service broadcasters to plan for the length of their own services.

11. DCMS welcome views on this approach.

Answer:

I have no issue with allowing the BBC to have coverage on SSDAB, and in fact it might provide a good opportunity for them to provide coverage for existing services and also provide additional services (long-term and temporary) to fit certain needs, I also do not have a problem with the BBC owning or part owning an SSDAB multiplex license, and in fact a partnership between the BBC and local community and maybe even commercial stations might be a great opportunity for all parties.

12. DCMS would welcome views on the implications of this approach.

Answer:

I do not feel that Ofcom should consider the impact SSDAB has on local multiplexes. The worse case is that local license owners might find some services moving off their platform so they can be served by SSDAB as it fits their purpose (and finances) better, or that local licenses find they have to lower their fees to enable them to “compete” with SSDAB services, I think both of these outcomes are actually a benefit to the entire sector, and why I don’t feel Ofcom should consider the impact of an SSDAB license on the local DAB license.

 

Community Radio Annual Reports

Gone are the days that CR stations had to create an submit a detailed annual report to Ofcom, in fact, one of the tasks I had when I did a work placement with the CR team at Ofcom was to read some of these reports. They were fantastic documents that showcased what the station had done that year, achievements on and off air and how the station was really benefitting and supporting their local community. It was also great to see how many stations promoted those reports on their websites and shared with their communities (and wider stakeholders we would assume) – Now all CR stations have to do if file a finance document and a tick sheet to say they have or haven’t stuck to their Key Commitments.

Whats more of a shame is that without that mandate a lot of stations don’t seem to really publish anything like this anymore, and I think that’s a missed opportunity!

Charities in the UK are regulated to produce an annual report to the Charities Commission (and share with their trustees, members, and wider stakeholders), now the trend for many years is for these reports to be shiny, packed full of pictures, testimonials, and impact statements, they are using them as an opportunity to shout about what they are doing, how and why – almost a manifesto of their organisation, going far beyond whats needed or required of them.

There is an opportunity for Community Radio to do the same, why? For the same reason that the Charity sector is. Not only do these documents become a record of what you have done, they speak a lot more about your achievements, your aims, and purpose. They become a fantastic resource to engage with all your key and wider stakeholders;

  • Share with your audience.
  • Share amongst all your presenters and volunteers to help give them a bigger picture and their role in it.
  • Share with all your key funders and advertisers so they can understand the impact of their support.
  • Send to anyone and everyone you receive support or want to receive support from, local MPs, Councillors, Schools, Colleges and big companies and organisations.

Then whilst you are at it, why not submit it to the Community Radio Awards!, shameless plug aside, if you need anything else to motivate you then why not that. I have said since the inception that the written element of the Station of the Year entry is a great starting point for your station’s annual report, and if you do nothing more would be a fantastic document to fit that purpose.

So I throw down the challenge, to encourage and recommend that all Community Radio stations consider writing an annual report and please do let me know how you get on.

You can find advice from the NCVO on how to write an annual report here.

Below is the 2017 Gold recipient of Station of the Years written reports (full details can be found here 2017 Gold Entries)

Please comment below with your thoughts as to what could be included in a report or links to your report!

Digital Radio Stakeholders’ Event November 2017

My brief thoughts and notes from the Digital Radio Stakeholders’ Event

Thursday 9th November hosted by the BBC

This is the quarterly meeting about digital radio, hosted by DR UK (Digital Radio UK), we hear about how digital radio is getting on, thoughts and feelings for the future etc.

Rajar

This was lead by Yvette Dore – DRUK

This last quarter saw a large DAB increase, there was a stall with DTV and internet listening, if not it would have hit over 50% of listening, there is a prediction that within the next 2 quarters we will hit 50% of digital listening.

In the 10 – 64 demographic its already at 51.6% but the over 65’s its around 40%.

31% in car, which is a growth of 26% year on year

87.5% new cars have DAB as standard

14.1 million devices have DAB+

SSDAB

This was lead by Ian O’Neill – DCMS

We are still due a short consultation, it will be a short window (6 weeks), the consultation is still being finalised but is due  out very soon.

The current trials might need to be extended past May.

SSDAB – Panel Discussion

With representatives from 7 of the trial mux operators.

143 estimated services of SSDAB, 94+ on DAB+ and numbers of services still growing.

Discussion on the panel about thoughts going forward for SSDAB

a) lets stop calling it SSDAB (small scale) as it sounds inferior to traditional DAB. Instead lets use ‘Local DAB’  as its for local audiences and communities, as opposed to the National DAB and what is actually County / Regional traditional local DAB. – My personal take away is this is a great idea, I certainly love the idea of local DAB and will adopt it!

b) General call for not for profit ownership, single ownership. (Maybe single ownership with profit, but if a multi ownership model than must be not for profit)

c) Need equivalence of signal strength, coverage inside houses can be a little patchy, need to be able to cover entire area of town / city / area as needed.

d) good mix of commercial stations and community radio (Ofcom CR licenses and digital only not for profit stations)

e) Length of license, so mux operators can plan for sustainability they need long license, suggested 12 years like commercial operator licenses.