We pay for the BBC. We pay for it to produce the very best, distinctive programming under its Charter.
Who makes sure it does?
The BBC Trust used to be its Governing body. I never thought I’d look back at those days fondly. Remember it was the BBC Trust which saved 6 Music and fought a reduction in BBC local output.
Since 2017, it’s been Ofcom’s job. The BBC claims its Board also performs a supervisory role, but most complaints sent to the headmaster appear to get delegated to the teacher you complained about.
Ofcom’s regulatory responsibility is enforced with a Service Licence. If one gets a magnifying glass, one can find the obligations of BBC local radio. As I have said several times since Ofcom assumed this BBC job, very little is required.
It seems odd bearing in mind it consumes more public money than any of the other BBC radio channels - and 95% of its listening is outside London. Had I drafted this in my time at the Radio Authority, as this was exactly my job, I fear my work would have been returned dripping with the ink from Tony Stoller’s red pen.
There are general requirements – the Public Purposes, although the Corporation would argue compliance is achieved if any part of the BBC obliges. Over reliance on that – as the Service Licence does – is a mad way to regulate such a large organisation. Have you cleaned the house? Yes, I polished the porch.
Public Purpose 1: To provide impartial news and information
Objective: The BBC must provide duly accurate and impartial news, current affairs and factual programming to build people’s understanding of all parts of the United Kingdom.
Unlike other radio services, there are no specific requirements for local radio.
Public Purpose 2: To support learning for people of all ages
Objective: To deliver a broad range of content that facilitates and encourages learning – reaching and serving and engaging all audiences and make content discoverable.
Unlike other radio services, there are no specific requirements for local radio.
Public Purpose 3: To show the most creative, highest quality and distinctive output and services
Unlike other radio services, there are no specific requirements for local radio.
Public Purpose 4: To reflect, represent and serve the diverse communities of all of the United Kingdom’s nations and regions and support the creative economy
Local radio gets a mention at last. There must be 60% speech during core hours (06:00 to 19:00 on Mondays to Fridays); and breakfast 7-830 weekdays must be 100% speech.
News bulletins and information "of particular relevance to the area and communities it serves" must be "regularly at frequent intervals throughout the day". This was amended from the earlier Licence which just asked for news at “intervals throughout the day” which made me laugh out loud. It’s two minutes past midday – next news at midnight.
There are no hard requirements on regularity and frequency – these are "determined by the BBC and to be assessed by Ofcom on a case-by-case basis having regard to what is appropriate in the context of each relevant". Make it up as you go along really. Is this the same Ofcom that makes privately funded radio companies and community radio do rather more?
The stations must provide "a significant amount of news and information of particular relevance to the area and communities they serve during the Breakfast Peak and other content of particular relevance to the area and communities".
Stations must ensure that in each (financial) year: "at least 4,954 hours are allocated on each BBC Local Radio station to original, locally-made programming". But “original, locally-made programming” includes programming shared with neighbouring stations broadcast between 06:00 and 19:00.
That's always been a funny old definition of local. As soon as content is shared, its own localness is diluted - unless you double the speech content. And remote bases certainly get something which is not local.
And don't tell me there's a bundle of interesting pan-regional content which appeals miraculously to all the people in a huge area. There isn't. Watch a regional TV bulletin - it tends to be story about City X, Y and Z. And I have little interest in Y and Z.
Dear Ofcom - If your definition aimed to preserve localness, it doesn't. Localness, at best, is beyond news stories and 'topics' - it's about human beings and people who understand their area.
Summary of Service licence requirements
So! In terms of content – BBC local radio has no specific obligations for target audience, no obligations for music, it can talk about whatever it likes really, so long as it talks continuously from 7-830 with a lot of news and information - and 60% the rest of the time - and provides local news and information of any duration they fancy regularly at frequent intervals.
That is all that is required – for £117m of public money – not even counting the absolutely huge transmission and ancillary costs. Is there any public funding pot of which so little is expected?
Revised service licence process
When the BBC execs arrived in a huge coach and horses ready to drive through the Service Licence with ease, Ofcom then thought it may have to do something. They pulled a loaded letter and a few service licence tweaks from their holster.
In the revised Service Licence, Ofcom insisted that the BBC "must also continue to offer a wide range of content, including to audiences who only use live broadcast TV and
radio services". And they are expected to monitor the impact of the changes. Yes. So shall we.
They were unsatisfied with the lack of clarity in the BBC’s announcements about the changes generating uncertainty for audiences and requested additional information from the BBC. Ofcom suggested more transparency is needed when “it announces similar changes” in the future. Joy of joys. There are more to look forward to.
The original BBC plans were announced on 31 October 2022, with amended plans later announced providing for 20 shared programmes between 2-6pm on weekdays, and 18 shared programmes between 10am and 2pm on Saturdays and Sundays. Regulators always like a concession from their licensees so they can go home feeling they’ve achieved something. I remember that feeling.
May I poke into a few Ofcom assertions?
Ofcom says: “our assessment of listening data is consistent with what the BBC set out in its initial plans, namely that the changes are focussed on times when listening is generally lower”.
Dear Ofcom – some very distinctive programmes are wisely scheduled off-peak for very reasons programmers understand. They can deliver incremental audiences, maximise share and serve as a real addition to the credibility and broad value of the station. Public service broadcasting, if you will. Distinctive, just like the Charter requires. Audiences may be small but they derive incredible value. Did you study response to any specific off-peak programmes and asked why some provide a higher audience share than others?
"We also looked at whether any audience groups may be particularly affected by the changes but have not identified any particular concerns in this regard."
Dear Ofcom - have you not detected any change in output since you removed the 50+. Target audience requirement the Trust had included? Have you conducted any research amongst that audience. I can tell you what they say. I’ve done some.
"The audience profile of local radio in England does skew towards those aged 65+ and so it is older audiences who are more likely to be affected by the changes."
Hooray. So you’re going to bear in mind that no other BBC service is charged with serving those audiences when making your decisions?
No. It seems. "The listening profile of local radio tends to be similar across the course of the day and there is no specific audience group who only listens at the times in the schedule where the changes will be focussed."
What are they talking about. What were they expecting to find? Do they know nothing of a 65+’s relationship with their chosen radio station and its personalities You can tell this
analysis is from someone who knows little about BBC local radio.
"We sought additional information about delivery of news and travel announcements."
Dear Ofcom - not that old chestnut. Great localness is more than that. It's belonging. It’s championing an area. The words you chose to erase from the BBC Trust requirements. Talk to listeners about their station. Many things will come up before travel news - just look at the BBC’s own research about what truly drives audience.
"A number of commitments on news and travel bulletin and major story coverage scheduling were made to Ofcom by the BBC."
Dear Ofcom - you should never have issued a Service Licence which permitted the BBC to do things you now clearly imply you really don’t want them to.
Ofcom wisely asked about local democracy provision. I would have thought that was a key purpose of the organisation which may have the only significant newsroom in town in many places.
The BBC assured it has a network of political reporters and its staffing level is being maintained. What about the fact that some work very hard and some less hard in this arena? No requirements? Are you fine with the fact that the last local elections were some of the first where some local stations did not trouble to cover fully?
What of regionalisation. Deep breath.
Ofcom says the BBC is "confident that shared programming will resonate with audiences in the same way that the regional 6:30pm TV news bulletins do (and the majority of shared radio programming will cover similar geographic areas). It has said that the groupings of stations aim to work within recognised regional cultures and identities."
Dear Ofcom. Let me guess. Your base is in London? Thought so.
The regional news programmes work because they are carried on a major TV channel and there’s little more localised alternative save for local TV which receives no public funds. Do people really care about a city they never visit which may be some way away?
Radio has always provided for much more localised info. And radio’s relationship with its audience is different. I really worry if you don’t know that. If that’s your view why not just regionalise the whole thing.
This is the crux of the whole issue.
Ofcom has allowed further regionalisation because it happens on TV and the BBC told you it will "resonate".
Why have you trusted the BBC’s 'confidence'? Not evidence. Not tailored qualitative research. No study of Rajar results of existing cobbled-together areas?
I’m sorry. I should have written this at the time you were consulting. Frankly, I’ve better things to do. I was rather relying on decent regulation.
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