I’ve just given David Lloyd’s Radiocentre commissioned report, ‘Small-Scale Radio in the UK – How Local Commercial and Community Radio can Co-Exist,’ a more detailed read, and I want to offer some personal thoughts and observations. I fully understand the rationale behind the report, but I can also see why the publication of the report, in its present form, has caused so much consternation among community radio leaders and volunteers.
Forty-Eight community radio leaders this week signed an open letter condemning the report. As Radio Today highlighted, the response from community radio station managers from across the UK was scathing. Condemning the report because it potentially:
“Makes a number of baseless allegations, including raising the possibility that stations may have attributed revenue to online services, taken cash payments or direct payments to contributors to circumvent the strict rules in place by the broadcast regulator regarding on-air advertising. No stations are named in the report nor are any examples given.”
It is up to others, Ofcom especially, to investigate any complaints of impropriety. Surely the duty of Radiocentre, though, is to advise its members of the complaints process, and what they need to do to make evidence-based complaints – if there is justification to support these concerns?
It is disappointing, therefore, that a report that purports to be objective, ends up besmirching the integrity of many committed and hard-working people by insinuation. Radio Today carries a comment from Siobhan Kenny, Chief Executive at Radiocentre. According to Kenny:
“This report is a comprehensive study on how small commercial radio stations in the UK can co-exist and collaborate with community radio. Based on the evidence, it is clear that there needs to be some changes from both Ofcom and Government to ensure that the smallest commercial operators are able to survive and thrive alongside a distinctive community radio sector.”
Fair enough up to a point. However, if this is what Kenny believes to be a comprehensive, independent, fair and responsible form of investigation and reporting, then I’m left wondering what the agenda really is? I wonder what the editorial and research methodology process was that was followed? I can only imagine if this report would get through an editorial meeting in a newsroom, given the vague nature of the claims it makes? The lack of citations and direct quotes worries me.
The consternation that the Lloyd report has created has been made worse because Radiocentre didn’t give anyone who might be associated with the issues covered in the report notice that they were actively investigating this topic for a public report. Nor did they give anyone who might be affected by the complaints an opportunity to comment.
The process seems to have been: gather the tinder, leave it next to something that might produce a spark, and then sound surprised that it caught fire! Protesting passive ignorance in this way might be a good use of public relations and lobbying acumen, but it’s certainly not a good way to build trust and form relationships that will solve ongoing regulatory or operational problems.
Had this report been produced as a contribution to the debate about the state of UK media, then I would be more supportive. There is little mention of any of the information that Ofcom regularly presents about the changing nature of media in the UK, and indeed across the world.
Ofcom reported in their Media Nations Report 2018 that the
- “Take-up of superfast broadband and connected televisions is changing how people watch television programmes
- The rise of online video is changing the picture for the TV industry
- Audiences continue to watch and value public service broadcasting, especially news, children’s programming and UK-made programmes
- But there are risks to the PSB system which we will continue to monitor
- The viability of local TV services remains uncertain
- Digital listening is transforming the radio landscape
- But radio continues to be resilient” [my emphasis].
What the Lloyd report doesn’t follow-up, moreover, is the way that alternative media providers in the form of the international technology conglomerates, are now the main drivers of change in the way we access media and sound services. Spotify, for example now includes a premium, personalised radio service. Apple Music offers a streaming service that combines with its well-established iTunes-based podcasting services. Amazon Alexa and Google Assistant can provide information and communication using smart speaker technologies. There is little mention of these, and the many other technological changes that are sweeping the entire media landscape.
Likewise, the report glosses over the corporate consolidation that has been the result of major economic and financial deregulation since the 1980s, and the break-up of the network approach of independent commercial radio stations (ILRs) that formed the backbone of the early UK commercial radio industry.
Dr Kathryn McDonald wrote in 2016 that “each change to the regulatory environment [has] brought with it a relaxation of the initially very demanding public service requirement” placed on the commercial radio industry. McDonald’s own examination of the impact of consolidation on local journalism concludes that
“The media landscape has changed dramatically since the inception of ILR in the 1970s, and although the element of truly local production in local radio journalism may have diminished since the 1980s and 1990s, greater access to other sources of local news and information may mean that the progressive changes to content regulation of the sector may be justified, especially in the case of smaller stations than were originally envisaged in the 1970s that would otherwise struggle to survive the competitive media market of today”
This report feels, then, like a blunt instrument. It’s a bit like the well-funded and muscular football team in a college having a run of bad luck, but then blaming the small group of geeky-kids in the corner for their lack of success. It’s not pleasant when the well-heeled and privileged pick on the weaker among us. After all, it’s not as if there haven’t been plenty of warnings about the impact of deregulation.
Radiocentre seems to suggest, without any hint of irony, that we are, at this time, somehow in a perfectly balanced and socially desirable place as far as our commercial media marketplace is concerned. Which is far from the truth, and perhaps illuminates the lack of self-awareness of an elite group of insiders who can’t see the cultural narrowness, social dysfunction and the civic deficit that is caused by the winner-takes-all, casino-like, shareholder-based, stitched-up (so-called) market-driven model that defines commercial radio in the U.K.
Talk about moving the goalposts! To mix my metaphors, this is complaining after the horse has bolted. As far as I can see, responsibility lies as much with the tech giants, the conglomerated media corporations, successive short-sighted media deregulation policies, and a disregard for the social value of local media in the UK. After all, it was only as recent as the 26th October that Ofcom announced a further relaxation of the localness guidelines for commercial radio. The complaints in the Lloyd report sound a lot like having your cake, eating your cake, and then whinging that you want more of everyone else’s cake!
So, no wonder the publication of the report has been viewed as antagonistic and hostile. Commenting on the academic mail list, Radio Studies Network, Eryl Price-Davies, a long-standing advocate of community radio, suggests that “for decades the Commercial Radio lobby has peddled untruths with no basis in fact and no back up research.”
Added to this, and based on the Radiocenter’s own figures, commercial radio in the UK is in apparently rude health. With a reported £645.8 million in advertising revenue for 2017. Radio Today reported Siobhan Kenny, CEO of Radiocentre saying:
“These figures show that commercial radio is in great shape. Advertisers continue to value the reach, effectiveness and impact of radio and are making the most of its ability to reach far and wide”.
Which raises the question, why then the suggestion that we further cannibalise the Community Radio Fund? Its present paltry level is only £400.000 per year for over two-hundred and seventy stations. Could not the commercial radio industry itself contribute more of its own funds to support and help smaller commercial stations deal with the effects of social, technological and regulatory change?
As the Community Media Association response indicates [Disclosure – I am a director on the CMA Council]:
“Ofcom recently announced that it will be relaxing the localness guidelines for commercial radio stations. This will reduce the number of hours that programmes have to be originated from a local station if they are part of a network. Commercial radio stations are also able to access the BBC Local News Partnership (LNP), which provides £8m per year funding from the television licence fee, for local civic news. This platform is open to commercial radio stations, as well as newspapers and local television. The LNP is supported by a network of 150 Local Democracy News Reporters that provide content that can be used for local news reporting. The Government also announced on the 19th October that it will be funding the commission and broadcast of public service programme production with the Audio Content Fund. With over £3m available during a three-year pilot phase for commercial radio stations to support their public service programming, the Audio Content Fund will be administered by Radiocentre and AudioUK.”
Commercial radio is clearly an industry that doesn’t go wanting for public support and funding from government in order for it to meet its basic public service obligations. This really is a cake-and-eat-it mentality.
Ultimately, there are two issues that I believe are fundamental to the misunderstandings and prejudices that are at the heart of this report and shape its bias.
Firstly, the suggestion that the grant funding that sustains many community radio stations comes without being competitively won, or isn’t subject to rigorous scrutiny. This is fanciful, and shows a complete lack of understanding of the regulatory and economic practice that charities, civic groups and community interest companies operate under.
The social sector, in my experience, doesn’t throw money around without applying a rigorous and careful set of criteria and processes that hold those funded to account. To suggest otherwise flies in the face of the experience of everyone who supports U.K. Social Value and Civic Engagement initiatives and practices.
Secondly, the suggestion that community radio in the U.K. has an economic value of something like £11 million per year, needs to be contested. This was a figure circulated by Ofcom in its Communication Market Report 2017. A less selective and more balanced reading of these figures shows that less than 40% of the whole income to all the Community Radio stations in the UK comes from on-air commercial activity. That means that 60% comes from volunteer activity, services in-kind, training, grants and donations.
Indeed, the Ofcom figures indicate that between 2014 and 2016 there was a 5% decline in the average nominal income for all community radio stations. According to Ofcom only five stations achieved an income above £150,00 in the whole of the UK. This nominalisation of the economic value of community radio masks and hides a multitude of issues that need to be explored in much greater detail.
One thing that I do agree with in the report, however, is that it would be timely that we look again at the role of social gain and social impact, but not just in community radio stations. Instead, we should look across the whole of the community media movement. Many things have changed since the initial implementation of the Access Radio projects. One thing that has happened has been a enormous change in the way that government funds (or doesn’t fund) local civic services.
Local authorities, charities and civic groups have been at the sharp end of sweeping cuts to their services during the last decade. So it is timely that we look again at the whole regime of social gain and social impact, particularly as the government has shifted towards a model of Social Value engagement that allows civic and social sector groups to bid to run commissioned services from the public sector. The Social Value Act puts in place a duty on commercial providers of public services, property developers and profit-driven businesses alike, to also fund civic sector activities.
Those of us who are committed to supporting and nurturing a sustainable and progressive community media culture in the UK, have an opportunity to push community radio much further away from the commercial shoreline, and to follow the tide of social value and social impact. To do this, however, we need to be able to build the capacity and the capability of already stretched and under-resourced community media practitioners and advocates, to help them meet the challenges of the social impact agenda.
I would therefore ask Radiocenter to put its money where its mouth is. Help those of us fighting to support and advance the inclusive social-gain practices of the community media movement. Help us to nurture a leadership culture and network of community media advocates and practitioners around the country who are dedicated to the inclusive, not-for-profit and social value ethos that comes with working across the social sector. With high standards of integrity and accountability applied to all, and the recognition that it is your contribution that matters most, not your status.
This is the ethos of community media. To champion the rights of communities to make our own media, and to have a say in the way our media is run. We say if we want better media, then we have to make it ourselves. To do this, however, we also have to actively remove the practical and the perceived barriers to entry that prevent people from making their contribution, regardless of the social status, background or ability. Inclusivity is more than just talk or ticking boxes, it requires structural change and is a challenge to everyone’s thinking and received ideas.
By supporting communities to have access to media services, that they themselves have meaningfully contributed to, and real control over the decision making process, we become a richer, more pluralistic, and more inclusive society. A demonstration of understanding of this basic principle of inclusive participation, that informs community media in practice, is absent from the Lloyd report, and so the opportunity to engage on the basis of this understanding will have to be taken-up elsewhere.
Whatever comes out of this, though, will no doubt require an extended commitment to developing training, advancing social-impact planning, developing verifiable evaluation techniques, civic business support practices, academic scrutiny and policy planning, as well as leadership and advocacy support. These things don’t come for free, there are no quick fixes, and they need to be supported from across all parts of our society – business, public services and government alike.