These are an initial set of observations about the DCMS Policy Paper – Digital Radio and Audio Review
This is an industry-led paper that has no civic-society or independent academic input. There is no reference to any sustained and independent research approach, or economic modelling, that is produced using internationally recognised methodologies. The methodologies that are presented in this paper are drawn from the audio industry itself, and can therefore be said to be self-representing, and biased towards the desired outcomes of the industry.
The paper therefore takes many of the listed observations and assumptions as truths, and does not seek to test or verify them. The dataset that much of this discussion is founded on is self-referential, and fails to consider or test alternative models or scenarios. There is no trial-data that tracks public engagement, or that allows for alternative scenarios to be weighed and considered.
The assumptions made about listeners stem from an obsession with the existing and outdated mass-media concepts of audience modelling, rather than taking a forward-looking approach that prefigures social change and innovation in community building and relationship management practices, as has formed the basis of the social media platform development model.
There were no representatives of community media or the academic community involved in the work of the main panel, only the sun-working groups. The research indicating the value of community radio, while a useful snapshot, is not methodologically sound. It is anecdotal and unverified.
Ofcom has a poor record on monitoring and tracking media diversity and inclusivity, and is not in a position to provide verifiable independent research. Ofcom’s media and diversity reporting does not include community media within its scope, because Ofcom does not undertake and publish any large-scale diversity and inclusivity research, particularly as defined by the Equalities Act 2010, preferring instead to rely on self-reporting from within the industry.
The fundamental problem with this report is that it puts industry requirements first, and fails to anticipate changing social needs or attitudes, particularly as they are linked to information management trends, cross-platform access, media literacies and civic engagement for social purposes. No consideration is given to the civic role of media in supporting and fostering a deliberative and participatory democracy. Where is the input from the Office for Civic Society and the Levelling-Up ministry?
Radio is presented in this report as simply a market-led commercial service, supplying needs within a consumerist marketplace, rather than as a social platform for the fostering of social skills, civic capabilities, cultural identities (both local and national), and as a participative platform that can be developed and undertaken by grass-roots communities themselves for the purpose of civic engagement, deliberation and representation.
Consideration of the radio industry in this paper is largely defined by the established broadcast providers, and thereby fails to examine the role of data-platforms and the telecoms market that has been developed in parallel to – and supplanted – broadcast radio services in recent decades.
When discussing carbon impact, for example, no consideration is given to the cost of running DAB devices or sets in the home. DAB sets require a mains supply, or the (very) regular replacement of batteries. Whereas, a low-cost FM/AM radio can run with minimal power requirements and is highly portable.
The economic framework intimated in the paper is largely extractive, as defined by large-scale service providers who prioritise platform efficiency and market consolidation over diversity of supply and pluralism of ownership, and subsequently fails to envisage clear opportunities to establish a community wealth building model for local media.
Likewise, notions of cultural innovation and diversity are absent, with an expectation that supply will continue to follow established models and should continue to support legacy providers of content creation and service delivery. The paper, therefore, does not anticipate a regulatory regime that fosters innovation and diversity of creative and editorial supply.
Subsidies for public service content have rapidly been normalised, but if commercial operators wish to act freely in the marketplace, based on risks they assume, then they should be denied any form of public subsidy, which means closing the Audio Content Fund to commercial providers.
The paper also fails to acknowledge the lack of investment in community radio, poor levels of funding associated with the Community Radio Fund, and the lack of government support for community media more generally.
Being realistic, DAB has taken nearly thirty years to reach mediocre levels of market penetration, and has required significant incentives from the regulators. DAB is now being supplanted by 4G and 5G mobile broadband services, and expanded wi-fi services, and may easilyfall-back as these systems become more prominent.
The original promise of additional data services associated with DAB has been supplanted with mobile data services provided via tablets, smartphones, watches and other devices.
There is no mention of Ireland and Norway’s decision to pull-back from analogue switch off, and their subsequent withdrawal of DAB services.
There is no acknowledgement of the limited supply of sets in shops in many communities. John Lewis customers are well supported, but sales of DAB radios on an average high street are negligible.
The growth of smart speakers is well accounted for in the paper, but other mobile devices, such as Bluetooth tethered speakers with smartphones, is only briefly mentioned – particularly as they are used by younger people whose listening habits are not established outside the family home. Car ownership is in decline in this age group, so radio is not seen as an integral media.
Mandating DAB+ devices to be standard for any sets sold in the future does not reflect the operational needs of consumers who would be asked to pay a DAB+ tax on devices for a service that they may not be able to receive or wish to use.
DAB is defined largely as an in-car media, accessible on major roads, but in response to the UK carbon targets, more investment needs to be given to modes of public transport that don’t use cars. Enhanced broadband speed wi-fi on buses and trains will therefore be a priority above those of individual vehicle-based travellers.
DAB is not used by train or bus travellers given the reception difficulties encountered on many routes. The UK 5G rail network is fragmented with patchy reception, and offers poor levels of service.
The withdrawal of AM services is a self-fulfilling prophecy. When services are poorly maintained and invested in, and the programming content is unsuited to the mode of the media, then demand will drop off.
Assumptions that digital audio is of perceived as of higher quality by listeners is not substantiated. Many DAB services sound worse than FM, as they are ‘mixed’ for car use and not home use. The resurgence in the vinyl music market is evidence that ‘digital’ services don’t suit all consumer needs or tastes.
AM/MW services should not be abandoned, as they can be easily maintained and operated at lower costs than digital platforms. Many DAB services require repeater transmission chains to in-fill gaps, which increases costs.
AM/MW services would be suitable platforms for civic, community and alternative public service providers operating at a regional, rather than a hyperlocal level.
SSDAB is a patchwork of fractured services that will not serve many communities who are self-identified across conurbations and regions. SSDAB will require significant in-fill services to reach rural and geographically dispersed audiences, and there is no guarantee that there is a sustainable market in these areas.
The consumer model described in relation to voice-activated systems, fails to anticipate the wider media and digital literacies deficit that exists in UK citizenship models. Consuming media is not done in isolation, but is part of an integrated social model that is founded on public realm principles of citizenship, information management and human rights.
For this reason access to radio services via digital interfaces does not simply represent a failure of technology, branding or rights-management, but is instead rooted in a lack of public capacity and media literacies, resulting in low demand for extended and relevant public media services.
Audio and radio services must now be fully integrated within a wholescale review of digital platform services. If the French government can establish the principle that Facebook must pay a licence fee to news providers that get shared on their platforms, so then can the UK government ensure that audio and radio content producers are similarly licenced for carriage.
The perception that FM will remain an essential medium only until 2030 is short-sighted. FM should be supported in perpetuity, as it is a simple and effective medium of broadcast, with many low-cost receivers already in place. If the commercial marketplace for DAB+ is robust enough, then major commercial providers and the BBC can leave FM and AM/MW, and the spectrum that is freed ca be offered to additional alternative and independent service providers, both local commercial, public and community.
If AM/MW services by the BBC and commercial providers are to be switched off, this spectrum should be offered to regional providers to develop services outside of the existing commercial or public service framework.
The reducing costs of data provision at home and via mobile broadband services is changing the dynamic and need to carry multiple devices when travelling and accessing news services. At what point will data services be effectively free at the point of use, thereby enabling access to online audio services? More emphasis on this shift needs to be considered in the investment planning of major content providers.
There is no detailed acknowledgement or analysis of the forms of content and the purpose of the programming that is provided by service carriers. The economic driver of content will be the relevance to the population that is being served. The main cost in producing radio is the editorial and production management costs associated with employing staff, training producers, maintaining studios and managing the editorial process.
This is not accounted for in this review, as the efficiencies of centralisation and networking have been allowed to mask a push for market consolidation, taking services away from local provision. In the context of the need for local news and information, serving local identities and civic engagement needs, the costs of a centralised broadcast system can not be fully appreciated.
This policy paper does not undertake a true cost-benefit analysis or social value analysis of the role of public media, but instead assumes that the free market will continue to meet the needs of consumers. This means that the rights of citizens for effective representation and information continue to be deprioritised, while extractive-value commercial models remain a priority.