Radio is changing. You might not have been aware but many local radio licences are about to become mostly national, resulting in hundreds of job losses, closure of local studios and removal of content tailored to individual areas of the country.

The big radio groups argue that radio is struggling against the likes of streaming services and other online media, and that this reduction in content is needed to survive.

So is the industry actually shrinking? Not in terms of the RAJAR audience figures which show radio in fine health. In terms of advertising, revenues are on the up according to Radiocentre. So why the scaremongering?

What we are actually seeing is the station owners, as any business would, simply pushing and pushing to reduce their running costs in order to maximise their profits.

It’s the radio regulator OFCOM’s duty to allocate the FM spectrum in the best interests of the listener. FM (and for that matter, DAB) spectrum remains our resource. As members of the public we trust OFCOM to represent our best interests, and for the most part OFCOM have done this by licencing a variety of specialist, commercial and community services.

However, OFCOM have recently taken the side of the heritage station owners citing “market conditions” and introduced new relaxed regulation that effectively allowed national licences by the back door. It's puzzling why OFCOM didn't show greater scrutiny of the radio marketplace, especially when the Radiocentre are trumpeting how well radio is doing in these supposedly difficult market conditions but we are where we are and I believe we're now in a position where we can turn this into a positive for the listener too.

I’ve always supported the idea of “let the market decide” but I do believe there should be a balance between allowing the larger groups the wriggle room to achieve their business goals whilst protecting a scarce resource that belongs to the listener. I believe the pendulum has swung too far in one direction but there's a way for it to swing back without anyone losing out.

I strongly feel FM spectrum should be earned in the same way that TV channels are required to provide certain output guarantees to secure a higher position in the tv channel listings.

FM is slightly different in that there isn't a priority frequency like a higher TV channel position, so there isn't really the same return for adding obligations. But by occupying lots of frequencies with the same programme, the larger groups are effectively squatting on land that could be shared out more fairly and give the listener and advertiser more choice. No one needs to lose out here, but now is the perfect time to re-evaluate how the FM band is carved up and re-allocate it for the modern radio market.

I am proposing a return to a "use it or lose it" approach that was employed in the late 80s and early 90s to prevent simulcasting on AM & FM and could be deployed in a similar manner to consolidate the way FM is used, freeing up spectrum for new commerical stations.

Whilst I am oversimplifying a very complex process of FM frequency planning for this article, there remains an opportunity here to say to the big groups "Go ahead and run your national brand you aspire to with very little reduction in coverage, but you must do so using better transmitter sites and occupying less FM spectrum".

As an example, Classic FM manages to provide national coverage in just 2MHz of space (100-102FM) whilst Heart FM currently occupies frequencies spanning 11MHz (96-107FM) and doesn’t even have full national coverage with that huge chunk of spectrum.Following the Classic FM model (which itself is loosely based on the BBC FM model) the amount of FM space that Heart FM uses up can be reduced considerably whilst at the same time retaining some split regions for advertising, as Classic FM currently does.

I’ve given a simplified example at the foot of this page, detailing how the London and the South macro region (an area defined by Heart FM themselves) is currently covered using 17 transmitters on 16 different frequencies. In comparison Classic FM achieves comparable coverage using 7 transmitters on 6 different frequencies. By applying the Classic FM pattern to Heart FM, 10 frequencies would be released with the possibility of space for a new regional commercial service in Berkshire, Hampshire, Sussex and Kent!

In the unlikely event a big group with national brand aspirations want to retain individual transmitter coverage of a particular area for advertising, they must provide the equivalent local programming. Let the market decide, would the cost of maintaining the extra content and transmitter cover its costs in extra revenue?

A consolidation of frequencies is a win for all concerned:

• The listener benefits from a new tier of regional commercial stations allocated in the FM spectrum subsequently freed up by the replanning.

• OFCOM do not have to reverse their controversial legislation, and are seen to be managing the scarce FM spectrum in a far more beneficial manner.

• The groups with national aspirations can reduce their transmission costs by operating less transmitters, whilst retaining the same coverage and even gain the opportunity to extend their brands.

By consolidating the FM band and replanning for the modern day radio market OFCOM will continue to act in a way that best represents using this spectrum to serve the public.

FAQ

What about the Digital Switchover? Would this not be the answer?

It wasn’t the answer for the big groups with their aspirations to run national brands. They could have quietly switched off their local FM transmitters and handed back the licences for the heritage ILRs to achieve their aims. Crucially at the time of writing they haven’t relinquished a single licence which shows the value FM still has to both broadcaster and listener.

Whilst DAB is growing, it is still too early to force any broadcaster to a specific platform which could result in cannibalisation of the existing audience and a two tier broadcasting system where national broadcasters are found on one platform and those with a lesser presence struggle left behind on the other.

How could this be funded?

OFCOM’s income from both existing radio licence fees and the future applications for any new FM licences should provide adequate funding for the spectrum replanning. There will be some initial cost to heritage licence holders but that would be offset against the long term reduction in FM transmission costs by running fewer transmission sites.

What value is placed on the FM frequency as part of the brand?

For the national stations, very little. Listening to the brands that would be affected by the frequency replanning we hear few references to their FM frequency and the advertising logos often show the full and often pointless frequency span covering large swathes of the fm band (eg. 96-107) rather than individual frequencies.

Would new stations be viable?

Again “Let the market decide”. But I’d cite the example of Wave 105 which remains editorially independent, 100% local and still market leader in one of the busiest markets in the South of England, and I strongly believe stations of that size would work in other areas too, extending listener choice in a commercially viable fashion.

What about community radio?

I haven’t covered community radio within the scope of this article as this is purely about local commercial radio - OFCOM’s current policy of allocating low power frequencies in between existing BBC and commercial services can and should continue. The viability and restrictions placed on community radio is an entirely different debate and doesn’t form part of this article.

What’s to stop the existing big groups applying for the new licences?

Potentially nothing. Let the market decide. However I strongly feel OFCOM should be minded to introduce commercial competition in areas where there is now no commercial competition.

Show me an example of what you mean about FM frequency allocation?

Ok this is the technical bit, I won’t be offended if you skip this bit but I include it as a “show your working out” approach.

It should be noted that international FM clearance in the South of England, especially Kent is tricky due to the close proximity with our European broadcasting colleagues and so this is an oversimplified example but with potentially 10 frequencies freed up and the same applied to the rest of the country I believe there is scope for a new regional FM service in many areas of the UK.

Heart FM: Current London / South of England Coverage	Classic FM: current FM Usage to cover London and the South of England
96.1 Ashford	100.3 Hampshire
96.7 Southampton & Winchester	100.6 London
96.9 Newhaven	100.9 Kent and East Sussex
97.0 Folkestone and Dover	101.3 Oxford
97.4 Banbury	101.9 Brighton
97.5 Portsmouth	101.8 Dover
97.5 Horsham	101.8 Reading
102 Hastings
102.4 East Sussex
102.6 Oxford
102.7 Surrey and North Sussex
102.8 East Kent
102.9 Berkshire
103.1 West Kent
103.4 Henley
103.5 Brighton
106.2 London
Total Transmitters: 17	Total Transmitters: 7
Total Frequencies: 16	Total Frequencies: 6
Total Frequencies Freed Up: 10

Who The Hell Are You?

Hello, I'm Simon Hardwick. My day job these days is Television but I have over 20 years experience in commercial radio ranging from national stations to small scale local FM services. I currently run two small scale DAB stations and still strongly believe in radio as a medium. See my radio page here.

For the record, I have no personal issues with any of the radio groups, stations or their actions - they are only doing what any business would do within the legislative framework they were presented with. I worked for one of the groups referred to in this article and even when they shut the station I was at they looked after me well.

I wish all those affected by these industry changes every future success.