Subject: OFCOM proposals to reduce localness on commercial local radio in Wales

I wanted to draw your attention to a new consultation OFCOM has launched in relation to amending the hours of local content commercial radio licence holders are obliged to produce.

https://www.ofcom.org.uk/__data/assets/pdf_file/0012/115113/consultation-localness-radio.pdf

I would urge you to read their proposals and consider a response to OFCOM from either individual Assembly members or from the Committee as a whole.

Their main proposals are..

a) Local FM stations that provide local news at regular intervals throughout the day should air at least three hours of programming each weekday between 6am and 7pm which has been made in the local (or approved) area, removing the demand for a breakfast show aimed at the local area  (e.g. Capital Cardiff, Bridge FM or Radio Ceredigion). Currently that is set at 10 hours per weekday and they must do a breakfast show locally.

b) To intend to make the ‘approved areas’, within which a programme can considered to be ‘locally-made’, bigger to match, as closely as possible, the ITV regions. Currently, there are three approved areas in Wales, but this will go down to one.

I am sure you will have your own views on how this might affect choice and delivery of content about Wales for Wales, but for what it is worth, here is my interpretation of the effects if the recommendations above were approved: -

1) Loss of Jobs (especially in North and West Wales): By merging three approved areas in Wales into one, companies which own multiple local licences will have the ability to switch shows that are produced in one part of Wales to a bigger hub somewhere else in Wales. 

The two examples I would cite are Global/Communicorp and Nation Broadcasting.

Global/Communicorp currently produce Capital breakfast shows for North Wales and in Welsh for NW Wales out of Wrexham and Cardiff out of Cardiff. 

The change in OFCOM regulations would allow those English language breakfast shows to be merged into one studio and the Welsh Language breakfast show to be moved to Cardiff (even though it is only broadcast in NW Wales). 

It is, unfortunately, obvious that the North Wales output would be moved to Cardiff, causing the closure of studios in Wrexham and job losses there. Jobs may be directly moved to Cardiff and there may be no net loss of jobs - but Wrexham staff will be told its 'relocate or redundancy'. However, it is likely the N Wales and S Wales breakfast show may be merged, leading to only one presentation team being required.

The second example I would cite is Nation Broadcasting. They have already closed local studios in Bridgend and Aberystwyth in the past and co-located those stations in their St Hilary base.

The proposed change in the OFCOM guidelines would allow them to close their Narberth studios and move all output from their West Wales stations into St Hilary.

2) Loss of creative talent for future businesses in North and West Wales. 

If the above happens and companies close down their studios in certain areas, an audio generation skill base will go. Bearing in mind one of the drivers behind this OFCOM proposal is to allow companies to invest more into digital opportunities such as podcasting, would it not be wise to see how those skills could be retained in a community to create new podcasting opportunities in those areas, as opposed to shipping all those skills to a big hub in Cardiff or London?

3) Concerns over future of Capital Cymru (Formerly Champion 103).

The OFCOM proposals would allow Capital Cymru - technically the local radio station for North West Wales, to be moved from Wrexham to Cardiff. It has to be questioned whether presenters in Cardiff would know what is like to be Caernarfon at the same time - least of all in terms of weather, which varies wildly across the country!

However, the bigger potential here is that the OFCOM proposal says local programming can be reduced to three hours per day. Bearing in mind Capital Cymru is already a bilingual station, what would the temptation be like to cut the Welsh Language output at breakfast or drive and run with a network English Language programme from Cardiff?
If Capital Cymru were genuinely in the market to be an all Wales, all Welsh Language station, then I would see a move to Cardiff as no threat to its content - it could even be a boost. 

Those are my three main thoughts relevant to Wales regarding this latest OFCOM consultation.

I think it should be noted the positive statement made by Communicorp in their evidence to you "Just because OFCOM says we only have to do so much, that doesn't mean we don't want to do more." But they have reduced local hours and presenters in the past.

Again, I do not blame radio companies making decisions which I feel lower the content about Wales when OFCOM has opened the door to this cost-cutting opportunity for them. They are businesses after all. 

And, as someone who has worked in podcasting and digital media for a decade, OFCOM are absolutely right to highlight the growth of digital services...both as a market threat and opportunity.

But I feel OFCOM needs to protect Welsh content better and protect what is becoming a non-existent market for competition in audio services in Wales.