[cma-l] 4ZZZ & born to fail

Tony Bailey ravensound at pilgrimsound.co.uk
Thu Dec 10 08:22:22 GMT 2015


Ian, you are clearly an optimist to be working for community radio - 
long may you succeed.  Perhaps we should rename this thread "regulated 
to fail" instead as the issue is more about the environment in which CR 
has to exist than a defect at birth.

I think Roy's point was that coverage was king in the urban 
environment.  My point is that this issue arises from the well debated 
analogue coverage policy document March 2011 (which was preceded by the 
Aegis report March 2000 from where the 3-5 km urban radius emerged) 
where a secondary service in the national sub bands was envisaged in 
urban areas.  However, the report could not take into account the impact 
of local rf pollution which Roy refers to.

Ofcom policy defines the 5 km coverage radius as not suitable for 
commercial radio but possibly suitable for community radio. It also 
quotes 64 dB field strength as a realistic contour. While this may be 
based on secondary usage such as in a National sub band it also cannot 
allow for urban rf pollution.

Given that coverage is important rf pollution implies higher field 
strength in urban areas, something which has already been recognised for 
the sallies.

Tony Bailey



On 09/12/15 13:34, Ian Hickling wrote:
> I thought I was a miserable old pessimist Tony - but you're obviously 
> much better at it than me.
> Just a few points:
> The awful term "Sallie" - allegedly short for "Small Scale Alternative 
> Location Local Licence" is often used by the unenlightened to describe 
> stand-alone commercial stations - whereas none as far as I can find 
> were ever put in place under that scheme.
> Ofcom requires a detailed Business Plan in a CR Application - so, as 
> it's fact, it's feasible - regardless of the form of animal husbandry 
> at that location.
> We all know how local commercial licences have been traded, but that's 
> irrelevant with Community Radio.
> There are currently 236 CR stations on air, only 7 of which are on AM, 
> 7 with licences have yet to launch and 21 have failed out of a total 
> of 281 licences awarded.
> Agreed, some are run as a hobby and few are operating with a sensible 
> level of business income.
> But there are a few which are doing the job successfully and there are 
> moves afoot to spread their expertise for the benefit of the others.
> That, I suggest, is a positive side to the argument.
>
> *Ian Hickling*
> Partner
>
> <http://www.transplanuk.com/>
> /Office: 01635 578435  (7am-11pm UK time)/
> /Carphone: 07530 980115 (only responds when driving)/
> /6 Horn Street, Compton, NEWBURY, RG20 6QS/
>
>
> ------------------------------------------------------------------------
> Date: Wed, 9 Dec 2015 10:52:13 +0000
> From: ravensound at pilgrimsound.co.uk
> To: cma-l at mailman.commedia.org.uk; roy at rplradio.com
> Subject: Re: [cma-l] 4ZZZ & born to fail
>
> Absolutely Roy,
>
> I haven't run a full time license but my experience over the years of 
> being involved in applications, ranging from county wide ILR to sallie 
> and community was that all of them were a licence to spend money!
>
> As you know, the frightening costs involved in the old IBA regs meant 
> huge borrowings and eventual sale (weren't GWR famous for buying most 
> if not all their stations?).  Some people managed to get round the 
> rules by using office space (then virtually impossible due to floor 
> loadings). At least you were guaranteed coverage although you couldn't 
> overlap anyone else.
>
> The "incremental" licence followed, I suspect had more to do with 
> unlicensed than licensed broadcasting, one well know operator was 
> busted by the enforcement brigade on a virtual daily basis and 
> eventually was given a licence.  I think they spent a small fortune 
> over the years in trying to provide what was probably one of the first 
> genuine community services.
>
> The pattern was repeated with the infamous sallie (small scale 
> alternative location local licence) a scheme of dubious legality, also 
> I think "light touch" whatever that means. I remember working out that 
> based on local press rates it was barely possible to balance the books 
> even if you sold all the spots and all the sponsorship.  The only 
> salvation with that scheme was you could sell the licence after a year 
> to avoid liquidation.
>
> In my opinion the requirement to have a business plan that delivers a 
> profitable outcome for the duration of the licence would only be 
> feasible in flying pig land.  A case I an aware of amply demonstrates 
> this: a licence awarded to a prospectus with a no profit forecast and 
> eventually sold on after a year to a tax loss enterprise.  Another 
> case where the licence was awarded and withdrawn due to fiscal 
> irregularities.
>
> With this background the draft of the community radio licence scheme 
> always looked like it was designed to bring about a rapid demise of 
> the whole proposal.
>
> Put all this lot into a city like London, add a dose of heavy politics 
> to the mix and a total lack of commitment to develop a third tier and 
> it becomes a no-go area - easy.
>
> It is nothing short of a miracle that a dedicated band of people who 
> believe in community radio (all right, media) still manage to soldier 
> on in spite of the impossibilities of the regime they have to work with.
>
> Regards,  Tony Bailey
>
> On 08/12/15 21:24, Roy Parsons wrote:
>
>     Hi Tony,
>     As far as I know the JFMG contract is now with Ofcom.
>     I would like to call this post born to fail.
>     I have personally worked on over 100 rsl stations as the equipment
>     provider and many have gone on to win a full time licence.
>     Why do many of these stations still struggle?
>     And what about the ones that sold out to commercial concerns
>     The take the money and run attitude that was the result of the
>     Sallie licences (remember them)
>     Another licensing shambles.
>     OK Richard Branson and Chris Evans did Ok from it but people
>     thinking that playing with radio in order to just make money is
>     part of how this system works.
>     The funding is a big part but the lack of coverage to get any
>     commercial support is always the final killer.
>     We can go a long way on 25 watts but in an urban enviroment with
>     bad terrain and local RF pollution it is a no hoper.
>     Link FM in Havering Essex gave back their licence for this reason
>     and are not the only ones.
>     I really only do community stations now abroad where we can have
>     1kw FM transmitters!
>     Roy Parsons
>
>     RPL
>     Worldwide Broadcast Equipment Suppliers
>     Radionet House
>     4 Greenock Road
>     London W3 8DU
>     England
>
>     Tel: +44 (0) 20 8992 7109
>     Mob: +44 7970 92 3526
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>     ----------------------- *Original Message* -----------------------
>     *From:* Tony Bailey <ravensound at pilgrimsound.co.uk>
>     <mailto:ravensound at pilgrimsound.co.uk>
>     *To:* cma-l at mailman.commedia.org.uk
>     <mailto:cma-l at mailman.commedia.org.uk>
>     *Cc:*
>     *Date:* Tue, 08 Dec 2015 18:20:34 +0000
>     *Subject: _Re: [cma-l] 4ZZZ accounts and parameters_*
>     Alex:
>
>     There has probably been more contention about delivering that part
>     of Section 105 than any other and not confined to community radio
>     either.
>
>     I hadn't heard that JFMG no longer had that contract, it looks
>     like the new contractor bounced it.
>
>     I thought that most radios used a high local oscillator which
>     would start around 98 megs?  Is the other one an image?
>
>     I also thought that one of the arguments for low power (<=25 W)
>     was that overseas co-ordination wasn't required.
>
>     The point about users having control over the assets is that the
>     parameters can be changed.
>
>     Regards,  Tony
>
>     On 08/12/15 17:09, Two Lochs Radio wrote:
>
>         /Alan Coote wrote: I’ve long contended that Ofcom have a
>         responsibility to only license stations that stand a fair
>         chance of being financially sustainable. /
>         //
>         Isn't that a legal obligation on Ofcom when awarding licences,
>         Alan? It certainly is a primary consideration when licensing
>         commercial stations. In fact, while they aren;t in orde rof
>         priority, it happens to be the very first of the criteria laid
>         down in the Broadcasting Act, Section 105, which says:
>         Ofcom is required to have regard to...
>         (a) the ability of each of the applicants for the licence to
>         maintain, throughout the period for which the licence would be
>         in force, the service which he proposes to provide;...
>         Maybe it's not the same for community licences, I haven't
>         checked, but I thought it was.
>         /Tony Bailey wrote: Actually now may be the time for the CMA
>         to bid for this, if the authorities wish to devolve
>         licensing?  For special events (JFMG) and radio amateurs
>         (RSGB) are doing it already./
>         Didn't Ofcom most recently move in the other direction - I
>         thought they brought JFMG back in-house?
>         It would be easy to underestimate the amount of work that
>         would be involved in administering a community sub-band.
>         The coordinating body for such a sub-band wouldn't have a free
>         hand within that band, since as well as keeping clearances
>         within the band, you also have to keep clear of local
>         transmissions that are +/-10.7MHz from any given frequency,
>         and around the periphery also coordinate with the
>         French/Dutch/Irish and co. That's a fair bit of work, and
>         potential duplication of effort in parallel with the same
>         coordination done for BBC/ILR frequencies. If the frequency
>         coordination and clearance paramters weren't changed it seems
>         unlikely that a separate body could do a much better job -
>         it's the parameters being used for frequency planning that
>         generally control the way things end up, not who does the leg
>         work.
>         Alex
>
>             ----- Original Message -----
>             *From:* Alan Coote <mailto:alan.coote at 5digital.co.uk>
>             *To:* cma-l at mailman.commedia.org.uk
>             <mailto:cma-l at mailman.commedia.org.uk>
>             *Sent:* Tuesday, December 08, 2015 12:59 PM
>             *Subject:* Re: [cma-l] 4ZZZ accounts
>
>             A prominent person at Ofcom told me that there wasn’t a
>             community station in the country that doesn’t want more
>             power – which tells you quite a lot about Ofcom and their
>             willingness and ability to support the sector!
>
>             I’ve long contended that Ofcom have a responsibility to
>             only license stations that stand a fair chance of being
>             financially sustainable. It stands to reason the larger
>             the audience the greater the potential revenue.
>
>
>             Kind Regards
>
>             Alan
>
>             Alan Coote
>
>
>
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