Submission to

BBC Trust Service Review:

BBC Radio 4, BBC Radio 4 Extra, BBC Radio 5 Live and BBC Radio 5 Live Sports Extra

February 2015

1. Global is a media and entertainment company comprising Global Radio, Global TV and Global Entertainment (music publishing and artist management). Our brands include Heart, Capital, Classic FM, Smooth, LBC, Gold, XFM and Capital XTRA, broadcasting from 20 broadcast centres across the country to over 23 million listeners every week.

2. LBC is the UK’s only dedicated commercial news and speech station. Since acquiring LBC in 2007, we have invested heavily in the station’s programming and in February 2014 we began broadcasting the station nationally on DAB. LBC has increased its hours by 10% year on year, reaching 1.3 million listeners. Our listeners are loyal, tuning in for more than 10 hours each week. In the latest RAJAR figures, LBC is up on last quarter and on last year of market share for all adults 15+.

3. As well as our award winning talk station LBC, we are known for our music stations. We combine our passion for great music with impartial national and local news, weather, traffic and travel and local information. We compete for listeners with the BBC’s national stations, Radio1, Radio 2 and Radio 3, 6 Music, 1Xtra, other commercial stations and increasingly with online music and entertainment services.

4. We submitted a response to the recent BBC Trust review of network music stations which set out our concerns regarding the BBC’s requirement to provide high quality, distinctive content for underserved audiences in line with their public service remits, rather than mainstream content which duplicates that which is already available on commercial stations.

5. BBC Network Radio has programming budgets of which commercial radio stations can only dream. Given this high level of public subsidy, the BBC has a responsibility to ensure that it is spending licence fee payers’ money wisely – and that the programmes it commissions do not duplicate the style and content of the output of commercial radio services.

6. Unlike the BBC music services, we believe that BBC speech services generally offer distinctive content for listeners which broadens choice.

7. It is clear that BBC Radio 4 is performing well against its service licence. The content is of a high quality and very distinctive. Its high level of funding ensures that it is able to provide a style and content of programming that would, in the main, not be economically affordable for a commercial radio service. BBC Radio 4 is rightly seen as an example of public service broadcasting at its best, providing content which is of high quality, varied and genuinely distinctive. The station’s consistently strong RAJAR performance also demonstrates that it is not necessary for the BBC to deviate from providing high value, distinctive public service content

8. BBC Radio 5 Live’s audience performance has been less strong and its market share has dropped back 4.3% to 3.5% during the past 12 months. Nevertheless, we believe it is possible for 5 Live to continue to deliver distinctive content and remain successful, provided that BBC management remains focussed on its public purposes and does not become distracted by chasing ratings.

9. We would be concerned if, in the pursuit of new audiences, BBC speech services began to attempt to emulate the success of LBC through the programming of similar elements such as phone ins and opinion pieces. The BBC Trust must ensure that BBC Radio 5 Live retains its distinctiveness and its commitment to broadcasting live sport. Any move towards a greater level of news- based phone-in content would bring the service closer to LBC, thereby reducing the distinctiveness of speech content across the BBC and commercial radio when taken as a whole. We would also encourage the BBC Trust to ensure that BBC 5 Live covers minority sports on its main service and does not relegate this editorial content to BBC Radio 5 Live Sports Extra.

10. All BBC Network radio services continue to operate on an uneven playing field with their commercial competitors when cross- promotion on BBC Television services is taken into account. There is a risk that this cross-promotion emphasises the more populist elements of the BBC’s speech networks, rather than the programme content that truly makes BBC Radios 4 and 5 unique because of its value in terms of public service.

11. Cross promotion on other BBC services is worth many millions of pounds in value to BBC radio services and therefore amounts to a significant market intervention in its own right. The BBC Trust must ensure that how this cross promotion is used is carefully measured and monitored and that it is only used appropriately and proportionately. We also believe that this information should be made public. The ability to cross promote radio programmes on BBC TV is a privilege only available to BBC Radio stations and it has the potential to distort the market and must be carefully monitored and controlled.

12. The BBC should not succumb to the temptation to broadcast all of its high value public service speech programming on Radio 4. It has a responsibility to deliver high public value programming across all of its national radio networks – particularly BBC Radio 1 and BBC Radio 2. In previous submissions to the BBC Trust, Global has highlighted concerns regarding both the lack of non-music programming on BBC Radios 1 and 2 – and a growing tendency to bury any high public value programming on these networks during off-peak hours.

13. The BBC also has a responsibility to spend public money wisely in its approach to talent pay, especially at the top end and with its most powerful stars. There should also be close scrutiny at the other end of the scale in payments to contributors. The BBC is artificially super-inflating the costs of production for commercial speech radio by paying hundreds of pounds to thousands of interviewees for appearing on programmes. It also strengthens its offer to guests by providing travel costs and ‘disturbance’ expenses. It is especially important that the BBC enforces its own guidelines on payments to elected politicians. We acknowledge that talent costs are not covered as part of this review and look forward to contributing to future reviews on this topic.

14. Although we have highlighted some areas where we are mindful of the potential impact that BBC speech services could have on commercial radio, in general we believe that these services are delivering distinctive content for audiences.