Cross-Media Ownership – the “Case” for Changes

INDEPENDENT REGIONAL RADIO

A response to the Discussion Paper on Media Reform Options

March 2006

1. Introduction

Independent Regional Radio (IRR) is an unincorporated association of licensees of some 73 regional commercial radio services located in 42 of Australia’s 96 regional radio licence areas.

Unlike most other regional radio broadcasters IRR members are committed to local service in that local station managements have both the responsibility and the autonomy to ensure the needs of their local communities are effectively served. For this reason, all IRR members’ main programs are produced locally, being neither dictated by, nor delivered from, some remote “hub” or headquarters organisation.

This submission on behalf of IRR members is concerned with only one section of the government’s discussion paper on so-called media reform options, namely the section dealing with media ownership and control, and in particular, only those matters which affect regional services.

Further information may be obtained from:

Mr Des Foster Director Independent Regional Radio Tel: (02) 9975 6746 E-mail: [email protected]

2 2. Executive summary

(a) The Government has a closed mind on the issue of cross-media rules in regional Australia, and the process of “consultation” it has adopted reflects this. (b) The real intent of removing the cross-media rules is to enable some existing media companies to increase profits through economies of scale and scope. (c) There is no public benefit in removing cross-media rules in regional markets, but there is serious potential detriment. (d) Removing the cross-media rules in regional markets under present conditions ignores the advice of the Productivity Commission. (e) Protections designed to offset counterproductive effects will not work.

3. The consultation process

At the outset, IRR is deeply concerned by the lack of consultation on the issue of media ownership in regional areas, and by the process which will lead to a decision.

The government’s intentions have been clearly signalled for some time, but at no point has it acknowledged the potential counter-productive outcomes which have been drawn to its attention, nor has it engaged in any dialogue on the subject. A lengthy letter from IRR to the Minister for Communications, dated 13 October 2005, has gone unanswered. A copy of that letter is attached to and forms part of this submission. (Attachment “A” – page 18).

It is clear from the discussion paper that the government’s views on media ownership in regional areas have not changed since the introduction of a bill in 2002, other than to recognise that bill entailed “a high degree of intervention”. The government’s “preferred options” are virtually the same as they were in 2002 and are in fact the only options for consideration in this paper.

None of the issues here is being referred to independent examination by a body such as the Productivity Commission (which expressed views on the subject in 2000). Instead, submissions are being referred to officers of the Minister’s Department who are already on notice of the government’s preferences. There will be no response to or dialogue with submitters.

In these circumstances, IRR has regretfully concluded that the government is not open to persuasion regarding cross media ownership in regional areas, that the

4 invitation to make submissions on this issue has been extended merely for the sake of appearances, and that the process lacks integrity.

IRR does not request confidentiality for any part of this submission.

4. Cross-media ownership – the “case” for changes

According to the discussion paper, the main arguments in favour of removing the cross-media ownership rules are that the rules-

1. increasingly risk growth of new services, 2. limit media companies from obtaining economies of scale and scope, 3. constrain media companies in addressing the challenges of emerging media forms, and 4. foreclose future developments in the market place.

The paper claims that as a result, investment and innovation in Australian media is limited and that this risks undermining an objective of the Broadcasting Services Act (Section 3(b)) which is to “provide a regulatory environment that will facilitate the development of a broadcasting industry…that is efficient, competitive and responsive to audience needs.”

Each of these broad generalisations, which are utterly unsupported by any kind of evidence, demands a response.

“Risk to growth of new services”

It is difficult to understand what this actually means. True, the discussion paper alludes to the encouragement of “new entrants, new investments and new services to contribute to diversity in a competitive environment.” But nowhere does it

6 illustrate how the present cross-media rules in regional markets frustrate that objective.

The barrier to entry in regional commercial radio and television is not the existence of the cross-media rules, but of quite sensible planning decisions which rule out the possibility, for the foreseeable future, of more licences. The number of regional commercial radio licences has more than doubled since the present legislation was enacted and both the regulator and the government have recognised there are practical limits to the number of stations which a market can sustain if adequate service is to be provided, commercial viability being a key factor.

There are no artificial barriers to entry into the newspaper industry or internet- based media, and in the case of internet-based media, established media companies have not been slow to invest or to innovate.

So far as regional media are concerned, the assertion of risk is just that, an unsubstantiated assertion.

“Economies of scale and scope”

The desirability of providing opportunities for existing media companies to achieve economies of scale and scope has been the most persistently repeated mantra in the government’s rhetoric. The benefits of such economies to business are obvious. What the government has never been able to explain is how such economies will benefit the public.

7 In its letter to the Minister (referred to in Section 3 – page 4) IRR gave examples of the effects of economies of scale and scope in regional broadcasting. It pointed out how some regional radio stations had been “converted from local, autonomous operations into mere outlets for programs provided from some remote central point, or hub.” This was a classic example of economy of scale, which is the relative saving realised when the size of an operation is increased.

Economy of scope, where the cost of performing multiple businesses simultaneously is more efficient than performing them independently, is exemplified in the media context by sharing facilities or functions such as news rooms and program, accounting and sales departments.

It is true that cross-media rules limit regional media companies’ ability to effect economies of scale and scope. However, it also true that such economies offer nothing to consumers unless there is strong competition. Otherwise they are purely and simply means to increasing profit.

While the discussion paper pays lip service to competition in this context there is nothing to suggest more broadcasting licences will be issued in regional markets, nor should they be given the economic realities of regional media, including the proliferation of stations which has occurred in recent years, the need for commercial viability and the proportion of stations operating at a loss.

“Challenges of emerging media forms”

“Emerging media forms” is code for services capable of being provided by digital technology. What the discussion paper fails to explain is in what manner the

8 existence of the cross-media rules constrains existing regional media from dealing with the perceived challenges.

“Foreclose future developments in the marketplace”

Apart from the fact that retaining the cross-media rules would prevent undesirable media takeovers in some regional markets, IRR has not the faintest idea what this impressive phrase means.

5. Consequences of removing cross-media rules

In all the rhetoric touting the government’s preferred options there is one clear and unequivocal intent – to enable existing media companies to achieve economies of scale and scope.

So far as regional media are concerned, cross-media rules stand in the way of this objective. Removing the cross-media rules would pave the way for companies to take over and merge in various combinations of press, radio and television.

If there were a proliferation of such media in regional areas, a case might well be made for allowing combinations of media on the basis that this would promote healthy competition.

This point was recognised by the Productivity Commission in its Broadcasting Inquiry Report in March 2000 when it stated: “The traditional media businesses in Australia are concentrated, and could become more so if the cross-media rules are relaxed and no other compensating measures, such as freeing entry, are taken.”

The Commission also stated: “Eventually, removing the cross-media rules while regulatory barriers to entry to television and radio are still in place would be counterproductive.”

Obviously, for the reasons already given on page 7, creating additional licences is not a practical option for the foreseeable future, but the logic of the Commission’s conclusions becomes abundantly clear in light of an analysis by

10 IRR of Australia’s 96 regional radio markets, showing the potential effect of removing the cross-media rules. This analysis is reproduced as Attachment “B” on page 25.

It shows that, because of the low numbers of media proprietors involved in these markets-

(a) There would be little likelihood of change in 46 markets. (b) In another 47 markets, one media proprietor could emerge in a position of dominance. (c) Competition between equals would be possible in only three markets.

Each of the 47 markets where one media proprietor would dominate would provide the opportunities for effecting economies of scale and scope which is the government’s objective.

While such economies would add to the profits of the businesses concerned, they would be counterproductive in public interest terms. Specifically, they would lead to-

(a) Dominance of the market by one company, with no likelihood of it having to face competition on equal terms. (b) Less diversity of opinions on matters of local importance. (c) More power to the media proprietor to set the news and current affairs agenda and influence public opinion. (d) Increased advertising rates for local businesses, the costs of which would be passed on to consumers.

11 (e) Less incentive to maintain services at the current levels. (f) Loss of local employment.

It is impossible to reconcile potential outcomes such as these with the rhetoric of the discussion paper which talks of protecting the public interest in a “diverse and vibrant media sector”.

12 6. Dealing with the consequences – the government’s “solution”

The government tacitly acknowledges the risks associated with the removal of cross-media rules in regional areas, otherwise there would be no need for its proposals for “Regional services protections”, namely-

(a) A legislated requirement would be established for the continued imposition of licence conditions in key regional television markets to provide minimum levels of content on matters of local significance. (b) ACMA would continue to ensure there is genuine competition between regional radio licensees through the requirement that, following the sale of a commercial radio licence, if the program format of that service changes from one of broad appeal to one of more limited appeal, it considers the allocation of a new commercial radio licence in that licence area. (c) ACMA and the Government will continue to monitor the provision of local content in other regional television licence areas and on regional commercial radio services. The Government may consider extending licence conditions relating to levels of local content to those markets if local content levels decline materially.

In addition-

(d) The Australian Competition and Consumer Commission (ACCC) would become involved under the general mergers provisions of the Trade Practices Act 1974, and would assess the competitive impacts of transactions.

13 (e) ACMA would police the “minimum number of media groups” requirement and the licence and reach limits, and its enforcement powers would be enhanced to enable it to make more timely and proportionate responses to industry activity.

It is ironic indeed that all of these measures are unnecessary under the current system.

14 7. “Protections” don’t address the real issues

It is readily apparent that so-called protections outlined in the discussion paper will have little if any effect on, and in fact do not address the counterproductive consequences listed at page 11.

Items (a), (b) and (c) of that list deal only with the maintenance of levels of local content and the possibility that in certain limited circumstances a commercial radio station’s format may change from one of broad appeal to one of more limited appeal.

While it is true that local content would probably be reduced substantially if and when a member station of IRR were taken over by certain other operators, the fact is that for the rest of the regional commercial radio industry this horse has already bolted. There are many instances of dissatisfaction in regional markets where local announcers have been sacked, programs emanate from some remote centre, local place names are incorrectly pronounced, weather information does not accord with what listeners can see for themselves, and local news and localism generally have been ignored.

Since this systematic degradation of service for the purpose of achieving economies of scale and scope has long been tolerated by both the government and the regulator, it sets the standard to which local content can be reduced in other markets in future. This makes a farce of the implication that local content will be protected under the government’s proposed new regime.

15 Item (d) proposes the involvement of the ACCC under the general mergers provision and in assessing the competitive aspects of takeovers. In this context, specific reference is made to section 50 of the Trade Practices Act.

Given the extensive list of matters in section 50 which the ACCC must take into account in determining whether an acquisition would have the effect of substantially lessening competition it is trite to say that every case would have to be considered according to the circumstances. No-one can say with certainty whether the ACCC would or would not approve all, any or some of the takeovers which could potentially result from removing the cross-media rules, but obviously the government anticipates that at the very least some takeovers would occur, otherwise its proposed legislation would be pointless.

IRR strongly doubts whether most of the counterproductive consequences it has identified, and in particular a proprietor’s powers to influence public opinion, to increase advertising rates and to reduce the standard of services, would in fact be prevented by Trade Practices legislation.

IRR has two other serious reservations about the use of the Trade Practices Act and the ACCC. First, there is a serious question as to whether the ACCC will have the resources, the time and the will to pursue matters in what are essentially very small markets. Second, the financial and resources burden on small regional media in being party to proceedings under trade practices law could in itself be a serious deterrent to those media which may have justifiable objections to takeovers.

16 8. Conclusion In various public utterances and in its discussion paper the Government has consistently referred to its cross-media proposals as “media reform”.

The Macquarie Dictionary relevantly defines “reform” as “the improvement or amendment of what is wrong, corrupt, etc”.

Reform is not the appropriate word for what is proposed in regional markets.

Removing cross-media rules in these markets will not lead to improvement, but to the degradation of media services in terms of localism, diversity, competition, jobs and influences on public opinion.

ATTACHMENT “A”

INDEPENDENT REGIONAL RADIO PO Box 429 FRENCHS FOREST NSW 2086 Tel: (02) 9975 6746 Fax: (02) 9975 6749 E-mail: [email protected]

13 October 2005

Senator the Hon Helen Coonan Minister for Communications, Information Technology and the Arts Parliament House CANBERRA ACT 2601

Dear Senator

Media ownership

I would like to thank you for meeting with representatives of this association1 recently to give us your views regarding media ownership issues. Since then, in your 31 August address to the National Press Club, you have expanded on those views and provided a broader rationale for your position. This calls for a considered response.

Our credentials are these: Our members are the licensees of some 73 commercial radio stations operating in 42 of the 97 regional radio licence areas throughout Australia. They differ from other regional radio operators in that their stations are locally autonomous, that is to say they have local managers with the authority, the responsibility and the resources – they are fully staffed - to ensure that localism and local service are maintained at the highest practical level.

1 Formerly known as the Australian Association of Independent Regional Radio Broadcasters (IRB)

18 There are enormous differences between regional markets and metropolitan markets, as I am sure you are aware. One of these differences is the number and diversity of media which are available2.

Another major difference is the way in which consumers employ and interact with media. People living in towns and most cities in regional Australia live in true communities. They look to their local media to provide local content, to cover local issues and to reflect whatever diversity exists within their communities. People living in the metropolitan capitals do not constitute single communities; rather they are comprised of many communities whose needs for localism and discussion of local issues are generally better served by local suburban newspapers and other local media rather than the main metropolitan media.

It is against this background that we urge you to dissociate regional media completely from the media reform debate. Whether or not there is a case for reform of metropolitan media ownership, a similar kind of “reform” of regional media will be counterproductive. It will mean fewer “voices”, less competition, less diversity, less employment and less localism.

It is reasonable, drawing on your comprehensive address to the National Press Club, to infer that metropolitan media are the principal focus of media reform.

The “challenge to the business models of existing players” is primarily a metropolitan challenge. For example, it is generally recognised that metropolitan newspaper circulations are in decline and that newspapers such as The Age and The Sydney Morning Herald are facing losses to the internet of revenue streams from classified advertising. A former editor of The Sydney Morning Herald, Eric Beecher, has described this as a “life threatening potential”3

However, to assert there is a need to relax the existing media ownership restrictions so that major metropolitan media players can evolve into globally competitive firms does not seem to accord with the facts. Nothing has prevented the major metropolitan media players from making massive investment in the internet. The Macquarie Bank’s Macquarie Media Group (MMG), which is reported as “casting its net far and wide in the hunt for assets, focusing first on Australia, the UK, Europe and the US, but also keeping an eye on the more

2 For example, even using the limited “voices” criterion (ie counting proprietors rather than outlets) Sydney has 11 “voices” compared with say, Bathurst, which has five. 3 Conference on the Future of Regional Media, Charles Sturt University, 20 September 2005

19 developed markets in Asia” will “look at broadcasters, outdoor advertising companies, newspapers and the internet ...” MMG Chairman Tim Hughes is quoted as saying: “I don’t know what will happen with cross-media ownership in Australia, but the expansion of MMG does not depend on those changes”.4

No-one so far has identified a challenge to the business models of regional media. Speakers at a conference on the subject as recently as 20 September 20055 generally agreed there was no threat, or could not predict one. The Chairman of Rural Press (Mr John Fairfax) indicated his company was carefully monitoring developments but did not profess to know how the future would unfold.

In your address, having supported the long term objective of moving to an open and competitive market environment without artificial and arbitrary restrictions you stated: “Policies need to ensure diversity of ownership and services in the local media market....” Most commentators would agree, and many of those opposing media ownership restrictions do so with the same qualification you have made. For example, the Productivity Commission6 recommendation that the cross-media rules be replaced was subject to very strong caveats:

“The traditional media businesses in Australia are concentrated, and could become more so if the cross-media rules are relaxed and no other compensating measures, such as freeing entry, are taken”7

“Eventually, removing the cross-media rules while regulatory barriers to entry to television and radio are still in place would be counterproductive. Repealing these regulatory barriers to entry would enhance the prospects for new players to emerge, but only if entrants have access to spectrum”8

In the present environment, reducing the number of media proprietors in a market inevitably will make it less open and competitive, and less diverse in ownership, than it already is. That being the case, where is the benefit, and to whom will the benefit go?

While there is no evidence or even assertion that consumers would benefit from such “reform”, there is abundant evidence that some media proprietors would

4 Sydney Morning Herald, 5 October 2005 5 Conference on the Future of Regional Media 6 Broadcasting Inquiry Report. Report No. 11. 3 March 2000 7 Ibid p.24 8 Ibid p.25

20 benefit from the economies of scale and economies of scope to which you have referred in your address.

Economy of scale is the relative saving realised when the size of a plant, enterprise etc is increased. A classic example of economy of scale is to be found in the trend, in recent years, for some regional radio stations to be converted from local, autonomous operations into mere outlets for programs provided from some remote central point, or hub.

For many communities this kind of behaviour has been a matter of concern and it was an important factor in triggering an inquiry by a House of Representatives Standing Committee in 2000-2001.9

In the course of its report, the Committee opined that “local radio is radio that-

• provides news and information that is of interest to and specifically about that local community; • provides an outlet for the community to broadcast announcements (and for businesses to advertise their wares or services....); • provides a forum for the community to hear the voices of its own region, and reflects back to the community its own identity and helps to shape that identity; and • resides within and is predominantly derived, produced and presented by the local community.”10

Economy of scale and its effect on regional radio are seen at work as recently as August this year. The Townsville Bulletin11 reported on 27 August:

“Another local radio program was slashed this week after the new owner of HOT FM wielded the axe again.

Macquarie Regional Radioworks bought HOT FM and 4TO earlier this year.

9 “Local voices – Inquiry into Regional Radio” – Report of House of Representatives Standing Committee on Communications, Transport and the Arts. September 2001. 10 Ibid. p 48, para 3.24 11 Edition 1, p 3

21 A locally produced afternoon radio program was cut at HOT FM early this year and this week it axed more local content from its afternoon programming.

The new program is now being beamed in from the Gold Coast between noon and 4 pm.”

Economy of scope occurs when the cost of performing multiple businesses simultaneously proves more efficient than performing them independently. Typical examples in a media context would be the use of a common news room to produce news for any combination of radio, TV or press, or a single accounting department, or a single sales department.

There is no basis for assuming, however, that either economy of scale or economy of scope will translate into benefits to the public. To be blunt about it, such economies are almost invariably directed to profit, and on occasions are achieved at some cost to the community. This is especially true where competition is limited. For that reason, while admiring the altruism in your observation that “cross media reform could help to limit reductions in local content in regional areas by enabling media proprietors to achieve economies...” we respectfully suggest it could also have the opposite effect.

It is clear from your address that you recognise the need to maintain diversity and localism in regional media. That is implicit in your proposal to place a “floor” under the number of media groups to be permitted in a market. In the case of regional markets you suggest that number would be 4.

We invite you now to consider the implications of that proposal, by hypothesising its effects in three disparate regional markets – Canberra (population 356,000), Bathurst (74,000) and Cooma (31,000)12.

Market Press13 Radio Television No. of “voices” Canberra 1 2 3 6 Bathurst 1 1 3 5 Cooma 0 1 3 4

12 Licence area population, rounded to nearest ‘000) 13 Newspapers as defined in the Broadcasting Services Act 1992

22 The 4-voice floor opens the way for many different scenarios, but let us assume the following-

Market Voice 1 Voice 2 Voice 3 Voice 4 Canberra 1 Press, 1 Radio, 1 TV 1 Radio 1 TV 1TV Bathurst 1 Press, 1 Radio 1 TV 1 TV 1 TV Cooma 1 Radio 1 TV 1 TV 1 TV

Cooma, of course, would remain unchanged, but it is immediately apparent that in both Bathurst (Press plus Radio) and Canberra (Press plus Radio plus TV) one company (or voice) – and only one - would emerge in a strong, dominant position..

Commercially, Voice 1 in each of these two markets would acquire substantial advantages not available to its competitors – economies of scale and scope, including staff reductions, substantially reduced competition in the sale of advertising, greater flexibility in setting advertising rates, substantially less competition for consumers’ attention.

Worse, Voice 1 would also acquire a greatly increased capability to set the news and current affairs agenda and to determine what opinions will be served up to the community.

Worse, yet again, Voice 1 would be entrenched in that position – immune to new players or serious competition - for years to come.

In regional markets the consequences of the proposed relaxation of the media ownership laws would be diametrically opposed to the Government’s objective, which you put so succinctly in your address when you said “the end-game is diversity and clear benefits for consumers”.

Of course, if it were not for the dangers inherent in the reform proposals in regional areas, you would not have to contemplate measures to protect diversity and local content, such as quotas, increased powers to ACMA and the use of the ACCC in competition issues - measures which at present are unnecessary because the existing system works quite well without them.

We note that when the government originally sought to implement its reform in Broadcasting Services Amendment (Media Ownership) Bill 2002 it drafted a complex set of procedures aimed at overcoming some of the predictably

23 undesirable consequences which would have resulted from relaxing the cross media rules. In the event those procedures were never put to the test, but we can assure you that had the Bill passed into law the government would have been seriously embarrassed when they proved to be unworkable in practice, as they inevitably would have done.

The harsh realities are that relaxing cross-media ownership restrictions in regional areas would impact adversely on localism in its fullest sense, on competition, on local employment, on the costs of advertising, and on diversity of opinion in news and current affairs. There would be no public benefit. Short of draconian powers far greater than anything proposed in the 2002 Bill, to claim otherwise would be to emulate King Canute. The ultimate irony is that in exercising such powers, the objective would be no more than trying to achieve the benefits of a system which already exists without them.

Minister, we earnestly request that you carefully consider these arguments, and respond in kind. We understand the government’s commitment to reform and its preoccupation with the big picture. However, legislation based on ideology and without regard for its counter-productive and destructive effects at the grass roots level would be beyond our comprehension.

This is why we ask for a response. If we are wrong, please tell us where you think we are wrong. What is it that we don’t understand, when we stand alongside bodies like the Productivity Commission, and say that in the present environment relaxing the cross-media rules will increase concentration and will be counterproductive?

Yours sincerely

(Signed)

D L FOSTER Director

24 ATTACHMENT “B”

INDEPENDENT REGIONAL RADIO

Potential effect of the “four voices” test applied to commercial radio licence areas in regional Australia

The following table shows the potential effect of applying a “four voices” test for media ownership to the 96 commercial radio licence areas in regional Australia.

The sources of this information are:

• Licence area populations and overlaps as determined by the Australian Broadcasting Authority under Section 30 of the Broadcasting Services Act 1992.

• The Associated Newspaper register maintained by the Australian Media and Communications Authority as at 20 February 2006.

• The ACMA register of current controllers of commercial radio and commercial television broadcasting licences as at 29 November 2005.

Under the heading “potential outcome” the figures in brackets represent the number of media which under the “four voices” test could be held by a single proprietor, and the total number of current voices. Thus (3/6) means that one proprietor could hold 3 of the current 6 media “voices”.

The tables reveal that the potential for equal competition under a “four voices” test exists in only 3 of the 96 markets listed. In 47 of the remaining 92 markets, one proprietor in each could emerge as the dominant operator, in the sense that no other operator could compete on equal terms.

10 March 2006

Radio licence area Radio TV Press Total Potential outcome Remarks Albany 1 2 0 3 No change Albury 2 3 1 6 1 dominant (3/6) Alice Springs 1 2 0 3 No change Armidale 1 3 0 4 No change Atherton 1 3 0 4 No change Ballarat 2 3 1 6 1 dominant (3/6) Bathurst 1 3 1 5 1 dominant (2/5) Bega 1 3 0 4 No change Bendigo 2 3 1 6 1 dominant (3/6) Bridgetown 1 3 0 4 No change Broken Hill 1 1 1 3 No change Bunbury 2 3 0 5 1 dominant (2/5) Bundaberg 2 3 1 6 1 dominant (3/6) Burnie 1 3 1 5 1 dominant (2/5) Cairns 3 3 1 7 1 dominant (3/7) Campbelltown 1 3 2 6 1 dominant (3/6) Canberra 2 3 1 6 1 dominant (3/6) Carnarvon 1 2 0 3 No change Charleville 1 3 0 4 No change Charters Towers 1 3 0 4 No change Coffs Harbour 2 3 0 5 1 dominant (2/5) Colac 1 3 0 4 No change Cooma 1 3 0 4 No change Darwin 1 2 1 4 No change Deniliquin 1 4 1 6 1 dominant (3/6) Devonport 1 3 1 5 1 dominant (2/5) Dubbo 2 3 1 6 1 dominant (3/6) Emerald 1 3 0 4 No change Esperance 1 0 0 1 No change Geelong 1 3 3 7 1 dominant (3/7) 1 Radio-TV-Press combination possible Geraldton 1 2 0 3 No change Gold Coast 2 6 1 9 1 dominant (3/9) 1 Radio-TV-Press combination possible Gosford 2 3 0 5 1 dominant (2/5) Goulburn 1 3 0 4 No change Grafton 1 3 1 5 1 dominant (2/5) Griffith 1 3 0 4 No change Gunnedah 1 3 0 4 No change Gympie 2 3 1 6 1 dominant (3/6) 2 newspapers commonly-owned Hamilton 1 3 0 4 No change Hobart 2 3 1 6 1 dominant (3/6) Horsham 1 3 0 4 No change Innisfail 1 3 0 4 No change Inverell 1 3 0 4 No change Ipswich 1 3 2 6 1 dominant (3/6) Kalgoorlie 1 2 1 4 No change Karratha 1 2 0 3 No change Katanning 1 3 0 4 No change

27 Katoomba 1 3 2 6 1 dominant (3/6) Kempsey 2 3 0 5 1 dominant (2/5) Kingaroy 1 3 0 4 No change Launceston 2 3 1 6 1 dominant (3/6) Lismore 1 3 1 5 1 dominant (2/5) Lithgow 1 3 0 4 No change Longreach 1 3 0 4 No change Mackay 3 3 1 7 1 dominant (3/7) 1 Radio-TV-Press combination possible Mandurah 1 5 0 6 1 dominant (2/6) Maryborough (QLD) 2 3 1 6 1 dominant (3/6) Maryborough (VIC) 1 3 1 5 1 dominant (2/5) Merredin 1 3 0 4 No change Mildura 2 3 1 6 1 dominant (3/6) Moree 1 3 0 4 No change Mt Gambier 1 3 1 5 1 dominant (2/5) Mt Isa 1 3 1 5 1 dominant (2/5) Mudgee 1 3 0 4 No change Murray Bridge 1 3 0 4 No change Murwillumbah 1 6 2 9 1 dominant (3/9) TV control limited to one licence per area Muswellbrook 1 3 1 5 1 dominant (2/5) Nambour 2 3 2 7 Competitive 2 Radio-TV-Press combinations possible Narrogin 1 3 0 4 No change Newcastle 2 3 1 6 1 dominant (3/6) Northam 1 5 0 6 1 dominant (2/6) Nowra 1 3 0 4 No change Orange 2 3 1 6 1 dominant (3/6) Parkes 1 3 0 4 No change Port Hedland 1 2 0 3 No change Port Lincoln 1 2 0 3 No change Queenstown 1 3 0 4 No change Riverland 1 2 0 3 No change Rockhampton 2 3 2 7 Competitive 2 Radio-TV-Press combinations possible Roma 1 3 1 5 1 dominant (2/5) Sale 1 3 0 4 No change Scottsdale 1 3 0 4 No change Shepparton 2 3 1 6 1 dominant (3/6) Spencer Gulf North 1 4 0 5 1 dominant (2/5) Swan Hill 1 3 0 4 No change Tamworth 1 3 1 5 1 dominant (2/5) Taree 1 3 0 4 No change Toowoomba/Warwick 2 3 2 7 Competitive 2 Radio-TV-Press combinations possible Townsville 2 3 1 6 1 dominant (3/6) Wagga Wagga 1 3 1 5 1 dominant (2/5) Wangaratta 1 3 0 4 No change Warragul 1 3 0 4 No change Warrnambool 1 3 1 5 1 dominant (2/5) Western Subs Sydney 1 3 2 6 1 dominant (3/6) Wollongong 2 3 1 6 1 dominant (3/6) Young 1 3 0 4 No change