Submission to

BBC Trust

Service Review of Network Music Radio (Radio 1, Radio 2, Radio 3, 6 Music, 1Xtra, Asian Network)

from

November 2014

INTRODUCTION

This paper should be seen in conjunction with a submission to the BBC Trust from Classic FM’s parent company Global and also from RadioCentre. It focuses on BBC Radio 3 and its exceptional role in broadcasting and commissioning classical music.

BBC Radio 3 holds a unique position in the British broadcasting landscape. Its strength in the past has been in its ability to use this unique position, with the safety net of generous public funding, to create bold, distinctive, brave programming, unfettered by the need to deliver audiences to advertisers. With a guaranteed income from the Licence Fee, BBC Radio 3 operates in common with other BBC services, without any fear of commercial failure.

The position of BBC Radio 3 in the marketplace means that the BBC occupies a potentially market-distorting role in terms of the commissioning, broadcast and promotion of live classical music in the UK, either on radio or via digital online broadcasts.

SUMMARY

The BBC must have greater regard for the impact of BBC Radio 3 on the market place and on the classical music eco-system in the UK. In future, the BBC should enforce far tighter content requirements on publicly subsidised services such as BBC Radio 3, with far greater regard to the overall competitive broadcast marketplace when programming changes are made.

Alone among any BBC radio or television service, it can be argued that BBC Radio 3’s uniquely guaranteed funding, along with the concentration of power in the hands of the station’s Controller, is unprecedented in any other area of broadcasting or the arts in the UK. Not only is this role editorially and financially responsible for the radio network, but the holder of the post is also the largest commissioner of classical music in the UK, controls the UK’s biggest live classical music festival (The BBC Proms) and is responsible for the five BBC Orchestras and the BBC Singers.

We hope that, with the benefit of hindsight, the BBC Trust will recognise and acknowledge the detrimental effect of its last service review of BBC Radio 3 on the UK’s classical music broadcast landscape and that it will give serious consideration to ensuring that this current review rights those wrongs.

Given the amount of public money available to BBC Radio 3’s management, it is imperative that this funding is invested to augment and widen the artistic depth and breadth of classical music broadcasting in the UK, rather than in replicating the service already provided by Classic FM, the BBC’s only commercial competitor in this area.

We would also welcome a new funding mechanism, which allows a far wider dissemination of classical music content from orchestras funded by the Arts Council. This could be through a public service fund, provided by a proportion of the licence fee, which allows commercial services to broadcast cultural events (such as live classical music concerts). This mechanism would ensure that these events reach a far wider audience, thereby making the ratio of public subsidy to audience reached far more economically justifiable.

Finally, any incursions into digital delivery of classical music by the BBC – either via Radio 3 or through other means should be closely monitored and controlled. At present, these appear to be unfettered.

PROGRAMMING CHANGES

This submission summarises the effect of recent programme changes at BBC Radio 3. It will argue that although each of these changes may on its own be regarded as being relatively minor, when taken cumulatively over a sustained period, they have profoundly affected both the character and the content of BBC Radio 3’s service. In the process, this has resulted in a significant change to the classical music radio landscape in the UK, with the serious erosion of listener choice in key dayparts being the principal outcome.

According to BBC Radio 3’s latest Service Licence, issued by the BBC Trust in April 2014:

“The remit of Radio 3 is to offer a mix of music and cultural programming in order to engage and entertain its audience… Radio 3’s programmes should exhibit some or all of the following characteristics: high quality, original, challenging, innovative and engaging, and it should nurture UK talent… The service should aim to educate audiences about music, broadcasting a wide range of programmes that expose listeners to new and sometimes challenging material they may not otherwise experience.”

The past few years have seen a series of major programming changes to the style and content of BBC Radio 3’s output. These changes have not been introduced all at once in one bold move. Rather, it is apparent that there has been a creeping popularisation of BBC Radio 3’s output over the past few years, with the effect that the clear gap between it and Classic FM has been gradually eroded, with the BBC station moving inexorably towards the position which has traditionally been occupied by its commercial competitor.

These changes have included (but are not limited to):

• An increase in the number of shorter works or extracts of works during the peak breakfast and drive periods, with a reduction in the number of multi- movement pieces being played in full. This change took place during the latter period of the life of the Morning on Three programme and was completed with the launch of the new Breakfast programme between 06:30 and 09:00 from September 2011. This new programme follows a format, which is extremely close to that of Classic FM.

• A new focus on ‘lighter’ repertoire, including increased airplay for film soundtracks within stripped sequence programmes (these are programmes where a series of CD recordings are played one after another with short excerpts of speech in between each track). This is evident in the playlists for the new Breakfast programme, which launched in September 2011.

• Far greater interaction from listeners, including requests, dedications and on- air telephone calls. The listener interaction, which has been a hallmark of Classic FM’s programming for many years, was distinctively absent from BBC Radio 3’s output, but it has now become a mainstay of the new Breakfast programme, with on air telephone calls from listeners also being introduced towards the end of 2011. This again follows a format which has formed a major part of Classic FM’s output since as long ago as 1997.

• The introduction of features and special programming pioneered by Classic FM in the area of classical music radio. These include:

• A ‘CD of the Week’ on the new Essential Classics morning programme (launched in September 2011). This has been an established feature on Classic FM’s morning programme since the station’s launch in 1992.

• The introduction of a weekly album sales chart by BBC Radio 3 at the beginning of 2010. Classic FM pioneered a classical album sales chart when it launched in 1992. This format has now been copied by BBC Radio 3.

• The introduction of listener voted polls to BBC Radio 3 (e.g. The Nation’s Favourite Aria in 2011). Again, this has been a format, which has been a central part of Classic FM’s output, with the annual Classic FM Hall of Fame poll running since 1996.

• The introduction of daily interactive Listener Request programmes (eg during The Genius of Mozart season at the beginning of 2011).

• The introduction of a new film music programme on Saturday afternoons at 4pm in September 2013 – just one hour before Classic FM broadcasts its own longstanding two-hour film music programme at 5pm.

• A reduction in specialist jazz programmes during daytime hours, with jazz and world music being marginalised to late night slots. This is particularly marked in the case of jazz, which had five specialist programmes across the week, including one on a weekday afternoon. With the exception of two hours on a Saturday afternoon, jazz has now completely been relegated to a late night off-peak slot.

• The ending of dedicated daily children’s classical music programming.

• The Saturday afternoon World Routes programme – a unique proposition in UK radio, featuring music from around the world, was abandoned altogether in September 2013.

• Radio 3’s commitment to a specialist Early Music programme was halved in September 2013.

• The extension of classical music concert programming between 9pm and 10pm, with a consequent removal of speech-based programming from this hour. (This is a time when Classic FM has consistently broadcast long-form full works content, so in effect, BBC Radio 3 has moved to offer the same style of programming as Classic FM at this time, thereby reducing listener choice).

• Radio 3’s Sunday night drama output was moved into a late night slot in September 2013, to be replaced by classical music content – once again directly reducing listener choice.

THE EFFECT OF THE LAST BBC TRUST SERVICE REVIEW

The BBC Trust’s last review of BBC Radio 3’s output appeared to give the BBC Management carte blanche to make significant changes to the network’s on air programming, the net effect of which has been to directly reduce programming choice for listeners to classical music radio in the UK. We appreciate that it may well not have been the intention of the BBC Trust for this to happen – but there is little doubt that BBC Management chose to interpret the BBC Trust’s words in a way that enabled them to use their Licence Fee funding to directly move Radio 3’s output closer towards that of Classic FM.

In its Service Review of BBC Radio 3, published in April 2011, the BBC Trust said:

“We are aware that there are ways in which Radio 3 could more actively target new listeners. In particular, it could pursue a far more populist approach by abandoning its commitment to a wide range of challenging music, or by playing much shorter excerpts of orchestral pieces. However, such an approach would significantly jeopardise and damage those elements that make Radio 3 distinctive and highly valued. Such a strategy would not be welcomed by either audiences or industry.”

Although it is clear to those intimately involved in classical music broadcasting that the character and content of BBC Radio 3’s output had in fact been creeping towards that of Classic FM for a number of years, the wider listening public and cultural commentators also began to notice the changes that came about following the publication of the BBC Trust’s last review of Radio 3.

The Voice of the Listener and Viewer said:

“We consider that Radio 3 needs to be highly distinctive in comparison with Classic FM. At present the morning drive time is often indistinguishable from the commercial station. The BBC should originate not copy.”

Nicholas de Jongh wrote in The Independent under the headline Radio 3 – Low-brow, lightweight and losing its way?:

“These days Radio 3 sometimes sounds as if intent on transforming itself into a superior version of Classic FM. The wretchedly low-brow three hours’ a night of listeners’ requests during The Genius of Mozart festival sounds for the first time as if the station were seriously dress-rehearsing to slip down-market.”

Sarah Spilsbury from the listeners’ group Friends of Radio 3 wrote in The Guardian shortly after the BBC Trust conducted its last review of the Radio 3 service:

“The BBC Trust agreed in February that Radio 3 must redouble its efforts to reach a “broader audience”. Indeed, for their recent report on the station’s performance, they sought the views of the broader public – most of whom do not listen to the station. Having ascertained that the non-listeners find Radio 3 ‘slightly daunting at times’, Mr Wright has imported all the tricks of popular, downmarket broadcasting to help win over a new audience…

Perhaps it will attract Classic FM listeners. But should the BBC be using public funds to provide a competitive alternative to a commercial station which has already staked out the territory as its own? Classic FM needs those listeners to survive; the BBC does not.

In order to be less “intimidating”, Radio 3 has lowered its intellectual standards. Instead of critical insights, the guests, listeners, presenters, even performers, are encouraged to share personal feelings, memories and tastes. Musical analysis has been reduced to the occasional concert interval talk, the same truncated morsels of longer works are played and replayed.”

And the Daily Telegraph reported that:

“Radio 3 is facing a growing backlash from listeners fed up with hearing the same pieces played repeatedly alongside an abundance of excerpts rather than entire works. Ardent classical music fans are becoming increasingly frustrated with the station’s attempts to appeal to the mass market by diluting its content. Online message boards and forums have been buzzing with disquiet from listeners unimpressed with the steady influx of celebrity presenters, the regular phone-ins and audience participation.”

Six months after publication of the BBC Trust’s 2011 Service Review, Michael White wrote in the Daily Telegraph under the headline “Radio 3 is getting out of tune with its audience”:

“In its search for that “wider public”, Radio 3 is edging ever closer to the comfortable banality of Classic FM. It uses celebrity presenters. It replaces informed discussion with vacuous blather. It fills vast tracts of airtime with disc- jockey formats. It slips into Classic FM’s (commercially successful) routine of selling art as relaxation – as if Bach, Brahms and the other towering giants of music churned out all those notes for tired executives to sleep through. Needless to say, no one at Radio 3 would admit this. For them, Classic FM is the elephant in the room, its existence barely acknowledged, its influence denied. Roger Wright, the station’s controller, will emphatically tell you that there’s no competition between the two, and no pressure for him to follow Classic’s lead. The truth is otherwise. Classic FM pulls an audience of around 5.7 million, while Radio 3 only manages 2.2 million. And that means pressure – which Wright has never resisted with the vigour that certain of his predecessors (especially John Drummond) managed.”

A month later, the Daily Telegraph radio critic Gillian Reynolds noted that:

“[Roger] Wright can plead he is obeying orders from the BBC Trust to reach new audiences by making Radio 3 less formal.”

While the Daily Mail reported that Breakfast on Radio 3…

“…has become Radio 2.5,’ say listeners who accuse BBC of cultural vandalism… Many called for a return to ‘pure and simple good music’, while others criticised the station’s creep into commercial territory saying the breakfast show sounded increasingly like rival network Classic FM.”

Two years later, the critics were still pointing out the changes in BBC Radio 3’s output, with Nicholas Lezard writing in the New Statesman in September 2013 about:

“The sad decline of Radio 3 into Classic FM without adverts”.

In October 2014, one correspondent wrote to the Daily Telegraph to say:

“I am a former Radio 3 listener. This is what I want as I wake up: a posh girl or boy introducing classical music. Some time later, the exercise is repeated. That’s it. What I don’t want is the news every 15 minutes, members of the public droning down the phone, the BBC advertising itself, the presenter telling me what I might hear 15 minutes hence and frequent encouragement to contact the programme by all possible methods.”

WHAT DO RADIO 3 LISTENERS SAY TODAY?

In October 2014, we commissioned BDRC Continental to conduct new research into the service provided by BBC Radio 3.

Key findings include:

• Only 18% of Radio 3 listeners think that the network is ‘innovative’.

• 43% of Radio 3 listeners believe that it plays ‘popular classics’, with 28% saying it plays music ‘from the classical charts’.

• More than a third (36%) of Radio 3 listeners think that it has become more populist recently and just under a third (31%) think that its personality is changing.

• Although listening to Radio 3’s breakfast show is relatively low, a third had noticed a change in style. Aspects such as ‘a more relaxed style’ and ‘more listener involvement’ were mentioned. When asked what they remembered from the Radio 3 breakfast show, 25% mentioned listener requests and 20% mentioned listener calls.

One respondent said of the BBC Radio 3 breakfast show:

“Now the early morning selection of music is more ‘accessible’ and less highbrow. Seems to be akin to Classic FM. Presenters are more informal in the way that they introduce musical items”.

While another said:

“It is being ‘dumbed down’, with presenters simply being silly – a very stupid ‘brainteaser’ is inflicted on us at 9.30am’.

• 86% of Radio 3 listeners believe that the Licence Fee funding of BBC Radio 3 should produce content that is distinctive from commercial radio and 56% of these respondents believe that the funding should be used to produce content that is even more distinctive than it is now.

• 32% want Radio 3 to broadcast more live opera, while 28% want it to commission more new music, 27% to broadcast more world music, 27% to broadcast more drama, 26% to broadcast more arts news and 25% to broadcast more jazz.

These are a selection of views of Radio 3 listeners about the station from the BDRC Continental research:

“If it doesn’t do anything different from Classic FM, what’s its point?”

“It seems that the things I dislike about Classic FM are being copied by the BBC. Phone-ins, record requests, gabbling presenters, guests on music programmes, which I find really annoying. BBC have lost their way, oh dear, I sound like Victor Meldrew! Oh yes, the competitions, what has happened to Essential Classics, completely ruined!”

“I used to turn to Radio 3 when I just wanted to listen to good classical music. Sadly this is no longer true.”

“I tend to confuse it in my mind with Classic FM.”

“A unique station which should not try too hard to be populist, ie, like Classic FM. Assume a certain degree of intelligence in your audience.”

“Can’t believe it costs ten times more to run a year than a commercial radio station. Absolutely shocking used of TV licence money.”

“Don’t dumb down any further. Talk to us as adult to adult.”

“Don’t have enough jazz… and I don’t mean Amy Winehouse… I mean proper jazz.”

“It is important that Radio 3 remains special, cutting-edge, and even high- brow. Please do not dumb it down.”

THE BBC TRUST’S RESPONSE TO RADIO 3’s CHANGES

The BBC Management’s decision to make these changes to Radio 3’s programming - and the BBC Trust’s decision to wave them through - has served to reduce the choice of listening available to audiences.

The BBC Trust’s Service Review of BBC Radio 3, published in February 2011, admits that:

“…over recent years, BBC management has made changes to Radio 3 in order to make the station more accessible and welcoming to potential listeners, particularly in peak-time slots (breakfast and drive) as these are the key entry points for potential listeners.”

However, we would argue that BBC Radio 3’s management has continued to plot a course firmly towards the programming style and content of Classic FM – a clear dilution of BBC Radio 3’s core public service output. Crucially, these changes erode the choice available to listeners. This view was echoed in submissions to the BBC Trust’s Service Review consultation by the Friends of Radio 3, by the Voice of the Listener and Viewer, and by the Incorporated Society of Musicians.

The BBC Trust acknowledged that:

“BBC management…has changed the nature of the programmes during these hours.”

Although, the BBC Trust then goes on to describe this as:

“Legitimate.”

We disagree. The cumulative effect of the alterations made to BBC Radio 3’s output, when taken collectively, constitute a significant change to the service. Under its own rules, the BBC Trust should have undertaken a Public Value Test, including a market impact assessment before allowing BBC Management to undertake such a radical overhaul of one of its national networks.

It is clear from the responses to BBC Radio 3’s programming outlined above (and there are many, many more similar – and some rather more trenchant – views in chatrooms online) that the listening public, critics and commentators have taken a very different view of these changes than that put forward by the BBC Trust.

Rather than pushing for BBC Radio 3 to maintain its distinctiveness, the BBC Trust’s last Service Review instead appears to have opened the door for Radio 3 to become more like Classic FM. It may not have been the intention of the BBC Trust for this to happen – but BBC Management have chosen to interpret the BBC Trust’s Service Review in this way. In a market of just two classical music radio stations in the UK, the BBC has significantly changed the output on Radio 3 in pursuit of audiences, rather than with the aim of offering distinctive and original programming content. This lessening of choice is particularly stark in the key morning dayparts, when listening to classical music on the radio reaches the largest number of people.

When it launched in 1992, Classic FM introduced a new way of broadcasting classical music on UK radio. It complemented the style and content of BBC Radio 3’s output at the time, providing a real point of difference. Given Classic FM’s success in building audiences for classical music radio, twenty years later, the BBC now appears to have decided to ape its commercial competitor, abandoning much of Radio 3’s distinctiveness in peak-time hours in the process.

No doubt, BBC Management will point to BBC Radio 3’s commitment to specialist off-peak programming, but so starkly changing BBC Radio 3’s programming to that of a ‘ratings by day, reputation by night’ strategy in a market place of just two, reduces choice when listeners are most likely to tune in and represents a potentially serious threat to the ability of Classic FM to operate as an effective commercial competitor. Classic FM is virtually unique in the classical music world in never having received a penny of public subsidy to fund its work; it also does not enjoy the certainty of a fixed income from the Licence Fee.

Not only did the BBC Trust fail to implement a Public Value Test into the BBC Management’s changes to Radio 3’s output, but it also failed to abide by its own ‘Competitive Impact Policy’, which requires the BBC ‘to minimise its negative competitive impacts on the wider market’.

The BBC Trust is obliged under the terms of the BBC Agreement with DCMS to undertake a Public Value Test before a decision is taken to make a significant change to a BBC service. Although this is a decision for the Trust, the BBC Agreement requires the Trust before exercising its judgement to ‘investigate or otherwise inform itself of any facts or considerations which it considers potentially relevant’.

It appears that no such investigation took place. RadioCentre requested further detail from the BBC on the proposed strategy to make Radio 3 more accessible and welcoming under the Freedom of Information Act 2000 (Letter, 24th February, 2011). In its response to the request, the BBC said:

“The BBC did not undertake a significance assessment of making Radio 3 more accessible and welcoming. This is because it is not a new proposal, but ‘business as usual’: BBC Management has been seeking for some time to make its content more accessible and welcoming, and will continue to strive to do so. As such, no significance assessment was required.”

This would suggest that the BBC Trust did not believe that a Public Value Test was appropriate because the changes made to BBC Radio 3 took place over a period of time, rather than at one single moment. However, the BBC Trust’s own protocols state that:

“A series of minor changes to a service licence may, cumulatively, require the Trust to consider whether a further regulatory approvals process, such as a Public Value Test, is required.”

Not only should a Public Value Test have been undertaken, but also in failing to undertake a ‘significance assessment’ at all, the BBC Trust did not abide by the terms of the BBC Agreement with DCMS.

BBC Radio 3, along with all BBC radio services, must have a tighter remit in future for which management are accountable. This new remit must reassert BBC Radio 3’s duty to play specialist music throughout the schedule and ensure that the station does not duplicate content available on commercial services.

A CHANGE OF BRAND POSITIONING

Classic FM’s pure classical music proposition has been hugely successful in building new audiences for the genre.

As the programming output of BBC Radio 3 continues to be allowed gradually to creep away from its responsibilities to non-classical music genres and peak-time broadcasting of speech-based arts programmes, the station now appears to be publicly acknowledging this move for the first time in its brand proposition.

During 2013, it has changed its brand strapline to ‘The Home of Classical Music’. Gone is any mention of other cultural or arts activities from its public-facing messaging. There could be no clearer admission of BBC Management’s strategy of competing head on with Classic FM.

This move in itself is worthy of investigation by the BBC Trust. Sadly, once again, the Trustees do not appear to be concerned about BBC Radio 3’s downgrading of the station’s responsibilities to support wider arts and cultural programming. It appears that BBC Radio 3 is being encouraged to use its public funding to chase ratings by broadcasting popular classical music, which is well served by a commercial competitor, at the expense of the promotion of other music genres, which are not well-served by the commercial radio sector.

A QUESTION OF COST

Yet further significant changes to BBC Radio 3’s programming output were discussed in the Delivering Quality First document, which was published by the BBC in October 2011.

These included:

• A reduction in lunchtime concerts

• Less specially recorded contemporary music

• A reduction in the amount of original drama on the station

Each of these changes resulted in additional dilution of the essence that makes BBC Radio 3’s output distinctive from that of Classic FM. These changes further compounded the radical nature of programming changes to the station.

Given these further changes to BBC Radio 3’s output and the public response to the changes, which have already taken place, it would have been an appropriate moment for the BBC Trust to follow the procedures which it itself put in place and to undertake a full Public Value Test at the earliest opportunity.

This particular round of programming changes was blamed on the need for the BBC to reduce costs. However, an analysis of the BBC’s annual report for 2013-14 suggests that BBC Radio 3 has an annual programme content budget of £40.8 million. It additionally spends £5.8 million on distribution, with a further £10.1 million spent on infrastructure and support. The BBC defines this latter figure as including: Property; HR; Policy and Strategy; Finance and Operations; and Marketing. It is important to note that these figures do not include the cost of newsgathering or of BBC Radio 3’s online digital services, which are accounted for separately. It is also unclear from the BBC’s published accounts where the costs of subsidy for the BBC Proms sit.

The BBC orchestras and performing groups receive total funding of £22.8 million per annum for content, with a further £5.1 million of infrastructure and support funding.

When added together, BBC Radio 3 and the BBC orchestras and performing groups spend £63.6 million on content, £5.8 million on distribution and £15.2 million on infrastructure and support – giving a grand total of £84.6 million of expenditure in the 2013-14 financial year.

This is a huge amount of money. BBC Radio 3 cited the need to cut costs as the reason for the reduction in its commitment to specialist music programming from September 2013. Given the scale of Licence Fee funding at BBC Radio 3’s disposal, it seems hard to reconcile the need for programme changes of this level with the relatively small amounts involved. It would suggest that there must be considerable inefficiencies in budgeting for this to make a material difference. We find it hard to believe that the stringent cost controls that would be in place in the commercial sector – out of commercial necessity - can possibly be being applied to a service that relies on a high level of guaranteed public subsidy via the Licence Fee.

It should also be noted that the live classical music market place already sees publicly funded orchestras in the geographic regions where the BBC funds additional orchestras. This is particularly the case in London, Manchester and Glasgow, where it could be argued that the Licence Fee duplicates provision already funded via Arts Council England and the Scottish Government.

THE CONCENTRATION OF POWER

Nowhere in the broadcasting or the arts world does so much power to spend such a large amount of public money rest in the hands of a single individual.

The Controller of Radio 3 is responsible for the UK’s biggest broadcaster of live classical music; the biggest commissioner of classical music; the UK’s biggest classical music festival (the BBC Proms); and responsibility for no fewer than five orchestras.

To concentrate so much power in the hands of one individual has the potential to create an abuse of this market dominant position. We remain concerned that this does not represent the best system for stewardship of a significant amount of licence fee money – and nor is it in the best interests of creating a plural and diverse classical music ecosystem in the UK.

Licence fee funding in this area should be open to competition to enable commercial operators to broadcast classical music concerts that are already funded or subsidised through Arts Council investment, perhaps through the creation of a ‘public service content publisher’ model, funded by a proportion of the licence fee.

Additionally, we are concerned that the creation in 2012 of The Space by the BBC and the Arts Council effectively creates a new publicly funded BBC service by the backdoor, without the usual checks and balances that are applied to the introduction of a new BBC channel. This introduces a new level of publicly subsidised competition to the classical music broadcasting marketplace that did not previously exist. Given the move towards wider digital distribution of radio services, a brand new online channel supported through Licence Fee funding should not be regarded in isolation, but should be seen as being a part of the overall media marketplace.

CONCLUSION

BBC Radio 3 offers a unique service, which adds enormous value on the occasions that it broadcasts content that is not provided by its commercial competitor. In these instances, it is a cultural gem which is rightly cherished – and which is deserving of its significant public funding.

However, there is clear evidence that programming changes to BBC Radio 3 cumulatively constitute a significant alteration to the station’s on-air output which is undermining listener choice and value for money for the licence fee payer.

This view is not only held by Classic FM and its parent company, Global. It has been commented upon widely in the press and both quantitative and qualitative independent research supports this assertion. Indeed, the view that BBC Radio 3’s output now apes that of Classic FM for much of the day has reached a crescendo.

We note that the incoming Controller of Radio 3 has suggested that he will return the station towards programming that has a clearer public service remit. In an interview with BBC Radio 4’s Today programme, Alan Davey said:

“I will be… doing what Radio 3 does best – offering complex culture, arts and ideas within the reach of lots of people. That’s what the original Third Programme did beautifully, but what the original Third Programme didn’t do was offer people context, was offer people a way of approaching the complex culture that’s offered.”

Asked if his arrival meant Radio 3 becoming more like Classic FM, he responded:

“It does not. If you look at what I’ve done at the Arts Council, it’s not been about dumbing down, it’s about wising up. It’s about putting on Stockhausen’s Mittwoch aus Licht in a way that’s intelligent and explains it, and that got a thrilled audience in Birmingham. If you do complex culture properly, it makes sense to people.”

We welcome these words. And we look forward to hearing them put into action on BBC Radio 3’s airwaves. Given this signal of a change in direction from BBC Management, it would now seem an opportune moment for the BBC Trust to ensure that they are enshrined in BBC Radio 3’s ongoing Service Licence, so that BBC Management can properly be held to account in the future.

Specifically, the new Service Licence should:

• Require BBC Radio 3 to broadcast the full range of the network’s music output, including jazz and world music, across weekday peaktime hours. These genres are currently under-represented on the network’s major daytime programme strands. For the avoidance of doubt, we would consider peaktime to be between the hours of 06:00 and 19:00.

• Require BBC Radio 3 to broadcast minimum amounts of jazz and world music within peaktime programme output, rather than allowing it to marginalised in off-peak programming after 22:00.

• Require BBC Radio 3 to broaden its coverage of speech-based arts, drama and religious programming within peaktime hours, rather than allowing it to be marginalised to off-peak programming after 22:00.

• As outlined above, BBC Radio 3 when coupled with the BBC Proms and the BBC Orchestras has the ability to distort the fragile ecology of the classical music marketplace. The BBC Trust should therefore require a full market impact test of any plans by BBC Radio 3 either to distribute classical music content digitally or to make it available as a permanent or semi-permanent online archive.

Failure to do so would allow BBC Management to continue to manoeuvre BBC Radio 3 away from its core remit, supported by the privilege of its generous public funding, further towards that of its commercial competitor. In future, station management must be held to account for a more detailed remit focused on delivering distinct public service content. To carry on as now would result in further erosion in listener choice and the UK’s broadcasting landscape would be the poorer for it.

Beyond 2016, a new set of public duties for the BBC and a new service licence for BBC Radio 3 must reverse and prevent further incursion of the service into territory currently occupied by the commercial radio sector

As it heads towards negotiating the BBC’s next Royal Charter, we will be calling on the Department for Culture, Media and Sport to examine ways in which these issues can be both monitored and controlled as any new funding agreement is negotiated. It is clear that the existing control mechanisms are both inadequate and open to abuse. In the meantime, we very much hope that the BBC Trust will itself act to put suitably robust measures in place.

November 2014