Australian Associated Press Submission to the Senate Inquiry on the Treasury Laws Amendment (News Media and Digital Platforms Mandatory Bargaining Code) Bill 2020

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AUSTRALIAN ASSOCIATED PRESS SUBMISSION TO THE SENATE INQUIRY ON THE TREASURY LAWS AMENDMENT (NEWS MEDIA AND DIGITAL PLATFORMS MANDATORY BARGAINING CODE) BILL 2020

Australian Associated Press (AAP) thanks the Senate for an opportunity to comment on the Treasury Laws Amendment (News Media and Digital Platforms Mandatory Bargaining Code) Bill 2020 (the Bill).

The Treasurer has stated that “[t]he News Media and Digital Platforms Mandatory Bargaining Code is a world-leading initiative. It is designed to level the playing field and to ensure a sustainable and viable Australian media landscape. It's a key part of the government's strategy to ensure that the Australian economy is able to take full advantage of the benefits of digital technology, supported by appropriate regulation to protect key elements of Australian society. One such key element is a strong and sustainable Australian news media landscape.”1

AAP supports the Bill in its current form as it assists ‘retail’ media, that is, news media who have a direct-to-consumer “News Source” (as defined in the Bill), at a time when the industry is in a state of deep and prolonged crisis.

However whilst the Bill helps AAP’s retail media customers, it does not contemplate a critical pillar of competition and media diversity in the news media industry in Australia - namely wholesale providers of news. One of the most important wholesale suppliers of news content in nearly every country is the national newswire. In Australia, this independent wholesale newswire service is fulfilled by AAP, which has been covering the news continuously for over 85 years. It is critical for diversity and competition that Australia’s media continue to have access to a strong and sustainable wholesale news source.

To be clear, AAP is not covered by the Code and will receive no direct benefit from its passage. While AAP supports the passage of the Bill, it will receive no support from the Code and, as such, it will need support from additional government policies designed to augment the Code in pursuit of the broader objectives outlined by the Treasurer and the Chair of the ACCC. In particular, AAP agrees 2 with Rod Sims’ statement that there is a “compelling” case for Government funding for AAP .

A strong and sustainable wholesale news supply chain is especially important for small to medium outlets who rely heavily on being able to source their news as part of a cost-efficient, pooled arrangement. For many of AAP’s customers, the cost of covering all the news from across the nation through with their own internal resources would be prohibitive. Without AAP, these customers would not be able to source high quality independent coverage and new entrants, like The Guardian, would find it difficult to enter the Australian market. The ability of all Australian media to access a strong wholesale news source has to be protected to facilitate competition and allow for a range of diverse voices.

1 Treasury Laws Amendment (News Media and Digital Platforms Mandatory Bargaining Code) Bill 2020, Minister’s Second Reading, 8 December 2020 2 https://7news.com.au/business/media/compelling-case-for-aap-fed-funding-accc-c-1301456

AAP was facing closure in March 2020. It would have resulted in the loss of thousands of stories each year covering all aspects of Australian life. AAP has been saved by a small group of philanthropists and, as a result, is now a not-for-profit news organisation (with charitable status), owned by no-one, and dedicated entirely to covering news and sport around Australia and the globe. AAP is still what it always has been; independent, trusted, reliable and accurate.

AAP’s content is used by over 400 outlets across Australia. Its content is licensed by hundreds of websites across Australia, including half of the top news sites in the country. It is printed in major newspapers throughout metropolitan and regional areas, and is broadcast by radio networks across the country. AAP has a shared audience of millions who consume its news daily in various formats. Yet AAP will not receive any remuneration under the Bill for the significant cost of the creation of public interest news content. Whilst AAP’s news content surfaces on digital search engines and news aggregator sites, AAP does not itself operate a “news source” as that expression is defined in the Bill. The Bill is not structured to compensate wholesale news media.

In order to truly achieve the objective of the Bill - namely to “help support the sustainability of the 3 Australian news media sector” - the Government must urgently consider additional measures to assist the wholesale news industry such as the provision for an appropriate form of recurrent Government support for AAP.

What is a newswire

A newswire is essentially a wholesaler of fact-based news content (text and imagery). It reports on politics, business, courts, sport and other news and provides this to other print, broadcast, digital and niche media outlets. Often the newswire provides the only reporting on a subject and hence its decisions as to what to report play a very important role in informing Australians about matters of public interest. It is essential democratic infrastructure. A newswire often partners with other global agencies to bring international stories to a domestic audience and also to take local content to a global audience. Newswires have traditionally served as the backbone of the news supply of their respective countries. Due to their business model they contribute strongly to the diversity of media. Pricing is traditionally based on circulation figures. The bigger the circulation, the higher the price thus making the same newswire accessible for small media with less purchasing power as well as for large media conglomerates with strong financial resources.4 Almost every democratic country has an independent national newswire; Associated Press (AP) in the United States, to the Press Association in the United Kingdom to Agence France Presse in France. Newswires provide an essential service in the media landscape.

This co-operative business model has been practically accepted world-wide since the founding of AP in the USA in the mid-19th century. Newswire agencies are “among the oldest media institutions to survive the evolution of media production from the age of the telegraph to the age of platform technologies”.5 Sharing the costs of newsgathering was one of the key ideas behind news agencies.

A news agency would collect and edit news and then provide that content to its customers, who would 6 publish it to their own audience. Recently there have been examples of larger media conglomerates especially, leaving this model for competitive reasons. This weakens the newswire model by applying greater pricing pressure to smaller outlets who depend heavily on the wholesale supply of news.

3 Treasury Laws Amendment (News Media and Digital Platforms Mandatory Bargaining Code) Bill 2020, Explanatory Memorandum, General Outline and Financial Impact 4 Peter Kropsch, President and CEO of dpa Deutsche Presse-Agentur Group, Hamburg, Germany 5 “The Future of National News Agencies in Europe: Executive Summary”, London School of Economics and Political Science, 2019, 6 Ibid. Alongside the passage of the Bill, the Government must address the sustainability of the wholesale media market. Failing to do so could jeopardise one of the most important mechanisms for ensuring that Australia retains a plurality of voices - small and large - and for facilitating new media entrants.

The AAP Newswire

AAP has been an integral part of the Australian media landscape for 85 years, providing the foundation of news content for newspapers, radio news and talkback programs, television news and more recently the digital versions of all of the above, as well as new market entrants.

Around the clock, 365 days a year, AAP writes core news stories about areas of high public interest, including national and state-level politics and policy, court reporting and breaking news from across the country. AAP’s news comes in the form of words and images. Every day, AAP publishes over 220 stories and captures more than 400 images and supplies them to 400 plus media outlets across Australia, over 250 of which are in regional Australia. AAP’s news services are drawn from its own correspondents at home and abroad, as well as from some of the world’s leading news agencies. This ensures a breadth of coverage which would not otherwise be available in Australia.

Widely regarded as a last bastion of public information, AAP has built its reputation on providing untainted, reliable, insightful and well-crafted content including extensive coverage of, for example, courts and royal commissions. AAP also has a factcheck unit with a growing profile, due to its involvement in recent domestic and international political elections. The newswire has reporters based in every Australian state and territory, plus New Zealand, where AAP is the only Australian media organisation with a permanent presence. Of particular importance to subscribers is AAP’s ‘diary’, which shows upcoming major events, locations, AAP’s coverage plans and when the content will be published. This information is vital to small newsrooms where operators need to know as much detail as soon as possible so they can meet increasingly earlier deadlines.

AAP’s coverage A snapshot of AAP’s output from 4 August to 4 December shows the significant number of stories and images provided to AAP’s customers over a 4 month period.

AAP Content 4 August 2020 to 4 December 2020

AAP Produced Content 18,328 stories published in total 10,691 stories excluding updates

Total Story count 27,865 total stories (excluding advisories) 17,741 unique stories (excluding updates) These figures include partner content.

AAP Images 45,814

Partner Images 1,553,231

Downloads of Images from AAP Photos site 95,086

Despite the extraordinary amount of pure news content, AAP will not receive compensation under the Code. The unique position of the newswire as the trusted source of public interest journalism to over 400 media outlets across Australia must be addressed alongside the passage of the Bill.

Labor MPs hold up signs in support of Australian Associated Press (AAP) during House of Representatives Question Time at Parliament House in Canberra, Tuesday, March 3, 2020. (AAP Image/Lukas Coch)

Why is a sustainable independent newswire important to Australia?

For 85 years, AAP was owned by a consortia of media competitors. It was first established so that the country’s newspapers could share the high expense of bringing international news into Australia.

With no political axe to grind, nor advertisers to please, AAP was formed to supply news "without any tendency toward or opportunity for the exercise of political partisanship or bias" (AAP Articles, 1935). As Rupert Murdoch himself noted "[a]s an organisation that sits to one side in a fiercely competitive industry, it has a vital role in ensuring an accurate, independent and comprehensive coverage of the daily news events across the country, providing a wide choice of content for the media, no matter what they are or 7 what their market" .

A pooled newswire service reduces the cost of general news collection for media companies, public broadcasters and the public at large. AAP is a 24 hour, 365 day operation playing a critical role in reporting areas of high public interest including national and state-level politics and policy, court reporting and breaking news from across the country.

AAP also curates and contextualises world news feeds so that the stories being supplied to its customers are relevant to the Australian audience. One journalist or one photographer from AAP can, quite literally, provide reporting and images from courts, parliaments, press conferences and sporting events to over 400 outlets.

The ownership of the pooled newswire service matters. No private media company has ever before owned, or aspired to own, an Australian newswire service. The oversight of newswires must be objective and independent to ensure competition and ongoing media diversity.

The public policy case for supporting AAP alongside the passage of the Bill

In introducing the Bill to Parliament, the Treasurer has stated that “[p]ublic interest journalism plays an important role in our society. It is critical to the functioning of our democracy. This role can only be fulfilled by a strong, diverse and sustainable Australian news media sector.”8

The Bill will provide a lifeline to consumer-facing news media services. However the Bill does not support AAP. In the absence of being able to access “appropriate compensation for the production of original 9 news content” under the Bill, additional measures will be required to ensure AAP’s sustainability. For the stated objectives of the Bill in supporting the “sustainability of the Australian news media sector” to be achieved, AAP must receive a form of recurrent support alongside the Code.

The public policy case for supporting AAP, an independently owned pooled media wire service is, in the 10 words of Rod Sims, ACCC Chair, “compelling”. AAP’s importance to the media landscape in Australia was recently highlighted by Australia’s Minister for Communications, Paul Fletcher who said “AAP is critical to media diversity and has consistently demonstrated its commitment to accurate, fact based and independent journalism over its 85 year history, including a strong contribution to regional news”.

Despite this, AAP also receives one of the lowest amounts of recurrent government support for a national newswire anywhere in the world (see Attachment B).

As Peter Kropsch, the Chair of the European Association of Newswire Agencies and the CEO of Deutsche Presse-Agentur Group, the German newswire, stated: “The Australian government purchases AAP´s newswire for around AUD $175 total spend per annum (recurrent). Compared to the government businesses of other media owned and independent news agencies this is for sure one of the lowest contract volumes I have learned about yet”.

The importance of an independently owned newswire to Australia include:

7 On the Wire: The Story of Australian Associated Press, 2010 8 Treasury Laws Amendment (News Media and Digital Platforms Mandatory Bargaining Code) Bill 2020, Minister’s Second Reading, 8 December 2020 9 Id. 10 https://7news.com.au/business/media/compelling-case-for-aap-fed-funding-accc-c-1301456

1. Diversity of voices: AAP provides a unique, unbiased voice to hundreds of independent media operators and has a shared audience in excess of 15 million. AAP is critical to media diversity in Australia.

2. Price competition: As an independent newswire, AAP has a vested interest in growth and diversity of the Australian media landscape. It is in AAP’s interests to set a price that is affordable for its customers.

3. Product differentiation: Many of AAP’s customers would be reluctant to buy a newswire service from a competitor.

4. Facilitates new entrants: It is in AAP’s interests to facilitate new entrants to the media market. As Lenore Taylor, The Guardian Editor, recently stated “The Guardian wouldn’t have been possible without the AAP newswire”. As a wholesale supplier, newswires traditionally thrive in a growing and competitive news market. AAP is uniquely positioned to assist new entrants. The content creation and distribution costs are shared across multiple customers for the same core content. New market entrants present an opportunity for AAP to either increase its coverage (through increased revenue from new customers) or to reduce the cost of its service to all its customers (through the impact of aggregating the cost of the service across a higher number of customers). AAP is aware of significant community efforts to re-establish regional publications and broadcasters in ‘news deserts’, which are areas identified to be no longer serviced by a local newspaper. AAP is in discussion with many of these new regional publishing entrants and is the best positioned media organisation in Australia to be able to offer low cost service to enable them to launch in a cost-effective and sustainable manner.

5. Cost efficiency for current customers: The costs of news gathering are high - especially for courts, sports and politics. As a wholesale supplier of news, those costs are shared across multiple customers for the same core content. This is particularly important for AAP's regional customers who could not afford to establish and fund bureaus and reporters in major cities around Australia to cover the national news cycle.

6. Digital disruption: News Corp have made clear their intention to open a range of new regional mastheads. AAP currently provides content to the regional papers that News Corp’s new mastheads would compete with.

7. Reach: The cross media ownership regime in Australia never anticipated that a major retailer of print news would also become the wholesale provider of newswire services to hundreds of radio stations.

8. Training of future journalists for the industry: AAP’s cadet program has always been a highly-regarded scheme seen as an important training ground for the next generation of journalists. AAP’s program produces highly skilled journalists who will continue to cover courts, politics, economics and sports for decades to come. Former AAP cadets have gone on to assume senior roles across a number of media outlets. The continuation of AAP’s cadet program is particularly important to the national media sector, especially given recent news that the national broadcaster will not proceed with its cadet program this year.

It is hard to imagine a more efficient way to support media diversity in Australia than supporting the AAP newswire which in turn provides a vital service to hundreds of small and regional news outlets. AAP is essential democratic infrastructure.

The Bill helps the retail media market. Additional support is needed to ensure the viability of the supply of wholesale news content.

Risks to newswires

11 Concentration of media ownership is a significant problem for newswires globally . Large media companies and individuals increasingly own or hold controlling shares in a range of media such as newspapers, websites, television and radio. Concentration produces large, monopolistic organisations which have the resources and capacity to develop in-house operations that replicate news agency functions fundamentally reshaping the markets within which news agencies now operate. The viability of the national newswire is jeopardised which in turn impacts the remaining, often smaller, media outlets.

In a recent study by the London School of Economics, the researchers noted that “[o]ne issue for national news agencies is that they are frequently either taken for granted or the role they play in the news ecosystem is structurally concealed. Lack of awareness at various levels is therefore a key problem. Whilst public service broadcasting has received significant attention in terms of media scholarship and policy-making, news agencies (including national news agencies), have received relatively little attention. National news agencies can and should address the fact that they have not always been entirely successful in informing politicians, policymakers and the public about their importance. The work of compiling news information remains a resource-intensive but socially valuable endeavor. Innovative approaches are needed if national news agencies become unable to successfully perform this social function. If it is not national news agencies who do this work, who will it be?”

European Experience

The European Parliament recently acknowledged that ongoing investment of the publishing industry was essential to “ensure the sustainability of the publishing industry and thereby foster the availability of reliable information” (Recital 55 to the DSM Directive). The Publishers Right was designed to protect the publishers’ investment and facilitate licensing and enforcement against Digital Platforms. Most importantly, the Publishers Right benefits not just news publishers but also newswire agencies in EU member states.

Recital 55 expressly referred to news agencies noting that “…the concept of publisher of press publications should be understood as covering service providers, such as news publishers or news agencies, when they publish press publications within the meaning of this Directive.” The right is described as a “neighbouring right” or an “ancillary right” in respect of works by other rights holders (such as journalists) that are incorporated in press publications.

France implemented Article 15 via the Neighbouring Rights Act which took effect on 24 October 2019. This was the first implementation of a part of the Copyright Directive into a Member State’s national laws. The French law includes a new Chapter VIII titled “‘Press publishers’ and news agencies rights’. Article L.218-1.II defines a "news agency" as any company mentioned in Article 1 of Ordinance No. 45-2646 of 2 November 1945 regulating press agencies, whose main activity is the collection, processing and formatting, under its own responsibility, of journalistic contents”.

The express inclusion of news agencies (newswires) under Article 15 of the DSM Directive in the EU is clear evidence of their critical importance to the news landscape in Europe.

So too the viability of the national newswire in Australia must be of critical importance to the Australian Parliament.

AAP’s position

AAP supports the passage of Bill in its current form.

The Code will likely assist many consumer-facing media organisations across Australia and will undoubtedly assist larger media organisations like News and Nine.

11 Ibid The Bill does not support the market for the wholesale supply of news, represented importantly by AAP. If all the Australian Government does is pass the Bill, then it will not have achieved its goal of protecting media diversity in Australia.

Australia needs a strong and sustainable independent newswire to underpin media diversity. Without an independent national newswire, hundreds of news outlets will be deprived of a key source of their news content and the barriers of entry for new media organisations will be unscalable.

The Bill helps the retail news media industry in Australia but does not help wholesale suppliers of news. In order to ensure competition and diversity in the Australian media landscape, additional support is required to ensure that AAP, the country’s independent wholesale supplier of news to over 400 outlets, is strong and sustainable.

ATTACHMENT A

R=Regional, M=Metro, RP=Regional Presence

Australian Capital Territory

AAP news outlets in ACT Type Area

Valley FM 89.5 Radio RP

2 Double X Radio RP

1WAY FM Radio RP

The Canberra Times (Canberra) Print RP

New South Wales

AAP news outlets in NSW Type Area

Central Western Daily (Orange) Print and Digital RP

Daily Liberal (Dubbo) Print and Digital RP

Illawarra Mercury (Wollongong) Print and Digital RP

The Newcastle Herald (Newcastle) Print and Digital M

The Daily Advertiser (Wagga Wagga) Print and Digital RP

The Northern Daily Leader (Tamworth) Print and Digital RP

Western Advocate (Bathurst) Print and Digital RP

Braidwood Times Print and Digital R

Crookwell Gazette Print and Digital R Goulburn Post Print and Digital R

Highlands Post (Bowral) Print and Digital R

Southern Highland News (Bowral) Print and Digital R

The Chronicle (Canberra) Print and Digital RP

The Post Weekly (Goulburn) Print and Digital R

The Queanbeyan Age Print and Digital R

Yass Tribune Print and Digital R

Bay Post (Batemans Bay) and Moruya Examiner Print and Digital R

Bega District News Print and Digital R

Bombala Times Print and Digital R

Eurobodalla Shire Independent Print and Digital R

Kiama Independent Print and Digital RP

Magnet (Eden) Print and Digital R

Merimbula News Weekly Print and Digital R

Milton Ulladulla Times Print and Digital R

Narooma News Print and Digital R

Shoalhaven & Nowra News Print and Digital R

South Coast Register (Nowra) Print and Digital R

The Advertiser (incorporating Lake Times) Print and Digital R

Glen Innes Examiner Print and Digital R The Courier Print and Digital R

Moree Champion Print and Digital R

Namoi Valley Independent (Gunnedah) Print and Digital R

Tenterfield Star Print and Digital R

The Armidale Express Print and Digital R

Armidale Express Extra Print and Digital R

The Guyra Argus Print and Digital R

The Inverell Times Print and Digital R

The Tamworth Times (including The Tamworth Independent) Print and Digital R

Walcha News Print and Digital R

Dungog Chronicle Print and Digital R

Hunter Valley News Print and Digital R

Lakes Mail Print and Digital R

Maitland & Lower Hunter Star Print and Digital R

Muswellbrook Chronicle Print and Digital R

Newcastle & Lake Macquarie Star Print and Digital RP

Port Stephens Examiner Print and Digital RP

The Advertiser (Cessnock) Print and Digital R

Maitland Mercury Print and Digital R

The Scone Advocate Print and Digital R The Singleton Argus Print and Digital R

Camden Haven Courier Print and Digital R

Express (Port Macquarie) Print and Digital RP

Gloucester Advocate Print and Digital R

Great Lakes Advocate Print and Digital R

Guardian News (Nambucca) Print and Digital R

Habiscus Happynings Print and Digital R

Macleay Valley Happynings Print and Digital R

Manning Great Lakes Extra Print and Digital R

Manning River Times Print and Digital R

Mid-Coast Observer (Macksville) Print and Digital R

Port Macquarie News Print and Digital RP

The Bellingen Shire Courier-Sun Print and Digital R

The Macleay Argus Print and Digital R

Wauchope Gazette Print and Digital R

Wingham Chronicle Print and Digital R

Cootamundra Herald Print and Digital R

Eastern Riverina Chronicle Print and Digital R

Harden Murrumburrah Express Print and Digital R

Southern Cross (Junee) Print and Digital R The Area News (Griffith) Print and Digital R

The Irrigator (Leeton) Print and Digital R

The Leader (Wagga Wagga) Print and Digital R

Southern Riverina News (Finley) Print and Digital R

The Corowa Free Press Print and Digital R

Deniliquin Pastoral Times Print and Digital R

The Observer (Darlington Point / Coleambally) Print and Digital R

Blue Mountains Gazette Print and Digital R

Fairfield City Champion Print and Digital R

Hawkesbury Courier Print and Digital R

Hawkesbury Gazette Print and Digital R

Liverpool City Champion Print and Digital R

St George and Sutherland Shire Leader Print and Digital R

The Advertiser (Campbelltown/Camden-Narellan/Wollondilly) Print and Digital R

Blayney Chronicle Print and Digital R

Boorowa News Print and Digital R

Canowindra News Print and Digital R

Cowra Guardian Print and Digital R

Dubbo Mailbox Shopper Print and Digital R

Forbes Advocate Print and Digital R Lithgow Mercury Print and Digital R

Midstate Observer (Orange) Print and Digital R

Mudgee Guardian and Gulgong Advertiser Print R

Narromine News and Trangie Advocate Print R

Nyngan Observer Print R

Oberon Review Print R

Parkes Champion-Post Print R

The Grenfell Record and Bland Advertiser Print R

The Young Witness Print R

Wellington Times Print R

Western Times (Bathurst) Print R

Country Leader Print R

Hunter Valley and North Coast Town & Country Print R

North West Magazine Print R

The Rural Print R

The Border News Print R

Town and Country Magazine Print R

Western Magazine Print R

QBN FM Radio R

2AIR FM Radio R Armidale Community Radio - 2ARM FM92.1 Radio R

Bay & Basin 92.7FM Radio R

2BACR Radio R

2BBB FM Radio R

RBM FM - 89.1 Radio Blue Mountains Radio R

2BOB Radio Radio R

2CBD Radio R

Casino's Own Wireless Association Radio R

2DRY FM Radio R

Eurobodalla Radio 107.5 Radio R

EZY-FM 90.5 Radio R

Bucketts Radio Radio R

RAMFM 103.3 Radio R

Triple H 100.1 FM Radio R

KRR 98.7 Radio R

2MCE Radio R

2MNO Monaro FM Radio R

MTM FM 91.9 Radio R

River FM - 92.9 Radio R

Northside Radio Radio R Nambucca Valley Radio Radio R

2RDJ FM Radio R

2RRR Radio R

2SSR 99.7 FM Radio R

Three Rivers Radio - Dunedoo Radio R

TUNE! FM 106.9 Radio R

VOX FM Radio R

WAR FM Radio R

2WCR FM 99.5 Radio R

TANK FM Radio R

WOW FM 100.7 Radio R

Wilcannia River Radio Radio R

Yass FM Radio R

Radio NAG 91.3 FM Radio R

Binjang Community Radio Inc Radio R

UCFM Radio R

2YYY Young Radio R

KIIS 1065 Radio M

WS FM101.7 Radio M

The Edge 96.One Radio M La Fiamma Print and Digital RP

96.5 Wave FM Digital RP

Radio 2NM Digital R

Radio 2ST Digital R

Power FM Digital R

Radio 2GN Digital R

Radio 2EC Digital R

Eagle FM Digital R

Magic 100.3FM Radio R

Life FM Wagga Wagga Radio R

Living Sound Broadcasters Radio R

Rhema FM Central Coast Radio R

Rhema FM Dubbo Radio R

Rhema FM Manning Great Lakes Radio R

Rhema FM Mid North Coast NSW Radio R

Rhema FM Tamworth Radio R

Barrier Daily Truth Print R

Australian New Express Print RP

Newcastle University 2NURFM Radio M

Sydney Educational Broadcasting Radio M

Queensland and Northern Territory

AAP news outlets in QLD & NT Type Area

Beaudesert Times Print and Digital R

Goondiwindi Argus Print and Digital R

Jimboomba Times Print and Digital R

Redland City Bulletin Print and Digital R

The North West Star (Mount Isa) Print and Digital R

Queensland Country Life Print and Digital R

North Queensland Register Print and Digital R

My Weekly Preview Print RP

Coral Coast Community Radio 94.7 FM Radio R

Burnett River Radio Radio R

Cairns FM 89.1 Radio RP

102.7FM Radio RP

Western Downs Region Radio Radio R

Noosa Community Radio 101.3 FM Radio RP

101.5FM Moreton Bay's Own Radio R

Radio 4RPH Radio M

Encore FM 96.3 Radio RP Gin Gin's Own 104.9FM Radio R

Radio 4YOU Radio R

97.3FM Radio M

4KQ 693 Radio M

InQLD Digital RP kixcountry.com.au Digital R

River94.9 FM Digital RP

Hot 91.1FM Digital R

ZInc96.1FM Digital R

Hot Tomato102.9FM Digital RP

Hitz93.9 FM Digital R

Radio 4BU Digital R

Radio 4CC Digital R

Radio 4RO Digital R

Classic Hits 4MK Digital RP

Star 101.9 Digital RP

Star1063 Digital RP

Classic Hits 4CA Digital RP

Star 102.7 Digital RP

Coastal Broadcasters Pty Ltd (Kik FM) Digital RP Cooloola Christian Broadcasters Radio RP

Live FM Radio RP

Rhema FM Gladstone Radio R

Rhema FM Wide Bay Radio R

Brisbane Indigenous Media Association 98.9FM Radio M

The Katherine Times (NT) Print R

8CCC FM Community Radio 102.1FM (NT) Radio R

Hot 100 FM (NT) Digital R

Mix 104.9FM (NT) Digital R

Rhema FM Darwin (NT) Radio RP

South Australia

AAP news outlets in SA Type Area

Barossa and Light Herald Print and Digital R

Border Chronicle Print and Digital R

Coastal Leader Print and Digital R

Eyre Peninsula Tribune Print and Digital R

Northern Argus Print and Digital R

The Times (Victor Harbor) Print and Digital R

On the Coast Print and Digital R Port Lincoln Times Print and Digital R

The Flinders News Print and Digital R

The Islander (Kangaroo Island) Print and Digital R

The Murray Valley Standard Print and Digital R

The Naracoorte Herald Print and Digital R

The Recorder Print and Digital R

The Transcontinental (Port Augusta) Print and Digital R

West Coast Sentinel Print and Digital R

Whyalla News Print and Digital R

90.1 Happy FM Radio R

5GTR Radio R

5THE FM Radio R

Mix 102.3 Radio R

Cruise 1323 Radio R

InDaily Digital RP

Magic 89.9FM Digital RP

Radio 5MU Digital RP

Radio 5CC Digital R

Radio 5CS Digital R

Radio 5RM Digital R Radio 5AU Digital R

Magic 105.9 Digital R

Magic 93.1FM Digital R

Flow FM Radio R

Radio Adelaide Radio M

Tasmania

AAP news outlets in Tasmania Type Area

The Advocate (Burnie) Print and Digital RP

The Examiner (Launceston) Print and Digital RP

City Park Radio 103.7 Radio RP

97.1FM The Voice of the Midlands Radio RP

TYGA FM Radio RP

Gove FM Radio RP

CAAMA Radio Radio RP

PAW Radio Radio RP

101.7 7HOFM Digital RP

LAFM.com.au Digital RP chillifm.com.au Digital RP

7AD FM Digital RP 107.7SeaFM Digital RP

7BU Digital RP

101.7 SeaFM Digital RP

7SD Digital RP

7XS Digital RP

WAY FM Radio RP

Victoria

AAP news outlets in VIC Type Area

3BBR-FM Radio R

Radio Eastern FM 98.1 Radio R

Life FM Gippsland Radio R

Gippsland FM Radio R

3HCR - High Country Radio Radio R

Triple H 96.5 FM Radio R

HOT FM Radio R

96.5 Inner FM Radio R

3MGB Radio R

OCR FM Radio R

Phoenix FM Radio R 94.7 The Pulse Radio RP

REG-FM Radio R

RPP FM Radio R

Smart FM 99.1 Radio R

UGFM - Radio Murrindindi Radio R

Alpine Radio Radio R

OAK FM Radio R

KIIS 101.1 Radio M

Gold 104.3 Radio M

Il Globo Print and Digital RP

95.5 KROCK Digital RP

Bay939 Digital RP

Radio 3BA Digital R

Gold Central Victoria Digital R

River1467 Digital R

Life FM Bendigo Radio RP

Rhema FM Geelong Radio RP

Rhema FM Orange Radio RP

Shepparton News Print and Digital R

Melbourne Chinese Post Print and Digital RP JOY FM Radio M

Pacific Star Network Limited Radio M

Bendigo Advertiser (Bendigo) Print RP

The Border Mail (Albury/Wodonga) Print RP

The Courier (Ballarat) Print RP

The Standard (Warrnambool) Print R

Latrobe Valley Express Print R

The Advocate (Daylesford) Print R

The Ararat Advertiser Print R

The Moyne Gazette Print R

The Stawell Times-News Print R

The Wimmera Mail-Times Print R

Sunraysia Daily Print R

Swan Hill Guardian Print R

Gannawarra Times Print R

Sunraysia Life Print R

Surf Coast Times Print and Digital R

Geelong Times Print and Digital RP

Bellarine Times Print and Digital RP

Armstrong Creek Times Print and Digital RP Golden Plains Times Print and Digital RP

Ballarat Times Print and Digital RP

Wangaratta Chronicle Print RP

1116 SEN Radio M

1377 SEN+ Radio M

SEN 2 and 3 Digital Radio Radio M

Golden Days Radio Radio M

Western Australia

AAP news outlets in WA Type Area

Augusta Margaret River Mail Print and Digital R

Bunbury Mail Print and Digital R

Busselton-Dunsborough Mail Print and Digital R

Collie Mail Print and Digital R

Donnybrook-Bridgetown-Manjimup Mail Print and Digital R

Mandurah Mail Print and Digital R

The Avon Valley and Wheatbelt Advocate Print and Digital R

The Esperance Express Print and Digital R

Albany Community Radio Radio R

Capital Community Radio 101.7FM Radio RP Collie Community Radio Radio R

96FM Radio M

The West Australian Print and Digital M thewest.com.au Digital RP perthnow.com.au Digital RP