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Town 102 Format Change Request

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Town 102 Format Change Request Analogue Commercial Radio Licence: Format Change Request Form Date of request: 25 April 2017 Station Name: Town 102 Licensed area and licence Ipswich number: AL000308BA/2 Licensee: Celador Radio Broadcasting Ltd Contact name: Paul Smith Details of requested change(s) to Format Character of Service Existing Character of Service: Complete this section if you are requesting a change to this part of your Format Proposed new Character of Service: Programme sharing and/or Current arrangements: co-location arrangements Town FM AL308-1 to share all programming Complete this section if with Dream 100 AL054-3, and the new service you are requesting a will remain located at the Town 102 office at change to this part of your Great Blakenham near Ipswich IP6 0LW where Format all programming is made. Proposed new arrangements: Town FM may share all programming with 99.9 Radio Norwich, North Norfolk Radio, The Beach or Dream 100, with the service originating from Radio Norwich. Locally-made hours and/or Current obligations: local news bulletins Locally made hours: Complete this section if At least 10 hours a day during daytime you are requesting a weekdays (must include Breakfast). change to this part of your At least 4 hours daytime Saturdays and Format Sundays. Local news bulletins: Hourly at peaktime weekdays and weekends. Outside peak, UK-wide, national and international news should feature. Proposed new obligations: Locally made hours: At least 7 hours a day during daytime weekdays (must include Breakfast). At least 4 hours daytime Saturdays and Sundays. Local news bulletins: At least hourly during weekday daytime and at peaktime weekends. UK-wide, national and international news should feature at other times. The holder of an analogue local commercial radio licence may apply to Ofcom to have the station’s Format amended. Any application should be made using the layout shown on this form, and should be in accordance with Ofcom’s published procedures for Format changes (available on our website at http://stakeholders.ofcom.org.uk/broadcasting/radio/formats-content/changes/ ) Under section 106(1A) of the Broadcasting Act 1990 (as amended), Ofcom may consent to a change of a Format only if it is satisfied that at least one of the following five statutory criteria is satisfied: (a) that the departure would not substantially alter the character of the service; (b) that the departure would not narrow the range of programmes available by way of relevant independent radio services to persons living the area or locality for which the service is licensed to be provided; (c) that the departure would be conducive to the maintenance or promotion of fair and effective competition (d) that there is evidence that, amongst persons living in that area or locality, there is a significant demand for, or significant support for, the change that would result from the departure; or (e) that (i) the departure would result from programmes included in the licensed service ceasing to be made at premises in the area or locality for which the service is provided, but (ii) those programmes would continue to be made wholly or partly at premises within the approved area (as defined in section 314 of the Communications Act 2003 (local content and character of services)). Only one of these five criteria need be satisfied in order for Ofcom to consent to the proposed change. However, even if Ofcom is of the opinion that the proposed change satisfies one or more of the statutory criteria, there may be reasons (depending on the particular circumstances of the case) why Ofcom may not consent to the proposed change. The additional criteria to which Ofcom will have regard when exercising this discretion can be found at: http://stakeholders.ofcom.org.uk/broadcasting/radio/formats-content/changes/ ) Applicants should note that, under section 106ZA of the same Act (as amended), a proposed change that does not satisfy the first or last of these criteria (i.e. a change that Ofcom considers would or could substantially alter the character of the service, or does not relate to the origin of locally-made programmes) must, if it is to be considered further under any of the other three criteria, be consulted upon. #. In the event that Ofcom receives a request for Format change and considers that criterion (a) or (e) is not satisfied, it will seek confirmation from the applicant as to whether it wishes to proceed with the request (and, if so, whether it wishes to amend or replace its submission in light of the necessity to make it public). Please set out the statutory criterion, or criteria, set out in section 106(1A) of the Broadcasting Act 1990 that you believe is/are satisfied in relation to this Format change request, and the reasons for this: (a) Our proposal would not in any way alter the character of the service. Town 102 would remain “a locally-oriented broad music, news and information service for listeners, particularly those aged 25+, in Ipswich, with a strong commitment to local issues.” In particular, the station will benefit from the same commitment to local news and information that all Celador stations carry. Local news bulletins, produced specifically for Ipswich, will run 0600- 1900 weekdays and 0800-1300 weekends, with local headlines on the half- hour during weekday breakfast. Additionally, split links specifically for Town 102 will include other local information, including weather, travel, sports news and what’s ons. While we intend to locate our regional broadcast centre in Norwich, we will continue to maintain a local sales office and news broadcast studio in or around Ipswich, to cover the southern part of the region. The two journalists here will provide easy access to local events and newsmakers in Suffolk and north Essex, as well as ensuring that, at all times, there is a journalist no more than one hour’s drive from any part of the region to provide emergency coverage of a major event or breaking news story. Given our commitment to providing an enhanced local news service, we are also requesting that the hours of locally-produced programming (defined as coming from the regional broadcast centre in Norwich) be reduced from 10 to 7, in line with Ofcom’s published policy in its Localness Guidelines issued in September 2010. (b) Since the character of the service will remain unchanged, the range of programme services available from local independent radio in Ipswich will also remain unchanged. In both its music and speech content, as well as its commitment to localness for Ipswich, Town 102 will remain clearly distinct from its competitors. (c) As we detail below, the principal reason for this request is to protect the financial viability of Town 102 for the remainder of its licence term and beyond. Currently, the commercial radio market in Ipswich is dominated, in terms of both audience and local revenue, by Heart. Town cannot compete effectively while it remains financially insecure and lacks the resources to maintain a high quality service, let alone market itself and build its audience. The cost savings that will result from co-location and programme sharing with Norwich will ensure the long-term sustainability of the service, and thereby promote more effective competition in the provision of local commercial radio in the area. (e) Ipswich is in the same ‘approved area’ as Norwich. Please provide any additional information and/or evidence in support of the proposed change(s) below. In particular, the applicant may wish to outline how they see that the proposed change fits within Ofcom’s published Format change request policy and also Ofcom’s Localness guidance, which includes our co-location and programme sharing policy. This request is being made in conjunction with an equivalent request for Dream 100 in Tendring. Town and Dream are currently permitted to be co-located and share their programming, following a change to the stations’ Formats requested by Anglian Radio’s previous owners and approved by Ofcom in November 2016. At the same time, Ofcom approved a request from Anglian for its other three stations in the East Anglia ‘approved area’ – Radio Norwich, North Norfolk Radio and The Beach – to co-locate and programme-share from Norwich. Celador Radio acquired Anglian Radio in January 2017. The Anglian group was running at a significant operating loss, and building up substantial debt as a consequence. Our outline analysis (which is attached, in confidence, with this request) suggests that, if no measures are taken to reduce costs, the Anglian group would be burdened with an overdraft of about £1.2m by April 2018, in addition to a debt to Celador of £1.4m. Anglian had already defaulted on this latter debt, so interest on it of 4% is now being charged. There is currently no schedule of repayments for any of Anglian’s debts because the group’s cashflow could not sustain such a strategy. Substantial cost-saving measures are required to re-establish the financial viability of the Anglian stations, allow for investment in marketing and programming quality and service the company’s significant debts. By consolidating the five stations into a single regional broadcast centre, we have identified savings of some £300k pa in overheads, plus an additional £89k in capital expenditure. We are optimistic that these savings would allow the Anglian group to achieve operating profit by 2020. These are small radio stations. Town 102 has an MCA of 155,000 adults, well under the 250,000 mark below which Ofcom has determined that there is a stronger case for co-location and programme sharing. We believe that Norwich, rather than Ipswich, is the more appropriate location for an East Anglian regional broadcast centre.
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