ILF’s Final Submission to the BBC Trust – 22nd May

NOTE – some of the evidence submissions referred to below are here

Thank you very much for meeting with the Independent Listeners Forum last week.

We are aware that you have many other parts of the Strategy that concern you, but, as representatives of listeners of the largest music digital-only radio station, we remain focussed on 6.

As agreed we’ve attached the Cool Brands Press Release and the Freedom of Information response that related to the issue of 4000 unique listeners.  Additionally, we’ve put together some new analysis around the value-for-money and commercial competition points,  bringing in last week’s RAJAR figures.

We have also done some other  new work for the value-for-money argument using historical (pre-Q1  2010 RAJARs) Cost Per Listener Hour figures, having been informed at  the meeting that this is the preferred measure.  You will probably be aware of the economic impact assessment on songwriters produced by the PRS, but we’ve included that as well.

Hopefully, the PR and FOI response are useful to you in terms of making your decision.  We recognise we’re biased, but in terms of wasting money on rebranding and being able to view the argument of unique listeners, we feel we are on reasonably steady ground.

Further media comment has made our arguments seem even stronger.  This from the Guardian: “With more than a million listeners now has half the audience of BBC Radio 3 on about a sixth of the budget. Director General Mark Thompson said 6 Music wasn’t value for money. It is now.” Evidence is attached.

We would also concur with the BPI that removing the station from the airwaves has a touch of cultural elitism about it. In case you never heard it, we have also attached the Guardian Media Talk mp3 from last week, which focussed on the RAJARs and Sony awards amongst other things.  Commentators described the decision to axe 6 Music as highly embarrassing and reflected our view that it would be appropriate for the Trust to ask the Executive to ‘think again’ – saying it would be kudos for the Trust to make this decision.  We’re sure you don’t need the Guardian’s advice, but it does echo what now seems to be pretty much accepted wisdom.

The other view was that should the station receive appropriate marketing, the figures could go up to 2 or 3 Million.  We’ve also been told that the RAJAR diaries don’t mention 6 Music specifically – if that is the case we feel the listenership is further underestimated in returns. The point is also made that, similar to the consultation response, the RAJAR figures in this quarter have been unprecedented where 6 Music and digital listening is concerned. The podcast also references Jarvis Cocker receiving his award and making the point that the commercial sector would simply not take up the slack should 6 go.  The fact that the RAJARs showed commercial stations had increased reach at the same time as 6 Music would seem to add to this strand of evidence.

On digital take up – they recognise that the rate of growth for digital listening is accelerating and that 6 Music is a major driver for this – their view is that use of DAB will ‘stall’ if 6 Music disappears.  This is thrown into even sharper focus when considering the BBC’s recent announcement (along with the commercial sector under the auspices of the Radio Council) to partake in the analogue radio scrappage scheme to increase digital take up.  It feels beyond irony that the most popular digital only music station should be under threat at this time. Despite this, Ford Ennals, chief executive of Digital Radio UK, criticised the BBC for not doing enough. “The BBC, as a clear leader in radio, can accelerate the movement of people to digital platforms by better communicating, better promoting, and having stronger content on their digital services.”  We think Mr Ennals previous comments on the Review are rather contradicted by this, but we’re pleased he has made the statement at this late stage.

We know that you were at the Ivor Novello Awards and that you will have heard the speech from Sarah Rodgers, who is yet another media insider to refer to the proposed closure as ‘an act of cultural vandalism.’  This put into words the arguments from PRS for Music.

Other evidence to reach us is outlined in the recent data from a GfK NOP Technology survey amongst a representative sample of UK residents with internet access. What emerged was a view on what the public feel the BBC should be delivering:  53% of adults agree that the BBC “has a duty to fulfil the needs of niche interest groups in the UK”, a figure which rises to 60% amongst 16 – 34 year olds. Furthermore, 64% agree that the BBC’s roster should be diverse enough to “satisfy all wider ranging interests, both mainstream and niche” (70% for 16 – 34 year olds.

On matters arising from the meeting:

At one point we discussed what might happen if The Trust asked the BBC to reconsider an aspect of the proposed strategy with a view to reversing the decision.  You mentioned we may be in uncharted territory if the BBC simply re-presented the proposal to close 6 Music.  Accordingly, we have taken soundings from management at the BBC and their view is clear.  If you state that the weight of evidence suggests that 6 Music should be retained with the adjustments to the service licence suggested in the February review, they would feel constitutionally bound to accept that position and go away to rethink other ways to meet your challenges.

Something we didn’t clarify on the day – you stated that the potential problem with the spike in listeners is that it may be reduced when the next RAJARs are announced.  We think this is unlikely given the announcement only came after 2 of the three months, the trend that was already underway in previous quarters and the fact that the Asian Network unfortunately did not see any increase. However, given that the Trust must respond to the Executive before the next quarter figures are released what assumptions are likely to be made on this?  Judging from the comments we are receiving, many of the new listeners are very pleased to have found the station.  We feel that the 20% awareness figure is now out of date and irrelevant.

On a technical matter – can you tell us if consultation responses made through 38degrees are getting through?  Also, we are aware that many people are making points as they think of them through the ‘srconsultation’ email address.  Are these being considered given that writers may have already tried to make a submission through the on line form? We mention this last point as we have had many reports of the form crashing as people near the end of the process.  Perhaps too late to do anything about it now, but we’d be reassured if you could let us know that the crashes do not permanently delete comments.

Finally, our recollection of the summary of the meeting is that we were making these key arguments amongst the many others:

• Radio 3 is the appropriate comparator for 6 Music from cultural value perspective
• The ILF is questioning the relevance of defining services on the basis of age
• The future of 6 Music is inexorably bound up with that of Digital Radio
• 6 Music has a disproportionately large economic impact (especially compared with that of other music radio stations)

Thanks again for taking time to hear our submission

On behalf of The 6 Music Independent Listeners Forum

Attachments:

·         Cool Brands Press Release ·         Summary of PRS Songwriting Figures – Also Full Report (2 attachments) ·         FOI Response regarding the ‘negligible’ nature of the Unique Listeners Figures ·         Commercial and Demographics Update – (ILF Addendum 1) ·         ILF Update on Value for Money (ILF Addendum 2) ·         Mp3 of Guardian Media Talk 14^th May 2010