Invitation for views on merging planned local TV coverage areas
- Start: 19 June 2013
- Status: Statement published
- End: 17 July 2013
Following the completion of its first round of local TV licensing, Ofcom invited expressions of interest in 30 further areas that the successful local multiplex licence applicant, Comux UK, had committed to cover. Following this invitation, we received a small number of requests asking us to consider merging some locations, for which we had sought separate expressions of interest, and to advertise a single local TV (L-DTPS) licence for the merged area.
On 19 June 2013, Ofcom accordingly published a short consultation inviting views on merging the coverage areas of the following locations:
- Tonbridge and Maidstone; and
- Hereford and Gloucester.
We also invited views on whether we should consult on merging any other areas for which we had determined technical feasibility.
We received 7 responses to this consultation. These were from an individual, 5 potential applicants for L-DTPS licences (First Broadcasting Company, The Triple Broadcasting Co and three others who asked to be kept anonymous) and the local multiplex licensee, Comux UK.
Tonbridge and Maidstone
We received two responses from potential applicants for an L-DTPS licence in these areas, which both supported the idea of merging the two locations. These respondents argued that these coverage areas should be merged because:
- The two towns share cultural similarities, as well as local institutions;
- The coverage areas may be contiguous in some places, if not actually overlap; and
- A larger coverage area would make a licence in this area more viable.
One of these respondents provided further research regarding potential overlaps and the direction of aerials in this location, and referred to further local research indicating an appetite among local advertisers for a larger coverage area.
Comux UK responded that the question of merging these areas is one for any potential L-DTPS licence applicants to consider, noting that a merged coverage area would be unlikely to materially reduce costs as it would still need to be covered from two transmitters.
The individual respondent was not in favour of merging any coverage areas, arguing that local TV should be as local as possible, and that merging areas would encourage consolidation of the local TV sector more generally.
Based on the responses we have received, we consider that we should advertise the Tonbridge and Maidstone coverage areas as a single licensed area. This is because we think that these two locations share sufficient cultural similarities that a service for both would have the potential to serve them well, particularly given the potential coverage overlaps. We also consider that merging these two areas will make it more likely that we receive applications for this licence, and that the licensed service would be more likely to be viable. We consider that the conditions and requirements for the award of an L-DTPS Licence, as set out in the Local Digital Television Programme Services Order 2012, will ensure that the licensed service will meet the needs of the area or locality where it is received.
Following our established policy of naming coverage areas after the principal conurbation in the area, this merged coverage area will be referred to as Maidstone. We do not anticipate that we will need to produce any further indicative coverage planning for this area.
Hereford and Gloucester
We received two responses from potential licence applicants. One of these respondents supported merging these two areas, primarily because:
- A larger, merged area would make a licence more viable in this area; and
- There are significant cultural similarities and institutional links between these two areas.
The other potential licence applicant, The Triple Broadcasting Co, argued for merging the two areas, but additionally for merging this merged area with the Malvern coverage area. In addition to the reasons give by the other respondent above, this was because:
- A merged Malvern/Gloucester area would be “likely to [be] creatively and editorially improved by covering a single area, in a way that more closely matches the audiences real life relationship with the communities and geography served.”
Comux UK’s response noted that although Gloucester was not part of its commitment to build out Phase 2 locations, the proposed coverage would be significant enough to benefit both the network and the local licensee, and therefore Comux would be happy to make the additional coverage a licence obligation. The response also noted that combining these two areas may not substantially increase both the capital expenditure of build out and the operating cost for a local licensee, although the actual cost would not be clear until after a licence had been awarded and detailed planning work is done.
The individual respondent was not in favour of merging any coverage areas, arguing that local TV should be as local as possible, and that merging areas would encourage consolidation in the local TV sector more generally.
Based on the responses we received, we consider that we should advertise the Hereford and Gloucester coverage areas as a single licensed area because this will provide a material increase in coverage for the network overall, and may make it more likely that we receive viable licence applications for this area. We are satisfied that there are local affinities between the merged areas and that the conditions and requirements for the award of an L-DTPS Licence, as set out in the Local Digital Television Programme Services Order 2012, will ensure that the licensed service will meet the needs of the area or locality where it is received.
Following our established policy of naming coverage areas after the principal conurbation in the area, this merged coverage area will be referred to as Gloucester. Before advertising a licence for this area we will produce fresh indicative coverage planning.
In light of The Triple Broadcasting Co’s request to merge this newly defined Gloucester coverage area with the Malvern coverage area, we consider that we should consult on this specific request.
In addition, following request by one of the respondents, Ofcom will be consulting on merging Luton and Bedford, which are currently planned as separate locations.
What we are asking and why
Ofcom has now completed its first round of local TV licensing. We invited expressions of interest in 30 further areas that the successful local multiplex licence applicant, Comux UK, has committed to cover. As a result of this invitation, we received a small number of requests asking us to consider merging some combinations of locations, for which we had sought separate expressions of interest, in order to advertise a single local TV (L-DTPS) licence for the merged area. These locations are:
- Tonbridge and Maidstone; and
- Hereford and Gloucester.
However, other respondents expressed interest in these areas as separate licences.
We therefore consider that we should take into account the views of all those who expressed interest, and wider local views, before deciding whether to merge these areas.
Tonbridge and Maidstone
Our 2012 coverage planning indicates that it is not possible to serve both of these areas from a single transmitter. Therefore, Tonbridge would be served by the Tunbridge Wells transmitter, and Maidstone would be served by the Bluebell Hill transmitter. As currently planned, these two coverage areas may not be contiguous. Although it may be possible to extend coverage at one of these locations by building practical transmission facilities that differ from the assumptions used in the 2012 coverage planning (for more detail on these assumptions see the Coverage Note), there is no guarantee that this is feasible, and there may still be gaps between one coverage area and another.
Hereford and Gloucester
In 2011 we commissioned some initial coverage planning that indicated that both of these locations could be served from the Ridge Hill transmitter. We anticipate that, subject to frequency availability and any existing restrictions in place, a merged coverage area would broadly reflect this coverage planning. Arqiva’s Reference Offer for transmission costs reflects the baseline technical arrangement envisaged when the Coverage Note was published in May 2012. Making changes to the technical arrangements to serve Gloucester as well as Hereford is likely to increase operating costs over that contained in the current Reference Offer, but be less expensive than serving both areas separately.
We are therefore consulting on the following questions. You do not have to respond to both questions, but please indicate which you are responding to, and who you are, and your interest in this question. Although we welcome responses from any interested party, this question is aimed in particular at respondents in the affected coverage areas, and at potential applicants for these licences. Where possible, please support your reasoning with evidence or data (please indicate if this is confidential).
Q1. Do you think we should merge the Tonbridge and Maidstone areas and advertise a single licence, or advertise these as separate licences? Why?
Q2. Do you think we should merge the Hereford and Gloucester areas and advertise a single licence, or advertise these as separate licences? Why?
We are seeking views on these particular coverage areas because of responses we received to our invitation for expressions of interest. Please therefore note that we are not seeking views at this time on any other coverage areas than the four mentioned above. We are also not seeking views on any coverage areas that we have already licensed or advertised.
However, if you are a potential applicant and consider that we should seek views on merging any further locations for which we have determined technical feasibility, and which we have not already licensed or advertised, we would welcome responses setting out why you consider that these locations would be better served by a single service than a number of separate ones. We will then consider whether we should consult on further mergers.
Please also note that we are not seeking views on extensions to coverage areas, as we have already set out a process by which licensees may negotiate such extensions with the local multiplex operator.
How to respond
The closing date for responses is 5pm on 17 July 2013.
There are two ways to respond to this consultation.
The quickest and simplest way is to complete our online consultation response form. This is ideal for people who have specific brief points to make and/or do not need to attach large documents to their response.
For larger consultation responses - particularly those with supporting charts, tables or other data - please email firstname.lastname@example.org attaching your response in Microsoft Word format, together with a consultation coversheet. We will confirm receipt of any responses received via email.
Please do not send hard copies via post.