Invitation for views on merging planned local TV coverage areas

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.

Further consultation

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.