Dear Ofcom

I would like to offer some comments in response to your consultation document The Future Licensing of FM Commercial Radio. I have no professional connection with the radio industry. I am a scientist with a personal interest in frequency planning and music radio in general.

Question 1: Do you agree with our broad objectives for the radio sector?

Yes.

Question 2: Do you agree with our proposed policy for allocating FM spectrum?

Partly yes and partly no:

I generally agree with the policy for allocating the former Radio Authority spectrum: 96.1-97.6, 99.9-103.4 and 105.0-107.9. I believe high power spare frequencies should be used for commercial radio because it extends choice for the maximum number of listeners and because there are plenty of frequencies which are only suited to low coverage stations, which would be ideal for community radio.

However, I believe the spectrum currently allocated to the BBC: 88.1-96.0, 97.7-99.8 and 103.5-104.9 could be used more efficiently. In particular, I believe there is scope to accommodate a small number (5 to 15) of regional and metropolitan commercial stations by making greater use of these bands and changing the frequencies of a handful of existing stations. This should not adversely impact improvements to the FM coverage of BBC local radio which might be made over the next few years. It should be noted that the BCI in Ireland has found room for more Dublin wide stations by moving several local stations into the national sub-bands.

In the annex to this letter, I have identified possible frequencies for new large scale stations in South and West Yorkshire, the East Midlands, London and Suffolk (which could be added to a Norwich licence), areas for which the Radio Authority did not find suitable frequencies in the parts of the FM band formerly allocated to it. I also include proposals for extending the proposed South Wales regional service to include Newport. In each case, I have given more than one option.

I urge Ofcom to do a full investigation of spare capacity in the BBC parts of the FM band before the advertisement of any new commercial radio licences on AM.

Question 3: Do you consider that, where possible, advertising larger or smaller licenses best serves the interests of citizen-consumers?

Question 4: Should we seek to aggregate any or all of the potentiallicence areas within the following broad regions.......

In general, I support larger licenses as these more easily support specialist formats which extend listener choice, whereas many of the small-scale stations have duplicated existing formats. Certainly, the North East, South Wales and Solent frequencies should be combined into regional licences. However, I believe the South West is an exception to this because Cornwall is currently served by an adult contemporary station, whereas Exeter, Torbay and Plymouth have top 40 stations. For a second FM service, Cornwall needs a station for younger listeners, whereas Devon needs a service for an older age group.

I would also recommend that the Liverpool and Manchester licenses and the Aberdeen and Dundee/Perth licenses each be advertised together to give broadcasters a choice between proposing local and regional stations.

Question 5: Should Ofcom adopt a policy of advertsing two new licenses of a different size each month, or would advertsing a larger number of licenses at longer intervals be preferable? ...

Where two frequencies are available for the same area it is more efficient for both Ofcom and applicants to advertise them together. Also, some adjoining licenses should be advertised together to give applicants the option of combining them.

Best regards,

Paul Groves