Manx Radio’s future is being discussed by Tynwald this week.

The Isle of Man Examiner reports on the issue on page 3 today.

In advance of the debate, station directors Anthony Pugh and Charles Guard made a presentation to Members of Tynwald last week, in which they also played a video about the station.

We have reproduced their words below.

Introduction

We at Manx Radio are deeply concerned about the implications of the recommendations in the Select Committee Report.

Your decision on the report’s recommendations will have a lasting impact on the island’s national station, on its audience, and how the ii=sland’s democratic credentials are perceived in the international community.

Radio Manx Ltd is owned by the Isle of Man Government, it is your company and we are your directors, approved by the Treasury and running this company on your behalf and, therefore ultimately, on behalf of the people of the island.

However, we would like to begin by acknowledging that our relationship with Government, and with the Treasury, has not been of the best in recent years.

I am told by some that we are seen as arrogant, wilful and difficult to deal with, as people who don’t listen and won’t be told. This has had the unfortunate effect of gradually distancing us from our shareholder and from some members of Tynwald.

This situation is something we deeply regret and it is not something we have actively sought to foster in any way.

As the island’s Public Service Broadcaster, we have a duty to protect our editorial and operational independence, both for our reputation, and for the reputation of the Manx Government which can’t be seen to be running a state broadcaster, as they do in Hungary or Russia.

However, this is an extremely difficult line to tread, and it is quite clear that our attempts to maintain that distance and independence have given the impression, over the years, that we won’t listen to government or engage in a helpful way with their concerns.

We very much want to draw a line under the way our relationship and channels of communication have deteriorated. A way has to be found to give us the operating and editorial independence that are hallmarks of Public Service Broadcasting around the world, and yet at the same time to be able to satisfy our shareholder’s and Tynwald’s requirements.

We feel that the recommendations in this report, which you will be debating next week, may have been drawn up with this deeply unsatisfactory situation as a background.

Unfortunately, we find ourselves in the very difficult position today, of being seriously alarmed by the recommendations and the possible outcomes that their approval would have, and we hope you’ll understand we have to take this opportunity to raise these doubts with you.

Yes, we may be accused of being the same old Manx Radio, refusing to take any criticism, but I can assure you, Honourable Members, this is not how things actually are.

More than anyone, we would welcome frank and open discussions about any issues that our shareholders and Tynwald might have, and I hope when this is all over, that’s precisely what will happen.

However, we don’t believe that this report offers that opportunity and we would respectfully put forward our concerns in the next few minutes.

To begin with we would like to play you a very short video presentation, just to remind you what Manx Radio does, after which we will comment briefly on the various recommendations and then invite any questions you might have.

Yet again, we have been the subject of a Select Committee Report. We are not entirely sure what this latest report is seeking to achieve, but we are quite sure of what will happen if the recommendations are approved: they effectively recommend the redefinition of Public Service Broadcasting and thereby undermine the internationally accepted principles of PSB as set out by the Council of Europe, and which were actually adopted by Tynwald in 2014. They have been adopted world-wide by PSB providers in mature democracies.

We feel that if you adopt the recommendations of this report - which will promote the idea that government can interfere with the direction and planning of a Public Service Broadcaster; which will dictate to us how and what we broadcast, which will disenfranchise the island’s business community – we feel that if you adopt these, Manx Radio will no longer be an independent Public Service Broadcaster, but will be more akin to a State Broadcaster, with all the resonances that that will have.

We would like to comment on the various recommendations in the following way:

Recommendation 1 states that: The definition of ‘public service broadcasting’ in primary legislation should be redrafted to distinguish between mandatory and discretionary components. The mandatory components should be limited to impartial news and other distinctly Manx content. The other elements of the existing definition, such as entertainment which responds to the tastes, interests and concerns of the community, should be discretionary components.

We suggest this is one of the most worrying recommendations as it has the possibility of delivering considerable reputational damage to the Isle of Man. As such, it should demand your most serious consideration.

The broadcaster’s mantra is ‘to inform, educate and entertain’ and it originated because Lord Reith, at the founding of the BBC, clearly understood to deliver information effectively it’s essential you entertain an audience as well.

We must make it clear that the 90-year-old definition of Public Service Broadcasting has obviously been refined and modernised. In fact, the guiding principles of PSB are now adopted by UNESCO and defined in the Council of Europe’s recommendations on public service media guidance which has been accepted throughout the world and was actually adopted by Tynwald in 2014.

This recommendation dismantles a fundamental part of programming and will signal the death knell of Manx Radio – the service you’ve said time after time in Tynwald, is a ‘national treasure’.

Recommendation 2 states that: The island’s public service media provider should “leapfrog” Digital Audio Broadcasting and move straight from the existing distribution framework, which relies only on FM and AM, to a future framework in which FM sits alongside an Internet Protocol-based infrastructure.

Whilst this recommendation is not the most important of the eleven, it is important to the Manx public because 93% of the Manx population listen to some radio every week, and amongst the huge number of stations they can listen to, 46% choose to listen to Manx Radio week in week out.

There are two essential criteria a public service media provider must meet in its transmission strategy: the programming should be free at the point of use and it should be resilient at times of emergency.

Once you’ve bought your radio – listening is free. But if you’re listening on a computer, odds are you’re paying up to £1,000-a-year to Manx Telecom for Ultima broadband and your phone, and at times of very heavy use, the internet becomes slower and slower and in emergencies it has been known to crash altogether.

You will be interested to know that last month Ofcom, the UK regulator, announced that it was about to licence the Digital Audio Broadcast multiplex for Jersey. As nations the world over embrace DAB or DAB+, the Isle of Man continues to believe that investing in our 50-year-old AM transmission network is the way forward. You should also understand that the investment we’ve made in replacements to the AM masts in the last few weeks would already have paid for a DAB+ solution for 50% of the Manx population!

Recommendation 3 states that: Tynwald calls on the Treasury as shareholder of Manx Radio to work towards a delivery model for public service media in which reliance on commercial advertising is progressively reduced and ultimately removed.

So, £1.2m of our income is to be removed from us. We can’t see any alternatives in this report to compensate for this loss of income. We also strongly feel that the backlash from the business community – who haven’t been consulted on this idea – will be enormous. 225 businesses currently advertise on Manx Radio. They will be disenfranchised as the other radio stations couldn’t possibly pick up that amount of business.

Besides which, it is impossible to progressively manage the reduction of commercial advertising.

Recommendation 4 states that: Legislation should be introduced to provide that a public service broadcaster in receipt of public funds for the purpose of meeting public service obligations should be obliged to budget for a surplus each year; and if such a broadcaster should find itself in the position of forecasting a loss in any particular year, then before the end of that year it should be obligatory for Tynwald to be asked, on behalf of the broadcaster, to approve a Supplementary Vote.

There are two ways of budgeting for a surplus, we can achieve it by cutting even more costs, if we do this by cutting programmes and staff we will definitely be in breach of the basic requirements of our licence; or, we can recklessly over-estimate our potential commercial income, which, when we don’t achieve it, means that we will be back to Tynwald for a supplementary vote as outlined in this recommendation.

Because Manx Radio benefits from public funds we have never planned for large surpluses as we would then be accused of not utilising those public funds effectively.

You will also all know that Manx Radio has, from time to time, traded at a loss. What you probably won’t know is that in the last 15 years at the station we have never overspent on our budgets. What we have occasionally failed to do is to meet our commercial income targets. What’s more, our operating expenses have actually fallen by £80,000 in the past 10 years – we are cut to the bone and must be one of the most efficient bodies in Government. We have been running our own ‘SAVE’ campaign for many years!

Recommendation 5 states that: The public body which owns Radio Manx Limited should play an active role in the strategic direction of the company, including engagement with medium- and long-term planning and recruitment of the directors of the company. If the Treasury does not have time to do this, ownership should be transferred to another body.

This is another of those fundamental recommendations that we suggest you consider extremely carefully.

A key pillar of the Council of Europe’s recommendations for Public Service Broadcasting, adopted by Tynwald in 2014, is that a public service provider is ‘independent’ from the State – editorially and, importantly, financially.

This recommendation is at complete odds with the core principles of public service broadcasting. It will also, undoubtedly, lead the audience to believe Manx Radio has become a government mouthpiece. This will do untold harm to democracy in the Isle of Man and the image and reputation of the Isle of Man as seen from around the world.

You should also know that after the publication of the Select Committee’s interim report Manx Radio wrote to the Committee pointing out that there were 17 factual errors in the report and that some of those errors had subsequently informed their recommendations. This is one such recommendation.

We can confirm that there is no ‘policy of allowing the directors to appoint their own successors’ at Manx Radio and that, since 2014, all appointments to the Radio Manx Ltd board (three in total) have been approved by Treasury prior to those appointments. In addition, since 2016, appointments to the board have been openly advertised.

Recommendation 6 states: That legislation should be introduced to provide that no public funds may be committed to public service broadcasting, and no broadcasting licence or station format may be issued or amended, in the absence of agreement between the Treasury, the Communications Commission, and the owners and directors of the public service broadcaster.

This is another recommendation that flies in the face of the ‘independence’ that is key to public service broadcast provision.

Legislation that allows the State to withhold funds in the absence of all party agreement has the potential for Manx Radio to be closed down or seriously compromised if there is any disagreement with the State. This is extremely dangerous in the wrong hands.

Recommendation 7 states: That Tynwald calls on the Office of Fair Trading to assess whether Manx Radio’s ability to supply a greater amount of advertising space is creating unfair competition in the radio advertising market.

Accusations were made to the Select Committee that Manx Radio might be selling advertising at ‘less than cost’. So, the Committee appointed the Audit Advisory Division of the Treasury to investigate. They concluded:

‘The figures prove that advertising has not been sold at potentially less than cost.’

Manx Radio’s decision to include advertising 24 hours a day as opposed to 3FM’s self-imposed policy of only during live programming, compelled the committee to say:

‘We consider (this) to be reasonable and fair competition in the market, as there is nothing to prevent others from doing likewise.’

So we aren’t clear what this recommendation is trying to achieve.

Recommendation 8 states: That Manx Radio’s licence conditions should be altered to provide for a level playing field in terms of its ability to place advertising during times of peak listenership generated by taxpayer-funded programming.

Effectively, this recommendation states that Manx Radio should only be allowed to broadcast its adverts at certain times of the day, and not during the parts of its output that the Government feel that they partly pay for.

What is the purpose of this, other than to give the commercial advantage to other stations?

Perhaps we could remind you again that our licence requires us to provide certain clearly defined services; the Government, our owners, do not provide enough money to fund those services; we have to go out into the market and get the remaining funds, 60% of our running costs. It is Manx Radio commercial activity that is providing the lion’s share of the funding for Public Service Broadcasting on the island, not the Government. It seems, well, frankly perverse to not only refuse to give us enough money to provide the services you require, but to then deliberately make it even more difficult for us to raise that money.

Furthermore, as recommendation 3 says we should get rid of all advertising anyway, these recommendations 7 & 8, about our commercial activity, seem irrelevant: what’s the point of discussing all of this if we don’t have any advertising anyway?

Recommendation 9 states: That the Treasury should reassess the long term cost and benefit of Broadcasting House as compared with alternative Government-owned or commercially rented premises.

We don’t mind where we operate from. Currently we are in a WWII concrete building, put up to War Ministry designs in a few weeks to house HMS Valkyrie, part of the Fleet Air Arm.

An inspection, some 10 years ago, by the Treasury’s Capital Projects Team declared it to be the worst building in the Government’s portfolio. For 11 years we have been trying to sort out this appalling state of affairs with the Treasury. At the request of the Treasury we have carried out detailed studies and created plans for relocation to Government-owned properties; we’ve costed out relocation to rented property and even had plans drawn up for two new-build properties. In fact, we’ve already spent £75,000 on professional fees investigating other locations and planning the redevelopment of Broadcasting House.

We can tell you, with absolute certainty, the additional sum required to complete the work at Broadcasting House, to provide a fit-for-purpose facility, is many millions less than the cost of any relocation. It is the most cost-effective solution. The Select Committee have received all this detailed information.

There is no disabled access to the station, or in the station. Just recently we had a double amputee in for an interview who had to lift himself up the stairs to our studios on his backside, and our inability to allow a group of war veterans to the studios in the lead up to Remembrance Day as they simply couldn’t use stairs is, frankly, a disgrace for a government owned building.

Recommendation 10 states: That the Treasury should examine the apparent lack of value for money which Manx Radio is achieving with respect to FM broadcasting infrastructure.

This recommendation comes about as a result of the report’s 18th error which claims that Manx Radio pays Arqiva, the owner of some of the Island’s masts, £60k per annum for its FM transmission sites. Manx Radio actually pays Arqiva around one third that sum for accommodation and antenna sharing. This recommendation is based on wrong information.

And finally...

Recommendation 11 states: That the Council of Ministers should pursue negotiations with the UK Government and the BBC aimed at securing one of the following outcomes:

We won’t repeat all of the options, but in essence the committee are asking for money from the BBC to help fund Manx Radio so that it doesn’t require advertising; or to provide a news service and other public service content for Manx Radio so Manx Radio again, doesn’t need to take advertising; or for the BBC to establish a local radio station here so you can get rid of Manx Radio altogether; or, finally, to keep the licence fee on the island and forgo the BBC on the island altogether.