'Radio Authority Local Licence Award: Buxton' by Grant Goddard

RA PAPER 43(03)
2 July 2003
LOCAL LICENCE AWARD:
BUXTON
Paper by the Staff
MATTER FOR DECISION
1. Members are asked to decide which of the five applicants, two of whom have been
identified as the strongest candidates, should be awarded the new local licence for the town
of Buxton and other parts of the High Peak district, in Derbyshire.
STAFF SUMMARY
2. Buxton and the High Peak district is one of the few remaining areas within England
that is presently unserved by local commercial radio, so that any of the five applicants
would succeed in broadening the choice of radio programming available to the local
population. The rugged terrain presents a challenge to applicants' ability to provide an
adequate signal for reception across the entire area, with four of the five applicants
addressing the problem by proposing multi-site transmission facilities. Neither is the area a
particularly coherent unit, as there is little economic or cultural traffic between the two
largest towns, Buxton and Glossop, which are separated by steep hills. Some of the
applicants have addressed this problem of serving two towns that have little in common
with each other by proposing to establish "contribution studios" in outlying areas of the
district and/or by locating the main radio studio roughly half-way between the two towns.
As staff marking indicates (shown in full in an Annex to this Paper), two of the five
applicants have emerged well ahead of the rest of the field as the strongest candidates for
licence award. High Peak Radio (72%) is a genuinely local group whose track record of
five Buxton RSLs has been enhanced by the involvement as director/shareholder of Chris
Carnegy, a pioneer in small-scale radio start-ups. The group has produced evidence of
substantial local support and proposes a full-service station that will emphasise localness
and appeal to a wide demographic spread of listeners. The economic challenge of serving a
relatively small and disparate TSA has led the applicant to propose a small staff and a
relatively high level of automation, whilst its local revenue estimates are the most
conservative of the five applicants. Although no radio group is involved, Carnegy's
participation and the appointment of Roger Price (ex-The Bear managing director) as launch

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director provide relevant radio management input. In the long run, day-to-day management
would pass to the Jenner brothers, who managed the group's Buxton RSLs. FM The Edge
(72%) is a combined application from the former managing director of Peak 107 (ILR
Chesterfield) Wayne Chadwick, The Wireless Group and a local group whose history of
RSLs dates back to 1988. While this group would similarly offer locally-oriented
programming designed to appeal to a wide audience, its ILR experience has led it to propose
a larger staff complement than High Peak Radio and the highest revenue projections of the
five applicants (assisted by The Wireless Group's access to national advertising). Local
support has not proved as substantial as that for High Peak Radio, probably because the four
RSLs to which the group lays claim were operated under four different names by the local
group and Peak 107 (acting alone and in concert). The heritage of the local group appears to
have been somewhat subsumed in this application to the ambition of The Wireless Group to
develop a cluster around its existing Stockport station, and to the ambition of Wayne
Chadwick to re-enter the ILR industry as manager of this cluster. The group's strength is the
radio management track record that both The Wireless Group and Chadwick bring to this
application. With the agreement of the 'nominated Member' for this licence, Sheila Hewitt,
these two applicants have been put forward for Members' detailed consideration, and their
proposals are assessed comparatively in paragraphs 24-40. The proposals of the three
considerably weaker applicants – Peak AM, Temple FM and Spring FM – are evaluated in
paragraphs 9-23.
BACKGROUND
Coverage brief
 Licence offered on FM or AM, but not both.
 Designed to facilitate coverage of the town of Buxton and other parts of the High Peak
district, in Derbyshire.
 Difficult area to serve due to unusually hilly terrain, dispersed population, and potential
planning permission problems in area of outstanding natural beauty.
3. Buxton was added to the 'working list' of planned new licences in March 1999. The
licence was not advertised until December of last year because of complicated frequency
planning issues that needed to be resolved in an area which is difficult to serve adequately
due to its scattered pattern of population distribution, its unusually hilly terrain, and the
potential difficulty of identifying (and, if necessary, obtaining planning permission for)
suitable transmission sites in an area of outstanding natural beauty. In June 2000, staff wrote
to the known prospective applicants for the licence to seek guidance on their coverage
ambitions and waveband preference. Two possible options were put forward for their
consideration. The first was for an AM licence, which potentially would achieve more
widespread geographical coverage than could probably be obtained on FM, and would not
have the terrain-related limitations on reception that would be inevitable with an FM licence
in the area. This is an approach which the Authority has previously adopted in other
geographically extensive areas containing sparsely distributed population and hilly terrain,
such as the Yorkshire Dales, Mid-Wales, and South Shropshire. The second suggestion was
that the Authority could offer a small-scale FM licence for the town of Buxton itself. It was
further indicated that, due to the terrain shielding of this and other population centres that

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might potentially come within the scope of a Buxton licence area, one or more frequencies
capable of being used for low-powered relay transmitters to serve areas of population in
valleys might also be identified. Prospective applicants were cautioned, however, that the
feasibility of being able to feed a signal to relay transmitters, given the existence of
intervening high ground, would require careful examination. Both of these options attracted
a measure of support. In the event, the licence has been offered for a service to be broadcast
on either FM or AM, but not both. Up to two FM frequencies are available for applicants
choosing this waveband, each of which may be used at one or more transmission sites, but
applicants preferring AM were advised to base their proposals on the use of a single
frequency at a single transmission site only. For the FM option it was anticipated, as
indicated above, that one transmission site would be used to serve the town of Buxton itself
and the other, if desired, to serve centres of population elsewhere in the High Peak district.
The maximum effective radiated power (e.r.p.) of each FM frequency was set at 500 Watts,
while for AM the Authority would intend to seek clearance for the use of the frequency
1521 kHz, at an effective monopole radiated power (e.m.r.p.) of 250 Watts.
Applicants' technical proposals
 Each of High Peak Radio, FM The Edge and Spring FM would provide robust coverage
of the main population centres.
 High Peak Radio and Spring FM have the most realistic TSA estimates.
 Temple FM would not serve the central part of the licence area and would overspill too
much into Stockport.
 Peak AM has completely misjudged both its coverage and its TSA.
4. Four of the applicants have applied for a licence on the FM waveband, with just one
selecting AM as its preferred waveband. The plans put forward by the FM applicants vary
considerably, however. High Peak Radio is proposing to use the most transmitters of any
applicant (four, with each frequency being re-used once), yet its likely coverage is not
significantly greater than that expected to be achieved by other applicants and its TSA of
66k adults is the second-lowest of those forecast by the five groups. However, in our
engineers' view this is an accurate assessment of the population coverage likely to be
achieved, and despite their obvious potential to prove onerous, the costs of this technical
plan have been thoroughly pre-planned by the group's experienced launch director Roger
Price and look reasonable. High Peak's main studio would be based centrally in the licence
area in Chapel-en-le-Frith, with additional contribution studios in Buxton and Glossop. Both
FM The Edge and Spring FM have proposed the use of three transmitters, one in each of
Buxton, Chapel-en-le-Frith and Glossop, with a studio located in the former of these towns.
One frequency would be used at both Buxton and Glossop, with the second frequency
providing coverage of the central part of the licence area. FM The Edge has anticipated an
adult population in its TSA of 95k whereas Spring's prediction is appreciably lower at 60k.
This difference is partly due to the fact that FM The Edge intends to utilise all of the
permitted 500 Watts at its Buxton site, while Spring has proposed using only 250 Watts at
its main site, but is also a function of the differing sites and aerial heights proposed by the
groups. Both of these TSA forecasts appear reasonable, though, and either applicant would
achieve robust coverage of the main population centres in the licence area. FM The Edge
states that it would be interested in implementing a fourth transmitter at a later date, to

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enhance coverage in the eastern part of the High Peak district. Although this area contains
no significant centres of population, a transmitter sited there would make the station's TSA
contiguous with that of the Chesterfield service Peak 107, an outcome which would not
necessarily be a coincidence (see paragraph 28 for discussion of this). Temple FM has based
its proposals on the use of just two transmitters, at Buxton and Glossop, but its plans are not
compliant with the coverage brief. The group's own predictions show that, as well as
achieving hardly any coverage of towns such as Chapel-en-le-Frith and Whaley Bridge in
the central part of the licence area, its signal would be very strong in parts of Stockport and
Manchester, areas outside of the scope of this licence. Consequently, a sizeable proportion
of the 120k adults in its anticipated TSA live outside of the High Peak district, and it seems
likely that such an over-estimation could have a significant impact on the group's business
plan (see also paragraph 18). The one applicant proposing to use AM, Peak AM, estimates
that its single transmitter located just outside Buxton would cover a radius of 15 miles in
daylight hours. However, our engineers believe that in fact it would struggle to reach 15
kilometres (around 9 miles). The group's estimated TSA population of 208k adults is not
derived from a coverage prediction, but rather represents the sum of the populations in the
three local authority districts that it believes it would serve - Staffordshire Moorlands,
Derbyshire Dales and High Peak. Aside from the fact that the first two of these areas are
outside of the scope of this Buxton licence, our engineers estimate that Peak AM would in
fact serve a population of no more than 60k adults from its chosen transmitter site. Given
that the group has made no attempt to determine the extent of reduced after-dark coverage
(though its chairman and prime mover Alastair Bates offers a 10-mile radius as "an educated
guess") and that its TSA is wildly optimistic, there are clearly ramifications for its business
plan (see also paragraph 13).
Area details
 Area forms core of Peak District National Park.
 Tourism and light engineering are the main local industries.
 Population is dispersed among several small towns and villages.
5. The High Peak district of Derbyshire forms the heart of the Peak District National
Park, a rural area characterised by rugged mountains, windswept moorlands, and limestone
caverns. Unsurprisingly, tourism is a key part of the local economy, with more than a third
of the UK population resident within 60 miles of the National Park. The traditional
industries of farming, textiles and quarrying have now largely been replaced by light
engineering and manufacturing companies, with Glossop in particular benefiting from its
location just twelve miles from the Greater Manchester conurbation. The area is relatively
prosperous, with below-average unemployment and relatively low crime rates, and recent
developments like the Glossopdale industrial area and the building in Buxton of a new
campus of the University of Derby are helping to create new jobs and attract inward
investment to the region. The main population centres are Buxton in the south of the district,
Chapel-en-le-Frith, New Mills and Whaley Bridge in the central part, and Glossop (the
largest town in the district, with a population of almost 30k) to the north. The rest of the
population live in numerous small villages. Buxton is a tourist destination in its own right
thanks to its spa, Georgian architecture and arts festivals, while, despite increasingly
becoming a dormitory for Manchester, Glossop has recovered well from the decline of

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cotton spinning and retains a strong sense of local identity. The two main newspapers in the
area, the Glossop Chronicle and Buxton Advertiser, are both paid-for weeklies, and will
provide the main competition for the new radio station in terms of advertising revenue.
Around 99% of the local population is white.
Local response
 Local MP would prefer licence to be awarded to either High Peak Radio or FM The
Edge.
 Majority of letters sent directly to the Authority are in support of High Peak Radio.
6. Correspondence in respect of this licence from local elected representatives was first
received at the Authority in December 1998, before the area was added to the 'working list',
when local MP Tom Levitt (Lab., High Peak) and the leader of High Peak Borough Council
both wrote to express their support for the establishment of a local radio station in the area.
In July 2000, the leader of Derbyshire County Council echoed this sentiment, and further
expressed the hope that the licence would allow for coverage of as much of the High Peak
district as possible. This latter aspiration was then reiterated by Levitt, who stated that such
a radio station could be a "unifying influence" in an area where no existing local media
cover the entire borough, and also by two Labour MEPs for the East Midlands. The last
flurry of correspondence prior to the advertisement of the licence came at the end of 2001,
when four residents of Glossop wrote to request that their town be included in the coverage
area of the licence and a Derbyshire County Councillor offered her support to the Radio
Buxton RSL group (now High Peak Radio). At the time of the licence advertisement, staff
wrote to the chief executives of the two aforementioned local authorities and to Tom Levitt,
whose constituency matches the High Peak district and thus the advertised coverage area of
this licence, inviting their views. Neither chief executive responded, but Levitt replied to
explain that while he would not be supporting any one particular candidate, he hoped that
the successful applicant would "feature news and views and not just music" and would
"work closely with other bodies to enable the maximum distribution of public information
within a diverse framework of entertainment". However, he wrote again in April to state
that, while wishing to maintain his impartiality, High Peak Radio and FM The Edge were
his preferred candidates on the basis that "both have a strong local base, a commitment to
community involvement and diversity as well as the professional expertise ... to see this
through". He added that "whilst High Peak Radio perhaps offers a greater degree of listener
access to the airwaves, the policy of FM The Edge to using the internet to support their
services is to be welcomed."
7. The response from members of the public has been relatively substantial, with a total
of 72 letters being sent directly to the Authority. The majority of these (44) are in support of
High Peak Radio; the only other applicants to receive backing in this way are Spring FM
(eight letters) and FM The Edge (five letters). Most of the letters in support of High Peak
Radio were sent during a Radio Buxton RSL; the first batch was received shortly after the
group's second trial broadcast in November 1999, with a further flurry around the time of
the third broadcast, in June 2000. All of the correspondents appeared to enjoy the
programme service provided by Radio Buxton, and many commented on the lack of existing
media serving the area. One supporter also assembled a petition containing almost 1,500

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signatures (although the actual document was mislaid by the Royal Mail), while a local
businessman who had advertised on the station described Radio Buxton, when compared to
the only other group to have undertaken a trial broadcast, FM The Edge, as "the only radio
station which has bothered to build up a proper client base and operate professionally".
Prominent individuals from whom letters of support for High Peak were sent to the
Authority include Philip Whitehead, one of the East Midlands MEPs mentioned in the
previous paragraph, and the now-deceased Major Ronald Ferguson who, although not a
resident of the area, had been impressed with the group after he was interviewed during one
of its RSLs to publicise a charity with which he was involved. Spring FM received the
backing of the chairman (who is also a director/shareholder of the group) and secretary of
Buxton Football Club, both of whom commented on what they perceived as the group's
professionalism and, at a presentation given alongside ones from High Peak Radio and FM
The Edge, impressed three people enough for them to write to the Authority in support. One
of these correspondents expressed the view that while Radio Buxton (i.e. High Peak Radio)
came across as "nothing more than enthusiastic amateurs" and FM The Edge were "too slick
for their own good", Spring FM "offer the right balance of local commitment and pre-
proven professionalism". Among those offering support to FM The Edge are Buxton Radio
Amateur Club, on the basis that the group has "local roots and connections" and "very
professional" directors, and a Derbyshire county councillor, who is pleased that the group
intends to locate studios in his ward. Most of the remaining letters, including one from
Whaley Bridge Town Council, offered generalised support for a new radio station in the
area, but three correspondents expressed concern about how much automation the new
service might utilise, while another worried that it might interfere with BBC Radio
Sheffield. The longest letter of all those sent directly to the Authority was received from a
local businessman who attended the public meeting mentioned above, at which High Peak
Radio, FM The Edge, and Spring FM gave presentations. After expressing concerns about a
possible lack of coverage in the Hope Valley area and the applicants' apparent concentration
on music to the detriment of speech output, he concluded that the two sets of proposals
which came closest to addressing his concerns were those from High Peak Radio and FM
The Edge. In addition to these letters sent directly to the Authority, each applicant has of
course assembled its own evidence of local support; this is discussed elsewhere in this
Paper.
Assessment of applications
8. Four members of staff have been involved in assessing the applications and
questioning the groups about their proposals: Grant Goddard as 'project officer,' with
contributions from David Burkin on the programming proposals, Andy Causby on finance
and Terry Dowland on the engineering arrangements. Sheila Hewitt was the 'nominated
Member'. The scores awarded are summarised below, with the full sets of marks attached as
an Annex to this Paper.

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I
General
II
Programming
III
Audience/
Support
IV
Finance
Total
[200] [300] [200] [300] [1000]
High Peak Radio 170 195 168 190 723
FM The Edge 160 205 160 195 720
Spring FM 88 170 96 155 509
Temple FM 124 145 70 170 509
Peak AM 70 120 64 130 384
The three applications which appear to be the least convincing candidates for licence award,
i.e. Peak AM, Temple FM and Spring FM, are evaluated in turn in paragraphs 9-23 of this
Paper. The applications of the two groups identified as stronger contenders, High Peak
Radio and FM The Edge, are assessed comparatively from paragraph 24 onwards.
THE APPLICATIONS
Peak AM (38%)
History and composition
 Only AM applicant.
 Poor quality application.
9. Peak AM Ltd. is the only one of the five applicants that proposes to use AM
transmission. The group's three directors are: Alastair Bates, who was involved in Stockport
station KFM; Graham Symonds, ex-founder and ex-MD of Ludlow AM Sunshine 855; and
"business consultant" Nicholas Holmes who worked in finance and sales at Sunshine 855.
(Both KFM and Sunshine were 'pirate' stations in the 1980s which subsequently became
licensed, and were in due course taken over in the process of radio industry consolidation).
None of the three live within the station's proposed TSA, though Bates says he submitted a
letter of intent to the IBA for the Peak District in 1990. After his role in setting up KFM,
Bates says he "stopped involvement in radio in 1984" to pursue a career as a civil servant,
though he says he "has always had an eye for the Peak District." Bates first met Symonds in
1983 when both were involved in their respective pirate stations. The two share a long-time
interest in AM transmission, and Bates (who will be the group's chairman) invited Symonds
to become the applicant group's managing director. The group only formed in January 2003
in response to the Authority's advertisement of the Buxton licence the previous month, and
it is committed to AM transmission above all other factors. "If you wander through the Peak
District, it lends itself to AM," explains Bates; "apart from small areas, FM is not really on
at all." During staff questioning, Bates waxed lyrically at length about the advantages of
AM, but had more difficulty answering staff questions about his fellow directors' past
business and radio experience, the group's staffing plans, and the background of the other
investors in the bid. (Asked about one of the group's largest shareholders, Bates told staff: "I

RA PAPER 43(03)
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don't know an awful lot about him"). Peak AM's application is of very poor quality and
appears hastily prepared, with little substantial content.
Staffing and management
 Most senior managers would work part-time only.
 Community volunteers would assist with news coverage.
10. The station would employ 8.0 FTE (full-time equivalent) staff, including three
salespersons (the highest of the five applicants) and two in news, which should prove
adequate. The group proposes that its chairman (Bates), managing director (Symonds) and
finance director (Holmes) would all work part-time. The only full-time management posts at
the station would be the combined station manager/programme controller (who manages
one lone presenter) and the sales manager (who manages two salespersons). The group has
confidentially identified Alan Thompson, an experienced journalist and broadcaster
(although with a less than convincing track-record in ILR), as a candidate for the former of
these two posts, but his appointment is by no means guaranteed. Freelance presenters would
be employed only "to cover periods of sickness and holiday," but not apparently to relieve
the lone presenter of his/her eternal on-air duties. The local news proposals for Peak AM
rely on the use of “village correspondents” which the group describes, in response to staff
questioning, as “volunteers who file us their village gossip once a week, scan the papers,
etc.”
Programming
 Inadequate programme proposals.
 Music categories too rigidly fixed.
11. Peak AM's programming proposals are inadequate to enable the formulation of a
meaningful Promise of Performance, or for staff to provide a proper assessment, and follow-
up questioning failed to alleviate these concerns. Offering easily the weakest application of
the five, Peak AM has provided insufficient information to earn even average marks by any
criteria, except for ‘choice’, which it cannot help but broaden because no other ILR service
is available within the TSA. The group proposes "a dynamic gold station programmed for
the 21st
century" targeted at 25-55 year olds. Automated programming would be broadcast
from 1900 on weekdays and Saturday, and all day on Sunday. Five hours per week of
syndicated US shows are planned. Most of the music would derive from the 60s, 70s and
80s, with a sprinkling of current hits and some songs from the 90s (which the application
defines, bizarrely, as "recurrents"). There would be no live local news bulletins during
weekends, and the weekday 0630 local news will be pre-recorded the previous day, with the
attendant risks which this practice entails. The group’s plans for speech content are as
incoherent as other aspects of the application. It proposes a minimum speech content of
20% Monday-Friday and 10% on Saturday, falling to 0-5% during automation periods
(which would include Sundays). Each speech feature will be four to seven minutes long, but
those that the applicant will commit to in its Promise of Performance are only vaguely
defined as “the doctor,” “CAB,” “solicitor,” “gardener” and “care-line,” with no additional
information regarding times or frequency. Consequently, it proves impossible to assess

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either the relevance of the proposed content, or whether the group would be capable of
maintaining the promised minimum speech levels. News coverage would comprise IRN or
agency news hourly in daytime to 1800, with two-minute local bulletins on the half-hour
between 0630-1830 on weekdays. The group’s local and regional news will be “obtained by
station’s own news staff … in association with local newspapers who will supply local daily
news for which they will be credited,” though it confirms that “no negotiations have been
undertaken as yet.” The group’s music proposals prove as inconsistent as its other
programming areas, with unnecessarily precise figures for each category – 85% of music
output is fixed, and there are narrow minimum/maximum bands – leaving little room for
future changes. Sunday daytime would have a more ‘middle of the road’ feel, and specialist
music shows may be introduced in the future.
Research and support
 Research only from market stall.
 Little evidence of local support.
12. The group's market research amounted to no more than a stall of publicity material in
Buxton's main shopping street one Saturday in February 2003. Survey sheets comprising
seven basic questions were distributed to passers-by, but the group says it "didn't take
formal numbers or percentages" of the opinions expressed. Asked how he knew what the
local population wanted from a radio station, Bates could only offer his fellow directors'
"experience of Sunshine and the way it has worked down there….. it is quite a similar sort
of thing." Bates' attempts to elicit support included sending an e-mail to twelve members of
Derbyshire Dales District Council (which falls outside the area which this licence is
designed to serve), informing them that the "three other probable applicants" for the licence
"would not cover your area" because they all planned to broadcast on FM, rather than AM.
Asked by staff how he could make such an assertion before the closing date for applications,
Bates argued that "there had been a fair amount of press coverage by that stage as to which
areas would be covered" by his competitors. The one noteworthy support letter was written
by Sir Nicholas Winterton MP, but his Macclesfield constituency is outside the proposed
TSA (and is served by Silk FM). Asked how much local support the group had managed to
attract for its application, Bates admits: "It would have been good to do an RSL, but we just
didn't have the people at the time [to do it]….. It's fair to say that for some other
[applicants], you can see from [their] applications, there is a fair amount of support….. We
haven't got so much of that on paper." Bates did manage to produce a support letter at the
end of June from Paul Hudson, with whom he had submitted a letter of intent for High Peak
in 1990. However, Hudson now lives in Kalgoorlie, Western Australia. The group's
projected year-one 16% reach is the lowest of the five applicants, but equates to the largest
projected number of listeners due to the implausibly large population in its proposed TSA
(see Finance section below).
Finance
 Greatly over-estimated TSA renders business plan unfeasible.
 No justified business case for AM.
 Unrealistic revenue forecasts.

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13. Peak AM's business plan hinges on its projected year-one 16% reach which, in its
proposed TSA of 208k adults, would give the station 33k listeners per week, the highest
audience of all applicants. However, given that the group's AM transmitter seems likely to
cover only a daytime population of 60k adults, the potential viability of Peak AM is highly
questionable. In addition to this problem, the group argues its case for using the AM
frequency on the basis that it would provide better coverage and lower transmission costs
than FM, but its application fails to expand the economic argument, or explain how it will
successfully sell AM to potential advertisers. Asked about this by staff, the group says it
anticipates no problem because the High Peak area is currently unserved by ILR and
therefore local businesses will advertise regardless of the new station's waveband. However,
staff experience is that local businesses are often reluctant to use the AM band for reasons
of both quality and audience demographics (a situation often exacerbated by FM
competitors). Even if Peak AM were to meet its target 16% weekly reach, which might be
possible given the lack of competition in this local area, it could prove difficult to convert
audience into revenue. The business plan is light on such detail, and has not considered the
economics of launching a new AM station at a time when AM listening is in long-term
decline. Advertising revenue is projected to be predominantly local, but a comparison of
Peak AM’s revenue forecasts against existing AM stations (Fresh, Sunshine, Maldwyn)
suggests that its £223k revenue forecast (the highest of all applicants) is too optimistic. Peak
AM's proposal to lease all its capital equipment reduces its initial cash outlay and keeps
cash balances at a high level, providing a cushion if revenue and costs prove under/over-
estimated. However, although Peak argues that the use of AM reduces its transmission
costs, its cashflow in this area is greater than all competing applicants except Temple FM,
and the £8k marketing budget looks lightweight for launching a new station, especially
when awareness of its brand has not been established through RSL activity. Total budgeted
expenditure of £20k per month seems low in comparison with stations of similar size, and
its funding of £150k share capital and £17k leases is the lowest of the five applicants. The
high revenue forecasts make the funding appear adequate, but the equilibrium becomes
quickly unbalanced when one takes account of the group's huge over-estimation of its TSA.
Peak AM was unable to provide finance confirmation letters from shareholders Roy Trevor
or Alan Thompson (total £30k) but, in further correspondence during June, did provide
alternative letters from Mr M.L. George (£10k) and Forward Media Ltd. (£40k), neither of
whom had been previously mentioned. Forward's 27% stake adds some comparative
reliability to the application, but the fact that the applicant's list of original investors could
not be relied upon must ultimately count against Peak AM. (Incidentally, Alec Craig, a
director of Forward Media, is already named as a director and investor in competing
applicant Temple FM.) In addition to the three aforementioned directors (Bates, Symonds
and Holmes), other shareholders include Tony Buckingham (who founded Fenland ILR
service X-Cel, before selling it to UKRD, which has now re-branded the station as Star
107.1) and Roy Trevor who, Bates explains vaguely, "bring an interest in radio listening and
finance to the group." 13% of shares would be allocated to unnamed "Peak District
investors" through an unspecified share offer.

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Temple FM (51%)
 Former Forward Media managers.
 Few local connections.
 No history of interest in the Buxton area.
14. Temple FM's name derives from the local heritage site Solomon's Temple, which
was built to provide work for the people of Buxton in the 1800s. The key individuals behind
the application were all involved in the successful 1993 launch of Morecambe's The Bay –
former managing director Kenni James, former news editor Chris Hornby, and former
company secretary Alec Craig. The Bay and Owen Oyston's other radio property, Belfast
City Beat, were subsequently placed in trust, until James created Forward Media Ltd with
venture capital funds to bid for both stations. The trust decided, instead, to sell the two
stations to what is now CN Group, and James, Hornby and Craig left The Bay to develop
Forward Media independently. As its chief executive, James turned his attentions to
Southport's Dune FM, which he bought in November 1999 from David Maker (who is now
Forward Media's chairman), and then went on to buy Kettering's Connect FM in March
2000 and Peterborough's Lite FM in March 2001. Subsequently, James says his "view on
the way the business should develop began to differ slightly from some of the other
shareholders." His initial policy of building two clusters of stations, one in the North West
and the other in the Midlands, was replaced with a policy to "purchase radio stations
wherever we could find them." Dissatisfied with Forward's new strategy which was, in
James' words, "to buy turf," he left the company in 2002, though he still retains a minor
shareholding. James then set up BJP Media Ltd., which he describes as his "little operating
company," buying radio advertising for clients, managing investments, and offering radio
programming consultancy services to clients such as the Spectrum FM group in Spain. The
nascent Temple FM applicant group had started while James was still employed at Forward
Media. In early 2001, Alec Craig (who remains a director at Forward) had introduced James
to successful retired businessman Peter Raymond, who had just left the post of acting chief
executive at a technology plc (though he remains non-executive chairman). Despite none of
them living within the High Peak district, Craig and James decided to bid for the Buxton
licence with Raymond (whose local connection is that he was born in the High Peak District
and several of his business interests are based there, although he lives in Cheshire) as the
group's chairman. In late 2001, James introduced former Bay and Forward cohort Hornby
(who lives in Lancashire) to Raymond as a fourth investor/director. Once James exited
Forward Media in 2002, the group started to gather more momentum and "a great deal of
time and effort has been expended on continuing to consult with local people and
organisations." At the same time as preparing this application, Raymond and James also
formed a separate company, Review Radio Ltd., of which they are both directors. It will be
a speech/lifestyle radio station, aimed at 35+ year old ABC1 businesspeople, that James
promises will launch live on the internet and on the Sky digital platform later this year.

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 No locally-based directors.
 Proposed station and sales manager has good track record.
15. The group's proposed 7.0 FTE staff and two freelance presenters seem adequate for a
station that would rely heavily on automation, although resources in the newsroom look
rather tight. The proposed appointment of Simon Walker as station/sales manager (and
executive director) is positive, given his experience in finance and radio management since
1995, and his track record of turning Connect FM and Lite FM into profit centres for
Forward Media. When asked why the group did not seek to appoint any locally-based
directors, James argued that "what gives a station localness is its programming – what it
does on air – rather than where the directors themselves come from." However, he admitted
that the group "realise, in terms of the heritage of our application, that we are way behind
one or two of the others that have been around for ten years or more in various guises."
Programming
 Basic commitment to speech content.
 Barely adequate newsroom coverage.
16. Temple FM would provide “an attractive mix of music from the 1950’s to the present
day,” with “full and up to date local information” in a full-service format aimed at 15-65
year olds. Apart from a network chart show, its output will be locally produced and
presented, with automation running between 1400-1500 and 1900-0600 daily on weekdays,
from 1800 on Saturdays, and from 1900 on Sundays. The group's commitment to speech
content is basic, offering 15-25% during daytime on weekdays and 5-15% in non-daytime.
However, its sample schedule shows live speech content considerably lower, at 12%
Monday-Saturday and 11% Sundays (excluding ‘Hit 40 UK’), while during its automated
output the speech reaches even lower levels. In response to staff questions, the group
explained that its daytime minima are, in fact, averages across daytime, and that it expects
to operate nearer its maximum limits, which only adds to the sense of confusion about its
proposals. Temple FM commits itself to seven short speech features: traffic and travel
updates hourly (half-hourly during weekday peaktimes); what’s on information six times
daily; farming news twice daily; business news twice each weekday; jobfinder and daily
public service information in each daytime show; and a weekly charity appeal.
Local/national 3½- to four-minute news bulletins are proposed hourly throughout the day,
with additional one-minute headlines and sport bulletins on the half-hour during peaktimes,
and 30-second headlines on the quarter hours during the weekday breakfast show. Extended
seven-minute news bulletins are proposed on weekdays at 1300 and 1800. Responses to
staff questioning show newsroom cover to be barely adequate to ensure updates for all the
scheduled bulletins and headlines, while future additional cover will be dependent upon
“appropriate financial performance.” The breakdown of categories in the group's music
policy, a 50s-current mix “with an emphasis on melodic, familiar tracks,” offers the highest
aggregate minima of all applicants, at 90%. This not only renders future variations in the
music mix almost impossible, but also makes many of the proposed maxima unachievable.
The proposed mix of era- and genre-based categories merely exacerbates the problem,

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inspiring little confidence in the group’s ability to have carefully considered its music
policies. The proposed minima for the era-based categories effectively render the genre-
based categories (easy listening and country) redundant. A weekend automated ‘Non-Stop
Country’ hour and a summer roadshow are also proposed. Temple FM would be heavy on
automation, suggesting that staff levels would probably be sufficient to cover the proposed
output, although, as noted above, newsroom cover would be stretched.
 No market research.
 High audience projections.
17. The group commissioned no market research because, it says, "accurate information
that would be invaluable for this application could be obtained by our own team and
helpers." It claims to have consulted "thousands of people" to determine what they want
from a local radio station, through a combination of presentations, e-mails and newsletters.
However, little direct evidence was submitted of the 480 responses which the group claims
that it received by phone, mail and e-mail, except for some e-mailed programming
suggestions from an ex-mayor of High Peak and some entries from the group's website
guestbook that merely demonstrate how little traffic it has generated (15 responses in two
months). The group says, oddly, that it "did not believe that it was appropriate to ask for
letters of support from the public." Its "experience of similar stations launching in a market
practically un-served by ILR" has guided Temple's audience projections, which are the
highest of all five applicants (24% reach and average weekly listening of 8 hours in year
one, rising to 32% and 11.5 hours in year three). This optimism is compounded by the
ambitiously large TSA within which it expects to obtain these figures. Despite staff
requests, the applicant provided scant statistical evidence to support its spectacular growth
predictions of a 92% increase in hours listened between year one and year three. "This will
be no ordinary station launch," the group promises. "This is what we do, as operators of
small-scale, professional radio stations." Staff are unconvinced.
Finance
 Optimistic revenue forecasts let down by over-estimated TSA.
 Over-confident sponsorship forecasts.
18. Aside from its lack of localness (none of the investors or directors lives within the
TSA), the application has a sustainable level of finance, costs are manageable, and revenue
projections look to have been based on Kenni James’ experience at Forward Media (though
this is not explicitly stated). The proposed station/sales manager, Simon Walker, is currently
station director of Forward Media Ltd.'s Connect FM (Kettering) and Lite FM
(Peterborough), both of whose revenues have improved rapidly to the extent that the two are
apparently now profitable. Projected year-one local revenue of £206k, increasing to £267k
in year three, is the highest of the four FM applicants, a direct result of the inflated 120k
adult TSA and the high reach/hours audience projections. Whether these would still prove
achievable in a more realistic business plan is unlikely. National revenue has been set at a
modest level, but sponsorship is unusually high – £75k in year one rising to £126k in year

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three – particularly since these projections are based on Forward Media stations, which
currently generate only £60k of sponsorship each. In response to staff questions, Kenni
James correctly asserts that Temple FM will need to sell advertising to the wider area of
High Peak, rather than to just one or two of the largest towns, and he argues that his
experience at The Bay (whose TSA comprises several disparate towns) is directly relevant
to this challenge. Projected revenue figures of £2.40-£2.55 per listener per quarter appear to
be based upon similar levels currently achieved by the Forward Media group. Such revenues
might be achievable, but are more likely to arise in years four or five, rather than during the
station's first three years. Cost projections are realistic, and the group has provided a
breakdown of its £36k marketing budget, which it views as a very important commitment,
alongside a visible involvement in the local community. Temple is funded by a mixture of
£200k share capital, £50k leases (mostly studio equipment) and a £100k overdraft that it
predicts will not be required. However, the group's over-optimism concerning the size of its
TSA and its high audience projections could impact significantly on its capital
requirements, particularly during the first three years on air.
Spring FM (51%)
 Localness largely rests on the fact that DLT was born in Buxton.
 Board lacks any kind of shared history.
 TWC FM is more focused on winning a licence in its native Leicestershire.
19. The substantial shadow of ex-Radio One presenter Dave Lee Travis (DLT) looms
large over the Spring FM application. DLT was born in Buxton, though he now lives near
Leighton Buzzard in Bedfordshire, and currently presents a weekend show on Luton-based
BBC Three Counties Radio. DLT's partner in the application is Cliff Sanderson, an IT
consultant who has run seven RSLs in the Vale of Belvoir area of Leicestershire since 2000.
The two first met in the mid-1990s at a London charity event, when Sanderson was planning
his campaign to have the Vale of Belvoir added to the 'working list'. DLT subsequently took
a 10% shareholding in Sanderson's company, The Wireless Company FM Ltd. (TWC FM),
and presented shows on some of its RSL broadcasts. However, he also hosted a programme
for rival applicant High Peak Radio during its final RSL broadcast in June 2001 and, in fact,
that group's application includes a letter from him in which he thanks the station's owners,
the Jenner brothers, for raising £2k for charity and "restates [his] support and best wishes for
their attempt to bring this radio station to Buxton and the High Peak on a permanent basis".
After that final RSL in Buxton had evidently fired his enthusiasm, DLT contacted
Sanderson in January 2002 and suggested that they submit a joint bid for the Buxton licence
based on their shared "passion for radio". However, the board of directors was not
assembled until the early part of this year, and only two of its members have any kind of
local connections. Successful broadcaster and author Michael Van Straten is a neighbour of
DLT (the two have broadcast together on Garrison Radio, which holds long-term restricted
service licences at four army barracks), while actress Sherrie Hewson (who plays Maureen
Naylor in Coronation Street) lives near Nottingham. Although he lives near Huddersfield,
schoolteacher Tony Tomlinson is chairman of Buxton Football Club, and Lance Dowson
was until recently the mayor and chairman of High Peak Borough Council, which is based

RA PAPER 43(03)
Page 15
in Buxton. Despite claiming publicly that "as Mayor, I clearly cannot support any one of the
five [applicant] groups", he nevertheless appeared at a Spring FM roadshow and joined the
group as a director, while still in office. This attracted the attention of the local press, who
questioned how the mayor's public promotion of Spring FM squared with the council's
declared neutrality between the five competing bids, and Dowson subsequently lost his
Labour seat in the May local elections. Not only is TWC FM the largest shareholder in the
group, but its remaining six individual shareholders all have existing relationships with
TWC FM Ltd, either as shareholders, staff or advertisers (DLT is a shareholder in TWC
FM, but not in Spring FM). Essentially, there is very little about Spring FM that seems
local. It is claimed that DLT would help to train the other presenters at the station, and even
that he might move back to the Buxton area, but he says that, if necessary, he could still
present his show from the studio at his Bedfordshire home. He adds that "the Buxton station
is a chance for me to prove to other colleagues in the radio industry something I have been
saying for years about how radio should be produced". However, in staff's view, DLT's
likely long-term commitment to Spring FM must be questionable at best, while Sanderson
and TWC FM appear to remain focused primarily on their native Leicestershire.
 Station manager has no previous commercial radio experience.
20. Spring FM's proposed station manager Mick Wilkojc, who lives in Hertfordshire, is
DLT's former producer at Radio One, and has assisted with the business plans though he has
no previous radio sales experience. The proposed 8.0 FTE staff are organised in an overly
bottom-heavy structure. The programming section has two "senior presenters" but no head,
and the sales department has two salespeople but no head, leaving Wilkojc directly
responsible for all areas of the station's operation. Given the group's ambitious speech
content proposals, the staffing levels seem barely adequate, and there is little consideration
given to serving Glossop or other outlying areas from the station's Buxton headquarters.
Programming
 Unrealistic programming proposals.
 Speech content too high for available resources.
21. Spring FM proposes a “unique radio service for all age groups” with “a diverse range
of music from the last six decades” and “devoted local news, issues and event coverage.”
Programming will be locally produced and presented for 22 hours a day on weekdays and
all weekend. Automated output is proposed between 0100-0600 daily for the first two years,
when it will be replaced by "an additional full time presenter and part time journalist.”
According to the application, daytime output would typically comprise “12 songs per hour
(39 minutes) … 4.5 minutes of commercials/sponsorships and … 16.5 minutes of news and
relevant speech…” These numbers serve to demonstrate the group's lack of experience in
managing a commercial radio station, being unrealistic in terms of track length, the volume
of advertising and the achievable speech content. From staff's experience, a typical daytime
hour of an average ILR music station comprises ten music tracks (38 minutes), ten minutes
of advertising, and 12 minutes of speech. Spring FM's speech content will be a minimum

RA PAPER 43(03)
Page 16
20% during weekday daytimes, increasing to 35% and 30% on Saturday and Sunday
respectively, levels which, in staff's view, are ambitiously high and unrealistic for a station
of this size. In response to staff questions, the group signals its intention to include in its
Promise of Performance seven short locally relevant weekday features, plus a one-hour
weekday breakfast ‘in the workplace’ feature to encourage listeners “to make requests,
dedications and comments.” Weekends would include an equally ambitious two-hour sports
programme with 60% speech content on Saturday afternoon; and three one-hour magazine
shows on Sunday evening, one of which (‘Spring Culture’) would have an unrealistically
high 80% speech content. Bulletins of local news, weather, travel and sport – 2.5 minutes
weekdays and 1.5 minutes weekends – would follow the IRN service hourly throughout
daytime, with the addition of headlines on the half-hour during peak times. News coverage
would be provided by two full-time journalists networking with local organisations and
contacts within the TSA. In response to staff questions, Spring FM explained that the
newsroom rota would consist of one journalist working weekdays, and the other from
Wednesday to Sunday, which leaves inadequate cover on Monday and Tuesday and casts
doubt on the amount of careful planning that has been put into the application. Spring FM
claims it would broadcast “the most diverse selection of popular music available from the
last six decades.” More specialised music output would include a network chart show, a pre-
90s music show ‘Memory Lane’ on Sunday (reminiscent of DLT's Radio One weekend
show), a show called ‘Generations’ that selects music from a specific decade, and a
children's show ‘Kids Stuff’ on Saturday morning (similar to Radio One's 1970s schedule,
but without Ed Stewart).
 No formal market research.
 Support confined largely to signatures on petitions.
22. Market research for this application was limited to a questionnaire designed by the
directors and distributed by station volunteers to 177 shoppers in Buxton and Glossop, the
results from which are wholly uninformative. Asked why no formal market research was
commissioned in support of its application, the group responded that "the board considered
that the market research undertaken was formal," though admitting that "a specialist was not
employed." The evidence of local support for Spring FM is not especially convincing either,
consisting largely of 1000 signatures gathered at the group's roadshows, plus around forty e-
mails and letters from individuals. The group's audience projections (18% reach and 11
hours in year one, rising to 30% reach and 11 hours by year three) have been calculated by
averaging the current performances of seven existing stations with TSAs of less than
85,000. However, two of the stations cited (Channel FM and Island FM) are atypical
because they dominate geographically isolated markets, and four of the seven (the two
aforementioned plus Vale FM and Delta FM) are hardly start-ups, having been on-air for
more than seven years.

RA PAPER 43(03)
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Finance
 Little local involvement.
 High and unjustified revenue forecasts.
 Personality presenter [DLT] may help in revenue generation.
23. Unsurprisingly, given that it is an applicant with no previous commercial radio
experience, Spring FM's financial research is poor, its forecasts were not submitted in the
required format, and its revenue assumptions are unjustified. Though the business plan has
no major omissions, the group's low level of funding could force it to seek additional
funding in the station's second year, without any obvious sources of additional finance.
Having a 'name' such as DLT involved in Spring FM may carry some weight with potential
advertisers, but this modest advantage certainly does not justify the anticipated doubling of
local revenue from £156k in year one to £352k in year two, with a further 25% increase to
£440k in year three. This is an overly ambitious three-year plan, and the applicant's own
description of these targets as "conservative and achievable" demonstrates its apparent
ignorance of revenue streams typically generated by new local radio stations. The group's
decision to price its local ratecard on a cost-per-thousand basis is particularly unusual for
such a small station, and could prove a particularly onerous way to sell advertising to local
businesses. In response to staff questions, the group argues that RAJAR audience data is
irrelevant to local revenue performance because local customers are more sensitive to price
competitiveness, but staff feel that customers might appreciate some stability in prices. The
group's cost projections are a mixed bag, with overheads of £30k in years one and two and
£34k in year three possibly achievable with good financial management. The cost of the
eight staff is high, due to an average salary of £24k which seems out of line with industry
norms, but the £21k marketing budget looks reasonable for the launch year. Transmitter
costs are a little confused, since the costs are fairly low and diminish in years two and three,
which makes little sense. Spring FM has the lowest funding requirement of all five
applicants and, worryingly, has no bank facility in place, though its correspondence
promises that an overdraft or share issue would make good any shortfall. The largest
shareholder, TWC FM, is unlikely to have access to large funds, and the budgeted £220k
capital base would produce cash balances of less than £100k in year one. Insufficient
attention has been paid to sensitivity issues and contingency plans, so that revenue shortfalls
in year two (as experienced by many new stations) would precipitate major cash shortages.
Although the directors have offered their services free of charge until profitability occurs
(forecast for year two), such financial problems could make them nervous and lead to
internal management problems, as has happened before at other small-scale stations.
Strongest applications
24. The rest of this Paper assesses the proposals of the two highest-marked applicants
under a series of specific subject headings, thereby enabling Members to compare and
contrast the groups' respective strengths and weaknesses.

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History and composition of the applicants
 High Peak Radio has conducted five RSLs in Buxton, and FM The Edge three.
 Both groups include individuals with small-scale ILR experience.
 High Peak Radio has more cohesive history and composition.
25. High Peak Radio (72%) has a track record of five RSLs in the area since June 1999.
The force behind the group are Derbyshire brothers Steve and Paul Jenner who, under the
name Broadcast Brothers Partnership, have operated a total of 14 RSLs within the Midlands
region since 1996. They made an unsuccessful bid for the Chesterfield licence in 1998,
which was awarded to Wayne Chadwick's Peak 107. The failure of that Chesterfield
application (which had slightly out-scored Peak in the staff's marking) forced the Jenner
brothers to turn their attentions to the neighbouring Peak District where, five years later,
they find themselves competing for a licence against the very same Chadwick, now no
longer involved in the Chesterfield station. To their credit, the Jenner brothers have a greater
claim to High Peak "localness" than does Chadwick. Paul Jenner lives in Buxton and works
as a self-employed "entertainments business manager" after building his own career as a
nightclub DJ and then as an agent for other DJs. He also appears to possess sales skills,
claiming to have generated £17k revenue from the group's last four-week RSL during June
2001 in Buxton. He will take the role of full-time sales director at the station. Brother Steve
Jenner also lives in Derbyshire, just outside the station's proposed TSA, and works as a
secondary school Deputy Head of English. His people and management skills have been
employed in organising the RSL broadcasts and he will take the role of part-time operations
director, becoming full-time if and when the station can afford it. Soon after their
disappointment in Chesterfield, the Jenners started recruiting local people to their board for
this application. Local businesswoman Jennie Ball had already been a board member for the
Chesterfield bid, conveniently lived within High Peak, and has served on the boards of the
local Enterprise Agency and NHS Trust. Retired civil servant and Buxton local historian Dr
Mike Langham joined in 1998, and brings his experience as a former management
consultant and management college assistant director. Buxton solicitor Tim Oddy joined the
board in 1999, having already lobbied the IBA for a Buxton licence as early as 1988, when
he incorporated the company Radio Peak Ltd with "veteran High Peak community radio
campaigner" Tony Francis, who will be chairman of the group's Feedback Panel. Buxton
resident and Conservative Borough Councillor Clive Beattie was recruited in 2000 to be the
group's chairman; he combines business experience (ex-group MD for National Freight, six
local business start-ups including a Buxton nightclub) with civic duties (chairman of the
Buxton & District Civic Association, director of High Peak Theatre Trust).
26. Four of the five Buxton RSLs between 1999 and 2001 used the name Radio Buxton,
confusingly the same name as adopted in 1988 by another local group for its first Home
Office-licensed temporary broadcast, which competitor FM The Edge [see below] now
incorporates into its heritage. FM The Edge claims that the Jenner Brothers used the name
"without agreement," whereas High Peak Radio chairman Beattie argues that his fellow
board member (and solicitor) Oddy incorporated a company of that name in 2000
specifically for the RSL. For the Jenner Brothers' fourth RSL in 2000, the name was
changed to 'Radio High Peak' because the transmitter site was re-positioned to offer
coverage to a wider area of the district, although the studio remained in Buxton. The subtle

RA PAPER 43(03)
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change to 'High Peak Radio' for this licence application is a result of "people's usage of the
terminology locally," according to Beattie. A lifelong Buxton resident, Beattie demonstrates
an understanding of the difficulties faced by a single radio station serving the whole High
Peak district, from Glossop in the north to Buxton in the south. He believes that the group's
decision to base its main studios in Chapel-en-le-Frith, between its two proposed radio
contribution centres in Glossop and Buxton, helps resolve the issue that "Glossop people
need to feel that it is their radio station, as much as Buxton people need to feel it is their
radio station." Beattie replaced Trevor Gilman as chairman, who held the post from 1998 to
2000, but did not wish to make a substantial investment in the group, which had become, as
Beattie explains, "a lot more serious than he had thought." The "serious aspect" of running
the radio station had been highlighted when the Jenner brothers were successfully sued for
£8,000 compensation by a Buxton RSL listener who, having won a Renault Clio in an on-air
competition, was surprised to be given a four-inch toy car as the prize, a story which
attracted national press coverage. Beattie says the group learned directly from this
experience "how important it is to control the station output." In 2000, Chrysalis Radio had
agreed to make an investment (of 40-50%) in the group and also sought to involve a
Manchester newspaper as an additional shareholder. However, in Spring 2002, Chrysalis
told the local group that its development strategy had changed and the investment would no
longer be made. According to chairman Beattie, the group "had to act very quickly when
they did pull out," and the Jenner brothers contacted potential investors to replace the
Chrysalis holding. A positive response was received from Chris Carnegy, owner/MD of
SouthCity FM (Southampton) and former chief executive of The Local Radio Company and
Spire FM in Salisbury (before its sale to Radio Investments). Carnegy first met the Jenner
brothers in 1996 and had been a shareholder in their failed bid for Chesterfield in 1998. He,
in turn, introduced the Buxton group to Roger Price, who had worked as deputy PD within
the Capital Radio group, chief engineer at GWR FM Swindon, and wrote The Bear's
winning licence application for Stratford-upon-Avon where he worked for five years as
MD. By October 2002, Carnegy and Price had together agreed to replace Chrysalis'
investment, with Price becoming the group's largest single shareholder. Price wrote the
licence application and will be employed as station launch director for a six-month period.
The group's final director, Sylvia Green, was added to the board in February this year as a
representative of Glossop, in the north of the proposed TSA, where she is director of the
town's Volunteer Bureau and an ex-Labour councillor.
27. FM The Edge (also 72%) is a combination of two distinct elements. The first is a
group of local radio activists who have been trying to bring local radio to Buxton since the
1980s. The second is radio executive Wayne Chadwick, with a little investment help from
The Wireless Group. Chadwick applied unsuccessfully last year for the Barnsley licence in
partnership with Radio Investments Ltd. He has been a station manager without a station
since 2001, when he sold Peak 107 to Forever Broadcasting for £4.8m (10% in cash plus
three million Forever shares). Forever promised that Chadwick would stay on "to help build
our business as the number one station for Chesterfield," but the two parties fell out and
Chadwick exited immediately. Since then, there has been a very public war between
Chadwick (who, with fellow ex-Peak directors, holds 17% of Forever) and Forever's
management team over the alleged £800k per year overheads of its Newcastle-upon-Tyne
headquarters, though Chadwick claims that a ceasefire prevails since the resignation of
Forever managing director Eric Lawrence earlier this year. Chadwick's association with The

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Wireless Group was forged when both attended meetings as significant shareholders in
Forever ("as concerned shareholders, not as conspirators," explains Chadwick). This
application's heritage derives from two acts of triumph over adversity. The first is
Chadwick's track record of success at Peak 107 between its 1998 launch and 2001 sale,
which is why the application gushes about that station's "substantial audience figures,"
"profit at the end of its first full year," and "achieving double the projected sales figures."
The second is the Buxton radio group's pioneering RSL in 1988 under the Home Office
Special Events licensing scheme. How the two came together in FM The Edge is a matter of
some conjecture. The application explains that "in March 2001, the [Buxton] group formally
joined forces with Peak 107," but the merger could equally be interpreted as a reverse
takeover, initially by Peak 107, then latterly by Wayne Chadwick individually once he had
left the station. The local group's history started in 1987 when Buxton resident Printz
Holman assembled a team of people interested in the idea of starting a local radio station.
Holman's background in offshore radio, radio commercial production and broadcast training
proved useful to the group's success in organising the town's first radio broadcast as Radio
Buxton to cover the 1988 Buxton Festival. After its initial success, the group held public
meetings to gather support for a permanent licence, one of which was attended by over 200
people, and set up a small radio production studio in 1990 which has trained local students
continually since then on a work experience scheme organised by Derbyshire County
Council. However, it was not until radio licences for two nearby areas were advertised in
1997 that interest in a radio station for Buxton was stimulated once more. Holman's group
merged with both High Peak Broadcasting, who had been campaigning separately for a
licence in the New Mills area, and with a local hospital radio group who were considering a
licence bid. In May 1998, Silk FM launched in Macclesfield, 12 miles to the west of
Buxton, and five months later, Peak 107 launched in Chesterfield, 24 miles east of Buxton.
Peak 107 had expressed interest in securing a low-powered relay to extend coverage to the
towns of Matlock and Bakewell in the Peak District, and Authority staff agreed that an
additional FM frequency could be made available without jeopardising any other anticipated
licence awards in the region. These developments understandably frustrated the Radio
Buxton group, who were fearful that their decade-long effort to secure a local licence might
suddenly be upstaged by Peak 107.
28. At the start of 1999, Holman and Chadwick met and reportedly found some common
ground, yet the two continued to pursue their own separate plans for a future licence
application. Chadwick wrote a Peak 107 letter of intent to the Radio Authority in January
1999 and, in March, Buxton was one of the areas added to the working list. Chadwick
agreed to provide Peak 107's outside broadcast facilities for Holman's group to stage an
RSL to cover the Millennium festival in Buxton at the end of 1999. In the meantime,
Chadwick pressed ahead with his own plans for a Peak 107 application for the Buxton
licence, recruiting Buxton businessman Mike Watson as his group's chairman. Chadwick
and Watson were already co-directors of a separate company, FM Interactive Ltd, that the
two had established to build interactive web sites for radio stations (neither is involved in
the business today, and its current chairman is Peak 107 chairman Barrie Evans). To
strengthen the localness of the board, Chadwick approached long-time associate Michael
Fay, Yorkshire regional officer at the ITC, while Watson enrolled High Peak resident Liz
Stillo who he knew through the local Chamber of Commerce. While Holman and Chadwick
were busy planning their strategies, in mid-1999, the Jenner brothers broadcast their first

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RSL in Buxton and adopted the same 'Radio Buxton' name that Holman had first used in
1988. Holman was forced to adopt a new name 'The Edge' for his Millennium RSL
broadcast. Two further RSLs followed, in 2000 and 2001, both with different names. The
2000 RSL, as 'Team Edge,' was a combined Holman/Peak 107 venture, with Chadwick's
station providing news resources, commercial production and some finance. The 2001 RSL
was named 'Peak FM' to reflect the fact that Peak 107 was now firmly in the driving seat
and viewed the licence as a trial for its own application for the Buxton licence. Chadwick
explains that Holman's local group "helped us considerably with the Peak FM RSL," and the
application says that "members of Team Edge were actively assisting with the RSL," which
is why "Printz Holman accepted an offer from Wayne Chadwick to join the board of this
group." Chadwick admits that, had he remained at Peak 107, any further RSLs would have
been organised under the station's aegis. Chadwick's plan for Peak 107 to bid for Buxton
ended abruptly on his departure in 2001, and the station's new owners Forever became too
preoccupied with Peak's subsequent ratings decline to maintain its own interest in a Buxton
application. Only then did Chadwick refocus the Buxton application around Printz Holman's
group, rather than Peak 107. The vexed question of whether it is Chadwick or the local
Buxton group leading this application is illuminated by Chadwick's response to one question
from staff: "If Printz [Holman] was sitting here, he would say he was supporting me
ostensibly." However, Chadwick and his chairman Mike Watson insist they have done
everything possible to involve the local group in the application process. Chadwick also told
staff that he has no burning ambition to buy back Peak 107 from Forever. However, if
awarded the Buxton licence, it is proposed that Chadwick would become managing director
of both FM The Edge and The Wireless Group's Imagine FM in Stockport. The planned
fourth transmitter mentioned in the group's application for the eastern part of the area would
ensure that FM The Edge's TSA becomes contiguous with that of Peak 107. It would then
appear to make perfect sense for The Wireless Group to purchase neighbouring Peak 107
from the ailing Forever group and reap economies of scale from owning three contiguous
stations in Stockport, Chesterfield and the High Peak district. The Wireless Group already
sells national advertising for the Forever stations, and this licence alone would fill a useful
gap between Imagine FM and Peak 107 on its sales map.
29. The staffing proposals of the two strongest applicants are as follows:
High Peak Radio FM The Edge
Presentation: 2.3 4.0
News: 1.6 2.0
Sales: 1.5 2.0
Management/administration: 1.2 1.0
TOTAL: 6.5 9.0
Note: Numbers shown are Full Time Equivalents (FTE). Jobs encompassing more than one role (e.g. managing/sales director)
have been split 50/50 unless otherwise stated in application. Part-time posts have been arbitrarily allocated FTE of 0.5.
Table portrays 'total manpower on site'; hence, no distinction has been made between staff and freelance personnel.

RA PAPER 43(03)
Page 22
 High Peak Radio proposes significantly lower staffing level than FM The Edge.
30. High Peak Radio's 6.5 FTE staff would work in a cross-functional environment that
covers the necessary departmental functions – news, programming and sales – within the
station. This is the lowest staffing level of the five applicants, but should prove feasible,
particularly given Carnegy's track record at Spire FM productively organising such
relatively small numbers of personnel. Launch director Roger Price has directly relevant
skills and, when he leaves after the station's first three months on air, either Steve or Paul
Jenner would assume the role of full-time station manager. FM The Edge's proposed 9.0
FTE staff is the highest number of the five applicants, although its first year salary costs are
only the third highest of the five, partly because managing director Wayne Chadwick's
salary would be shared with Imagine FM. The organisational structure, with a sales manager
and programme controller reporting to Chadwick and providing day-to-day supervision of
the other staff, would provide the station with an effective management system.
Programming
31. Significant aspects of the two strongest applicants' programme proposals which are
quantifiable are as shown below:
Primary target audience (age) 25-54 25-64
Daytime speech (%): weekdays
weekends
20-35
15-30 (Sat)
10-25 (Sun)
15-30
15-25
Local news: weekdays
weekends
06.30-18.30
08.00-12.00
07.00-18.00
08.00-13.00 (Sat)
08.00-12.00 (Sun)
Automation (hours per week) 100 76
 High Peak Radio proposes higher level of automation.
 FM The Edge proposes more contemporary music mix.
 Both offer similar weekday daytime speech content.
32. High Peak Radio proposes a full music and information service for adults, with
“something local in every link,” aimed at 25-54 year olds. It promises that “over 97% of
regular programming will be locally produced and presented,” the exceptions being a
networked chart show and “certain one-off special programmes [that] may be originated
from outside the High Peak” in the form of live outside broadcasts. The group's intention to
automate its weekday afternoon programme (1300-1700) represents the first occasion on
which an applicant's proposals have contravened the Programme Code which states that "as
a general rule, FM stations with a Measured Coverage Area with an adult population of
more than 50k should not broadcast more than two hours of automated output during

RA PAPER 43(03)
Page 23
daytime hours." However, one of the main grounds for exemption from this rule is the level
of daytime automation indicated at the time of application, and a licence award to High
Peak Radio would need to be made on the understanding that the station would broadcast
four hours of automated output during daytime hours. The group would also schedule
automation between 1900-0600 on weekdays, 1800-0700 on Saturday and 1900-0600 on
Sunday, although it wishes "to reserve the right to reduce automation in future.” The music
policy would comprise hits from the last four decades, with 25-35% current hits, 5-10%
recurrents (6 to 24 months old), 25-40% 80s/90s and 25-40% 60s/70s. This would give the
station a less contemporary feel than proposed by competitor FM The Edge, but leaves little
flexibility for its programmers. ‘High Peak Party’ on Saturday evening “will feature a
variety of up-tempo songs,” while ‘Love Town’ every other evening would be non-stop love
songs. Speech content is proposed to comprise a minimum 20% of weekday output, 15% on
Saturday and 10% on Sunday. Eight locally-oriented short features would be included in the
Promise of Performance: weather reports following all news bulletins/headlines, 0600-2100;
travel news twice an hour during peak periods; ‘Park Life’, a weekend breakfast feature for
outdoor pursuits including a notice board for Peak Park Rangers and regular park users; at
least three daytime what’s on roundups; a weekday mid-afternoon ‘News Focus’; twenty
daily local community group appeals and/or information; a weekday mid-morning ‘Insiders’
local expert slot; and a twice-daily ‘High Peak Performance’ showcasing local arts events.
IRN news would be appended by two-minute local news bulletins during weekday peak
times, supplemented by 90-second headlines and one minute of sport on the half-hour.
‘Action Afternoon’, a Saturday afternoon music-led show with local sports features and
score updates, would also be included in the Promise of Performance. High Peak Radio's
application offers a large dose of enthusiasm, but its proposals should be deliverable within
the resources outlined, particularly in light of the above-average commitment to automation.
33. FM The Edge offers a variation on the standard small-scale ILR format of classic
hits mixed with local news and information. The group has given itself enough flexibility to
vary its music mix in order to meet changing tastes without the risk that it could lose its
broad character of a classic hits station, while its proposals for speech content would
guarantee a range of locally-relevant features throughout daytime output. FM The Edge
would be almost entirely locally-produced and presented, and would be automated during
non-daytime periods only. At 15%, the group is offering a lower minimum commitment to
speech content during weekday daytime than its main rival High Peak Radio. However, its
sample programme schedule suggests that in fact speech would never fall below 20% during
this key period, and more than enough features are proposed to enable the station to
maintain such a level. In response to follow-up questioning on this point, the group stated
that the 15% minimum was to allow for occasions when an "abnormally low advertising
load" might lead to one additional music track being played in any hour, and thus the
percentage of speech falling below 20%. Given that Promises of Performance and Formats
allow for a degree of flexibility in respect of minimum speech content levels, staff believe
that FM The Edge would be prepared to commit to a 20% minimum if this was suggested.
In addition to the standard features such as travel, weather and what's ons, the group is also
committed to broadcasting a range of short items, many with the opportunity for audience
participation, and longer items such as outside broadcasts (which would appear monthly)
and exposure for local charities. In response to a staff question regarding its claimed
recognition of children and family values, the group offered additional commitment (i.e. for

RA PAPER 43(03)
Page 24
inclusion in its Promise of Performance) to its weekday evening output, which is
specifically aimed at teenagers, and its Sunday breakfast show, which is proposed to have
"an emphasis on the local family at home." A fairly standard news schedule would see
bulletins including local stories broadcast hourly throughout weekday daytime and until
lunchtime at weekends, with an extended 10-minute bulletin at 1800 each weekday. This
output would be produced and presented by the two in-house news staff, each of whom
would work six days a week. It is stated in the application that additional support would be
provided by local news agencies, but in response to follow-up questioning the group
revealed that no such agencies exist in the High Peak area. Musically, FM The Edge is
offering what appears to be a more contemporary service than its rivals, with current and
recent hits likely to form the largest proportion of the daytime output. Its proposals have
enough flexibility that songs which were hits between one and forty years ago could form a
majority (60%) of the output, but given the widespread popularity of current music in the
group's research and the lack of any ILR competitors in the area, it seems unlikely that the
station would seek to adopt this approach. The two proposed specialist music programmes,
country and soul, both proved popular when included in the group's RSLs and were also
well received in the research, while the 'Local and Live' programme scheduled for Sunday
evenings would provide exposure for local bands and feature live sessions. All three are for
inclusion in a 'Promise of Performance'.
Market and audience research
 High Peak Radio's research is flawed.
 FM The Edge's research provides useful insights.
34. High Peak Radio's audience research was commissioned from Nichola Atkinson,
who has provided an unfathomable analysis of results that merely state obvious
generalisations which would be applicable to any radio market. Respondents said they
wanted lots of local news and information, classic hits, professional presenters and mostly
music. The net effect of the research is to detract from, rather than add to, the application,
particularly with bar graphs that reach 240%, tables that show respondents choosing Radio 5
for its music output, and questions about music preferences that offer two-decade tranches
(such as "80s/90s"). Asked by staff to explain this last anomaly, the group replied that it was
"keen to keep things simple" and was "mindful that respondents are unlikely to be aware of
precise music history," seemingly regardless of whether the resultant data might be of any
use when programming the station. FM The Edge commissioned higher quality market
research from Keith Gorton Services that offers true insights into the district. Respondents'
answers from 500 street interviews demonstrate that the largely rural High Peak lacks
cohesion because the two largest towns are fifteen miles apart, at opposite ends of the local
authority area. Buxton, in the south, is geographically closer to Macclesfield (which already
has its own ILR station) than it is to Glossop in the north, and Glossop itself is closer to
Manchester than Buxton. The group's research shows graphically the lack of intercourse
between the two towns, with very few residents travelling from one to the other for work,
leisure or major household purchases. Inhabitants of Buxton and Glossop appear to have
little in common except that both clearly look to Manchester, and particularly to its southern
suburb Stockport, as their metropolitan centre, and both are technically unserved by ILR.
The group has addressed the need to attract audiences at both ends of the TSA by providing

RA PAPER 43(03)
Page 25
a contribution studio in Glossop that will support its main studio in Buxton, but has not
proposed opt-outs or split programming. Substantial proportions of Glossop residents
named their local radio station as Piccadilly/Key 103 and BBC GMR (40% and 29%
respectively), which reveals a degree of out-of-area listening, whereas Buxton residents
correctly believed their local radio station to be BBC Radio Derby (31%). More
significantly, 43% of Buxton residents named their local station as one of the nine RSLs that
has broadcast in the town since 1988, a reflection of the collective impact that short-term
licensees have made despite their temporary nature.
Audience forecasts
35. The weekly reach and average hours forecasts for years 1-3 of each of the two
strongest applicants are as follows:
TSA population (adults) 66,250 95,000
Year 1: Weekly reach
Average hours
24%
9.5
21%
9.5
Average hours
27%
10.5
22%
10.0
Average hours
30%
11.0
24%
10.5
 Both propose reasonable audience forecasts.
 High Peak Radio's choice of TSA size is more realistic.
36. High Peak Radio based its forecasts on findings from its survey and also "the actual
recent experience of young, small FM stations in underserved English local radio markets."
The average hours performance of South Hams Radio is cited as a comparable example, as
the Devon station currently obtains a 33% weekly reach in a TSA almost identical in
population terms to that proposed by High Peak Radio. FM The Edge's forecasts were also
based on research findings, but the existing stations it studied as comparators (Hallam FM
and Orchard FM) do not seem at all relevant to this Buxton market. That said, the steady
growth projected to year three seems attainable. Questioned by staff about the new station's
effect on existing listening patterns, the applicant asserts realistically that "most listeners
will view FM The Edge as an addition to the bouquet of services available in the area, rather
than as a replacement for any existing station."
Local involvement and support
 High Peak Radio provides greater evidence of local support.
 Most of FM The Edge's support is in the form of pre-printed postcards.

RA PAPER 43(03)
Page 26
37. While its market research lacks substance, High Peak Radio's local support proves
to be more significant. The five RSL broadcasts attracted substantial local press coverage
and the group commissioned independent research reports (not from Nichola Atkinson)
after the two 1999 broadcasts which showed that 75% and 92% respectively of respondents
had listened to the RSLs. The first RSL alone elicited 1700 phone calls from listeners; the
third RSL raised £2000 for a local cancer hospice; the fourth RSL broadcast information for
residents about local floods; and the fifth RSL provided a live, ten-hour General Election
special preceded by a pre-election debate between local candidates. Devoted Buxton RSL
listener Sheila Smith organised a petition of 1,434 signatures asking the Authority to grant
Buxton a permanent licence, while one independent Buxton newsagent organised a petition
that attracted 130 signatures. Additional support letters were received from 301 individuals,
64 businesses, 41 community organisations and 26 public bodies. Letters specifically
supporting this group's application were received from Tom Levitt MP (Labour, High Peak),
three East Midlands MEPs, two county councillors, two borough councillors, eight parish
councils, Buxton Opera House, Federal Mogul (the area's largest private employer), Glossop
residents Wayne Fontana (of Mindbenders fame) and Eric Haydock (of the Hollies), and
actor Bruno Langley (Todd Grimshaw in Coronation Street). Despite its legacy of Buxton
RSLs, FM The Edge provided significantly fewer press cuttings than competitor High Peak
Radio to demonstrate the impact of its activities. 1222 pre-printed postcards were returned
by supporters (without the incentive of a competition prize). 245 letters of support from
local individuals and organisations were received, with specific endorsements from Tom
Levitt MP (again; he is well disposed towards both of these applicants), the High Peak
Council for Voluntary Service, Derbyshire Learning & Skills Council, Castleton Chamber
of Commerce, Glossopdale Community College, Freemasons Buxton Lodge, and actor Nick
Cochrane (Andy McDonald in Coronation Street).
Financial proposals
38. The major shareholders of each of the two strongest applicants are as follows:
Roger Price 26% Wayne Chadwick 35%
Chris Carnegy 15% The Wireless Group 30%
Steve Jenner 14% Mike Watson (chairman) 10%
Paul Jenner 14%
Clive Beattie (chairman) 10%
 High Peak Radio is the most local applicant with good contacts.
 FM The Edge financially reliable with few omissions.
 High Peak Radio proposes achievable revenue forecasts, though costs underestimated.
39. Deriving about 40% of its funding from within the proposed TSA, and having
conducted five RSLs, High Peak Radio is easily the most local of the five applicants.
Consolidating its already impressive local support in the area, the group contacted former
advertisers from its RSLs to determine their interest in a full-time station, and claims to
have received more than forty positive responses from local businesses keen to advertise on

RA PAPER 43(03)
Page 27
High Peak Radio. Such advertiser support should not be underestimated when it comes to
launching a local station, with Radio Pembrokeshire providing an excellent example of how
such relationships with local businesses have helped generate an estimated £450k revenue in
year one. High Peak Radio has run sensitivity tests on its business plan and finds revenue to
be the key driver. Consequently, the group has ensured that its cost base can be fine-tuned
by, for example, employing a part-time operations director whose hours can easily be
adjusted. The business plan has taken into account the economics of the TSA (e.g. much
consumer spending power is diverted to Manchester) and understands the need both to
deliver an audience and to communicate the benefits of radio to potential advertisers,
especially those outside the immediate TSA. High Peak Radio's local revenue forecasts are
by far the most prudent of the five applicants – £124k in year one rising to £161k in year
three – and should be easily achievable, as should the £50-70k sponsorship income.
National revenue has sensibly been set to zero for the first three years. The group has
already identified 17 local businesses who would be expected to spend £70k per annum in
total, and should have no trouble reaching its £232k income forecast for year three. High
Peak Radio has taken care to keep its costs low by proposing multi-skilling, minimising
fixed overheads (through equipment purchase), avoiding leasing and interest charges, and
using technology (i.e. automation). The £100k cost of the 6.5 FTE staff is considerably
lower than competing applicants, while the marketing budget of £33k is sensible and fits
with the group's stated marketing strategy. Nonetheless, a cost base of £17k per month
seems too low, even with high usage of automation, when small commercial (i.e. not
community) stations typically cost £30k or more. Asked to explain why its forecast costs are
so low, the group cites Connect FM's launch in 1990 with a cost base of £15k, and says “we
suspect there has been deflation in small station costs since then.” However, the costs of
Connect (and Spire FM and Vale FM, who are also cited) are currently more than £40k per
month (although there are stations, such as Waves Radio Peterhead, which are known to
operate on a figure as low as £17k per month). The station would be funded by a healthy
£272k of share capital, the majority from Chris Carnegy and Roger Price who, with carried
interest, would hold 15% and 26% respectively of the shares. The group's investors are
considered reliable, since South City FM (which Carnegy controls) issued a further £150k
share capital in May 2003, most of which was purchased by Carnegy. Overall, the level of
funding is not necessarily too low, but both revenue and costs seem somewhat
underestimated.
40. FM The Edge's national revenue forecasts of £8k in year one, rising to £25k in year
three, are justifiable because shareholder The Wireless Group would handle national sales
through its Impact subsidiary (as an example, nearby Peak 107's national sales are currently
£70k). The group's local revenue forecast of £179k in year one, rising to £236 in year three,
should be manageable, given Chadwick’s ILR experience and the proposed team of two
salesmen. The station could potentially benefit from joint sales with TWG-owned stations in
nearby areas, such as Imagine FM in Stockport which also serves a 'Manchester fringe'
district. Sponsorship income is forecast at a constant 21% of income, which is comparable
to similarly-sized Wireless Group stations. The group's year three income projection of
£390k seems a little optimistic, but that target is much more likely to be achieved by FM
The Edge than by Temple (who predicted the same amount). As local advertisers will not
have used radio before, the group sensibly intends to offer simple spot packages, making it
considerably easier to see what you would get for your money than Spring FM's reliance on

RA PAPER 43(03)
Page 28
a cost-per-thousand basis. Because functions such as engineering, sales traffic, credit control
and management accounts will be contracted to The Wireless Group, the group's cost base
of £30k per month will be put to productive use, allowing the station to focus on editorial
and sales decisions. FM The Edge is proposing more staff – nine FTE (seven full-time, four
part-time) – than other applicants, and is rightly expecting them to work flexibly. The
marketing budget of £31k for the launch year compares well with competing applicants
(Wave 102, The Wireless Group's station in Dundee, was launched with a budget of £33k in
a market already served by ILR). The group's £233k capital outlay is large because it plans
to purchase all its equipment, which is effective in reducing its ongoing costs, but produces
negative cash balances almost immediately that will strain the £150k overdraft facility that
proves necessary throughout the first three years. The group's combined £300k share capital
and overdraft provide the highest level of funding of the five applicants. Because the
operational cost base has been set at a realistic level and, because revenues do not appear
over-estimated, the financial structure of the application does not appear clumsy. The group
has opted to use its overdraft to fund working capital before its cash returns become positive
in year four, which is sensible and common practice at other stations (i.e. few profits and
continued borrowings, well after the three-year forecast period). Both The Wireless Group
and Chadwick are considered to be reliable investors – the latter has cash from the sale of
Peak 107, and the former, despite continuing losses, is improving its results and has an
estimated £4m unused on its credit facility. There is perhaps an over-abundance of small
individual investors in the application, who were probably included to increase its localness
and, while the small amounts involved give no cause for concern, these investors seem
unlikely to be involved for longer than the short term.
Grant Goddard
2 July 2003

'Radio Authority Local Licence Award: Buxton' by Grant Goddard

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'Radio Authority Local Licence Award: Buxton' by Grant Goddard