Social Gain Principles of Community Radio Threatened

I’ve been told that Community Media Association is consulting on the principle of lifting the cap on commercial on-air advertising for community radio stations, and thereby moving away from the primary purpose of community radio for social gain.

I’ve attached some screenshots that were shared with me from an open forum, which indicate the tenor of the discussion and the intent to move away from the established principles on which community radio has been established in the UK.

I have two principal observations:

  1. The social gain principles embedded in the legislation founding Community Radio define the core principles of public benefit and should not be watered down for narrow expediency or subjective opinion.
  2. If community radio stations wish to change their licence status, and operate freely in the commercial marketplace, they should transition to an ILR licence, and develop a sustainable business plan, but forgo the discounted licences for PPL/PRS and the WTF fees.

As you can all attest, many stations are not dependent on the income generated from on-air advertising, nor do they wish to use this mechanism to develop their service, as they value their distinctiveness, independence and their editorial integrity, which they seek to put in service to their defined communities.

Many stations have developed models of funding and support that are based on low-cost, participative and developmental models of community radio, that are clearly different from those stations that are imitating commercial models of radio. They are dependent on the licence discounts and the protections that community radio licences give them.

My intuition tells me that if the principal of social gain is forgone, then so goes the principal of protected status for community radio.

It would subsequently be impossible to argue that community radio stations should be subjected to protection and discounted licence fees.

I understand that interests change and evolve, but this attack on the principles of community radio, is likely to lead to be detrimental and lead to the dissolution of community radio as an active social movement here in the UK.

I am not against a free market for media services, but the freedom to operate commercially should be applied without recourse to public subsidy.

Therefore, if stations who presently operate on a community radio licence want to transition to a commercial funding model, then they should speak with Ofcom individually about transitioning to an ILR licence, and pay the full commercial carriage and copyright fees those licences come with.

I think we need to give this some careful thought and discussion, but it seems like a moment when we should be prepared to let Ofcom and DCMS know that those of us who fully support social-gain driven community media, do not agree with this proposal.

Any thoughts on how to respond to this would be welcome.

Rob

I think these ill-informed stations don’t realise that most “commercial” local stations have become “Greatest Hits Radio” not because they are run by greedy profit-hungry people but simply because sustaining a local service under a traditional “commercial” model just is not economically viable. These community stations who wish to recreate a mid-1990’s ILR clearly are in dreamland.

Community Radio services many deprived and hard to reach minority audiences. These would never sustain a commercial model. Without the significant amount of support in the form of reduced fees, etc, they would never survive. For many of these stations they go nowhere near the £15k cap as the audience is so commercially unattractive that grants and voluntary hours are the main things keeping the service on air, not commercial advertising income.

What do these “community” stations struggling with the £15k cap need the extra money for? Fancy studios? Signwritten cars? Lots of billboards with pictures of the presenters all over? How does any of this help deprived or hard to reach communities? Nobody cares what the studios look like and many can’t even afford a car so certainly don’t care if the station is driving around in a 15 year old Mondeo, if they even have a car at all.

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I have never been against revisiting and reconsidering restrictions as long as social gain remains at the core of the sector’s activity, but I am a democratic socialist and the current government definitely are not of the same mind as me.

I agree that it is possible that some of those suggesting lifting the cap like the idea of transitioning to a profit making station and have people working with them who like the idea of being celebrity radio presenters or DJs. However, I also suspect there are people doing so because they are struggling with securing funding, partnerships or engaging volunteers to keep the station on air. They may need to update kit so they can offer training courses which will bring money in from partners. These are very real issues which we all know can keep them on, or drive them off air. If a station gives back its licence because of a lack of resources or volunteers, it can’t provide social gain.

I think those in favour of lifting commercial caps won’t remember that the reason ILR failed in the 1980s and the reason we have a commercial sector in it’s current form, is because they couldn’t retain public service principles, pay everyone and make a profit at the same time. This was one of the reasons the community radio sector gained favour across the political, social and economic spectrums (pardon the pun), to fill this gap and benefit local communities by providing local services which were different to the BBC’s offer.

I do agree it is time to look at funding structures and how stations can be supported more, because the pandemic and subsequent lockdowns have shown how important the sector is for connecting and informing local communities, but also the lifeline they have offered to people who have shielded and been isolated during lockdown. The challenge will be retaining social principles at the core, so as the sector moves forward and social gain commitments are re-framed as they likely will be, benefitting communities remains at the core of the sector, so it doesn’t become just a commercial offering under a community licence.

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What worries me, is that there is no leadership being given by DCMS and Ofcom that recognises the deep and long-term disparities and biases that have to be overcome in community radio projects, particularly when they are promoting access to platforms.

The response by Sir Michael Marmot to the inquiry into racial disparities is a good example of the failure of public health policy to recognise and account for “the causes of the causes.” I think these views are a good parallel to what is occurring with our media. Marmot is quoted in The Guardian, stating that

“The links between ill health, including Covid-19, and deprivation are all too familiar. Less so have been the findings of shockingly high Covid-19 mortality rates among British people who self-identify as black, Bangladeshi, Pakistani and Indian. Much, but not all, of this excess can be attributed to living in deprived areas, crowded housing and being more exposed to the virus at work and at home – these conditions are themselves the result of longstanding inequalities and structural racism.” https://www.theguardian.com/world/2021/apr/07/uk-public-health-expert-michael-marmot-criticises-no-10-race-report-shortcomings

Given that Ofcom doesn’t even commission research into Community Radio in its media diversity reports, we don’t have a full picture of what is taking place. It’s impossible to say how community radio is fulfilling its social gain purpose, particularly when it comes to addressing equalities issues as defined in the Equalities Act 2010, because we don’t have the verifiable and structured data. While there might be the occasional informal survey undertaken, this doesn’t give us strategic insight.

We need to caution that policy relating to community media shouldn’t be developed on the back of an envelope, but needs to be strategically defined and critically accounted for so that it stands up to scrutiny. The health data that is coming in from the pandemic shows that this can be done, but where is the related data about community-focussed communications? As Marmot says

“Those of us who recognise that the nature of society is vital want to look upstream to the social structures that have such powerful influences on health and wellbeing. Achieving a fair distribution of health among social and ethnic groups will be a sign that we have changed society for the better.” https://www.theguardian.com/commentisfree/2021/apr/07/sewell-report-structural-racism-research

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