With the publication of ‘Next Up’, the UK Government’s White Paper on Broadcasting, it’s not clear how community radio is going to be protected in the anticipated deregulated world being put forward by ministers. Will Nadine Dorries, the Secretary of State for Digital, Culture, Media and Sport (DCMS) continue to protect minority broadcasters as the government strips-away regulation and pushes for increased marketisation because they think everything should be pushed onto digital platforms?
One of many worrying proposals in the White Paper is the suggested removal of economic protections from community radio. By focussing on the potential for increased ‘monetisation’ of programme content, over and above the limits that are presently set in place by Ofcom, then community radio risks being fatally undermined as a distinctive and established social movement.
There seems to be a misunderstanding expressed in the White Paper, that community radio stations are unable to maximise their income from all possible sources of revenue that they generate, such as public project funding, support for training, charitable work, enhanced social access for people who are otherwise unable to gain access in mainstream media. According to Ofcom:
“In the Community Radio (Amendment) Order 2015 changes were made to the rules regarding income from the sale of remunerated on-air advertising and sponsorship. In summary these are:
- Each station is allowed a ‘fixed revenue allowance’ of £15,000 per financial year from paid for on-air advertising and sponsorship;
- Some stations may also be allowed up to 50% of their total relevant income per financial year (i.e. disregarding the ‘fixed revenue allowance’) from paid-for on-air advertising and sponsorship, if certain qualifications apply.”
This means that Ofcom’s rules have been modified “in relation to how much income licensees need to seek from sources other than on-air advertising and sponsorship, and the value of volunteer inputs.”
For example, and according to Ofcom, licensees that “receive up to £15,000 per annum from on-air advertising and sponsorship do NOT need to match this income with funding from other sources.” However, for licensees whose “licence allows them to take more than £15,000 per annum from on-air advertising and sponsorship the following key rule applies:
After taking into account the annual ‘fixed revenue allowance’ of £15,000, a minimum of 25% of remaining annual operational income must come from sources other than on-air commercial funding and the value of volunteer inputs.”
In other words, as Ofcom specifies, with “regard to on-air advertising and sponsorship income above £15,000, rule 2 says that stations claiming a value for volunteer inputs and generating further income from on-air commercial sources must always generate at least 25% of this remaining income from other sources (grants, donations, service level agreements, the value of non-volunteer in-kind support etc).”
Effectively, this rule allows community radio stations to maximise their income from volunteer contributions and other sources. It’s a match-funding model that puts no limit on the potential for monetisation of on-air content, as long as at least 25% of a stations’ income is generated from these other sources. Does this seem like a restraint on community radio stations to raise income from a variety of sources?
In fact, this is the standard operating model that has been pursued and developed by many community radio stations for a long time. Especially those who recognise that commercial monetisation of their on-air content is neither desirable nor likely. Stations have to be free to take account for themselves the nature of the communities they serve, so any talk of universal viability through on-air commercial activity is fanciful.
This is compounded when taking into acount the marginal economic viability threshold of managing a business-level advertising capability for each individual station. Not all community radio stations want to operate with an advertising or commercial monetisation model. Many have strong reasons, sometimes religious, sometimes creative, sometimes motivational, for not operating in this way. If DCMS follows through with this, and the Community Radio Fund is wound down as a result of this push for monetisation, then projects that can’t raise income from commercial activity will suffer, and the social gain model of community radio is effectively delegitimated.
Community radio was never intended to be financed primarily through advertising. Commercial advertising is rightly the purview of commercial providers who feel confident they can take the risk of operating in a competitive market. Instead, community radio was always intended to be part of the social economy, and would operate through a mixture of grant funding, volunteer contributions, some limited commercial activity, fundraising, service work with education, health or public authorities, and so on.
The recent report on Ofcom’s management of the Community Radio Fund makes a significant, but under-reported recommendation, that more needs to be done by Ofcom and DCMS to facilitate and promote links with the public sector, such as the Local Government Association, so that community radio can more easily partner with local authorities, health, skills and education agencies, in a reciprocal social value relationship. The fact that this has not been undertaken is telling. Community media wasn’t even mentioned in the recent White Paper on Levelling Up.
The obvious question, then, is where does this push for market deregulation come from? Why are ministers in DCMS considering relaxing the rules that keep community radio separate and distinctive from the BBC and the commercial sector?
If a commercial station wishes to operate in the free market, and take the risks of this kind of commercial venture, then they should expect no public subsidy – either directly or indirectly. Similarly, if a community station wishes to actively monetise its on-air content to the max, then it should be on a commercial licence, and not a community licence. It would be interesting if Ofcom could tell us how many community stations have ever applied to convert their licence to a commercial radio broadcast licence because they want more financial freedom.
Why does any of this matter? As with any public service, when marketisation is introduced, there are people who benefit and people who lose out. Some services are provided effectively in the market, and others are not. The question for any government, always, is how do the small-scale and marginal voices that are necessary for a functioning civic society and democracy continue to have access to the means of communication, without being swamped in the market, or being destabilised by rapacious international technology platforms?
Pushing community stations onto digital platforms, such as SSDAB, is only going to undermine the independence and viability of the community and independent commercial radio. As with Norway, Sweden and Ireland, many people are beginning to recognise that DAB is not the panacea that has been sold, and that many people are happy to stay with AM and FM station because they are able to provide the local content that they want and identify with. What else is the spectrum allocated to analogue radio going to be used for? It is of no commercial value, so why not let local, independent commercial and community stations use this resource once the national and regional commercial and national public service broadcasters are moved over to DAB?
For stations who serve under-represented, marginalised and non-commercial social provision, there is still an essential need to protect and support not-for-profit broadcasters from the excesses and the sharp ends of the market. Most community radio stations are sustainable only because the people involved want to give something back to their local or identified community, and they want to do it in a way that isn’t just about monetisation and commercialism. As community media makers, experience tells us that we want to offer our listeners something that they feel is representative of their community and the place where they live, not simply a hodgepodge of formatted and generic content.
Many of us are crying out for content that steps outside the homogenised and narrow expectations of both the BBC and commercial media provision. Instead, we want to be able to be involved in making something for ourselves, that our fellow citizens can join in and value as a joint collaboration, and thereby make an effective and lasting contribution to our community life. If the market is able to provide this, then great, but if it can’t, then government must protect those of us with the least power, and who are the furthest away from the points of corporate media control and ownership, and instead foster a democratic alternative that really does bring about a genuine levelling up for media access in the UK.
To follow-up discussion on this topic join Better Media, which is a members-based organisation, campaigning for openness and transparency in media policy, pluralism in media ownership, and access to media platforms as a civic right.