[cma-l] Review of the approach to community radio Key Commitments

[mary dowson]

Hi Bill and Phil 


Just endorsing the comments that you've both made in relation to the
community radio key commitments consultation. 


This is my response to the consultation that I submitted earlier today:


Question 1: Do you agree with the proposal to revise Key Commitments as set
out in this consultation? Please explain the reasons for your view.:


No.I believe that key commitments should continue to contain specific
details of how social gain will be delivered. This should be a specific
section, with a level of detail on how this will be achieved.The proposed
example of how the new key commitments might look dilutes this to a degree
where its importance is negligible. 

The distinguishing feature of a community radio station is social gain. The
community radio legislation which established a third sector of radio, was
specifically brought in to enable the airwaves to be used for social gain.
If this is diluted in any way then there is a real danger that there will be
little to distinguish the operation of a community radio from a commercial
radio. Its vital that social gain lies right at the heart of community radio
and this therefore must be specifically reflected in the key commitments of
a licence holder. 

I do agree with the premise that it should be easier for Community radio
stations to have some flexibility in just how they deliver their key
commitments over the course of a 5 year licence period. Its true that as a
station develops and responds to its community, it may well find more
appropriate ways to deliver its agreed social gain objectives. Any change in
how they deliver the stated social gain objectives could be proposed,
possibly with their annual report , and then negotiated/agreed directly with
OFCOM. But it should be clearly be a change in HOW they are delivered in
order to to achieve the same objectives, not a dilution/removal of the
social gain obligations themselves. 

Clearly a licence application itself could well contain statements of great
intention - and a licence could be granted on that basis. If the subsequent
key commitments document doesn't reflect those intentions, and just has the
proposed vague outline of community benefits, then itill be much harder to
call the station to account for non delivery.

Additional comments:

I'm concerned that this revision in the regulation of community radio is
moving more towards how commercial radio is regulated. It does not reflect
the uniqueness of a community radio station, delivering a service
specifically designed by and for the community that it serves. 
Although there could be some measurable objectives that can be quantified to
enable comparison between stations, the qualitative reporting aspects of a
community radio station are vital. Just how a community radio station serves
its community will be very different from one station to another.. There is
a real story to be told by each station and this qualitative element must
remain in the design of the reporting. 

Mary Dowson

BCB Director



  _____  

From: cma-l-bounces at mailman.commedia.org.uk
[mailto:cma-l-bounces at mailman.commedia.org.uk] On Behalf Of CMA-L
Sent: 15 October 2015 17:35
To: cma-l at commedia.org.uk
Subject: [cma-l] Review of the approach to community radio Key Commitments


Community radio services broadcasting on FM or AM provide social gain and
other community benefits on a not-for-profit basis.

Each station is required to provide the service described in its licence,
which is based on the proposals it made during the application process for
the licence.

These service descriptions recorded in community radio licences are called
'Key Commitments'.

This Ofcom consultation seeks views on a proposal to streamline and simplify
the Key Commitments.

This will free up community radio stations, enabling them to focus on
serving their target communities, adapt better to the changing needs of
those communities, and deliver social gain.

Ofcom invites written comments on the questions raised in this consultation,
to be submitted by 5pm on 21 October 2015. Ofcom strongly prefers to receive
responses in electronic format and their web form will allow you to indicate
your data protection preferences and send your views to the team responsible
for this consultation.

 <http://stakeholders.ofcom.org.uk/consultations/key-commitments/>
http://stakeholders.ofcom.org.uk/consultations/key-commitments/

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