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<H3><FONT size=2><SPAN class=250504211-21102015>Hi Bill and Phil
</SPAN></FONT></H3>
<H3><SPAN class=250504211-21102015></SPAN><FONT size=2><SPAN
class=250504211-21102015>Just endorsing the comments that you've both made in
relation to the community radio key commitments consultation.
</SPAN></FONT></H3>
<H3><FONT size=2><SPAN class=250504211-21102015>This is my response to the
consultation that I submitted earlier today:</SPAN></FONT></H3>
<H3><FONT size=2><SPAN class=250504211-21102015></SPAN></FONT><FONT
size=2>Question 1:</FONT><FONT size=2> Do you agree with the proposal to revise
Key Commitments as set out in this consultation? Please explain the reasons for
your view.:</FONT></H3>
<P><FONT size=2>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. <BR><BR>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. <BR><BR>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 <SPAN
class=250504211-21102015>ov</SPAN>er 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. <BR><BR>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.</FONT></P>
<P><FONT size=2><STRONG>Additional comments</STRONG>:</FONT></P></DIV>
<P><FONT size=2>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. <BR>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. </FONT></P>
<P><SPAN class=250504211-21102015></SPAN><FONT size=2>M<SPAN
class=250504211-21102015>ary Dowson</SPAN></FONT></P>
<P><SPAN class=250504211-21102015></SPAN><SPAN
class=250504211-21102015></SPAN><FONT size=2>B<SPAN class=250504211-21102015>CB
Director</SPAN><BR></FONT></P><BR>
<DIV dir=ltr lang=en-us class=OutlookMessageHeader align=left><FONT size=2>
<HR tabIndex=-1>
</FONT><FONT size=2><FONT face=Tahoma><B>From:</B>
cma-l-bounces@mailman.commedia.org.uk
[mailto:cma-l-bounces@mailman.commedia.org.uk] <B>On Behalf Of
</B>CMA-L<BR><B>Sent:</B> 15 October 2015 17:35<BR><B>To:</B>
cma-l@commedia.org.uk<BR><B>Subject:</B> [cma-l] Review of the approach to
community radio Key Commitments<BR></FONT><BR></FONT></DIV>
<DIV><FONT size=2></FONT></DIV>
<DIV dir=ltr>
<DIV class=gmail_quote>
<DIV dir=ltr><FONT size=2>Community radio services broadcasting on FM or AM
provide social gain and other community benefits on a not-for-profit
basis.<BR><BR>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.<BR><BR>These service descriptions recorded in community radio
licences are called ‘Key Commitments’.<BR><BR>This Ofcom consultation seeks
views on a proposal to streamline and simplify the Key Commitments.<BR><BR>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.<BR><BR>Ofcom invites written comments on the questions
raised in this consultation, to be submitted by <B>5pm on 21 October 2015</B>.
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.<BR><BR></FONT><A
href="http://stakeholders.ofcom.org.uk/consultations/key-commitments/"
target=_blank><FONT
size=2>http://stakeholders.ofcom.org.uk/consultations/key-commitments/</FONT></A><BR><BR><FONT
size=2>\\<BR><BR>Community Media Association<BR>--<BR></FONT><A
href="http://www.commedia.org.uk/" target=_blank><FONT
size=2>http://www.commedia.org.uk/</FONT></A><BR><A
href="http://twitter.com/community_media" target=_blank><FONT
size=2>http://twitter.com/community_media</FONT></A><BR><A
href="https://www.facebook.com/CommunityMediaAssociation" target=_blank><FONT
size=2>https://www.facebook.com/CommunityMediaAssociation</FONT></A><BR><BR><FONT
size=2>Canstream Internet Radio & Video<BR></FONT><A
href="http://www.canstream.co.uk/" target=_blank><FONT
size=2>http://www.canstream.co.uk/</FONT></A><BR><A
href="https://twitter.com/canstream" target=_blank><FONT
size=2>https://twitter.com/canstream</FONT></A><BR></DIV></DIV><BR></DIV></BODY></HTML>