An open letter to the Department for Digital, Culture, Media, and Sport

Dr Rob Watson, Director, Decentred Media, Leicester

Lucinda Guy, Co-Founder and Artistic Director of Soundart Radio, Totnes (Devon) and Former Chairperson, Community Media Association, UK


1 Background

This statement is the result of a collective consultation between experienced community radio broadcasters, community media advocates, academic researchers and practice-based trainers who wish to see the integrity of media for community purpose advanced and expanded. This is a summary of priorities and principles that aims to build on the established benefits and social value of community radio, and other forms of community media in the United Kingdom. By stating what we believe to be the essential character of community radio and media in the UK, we are seeking to make a positive and constructive contribution to the ongoing discussions.

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2 Maintaining the Nature of Community Radio by Promoting Access.

Fundamental to all principles and practices of community media in the UK, is the promotion and extension of access to the means of media production and distribution that is not-for-profit, locally based, prioritises social gain, and is accountable to the communities that they serve. This is enshrined in existing legislation for community radio, which is presently the only media sector mandated to make a purposeful contribution to civic discourse and discussion based on the direct access to programme making by people within communities, for the purpose of enhancing understanding between, and the wellbeing of those communities. The BBC and the commercial media sectors produce content for audiences, while community radio empowers people to come together to produce and share content for themselves. Promoting access, however, comes with a number of challenges that any future broadcasting legislation must be mindful of, which can be characterised as People, Place and Purpose:

  • People: to ensure access and proficiency in the skills of community-focussed communication, significant investment (i.e. economic and social capital), has to be provided to train volunteers, to improve media and civic literacies, and to protect and safeguard people who may not otherwise wish, or be able, to engage with commercial or professional forms of media broadcasting.
  • Place: to ensure that people have access to the means of producing programming, community media operates as a social space for communities of place, interest and identity to come together in-person, where they can establish links within and across communities. Community radio stations are embedded within the places and neighbourhoods that they serve, and guarantee access to programming that is specifically produced by the people of that place, not for them or otherwise on their behalf.
  • Purpose: by ensuring direct access to programme production, community radio supports the expression of a range of social views, interests, opinions, life experiences and social perspectives. The pluralistic representation of democratic expression across all media platforms is a counterbalance to misinformation, media homogenisation and corporate centralisation. As a counterbalance, community radio promotes participative access that ensures that people who are otherwise disinterested, marginalised, isolated or ignored in mainstream media and civic discourse, have an opportunity for their voices to be heard for the purpose of social gain and development.

3 Challenges

Given the challenges that have been outlined in supporting documentation to Up Next, there are a number of issues that we believe should be discussed more extensively, before permanent decisions are made that will have lasting impact on the aforementioned character of community radio in the United Kingdom.

  • Plurality of Platforms: with the increased availability of multiple digital platforms such as DAB, streaming, podcasting, and so on, there must be protection for legacy platforms such as AM and FM, and those who wish to access content via them. In addition to those who wish to produce content that matches the individual aesthetic tastes, histories and values embodied in each form of communication. While the analogue radio frequencies may not remain large-scale commercially viable, they will still afford community and local broadcasters extensive opportunities to establish and develop viable services. Planning for a ‘digital move over’ of BBC and national and regional commercial services to DAB only, rather than a ‘switch-off’, would be a sustainable way to encourage greater diversity of supply, including both local community and local commercial analogue radio.
  • Determinations of Local: current regulation and legislation effectively designates anything that isn’t national as local. The determinations of local character of media services, we believe, do not sufficiently anticipate meaningful local civic, cultural and economic needs. Many stations and services are being squeezed by centralising network arrangements and homogenising platform changes (i.e. towards brands, not locality). This is leading, in many instances, to services ‘passing-off’ content as local when there is no evidence of local input, production, accountability, economic gain, or meaningful relevance. By ensuring access for local people to meaningful and verifiable participation in programme production, community radio builds stronger communities with more distinctive local content.
  • Separation of Service Characteristic: pressures on income and financial sustainability may tempt some to seek to dilute the separation of service characteristics that define commercial, public service and community programming. We believe this is unnecessary for two reasons. First, sufficient routes to commercial licencing already exist, and secondly, community radio has an established investment model of funding that seeks to mix forms of income and service provision, thereby reducing dependency on monetisation of on-air content. The cash limits may be adjusted, but the practice of balancing volunteer time, grant funding, and other forms of social investment, along with on-air advertising and sponsorship, should be retained. Protection for services that would be non-viable on a commercial basis must be maintained. Shifts to more ‘commercial’ forms of community radio broadcasting will redirect attention away from verifiable social gain.

Effective Regulation: since the principles of regulation for community radio were established in legislation in the late 1990s much has changed. However, little has been published by Ofcom or other parties of late that demonstrates the extent to which community radio continues to systematically meet its social gain purposes. Much of the available evidence is anecdotal and self-affirming. In addition to gathering further research and evidence, therefore, there needs to be a shift to open reporting and public data transparency models of data collection for all community radio stations, and their regulation across the UK. Presently Ofcom’s expertise is with communications economic planning, technical platform management, and broadcast programme content regulation, and does not, therefore, reflect the need for regulatory capacity for access-based participation, including oversight of safeguarding, volunteer management, equality and diversity, good governance, and so on. While Ofcom rightly regulates on-air harm, there is little concern for off-air harm. Other regulators, such as Ofsted, review their domains holistically, and can offer models for a shift in regulatory purpose in order to ensure that community radio and media fulfils its designated social purpose. We are mindful that these are summarised as general concerns, and would welcome further discussion and clarification so that we may provide evidence that sustains the benefit of maintaining the principle and accepted characteristics of community radio in the United Kingdom.

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Gathered Comments

“I’m also not sure my opinion would be of much use here as legally, we’re NOT classed as a community station and would not present ourselves as this, we’re classed as an internet radio station that is community led. We’re pretty happy with this model and managing our own output and striving for excellent accessibility throughout everything we do without the regulation of Ofcom of which we don’t want. We’re very content striving for inclusion, diversity and access through everything we do independently and feel that regulation on this would simply hinder our development, and also not allow us to engage in the most forward-thinking ways of working on inclusion and access as most of these centralised regulatory bodies are draconian and archaic, and don’t really understand what we are trying to achieve.” Josh Aitman, Melodic Distraction “Over recent years a certain ideology tends to get more exposure, one that sees community radio as a replacement for local commercial radio. It seems to be about branding and growing that brand to cover bigger areas with spin-off services. In some cases, this probably needs to happen to support the main format, but my worry is that we could end up with community radio services that are dependent upon participants having their own home studio. This seems to be the case with some CDSP’s. There are a number on-air here (we have 2 SSDAB Mux’s on-air) that I can’t always separate from DSP’s! The ideology is different and that may be fine, but it needs more thought now we know how applicants view the opportunity in reality. I am very lucky to have a lot of support for our station in Sunderland. Very lucky. But the system does need looking at. I agree with Jo that the 15K formula needs looking at and the CR fund needs increasing, possibly via a formula that links to the number of licences in the system. I do agree that Key Commitments need looking at given the high incidences of breaches, although in honesty this is often a case of over promising and not giving yourself enough headroom to drop the ball occasionally. That said, Ofcom do need to look at how they enforce and how they educate stations, especially when the management changes.” Richard Berry, Spark FM.

“Key Commitment reporting has been diluted by Ofcom in recent years, leading to a lack of general information about community radio and what it is achieving.”

Terry Lee, Radio LAB “Commercial broadcasting has its own challenges, but it should be recognised that the commercial relationship with advertisers can limit the independent editorial scope of stations.”

Jo Coleman “Voice empowerment remains a fundamental part of the need for community media, along with independent, democratic governance and ownership, independent of state and corporate control.”

Siobhán Stevenson “The lessening of standards for social gain, from ‘significant’ to ‘some’ is leading to a two-tier licencing difference between CR and C-DSP services, with some operators potentially passing-off community notices in lieu of more meaningful and long-term engagement.”

Sam Hunt, LCR “We need to ensure that we have a vibrant, independent media in the UK, with local control over both the production of content, and its distribution. Improving access, assuring accountability, and diversifying the voices that can get on air is essential for a healthy democracy. We need decentralisation of media ownership and control to counter the concentration of commercial and state-backed public service media. We need media that is independently managed and governed. We need independent media which can meet independent and alternative interests and concerns, which help promote discussion and deliberation, with communities of interests, as well as identity and place, speaking for themselves, and not being spoken for by distant and impenetrable managers.” Josef Davies-Coates, Better Media.

“Democratisation of airwaves requires not only that radio frequencies are licensed to communities and community-based organisations, but also that local communities get to directly access these voice infrastructures to articulate their concerns and issues, not as mere passive listeners, but as active producers of content. It is only then that a more pluralistic media landscape could emerge, one in which the historically unheard voices can represent themselves without the mediation of interlocutors, however well-meaning they may be. Democratic access can be assured by regulators and civil society organisations through provision of licensing through liberal terms, the insistence on community licence-holders adhering to the non-negotiable principles of community media (e.g. not-for-profit, community production, and community participation in management), constant widening of the volunteer base through training, and an enabling framework for public financial support to the sector.” Professor Vinod Pavarala, UNESCO Chair on Community Media, University of Hyderabad