Submission to the DCMS Consultation on Analogue Community Radio Licensing

Over the past few weeks, we at Better Media have been working on putting together a submission to the Department for Culture, Media and Sport (DCMS) consultation on future licensing arrangements for analogue (AM & FM) community radio. In our view the DCMS proposals are based on flawed evidence and assumptions, and as such we advocate for significant changes to existing licensing policy. Our submission was completed and submitted on January 25th.

You can read the full submission here, or read a shorter summary below.

Thanks and credit to Rob Watson, Better Media member and host of Decentred Media, who led on this work.

Summary of Response

Our submission raises a number of general concerns with the basis of this consultation. We are disappointed that DCMS have not commissioned any robust independent research to provide a credible evidence base for this consultation. Instead, the proposals are overly influenced by large scale commercial industry, with a notable lack of transparency and citizen engagement. We are concerned that this is a sign of regulatory capture by the commercial radio industry, which is counter to the interests of citizens and consumers.

We are also concerned that the consultation does not adequately address two important issues of policy that should have significant consequences for decisions around radio licensing. Firstly, there is no recognition of the significant evidence that the Digital Switchover policy, which aimed to expand DAB coverage to the point that it could replace AM & FM radio, has failed. DAB itself is becoming a legacy platform with the advent of internet radio and podcasting, and yet DAB expansion is still the focus of a lot of policy discussion among DCMS and Ofcom.

Secondly, we were surprised to see that the proposals fail to address the substantial changes being considered in the Media Bill. The Bill as currently drafted would remove safeguards for pluralism in local broadcasting, allowing commercial providers to continue dominating the airwaves with cut-and-paste pseudo-local content. New policy around licensing that built on a robust consultation could help retain or remake those safeguards, but from the consultation we have been given it seems DCMS are not making any significant effort to prevent the local radio industry becoming a protectionist racket.

Ultimately, it is our belief that the DCMS proposals undermine the core principle of universal access to broadcast radio. DCMS is failing to incorporate other elements of government policy that promote universality and inclusivity, such as the levelling up agenda, showing a lack of joined up, strategic thinking about the social gain and community cohesion that community radio can provide.

As for the content of the proposals, our responses to the specific questions about licensing policy that the consultation asked are as follows:

1. We don’t support automatic renewal of analogue community radio licenses.
2. We support the proposal to allow analogue community radio licenses to expire and be readvertised.
3. We don’t support granting further five-year or ten-year extensions of analogue community radio licenses.
4. We don’t support allowing analogue community radio licenses to be extended indefinitely.
5. We support current restrictions on revenue generation through advertising and sponsorship for analogue community radio stations, which we agree should remain in place.

Overall we are keen to see the community radio sector opened up to new entrants, while ensuring that truly local and community-run providers are not run over by the one-size-fits-all approach of large commercial providers.

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Read the full submission here, join the discussion on our forums here, and become a Better Media member on OpenCollective here.