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The space between: Defining the place for community radio
Hallett, L.
This is an electronic version of a PhD thesis awarded by the University of Westminster.
© Mr Lawrie Hallett, 2015.
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THE SPACE BETWEEN
DEFINING THE PLACE
FOR COMMUNITY RADIO
LAWRIE HALLETT
A thesis submitted in partial fulfilment of the
requirements of the University of Westminster
for the degree of Doctor of Philosophy
October 2015
ABSTRACT
This thesis examines the emergence of Community Radio in the United Kingdom. It
places the sector within an historical context dominated by the BBC and strongly
influenced by the subsequent arrival of commercial radio broadcasting. Understanding this
historical context, which includes consideration of the role played by unlicensed 'pirate'
radio operators, is, in the opinion of the author, a critical prerequisite necessary for
assessing how and why current Community Radio practice has developed in the way it has.
Primary research for this thesis includes a variety of semi-structured interviews with
campaigners, practitioners and regulators and, whilst primarily focused on the emergence of
the Community Radio sector within the British context, it does not ignore wider
international perspectives. Recognising that, well before Community Radio began to
emerge in the UK, much of the early conceptual development of the sector took place in
other jurisdictions, the author also draws upon a number of international sources,
including some primary research in the Republic of Ireland, Norway and the United States
of America.
The influence of two key factors, those of regulation and technology, are central to this
research, the author arguing that these in particular have helped define (and constrain) the
current position and future opportunities available to Community Radio within the United
Kingdom. Legislation and regulation may have defined clear, and in some instances
unique, operational objectives for British Community Radio, but when defining such
objectives they have also had to take into account limited broadcast spectrum availability,
constraining the scope and scale of the sector as a result.
Beyond a consideration of the historical and of present day practice, this thesis also looks
towards the future, examining current developments in digital broadcasting which offer the
potential to counter such current capacity constraints and provide opportunities for
additional community-based services in future.
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CONTENTS
Abstract
ii
Contents
iii
List of Tables
iv
Accompanying Materials
v
Acknowledgements
vi
Author's Declaration
vii
Chapter 1:
A Brief History of Radio Broadcasting
1
Chapters 2:
The Arrival of Community Radio
44
Chapter 3:
Theories, Practices (and Policies) of Community Radio
97
Chapter 4:
Methodology
129
Chapter 5:
Regulation in the Community Radio Sector
148
Chapter 6:
Transmission in the Community Radio Sector
189
Chapter 7:
Conclusions
223
Appendices:
(i)
(ii)
AMARC Europe Charter
Previously published materials
Glossary
References
Bibliography
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LIST OF TABLES
Table 1.1
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Key Elements of Broadcast Regulation
p. 24
iv
ACCOMPANYING MATERIALS
Appendix (i)
• AMARC - Community Radio Charter for Europe.
Appendix (ii)
• Previously published papers by the author, referred to in this thesis:
•
Hallett, Lawrie (2009). Community Radio Regulation - A Collaborative
Model. Paper presented at the International Association of Media &
Communication Research (IAMCR) Conference. Mexico, July 2009.
•
Hallett, Lawrie (2009). The Space Between: Making Room for Community
Radio. In Gordon, Janey (Editor), Notions of Community, p.p. 33-58 (inclusive).
•
Hallett, Lawrie (2010). Community Radio In Transition - The Challenge Of
Digital Migration. In O'Neill et al. (Editors), Digital Radio in Europe,
Technologies, Industries and Cultures, p.p. 175-191 (inclusive).
•
Hallett, Lawrie & Wilson, Deborah (2010). Community Radio:
Collaboration & Regulation. Paper presented at the Media Communication &
Cultural Studies Association (MeCCSA) Conference. London, January 2010.
•
Hallett, Lawrie & Arne Hintz (2010). Digital Broadcasting - Challenges And
Opportunities For European Community Radio Broadcasters. Journal Article:
Telematics and Informatics (Volume 27, Issue 2, p.p. 151-161). Amsterdam:
Elsevier Publishing BV.
•
Hallett, Lawrie (2014). Democratising Digital Audio Broadcasting. Paper
presented by the author at the International Association for Media and
Communications Research (IAMCR) Conference). Hyderabad, India, July 2014.
•
Hallett, Lawrie (2015). UK Small Scale DAB Trials Move to Next Phase.
Magazine Article: Radio World International, August 2015.
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ACKNOWLEDGEMENTS
This thesis is dedicated to my parents, Barbara and Geoff Hallett. I would not have been
able to complete it without the constant love, help and support of Aurogeeta Das.
At the University of Westminster, I would like to thank my Director of Studies, Steven
Barnett, and my Second Supervisors, David Hendy and latterly, Paul Dwyer. At the
University of Bedfordshire, I would also like to thank Alexis Weedon, Gavin Stewart and,
especially, Janey Gordon.
This PhD thesis could not have been completed without the support of my previous
colleagues at Ofcom, in particular Soo Williams and Peter Davies who gave me plenty to
think about in relation to regulation, and Rashid Mustapha who championed the cause of
small-scale DAB there. Martin Spencer at Audessence also deserves a special mention.
I am also grateful to those that provided primary research materials for this thesis, in
particular the various interviewees and all the others who gave freely of their time and
knowledge. The staff and volunteers at Future Projects and Future Radio in Norwich
deserve a particular mention here.
Finally, I would like to thank my various other relatives, friends and colleagues, too
numerous to mention, for all their various help and support in relation to this project.
Lawrie Hallett
October 2015.
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AUTHOR'S DECLARATION
I declare that all the material contained in this thesis is my own work.
Note:
Where materials from jointly authored papers are drawn upon,
only the sections written by me are used.
Word Count: 73,286.
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CHAPTER ONE:
A Brief History of Radio Broadcasting
Some elements of this chapter are taken or adapted from the author's contribution: "The
Space Between: Making Room for Community Radio" in Gordon (Editor) Notions of
Community, 2009: 33-58 (inclusive).
Introduction
This PhD is about Community Radio, its characteristics, ideals and objectives. The
primary focus of this research is on two key factors, both of which impact upon the
operation of such services; namely, the role that is played by technology and the effects
of regulation. As this thesis will show, in part because of the distinctive nature of the
Community Radio sector and in part because of wider external factors, such influences
are particularly relevant to its successful operation, development and sustainability.
Before examining these twin themes of technology and regulation in more detail, an
historical context is required within which to 'frame' the emergence of Community
Radio. Setting out the relevant historical background also helps begin the process of
defining what is meant by the term Community Radio: how it differs from other forms
of radio broadcasting, in terms of what it seeks to do, and in relation to the processes
through which it seeks to achieve such outcomes. This first chapter exploring the broad
history of broadcast radio development since the early years of the twentieth century is
followed by a second, which, in more detail, examines and contextualises the emergence
of Community Radio as a 'third tier' of radio broadcasting.
First however, a brief note about terminology. Whilst many parts of the world might be
comfortable with the term 'community' as it relates to broadcast radio or to wider
media, there exists a plethora of other options. Often near synonyms (although not
exactly so), these include well known terms such as alternative media, participatory
media and citizens' media, as well as perhaps more niche terms, including activist media,
autonomous media, tactical media, independent media, the list goes on…. Hugh
Chignell notes just how difficult the term is to define:
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Unfortunately, stating that it is radio specifically designed to meet
the needs of the community will not do. Mainstream radio may also
claim to meet those needs and may indeed be right. Similarly,
'small-scale', 'alternative' and 'socially beneficial' do not define
community radio as these can also be characteristics of commercial
and public service radio…
It follows that attempting a really convincing definition of what has
become one of the most interesting and rewarding areas of study
within radio is beset with problems. It seems however, to be
generally agreed that community radio stations place a priority on
their relationship with an identified community and attempt to
satisfy the perceived social and cultural needs of that group (Chignell,
2009: 119).
The point here is that, not only can the term Community Radio mean somewhat
different things to different people, but also that it is not universally accepted as the
norm. However, it is perhaps the most accepted term in relation to the specific medium
of radio, and, on that basis, it is the term that will be used here. Although this thesis
focuses on the regulation of radio broadcasting and on technologies used for its delivery,
some of its underlying arguments may also, to a greater or lesser extent, be applicable to
other platforms as well. The notion of the term 'community' is itself explored in more
detail later in this thesis.
Community radio is an outsider: a relative latecomer to the increasingly complex world
of broadcasting. The so-called 'third-tier' of radio is now firmly established in many
jurisdictions, but where does it fit in the wider broadcast media ecology? In particular,
how and why is it subject to specific regulation, and what might the implications be of
particular changes in broadcast and broadcast related technologies? By comparison with
public service and commercial broadcasting, community radio is a relatively recent
phenomenon. As such, it has typically had to find its place within an established media
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landscape. Its ability to exist at all is, this thesis will argue, due, at least in part, to
changes in regulatory outlooks and advances in radio broadcasting technologies.
Operationally, the Community Radio sector might best be described as a shoal of small
fish in a very large media pond. To continue the analogy, it is also a shoal that tends to
swim against the increasingly market-orientated tide of modern-day media. Deliberately
small in scale, but increasingly large in number; each Community Radio station is as
unique as the community it is set up to serve.
The result of this diversity of approach is a broadcast radio sector of considerable
breadth; there really is no such thing as a typical Community Radio service. That said,
there is a remarkable degree of commonality between individual Community Radio
stations. Not only within a given jurisdiction, but also around the world, across the
sector as a whole, there is general agreement as to the core elements of what constitutes a
genuine Community Radio service.
This thesis examines the nature and role of Community Radio, exploring how the
effects of technological change and regulatory frameworks impact upon the effectiveness
of its delivery and its ability to achieve its stated objectives.
This chapter of the thesis is split into a number of distinct sections as set out below:
1.
Broadcast Radio - The Historical Context
Firstly, this chapter provides an outline of the history of radio broadcasting. It examines
both the emergence of radio broadcasting technology and the development of the
medium as a cultural phenomenon within modern society.
2.
Platform Evolution and Diversification
Secondly, this chapter examines the way in which broadcast radio technologies have
developed since the medium first became established. This section explores the
evolution of traditional radio broadcasting, both in terms of its increasing capacity and
improved performance. It also considers why, despite the emergence of alternative
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digital broadcasting platforms and telecommunications-based content delivery systems,
the established analogue transmission standards continue to maintain their dominance.
3.
Radio, Regulation and Change
Thirdly, the next core issue of this thesis is introduced, namely, the development and
implementation of regulatory frameworks as they relate to radio broadcasting. Again,
some historical context is provided, beginning with the earliest days of the medium and
coming up to date with a consideration of issues such as digitisation and the increasingly
porous and ineffective nature of national borders as they relate to the maintenance of
broadcasting policy.
4.
The Link Between Technology and Regulation
Next, the bi-directional relationship between technology and broadcast radio regulation
is explored. This section examines the impact of technological changes upon the nature
of broadcast radio regulation as well as the reverse impacts of regulation on the
development and implementation of broadcasting technologies.
5.
The 'Place' for Community Radio
In the penultimate section of this introductory chapter, prior to its conclusions,
Community Radio is positioned within the wider broadcast radio context. The unique
nature of Community Radio services is identified, and the notion of three distinct types,
or sectors, of radio broadcasting is introduced, with Community Radio taking its place
alongside the established duopoly of Public Service Broadcasting (PSB) and commercial
broadcasting. The issue and relevance of unlicensed 'pirate', or 'fourth sector'
broadcasting activity is also considered.
1. Broadcast Radio - The Historical Context.
Before examining the relatively recent phenomenon of Community Radio broadcasting,
it is important to provide something of a wider historical background. How did
broadcast radio as a whole evolve, and what were the major factors influencing its
development? Although this PhD is not, per se, about the history of broadcasting,
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providing this context is essential, because an understanding of the wider development
of the medium helps to explain the foundations upon which the Community Radio
sector has been built and which have, to a certain extent at least, shaped its current
existence.
Broadcast Radio has never existed in isolation. More than a technology, it is a social
phenomenon that both reflects and influences the society within which it operates. As
Western society has changed over the past century, so too has what we mean by the term
'radio'. Specifically in the case of the English language, the term 'radio' as part of the
phrase 'broadcast radio', is a somewhat ambivalent one, referring to both the broadcast
programme content as well as to the technical platforms (transmission systems and
receivers) via which such material is delivered.
The history of broadcast radio is now a relatively long one. Scientific developments, in
the late nineteenth and early twentieth centuries, provided prototypes of the required
technological platforms. These were effectively commandeered and modified to deliver
a new form of long-distance social communication, one that gradually evolved into
today's broadcast radio ecology, in all its current diversity of form.
Economic, commercial, social and political factors have all played their part in the
evolution of the broadcast radio medium. However, without taking an overtly
technologically deterministic perspective, the history of the medium undoubtedly did
begin with the emergence of its underlying technology. Especially in the early days, its
development was largely one of unplanned, even accidental, incremental evolution.
Radio telephony, i.e. one-to-one voice communication, sometimes described at the time
as 'narrow-casting', itself a development of earlier wireless telegraphy, was one starting
point for broadcast radio. As Hugh G. Aitken points out in his book The Continuous
Wave, the development of radio broadcasting:
would have been impossible without previous advances … that had
originally been made with quite different objectives in view … - the
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rise of radio broadcasting is a classic example of the unanticipated
consequences of technological change (Aitken, 1985: 12).
Technical advances in wireless telegraphy were a necessary precursor for the creation of
broadcast radio, followed by the equally import emergence of radio telephony.
However, even with such technological developments in place, it still took some time for
the concept of broadcasting itself to emerge, as various experimenters in wireless began
to re-evaluate the potential of the new technology they were working with:
Almost accidentally, a small number of these experimenters began to
consider whether there were advantages to what seemed to be one of
early radio's most annoying attributes – that anyone could eavesdrop
– and wondered how it might have a possible benefit. The idea that
there might be reasons to seriously engage in "broadcasting" – one
person sending out messages to many – started to percolate (Greb &
Adams, 2003: 15).
At this point in their development, wireless telegraphy and wireless telephony were still
not entirely separate from one another. Thus, perhaps the earliest conception of wireless
as a broadcasting medium was in fact the use of marine wireless telegraphy for the
transmission of emergency messages. Unlike other forms of wireless telegraphy, ship-toship and ship-to-shore emergency messages were intended for general reception;
maximising the number of people receiving the message also maximised the chances of
its contents being acted upon. (Coe, 1996: 6 & 16-17). The earliest transfer of such
activities from the sea to land, what McLuhan called "the first radio broadcast"
(McLuhan, 1964: 332), was during the Dublin Easter Rising of April 1916:
The leaders of the rising, realising that the British authorities would
suppress or distort news of it dispatched by the normal channels
decided to send out the information themselves... This was not
broadcasting as we know it, for wireless telephony was not yet
available and Morse messages were all that could be sent out. But it
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was news by wireless, not aimed at any known receiver but sent out
broadcast, and that was a new idea in 1916 (Gorham, 1967, quoted in
Fisher, 1978: XV).
The earliest developments of wireless telegraphy and telephony were dominated by a
combination of professional and amateur scientists, engineers and academics. Whereas
the professionals involved tended to work for commercial or military masters with
specific pre-defined objectives, amateurs and academics were often more interested in
pushing boundaries more generally, following experimental outcomes to see where they
might lead, often without having any specific, clearly defined, objective at the outset of
their experimentation.
Of course, the separation between the professional and the amateur was not always total,
often those with a professional career in the field carried on experimenting in a personal
capacity, outside the typically more rigid confines of the day job. It is perhaps not
surprising therefore that the first experimental 'broadcast' of speech and music content
via radio waves is attributed to one such individual, Canadian, Reginald Aubrey
Fessenden (6th October, 1866 – 22nd July, 1932). According to the history books, he
made the first broadcast containing both speech and music, from Brant Rock,
Massachusetts, on the 24th of December, 1906 (Douglas, 1987: 156).
As it evolved, the new medium embraced the growing opportunities presented by
further advances in radio telephony, beginning to adapt and use them in ways rarely
envisaged by their original inventors. From the outset, music played its part in the
development and sustainability of the medium. David Sarnoff, later the head of the
Radio Corporation of America (RCA) and founder of the National Broadcasting
Corporation (NBC) in the USA, said, as early as 1916:
I have in mind a plan of development which would make radio a
household utility in the same sense as the piano or the phonograph.
The idea is to bring music into the home by wireless (Sarnoff, 1916,
quoted in Shurick, 1946: 11).
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Since the first known 'broadcast' of speech and music by Fessenden had taken place
some ten years earlier in 1906, Sarnoff's idea was not exactly new, nor was it unique, as
others were having similar ideas at around the same time. However, the increasing
emergence of such ideas showed that the new medium of radio broadcasting was already
developing, becoming less of a technological curiosity and, instead, showing signs of
social relevance and potential economic viability.
A demonstration of this emerging relevance came in 1919 with the first transmission of
scheduled and publicised content, material delivered in a form that would certainly be
recognised today as a radio broadcast.
… a concert was broadcast from The Hague, organised by two Dutch
pioneers, Hanso Henricus Schotanus and Steringa Idzerda. The
programme was entitled "Soiree Musicale", and its claim as the first
"real" radio broadcast in the world rests on the fact that the time,
frequency and content was announced in advance of the broadcast in
the press (Street, 2006: 40).
The emergence of proto-radio broadcasting was a truly international phenomenon.
Soon after the above transmissions, both Britain and America also become involved in
scheduled radio broadcasting. In June 1920, following various informal tests and other
broadcasts, Australian opera singer, Dame Nellie Melba, broadcast a thirty-minute
concert from the Marconi Long-Wave transmitter near Chelmsford, England.
Publicised (and sponsored to the tune of £1,000) by Lord Northcliffe's Daily Mail, the
broadcast "was a turning point in the public response to radio. It caught the
people's imagination" (Briggs, 1961: 47).
Across the Atlantic, by November 1920, station KDKA was broadcasting regularly in
Pittsburgh, Pennsylvania. The Westinghouse Corporation saw radio broadcasting as a
way of selling radio receivers and opened the station by using it to announce the results
of the 1920 Presidential Election (Lewis, 1991: 152-153). An indication of the frenzy
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of developments around radio broadcasting at that time is demonstrated by the fact that
historians are unsure that KDKA was indeed the first scheduled radio broadcaster in the
USA, thus "there is some dispute over KDKA's 'earliest' claim" (Bensman, 2000:
15).
Undoubtedly, "the "radio craze" of the 1920s" (Lacey, in Hilmes and Loviglio
(Editors), 2002: 24) had begun. What drove this development was not just the interest
of those building and operating the transmitters, but also the increasing number of
enthusiasts building equipment to receive their signals.
Broadcasting developed because audiences wanted it and
experimenters began to provide it. It was fun and entertaining. It
was available and free. Only later did it become commercial and
profitable (Greb & Adams, 2003: 16).
From such experimental beginnings, broadcast radio quickly evolved. Initially it tended
to be dominated by commercial objectives, but, particularly in many parts of Europe,
the state soon intervened in an attempt to exert control over this fledgling electronic
medium. Many countries, which began with private broadcasters, for example, the
United Kingdom, Norway and the Republic of Ireland, effectively nationalised early
private radio stations, assimilating them into state broadcasting monopolies such as the
British Broadcasting Corporation (BBC) (Crisell, 1987: 22), Norsk Riks-Kringkasting
(NRK) and Radio Éireann (known today as Radio Telefís Éireann - RTE).
The attitude of politicians to the emergence of broadcast radio was shaped by a variety
of factors. In the United Kingdom, the government demonstrated its willingness to go
against public opinion and private interests very early on. Despite their popularity
amongst wireless enthusiasts, the various experimental radio broadcasts of music and
news material, which were carried out by the Marconi Company under an experimental
licence during 1920, were suspended by the Postmaster General later that same year.
The reason cited for this action was interference to other radio users, in particular the
military (Briggs, 1961: 49-50):
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There was – in spite of growing public interest in radio as an
entertainment medium – a sense that radio transmissions should not
be used for other than official or military purposes (Street, 2006: 41).
This early use of the 'interference argument' was one of the first of many. This
supposed justification, or excuse, for inaction or the restriction of broadcasting
development, has continued to be used, by numerous jurisdictions around the world,
right up to the present day. Although public pressure did lead to further speech and
music transmissions prior to the formation of the British Broadcasting Company in late
1922:
It is noteworthy that in order to be able to establish regular
entertainment on radio in the first place, pressure had to be exerted
on official British government departments at a time when elsewhere
around the world, including the USA and France, the idea of the
medium as a disseminator of speech and music was widely accepted
(ibid, 43).
The more relaxed and market orientated approach to radio broadcasting as taken by
some other jurisdictions marked the beginning of differentiation of broadcasting on a
national basis. For example, although British and American approaches to radio
broadcasting quickly became very different from each other:
In their birth and infancy, however, they were not so distinct as they
have since become. In both countries there were the same pressures
and the same outspoken advocates of common ideas and comparable
institutions. (Briggs 1961: 59).
In parallel with developments in the United Kingdom, the American radio industry was
growing rapidly. When the first advertising was introduced in 1922, there was
considerable opposition to the move. Speaking at the first American Radio Conference
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in the same year, Herbert Hover, Secretary of the Department of Commerce stated that
it was "inconceivable that we should allow so great a possibility for service …
to be drowned in advertising chatter" (ibid, 63, quoted in Siepmann, 1946: 140).
However, "[h]igh minded opposition … did not destroy the practice, largely
because no reasonable alternative means of securing revenue for
broadcasting companies was ever proposed" (ibid.). Thus, financed largely
through the sale of advertising, by the end of 1924, there were over 500 stations
operating in the United States, with very little control by the state of their broadcasting
activities:
During the first years of broadcasting experience it was not distaste
for American advertising which influenced the first British critics of
American broadcasting, but alarm at the 'chaos of the ether' in the
United States. The multiplicity of radio stations and the scarcity of
wavelengths led to interference and overlapping 'a jumble of signals'
and a 'blasting and blanketing of rival programmes'. Even in
America itself, despite its tradition of free enterprise, there was
pressure for government 'policing of the ether' … A few Americans
were even tempted to look with approval on the British Post Office
(ibid., 64).
Whereas in the United States the 'genie was out of the bottle', in Britain and in other
parts of Europe, perceptions of the chaotic state of American radio broadcasting
undoubtedly helped shape the attitude of politicians in relation to the future
development of the medium. A key event was the American 1922 Radio Conference
organised by the Secretary of Commerce, Herbert Hover to share and regulate the
already crowded airwaves of the USA (Lewis and Booth, 1989: 36). Taking place in
Washington DC, the conference was attended by a representative of the British General
Post Office, one F. J. Brown. Reporting back to the British Imperial Communications
Committee in Westminster, Brown took the view that:
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… only bona fide set manufacturers should be involved in
broadcasting and that 'clashing' of wavelengths had to be avoided.
(ibid., 52)
This struggle for the control of broadcasting demonstrated by such early social and
political manoeuvrings has arguably been a feature of the medium ever since. The ongoing debate over the scope and scale of Community Radio is but one modern-day
element of the continuing media policy debate which can trace its roots right back to
the emergence of radio broadcasting in the early years of the Twentieth Century.
From the outset however, commercial broadcasting was not limited to the confines of
the Americas. In other parts of the world, including European countries such as France
and Luxembourg, some commercial broadcasters prevailed, succeeding in maintaining
their independence from the state. Conceptually, the two types of broadcasting rapidly
became very different from each other. Rather than being driven by the commercial
imperative to maximise audiences and thus profits for shareholders, state-owned
broadcasters, most notably the BBC in the United Kingdom, soon developed the
concept of a public service broadcasting ethos and practice, promoting the delivery of
information, education and entertainment as an end in its own right. For commercial
broadcasters, delivering the greatest number of listeners at the minimum possible cost
was the priority from the outset, even if this meant broadcasting across borders and thus
sometimes competing directly with the PSB broadcasters in neighbouring jurisdictions.1
Inevitably therefore, particularly in a European context, it soon became impossible for
either type of broadcasting to ignore the impacts of its rival. Over time, in the post-war
period, the early divergence in approaches to broadcasting was, in most countries,
gradually superseded by a duopoly of state and commercial radio broadcasting. Even in
the United States, the cradle of commercial broadcasting, a limited amount of public
service broadcasting was eventually introduced with the launch of National Public Radio
(NPR) in 1970. In addition, the Federal Communications Commission (FCC) has,
1
As for example in the case of Radio Normandie and Radio Luxembourg etc., which, from the 1930s,
targeted specific programming at listeners in the United Kingdom, where the BBC otherwise had a defacto and de-jure broadcasting monopoly.
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historically, always reserved some broadcasting frequencies for non-commercial use.
These allocations allow the operation of educational stations and alternative services,
such as those provided by stations within the Pacifica Network.
With dual PSB and commercial radio broadcasting systems becoming the norm over
recent decades, the demand for additional broadcasting spectrum, or for improvements
in the efficiency of its use has been almost ever present. As technological competence
has increased, so has the number of frequencies used for broadcasting, along with overall
information carrying capacity they provide. However, because broadcasting spectrum is
a finite resource, the laws of physics dictate that as the number of operational services
increases, the inevitable result is that the number of frequencies available at any location
for additional broadcasting services becomes increasingly limited.
For 'third sector' community broadcasters seeking frequencies in jurisdictions where
dual broadcasting systems have already become firmly established, the lack of available
broadcasting frequencies can be a limiting factor in the development of their services.
Fortunately for prospective broadcasters, technological advances have, at least to some
extent, progressively increased the availability of frequencies at any given location; as
discussed further below, demand does not outstrip supply to the extent that it might
have done in the absence of such advances.
2. Platform Evolution and Diversification
Once the practice of radio broadcasting became established during the 1920s, it
continued to develop, not just in terms of programming diversity but also in relation to
its own technological requirements. Thereafter, the development of one-to-one radio
telephony, or radio communications systems, rapidly became separate from the
development of one-to-many radio broadcasting. As the potential for this new form of
mass communication became clear, inventors, engineers and technicians took up the
challenge of improving its performance.
At the outset of radio broadcasting, the state of available technology was such that it was
only possible to transmit and receive on relatively low frequency, long-wave and
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medium-wave, spectrum allocations. Gradually however, technological advances meant
that it became possible to use higher and higher frequencies, resulting in the availability
of access to considerable additional spectrum. In terms of radio broadcasting, first came
various short-wave allocations (used primarily for international broadcasting, but also
for domestic broadcasting in some regions), then came vhf Band II (the FM stereo
band) and, more recently, Band III (used for digital audio broadcasting). Other
microwave frequencies, such as L-Band (approximately 1.4 to 1.5 GHz), have been used
for satellite delivered services such as 'WorldSpace' and for short-range terrestrial DAB
transmissions, but to date, only to a very limited extent.
Whilst not all of the above allocations are universally used for broadcasting, and whilst
various other frequencies may also be used for broadcasting, the overarching effect is
that, throughout its history, the availability of broadcasting frequencies has tended to
increase albeit at a relatively slow pace. Higher frequencies, such as FM Band II, have
additional advantages. As well as being less susceptible to degradation due to changes in
atmospheric conditions, they can also be used to serve more accurately defined coverage
areas and be re-used more frequently, without degrading other transmissions sharing the
same spectrum.
Alongside expanded carrying capacity, and enhanced coverage flexibility, throughout its
history, broadcast radio has also gradually become an increasingly high quality medium
in terms of its content delivery capabilities. From its low-fidelity, monophonic, speechonly, beginnings, the medium has evolved to become capable of delivering high-fidelity
stereophonic music content, as well as additional non-audio data-streams (such as RDS
RadioText etc.), through increasingly robust transmission pathways.
More recently, further technological advances have also increased the number of
platforms over which radio programming can now be delivered. Such change has been
especially prevalent over the past fifteen to 25 years. From the early 1990s, in particular,
digitisation and convergence have both played their part, with new digital broadcasting
technologies, such as EUREKA 147 Digital Audio Broadcasting (DAB), cable and
satellite, all emerging in competition with established analogue platforms. In addition,
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the delivery of broadcast content over non-broadcast infrastructure, such as the Internet
and mobile phone networks, has become increasingly viable, at least from a
technological perspective. The availability of Internet-based 'broadcasting' in particular
has become relatively commonplace, although mass audiences and viable economic
models, whilst existing in a minority of cases, generally remain elusive.
As a direct result of such developments, today, broadcast radio stations can be delivered
via an increasing range of technologies, including both analogue and digital broadcasting
platforms as well as other Internet-based and telecommunications-based networks,
which were not originally intended as broadcast content delivery mediums. However,
this plethora of options is not necessarily entirely beneficial; stations are plagued with a
surfeit of choice. As one specialist broadcast radio operator put it:
Only as recently as the early 1990s, everything was clear: get a
licence and an FM frequency and just get on with it! Today, it's
much more complicated, there's much more competition and
everything is multi-platform. We have to be more innovative to
survive, and it's not clear which of the platforms out there we should
be backing.2
Over recent years, technological advances in broadcasting and related fields have
undoubtedly multiplied the number of potential programme delivery options for radio
broadcasters. However, despite such advances, and at least for the present, traditional
analogue radio platforms (FM & AM transmissions) remain very much the dominant
delivery conduits for broadcast radio (such dominance being one of the key justifications
for their continued regulation). Analogue platforms remain primary for a number of
reasons, not least the fact of their ubiquity. Today, analogue broadcast radio coverage is
near universal in terms of its geographical reach; whilst analogue broadcast receivers are
almost omnipresent, not just in the home and workplace, but also in the car, in mobile
phones and in a variety of other portable entertainment devices.
2
Sammy Jacob, Managing Director of NME Radio, in conversation, October 2009.
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Despite the increasing diversity of alternative programme delivery options for
broadcasters, a further reason for the continued dominance of the 'old-guard' analogue
transmission platforms is the location-specific focus of the majority of broadcast radio
content. Where consumption (listening) is concentrated around a specific location, the
one-to-many broadcasting model has particular economic and practical advantages over
the telecommunications one-to-one model. Although digital transmission platforms
also have the advantage of being broadcast technologies, the 'first generation' systems,
which are currently prevalent, have, historically at least, tended to be less flexible in
terms of their ability to meet the specific geographical coverage requirements of
individual radio stations.
In the case of speech-based radio services, to a greater, rather than lesser extent, these
require some geographical focus in order to be of relevance to their listeners. At the
macro-level (for example in the case of national and regional services), such a focus may
be used to help put international events into a national context or to focus on broader
national issues. At the micro-level (of local and community broadcasting), it involves
reporting and reflecting local experiences, tastes and interests. Despite the fact that
music-focused radio programming can be created and delivered without much in the
way of a geographical focus, nevertheless, in the majority of cases, elements of its
content will still have a degree of geographically focused content included in their
output.
For geographically targeted services, the key benefit of one-to-many broadcast delivery is
that, although stations may pay extra for additional geographical coverage (range), there
is no appreciable economic marginal cost for adding additional listeners. Broadcast
radio stations must pay to achieve their broadcast range, regardless of the number of
people actually listening to them. In addition, within the area to which the station
broadcasts (its 'service area'), there is no upper limit to the number of individuals that
can listen to its output; a 100% reach is, theoretically at least, achievable.
However, in comparison, although they tend not to have to pay for coverage range, for
one-to-one telecommunications based delivery platforms, the greater the number of
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listeners to a station, the greater the cost of programme delivery becomes. Not only is
there a specific financial marginal cost per listener (typically fixed regardless of the
distances involved), but, where consumption is concentrated around a specific
geographical location, there may also be capacity limitations as to the number of
concurrent listeners that the local telecommunications infrastructure can reliably
accommodate.
Analogue broadcast radio platforms, therefore, currently offer a number of advantages
beyond the fact that they can, to all intents and purposes, be said to be universally
available and accessible to all, regardless of location, when at home, at work or when
travelling. The penetration of even the most popular of digital technologies pales by
comparison, both in terms of signal distribution and in relation to receiver availability.
To date, in those countries that have pursued the introduction of one or another form
of digital radio broadcasting, there remain locations (typically those that are more
remote and rural) that are not yet properly served by the technology or technologies
concerned. Moreover, the availability of digital radio receivers remains limited.
Portable and mobile designs are particularly rare and, where they do exist, command a
considerable price premium over their analogue counterparts.
Price premiums do not apply to the cost of digital receivers alone. Costs of transmission
infrastructure also tend to be higher for digital transmissions than for equivalent
analogue alternatives. There are a number of reasons for such discrepancies, including
the need for royalty payments and the added complexity of the digital transmission
chain. Such additional complexity can also load the cost of on-going maintenance,
particularly because the engineering skills-base available will be smaller in relation to
emergent technologies.
Perhaps the greatest problem for the proponents of new digital radio broadcast
transmission systems is the flexibility and robustness of the established analogue
platforms. FM broadcasting, in particular, can be scaled from the micro-level to the
national, providing high quality stereophonic audio with limited digital data carrying
capacity (RDS) built-in. Digital alternatives such as DAB can offer clear benefits in
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some areas, such as spectral efficiency for wide-area coverage services, but they currently
struggle to achieve levels of flexibility and cost-effectiveness similar to those offered by
analogue FM. A further problem is that, at present, there are a number of different
digital radio broadcasting systems competing with each other, with no one standard yet
obtaining a clear dominance. Add to the mix the various concurrent developments in
online, web-based, audio content delivery and it soon becomes clear that digital radio
broadcasting is attempting to establish itself in a highly competitive media technology
environment.
The relative merits of analogue and digital platforms are complex and are explored in
more detail later in this thesis. However, as a result of all of the above, it is clear that
there is public confusion over the potential benefits of digital radio broadcasting, whilst
satisfaction levels for FM broadcasting remain high. It is for these reasons that analogue
terrestrial broadcast radio spectrum remains a scarce resource, with demand continuing
to outstrip supply. All broadcasters continue to want access to analogue broadcast
spectrum because this remains the platform of choice for the vast majority of potential
listeners as well as being the only currently viable route for reliable mass mobile and
portable reception. Despite some attempts by individual administrations to encourage
digital alternatives, it is not yet the case that even a minority of terrestrial broadcasters
are volunteering to surrender their analogue spectrum. Indeed some, including
numerous Community Radio operators, continue to press for access to more analogue
frequencies, arguing that the current imbalance in their distribution unfairly
disadvantages them, discriminating against their further expansion and development.
Building on this introduction, the roll of technology today as it relates specifically to the
operation of Community Radio services is examined in further detail later in this thesis.
Although technological developments (and changes in the attitudes of politicians) have
allowed the total number of broadcast radio services available at a given location to
increase dramatically over the years, the problem is that such increases in carrying
capacity have failed (particularly in urban environments) to keep pace with the parallel
demand for yet more additional radio services. With other non-broadcast demands for
access to spectrum continuing to increase, the likelihood of additional spectrum being
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allocated to broadcasting in the foreseeable future looks remote. An end to simulcasting
(the transmission of a single programme stream on more than one broadcast frequency,
for example on both FM and DAB) could, in some jurisdictions, potentially free up
some additional resources. However, in many jurisdictions, the scale of imbalance
between supply and demand is such that it would only be marginally reduced by any
such moves.
3. Radio, Regulation and Change
A variety of external factors each play their part in the emergence of any new product or
service. Radio broadcasting, as both a product and a service, is a case in point. In the
early part of the Twentieth Century, "[s]ocial, political and technological
implications paved the way to regulation of [radio] broadcasting" (Bensman,
2000: 3). As broadcast radio expanded, these factors were joined by commercial and
wider economic considerations, creating, over time, the complex regulatory structures
that underpin the operation of the medium today. Broadcast radio regulation imposes
requirements and limits on the operation of licensed broadcast radio services,
contributing towards the success or failure of individual new ideas and directions within
the medium, helping or hindering their development, popularity, viability and
longevity.
It might be argued that modern-day regulation of the broadcast radio medium must
inevitably be more complex than it was earlier on, simply because it has to accommodate
greater diversity and scale. However, on the other hand, it is important to keep in mind
that it is not only the expansion and diversification that has taken place within radio
broadcasting itself that has affected the way in which the medium is regulated today.
Equally important is the wider socio-political context within which such regulation is
implemented.
Radio broadcasting has matured and changed in ways that have been shaped, and in
some cases dictated, by the impact of such external factors. Although partly comprising
elements concerned with internal aspects of broadcast radio itself, in many respects,
broadcast radio regulation can be understood as an intermediary. Such regulation
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defines and controls the nature of the relationship between the radio 'industry', in all its
various forms, and the demands of wider society as represented by the various external
factors that impact upon the medium.
Although this thesis focuses on radio broadcasting and on Community Radio in
particular, it is impossible to examine the specifics of broadcast radio regulation without
first considering, albeit briefly, the wider concept of regulation as a whole. The notion
of government regulation is a contested one, particularly in terms of degree and balance:
From the beginnings of modern political theory, there has been a
debate about whether the state is best when this is small in scope,
focused on creating the conditions in which people can live without
constraint and allowing commerce to innovate and develop according
to its own logic, or whether a strong state is necessary to counter the
extreme effects of modernisation and capitalism so as to enable
citizens themselves to further their interests and realise their
potential (Lunt & Livingstone, 2012: 4).
UK broadcast radio regulation, as it exists today, reflects this debate in microcosm,
being the result of a (sometimes shifting) compromise between competing demands and
objectives from both sides of the above debate. As Lunt and Livingstone highlight:
There are considerable intellectual, political and social challenges to
be faced as the state seeks to balance the protection of public interests
in the face of powerful global economic interests exerting long-term
pressures towards deregulation. (ibid.).
A key justification for the existence of broadcast radio regulation is the issue of scarcity.
As discussed earlier, throughout its history, broadcast radio has been plagued by an
imbalance between demand and supply in terms of available broadcasting frequencies.
Despite technological advances, this imbalance continues, constraining licensing
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opportunities and thus adding to the challenge of balancing the competing demands
referred to above.
It is perhaps fortunate for the survival of broadcast regulators as a breed that the
continued dominance of long-established analogue platforms means that the problems
of spectrum scarcity have yet to be completely solved. Because demand for analogue
frequencies continues to outstrip supply, decisions still have to be made about who
should be granted the privilege of access to the airwaves and on what basis such access
should be granted. Unless and until the dominance of the analogue broadcast radio
delivery model is broken, such scarcity will, in one form or another, continue to require
regulation. Even when such platforms are, eventually, superseded, it is still too early to
judge how well their replacements might cope with future capacity demands.
Modern broadcast regulation is however concerned with more than simply allocating a
range of scarce frequency resources. In the UK, and to a greater or lesser extent in most
democratic countries, in terms of broader regulatory theory, it comes down firmly in
favour of addressing "not only economic but also social and cultural policy"
(ibid., 18). It was this broad-based approach to regulation which underpinned the
foundation of non-commercial BBC as a public service broadcaster and which, more
recently, has provided a justification for the development of smaller-scale communitybased broadcasting.
The politics behind broadcast regulation are by no means static and over the years have
influenced the development of broadcast regulation from its original "top-down stateled, command-and-control style" (ibid.), to a more dispersed approach
"encompassing both administrative … and even 'softer' or more discursive
modes and techniques of power" (ibid.). This gradual change is perhaps best
exemplified by the way in which regulatory control of broadcasting has, over recent
years, been removed from direct government oversight to become the responsibility of a
succession of increasingly autonomous regulatory bodies.
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One broader outcome of such developments is that the breadth and depth of broadcast
radio regulation as a whole has tended to decrease. For example, detailed regulations
concerning programming formats have gradually been diluted, and traditionally
proactive and broad-ranging rules concerning 'taste and decency' have, as discussed
further below, been largely replaced with reactive regulation, relating to a narrower set of
issues encompassed by the phrase 'harm and offence'. Over recent years, and
particularly in relation to commercial radio broadcasting, both 'input regulations', the
imposition of regulations over how programmes are produced (for example, in terms of
where programmes are produced) and 'output regulations' (for example, in terms of
what content is required to be broadcast), have tended to be gradually reduced. From
this perspective, it is possible to suggest that the 'high tide' of radio regulation is already
receding.
Such changes do not simply reflect the changing attitudes and priorities of politicians
and regulators. They also affect the attitudes and expectations of station operators,
prospective station operators, and, not least, members of the wider general public. Such
relaxations in the area of programme content have been driven not only by wider social
change, but also, internally to the broadcast radio industry, by the commercial sector, in
its constant search for lower costs and higher profitability. It is into this new world of
reduced content regulation that UK Community Radio has emerged over the past
decade. However, as the aims and objectives of Community Radio are very different
from those of its commercial competitors, it remains to be seen whether or not such a
'light-touch' regulatory approach is also appropriate for non-profit-distributing services.
Over the years, technological advances have provided increasing opportunities for the
expansion of radio broadcasting. Individual broadcasting platforms have matured, and
others have emerged, diversifying the delivery options for radio programming beyond
the confines of traditional broadcast transmission. Such evolution has, inevitably,
affected the direction and development of broadcast radio regulation. Radio
broadcasting has expanded, in terms of its scope, scale and influence, changing the
make-up of broadcast radio regulation in the process. Even in the current situation
where analogue radio broadcasting remains dominant, by definition, the modern-day
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regulation of competitive broadcast radio plurality is inevitably very different from the
earlier regulation of a small number of pioneering and often monopolistic providers.
Taking advantage of technological advances and adopting more market orientated
approaches, over recent years, the attitude of British and European politicians has
gradually relaxed somewhat. Rather than seeking to ensure the provision of only a small
number of universally available, common interest, PSB services, as was the case during
much of the earlier history of European radio broadcasting, today's politicians and
regulators have somewhat eschewed such 'old-fashioned' notions of mutuality, in favour
of approaches designed to provide choice, or perhaps, more precisely, 'consumer choice'.
Thus, broadcast radio today has evolved to reflect underlying changes in society; more
specifically, its regulatory guiding principles have become less centralised and
paternalistic.
The regulation of broadcast radio can be sub-divided into a number of key policy areas,
as summarised in Table 1.1 (below). Although many of these areas are distinct and
separate from each other, broadcast radio regulation is complex and, inevitably, there are
aspects that also overlap with each other.
The following table summarises a number of key policy areas that may be covered by
broadcast radio regulation. However, it should be noted that the relative importance of
these various elements will tend to vary on a jurisdiction-by-jurisdiction basis. In the
UK, the principles of analogue radio regulation are currently set out within the
Broadcasting Act 1990 (HMG UK, 1990). Digital radio is covered both by this Act
and by the subsequent Broadcasting Act 1996 (HMG UK, 1996). The underlying
powers of Ofcom are defined in the Communications Act 2003 (HMG UK, 2003),
with specific duties concerning Community Radio being set out in the Community
Radio Order 2004 (HMG UK, 2004) and the Community Radio (Amendment) Orders
2010 (HMG UK, 2010) and 2015 (HMG UK, 2015).
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Table 1.1: Key Elements of Broadcast Regulation.
Ensuring the optimal use of the electro-magnetic spectrum
(A) Spectrum
Planning
used for broadcasting. Preventing interference to other
spectrum users. Defining coverage areas and preventing
unlicensed transmissions (consisting of both international
and national elements).
(B) Service
Ensuring a diverse range of services is available by limiting
Diversity /
content overlap between services available at a particular
Plurality
location (consisting of national and local elements).
(C) Content &
Miscellaneous
Regulation
Covering issues such as 'harm and offence', the protection
of minors, electoral law, balance, undue influence, criminal
activities, religion and privacy (in the UK, these matters are
primarily covered by the Ofcom Broadcasting Code).
Restrictions and requirements concerning the carriage and
(D) Revenue
content of spot advertising and station / programme
Generation
sponsorship (in the UK, these matters are covered by the
Ofcom Broadcasting Code).
(E) Ownership
Restrictions
Limits on station ownership within a given area and / or in
terms of potential audience reach etc. 'Fit and proper'
ownership etc.
Drawing upon Ofcom as the primary source of information, this table presents the
issues surrounding the regulation of broadcast radio as discussed in detail in the
regulator's various publications: Radio – Preparing for the Future (Phase 1: Developing a
New Framework) (Ofcom, 2004(b)) and The Future of Radio: The Future of FM and AM
Services and the Alignment of Analogue and Digital Regulation (Ofcom, 2006). Specific
duties and approaches to the licensing of Community Radio services are set out in its
consultation document: Licensing Community Radio, published in February 2004
(Ofcom, 2004). These various elements of broadcast radio regulation are applied in
varying degrees to both the licensing process, prior to commencement of broadcasting,
and to the operational activities of individual radio stations once licensed.
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(A) Spectrum Planning
Limits on the availability of spectrum and managing competing demands for its use,
were the original justifications for regulation of the airwaves. Both requirements remain
relevant today and continue to influence the implementation of various elements of
radio policy and regulation. At first glance, maximising access to the airwaves and
minimising interference might appear to be relatively simple issues. However, as has
previously been discussed, the whole concept of frequency scarcity (both real and
invented) has been the subject of heated debate and argument since the earliest days of
radio broadcasting. Sharing out the 'cake' of broadcast frequencies is not easy,
particularly when the parties involved not only argue over how it should be sliced, but
also disagree about the proportion of its ingredients, its shape and overall size!
The original twin objectives of sharing access to the airwaves and minimising
interference remain the same today as they have always been. As spectrum usage has
intensified, so too has the importance of minimising the amount of interference that
might be caused, both between individual stations, and between radio broadcasters and
other non-broadcast spectrum users. Meanwhile, the demand of additional broadcast
radio services has also increased, adding weight to the importance of maximising the
number of broadcast services that can co-exist and be received within any given area.
Moreover, with control of frequency allocations requiring, by necessity, international
collaboration, the importance of national self-image and external profile cannot be
ignored. Frequency planning, particularly across the crowded continent of Europe, has
always been the subject of inter-jurisdictional rivalry, as countries seek to maximise their
own access to the airwaves.
From a technical perspective, spectrum is shared between competing users through
frequency planning. In the analogue world, the coverage achieved by a particular radio
station can be increased in three ways: firstly, by selecting the most appropriate
transmitter site; secondly, by maximising the amount of power radiated by the
transmitter; and thirdly, by introducing additional frequencies and transmitter sites to
carry the same programming beyond the range of the original transmitter. However, in
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the analogue domain, the greater the coverage achieved by a particular radio station, the
further away from it the frequencies concerned can be re-used by other services. On the
other hand, weaker signals create problems of inadequate mobile and portable reception
as well as an increased susceptibility of the programme material being carried to
interference. The higher the level of unwanted signal 'noise' from other distant,
unwanted services, the greater the amount of degradation that occurs to the wanted
radio signal. The objective of regulation here is to maximise the degree to which such
problems can be ameliorated through the imposition of rules and limits that ensure
adequate coverage, whilst at the same time attempting to prevent interference between
broadcasters and between broadcasters and other spectrum users. In a crowded
broadcasting environment, it is still possible to introduce additional services, but only at
the expense of causing increased degradation to the reception of services already
broadcasting in the same and adjacent areas. Under such circumstances, coverage is
effectively constrained by a process referred to as 'interference limiting'.
Part of the reason for on-going technological developments in radio broadcasting is a
drive to overcome the various limitations mentioned above. However, from another
perspective, the evolution of radio broadcasting policy as it relates to technological
change can often appear to take the form of an on-going game of catch-up the other way
around. Politicians and regulators often struggle to keep abreast of an increasing range
of technological developments, failing to understand fully their various implications. As
a result, the reactions of politicians and regulators can often be slow (they might argue
cautious) and inappropriate, resulting in regulatory environments that are less than ideal
for the radio industry and / or the wider general public (as both citizens and consumers).
The requirements of spectrum planning (A in Table 1.1 above) place specific technical
limits on the number of radio services that can be broadcast to a given location.
However, as a multitude of technological advances have been made in relation to the
transmission of broadcast radio services, it has been possible to increase the number of
radio services provided. For example, as AM broadcasting was supplemented by FM,
regulators were able to increase variety of radio stations they licensed to broadcast. In
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some areas at least, the subsequent arrival of digital transmission systems has further
increased the availability of additional services.
Although technological advances have facilitated a gradual expansion in the availability
and increasingly efficient use of broadcast radio spectrum, there remain other nontechnical uses of the frequency scarcity argument. Specifically, a further fundamental
limitation on the licensing of additional services has been the traditional and often
entrenched cautiousness of politicians and regulators. These actors have historically
tended to regard access to the airwaves as a privilege to be jealously guarded, rather than
a right to be facilitated by the state for the benefit of its citizens. Concerns about the
technical issues of frequency scarcity and interference, genuine as to some extent they
may be, have also been used as a proxy for the broadly political placing of limits on the
types of groups and individuals granted access to the airwaves.
From its earliest days, the perception of radio broadcasting has been one of a powerful
medium, one with a potential to exercise considerable influence over its listeners (as
both citizens and consumers). Such perceptions have undoubtedly influenced the way
in which the medium has been permitted to develop, and, to a certain degree, this still
remains the case today. Particularly in Europe, politicians have tended towards caution,
limiting access to the airwaves through legislation and regulation in ways that would
probably be considered intolerable if applied to other walks of life, or to other media. It
is difficult to imagine more traditional media, such as printed newspapers and
magazines, or so-called 'new media', such as Internet communications and the World
Wide Web being regulated to the same degree. It is the existence of the frequency
scarcity argument that underpins the application of stricter regulation in relation to
broadcasting alone.
Nevertheless, as Western society has become less homogeneous, so the demand for
additional radio services, which encompass and reflect the increasingly diverse range of
individual tastes and interests, has expanded accordingly. In trying to accommodate
such demands, the response of British and Western European politicians and regulators
has tended to err on the side of restraint, particularly when it comes to considering the
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demands of more marginalised elements of society, as so often represented by the
Community Radio sector. Thus, official attempts to reflect and accommodate some of
the growing diversity and individualism to be found within today's increasingly
multicultural and consumer-driven society have tended to be limited in terms of their
relative scope and scale.
Regulation in relation to frequency availability has not therefore developed solely as the
result of attempts to minimise purely technical problems caused by practice coming up
against the current limits of broadcast radio technology. From the outset, such concrete
considerations have undoubtedly been important, but so too have political and cultural
concerns about the potential social impacts of radio broadcasting.
(B) Service Diversity and Plurality
This second element of broadcast radio regulation arises, at least in part, out of the first.
Over the years, the popularity of radio broadcasting along with a desire to control access
to it, have conspired to create a consistent problem of imbalance (genuine and
manufactured) between supply and demand in terms of available broadcasting
frequencies. Although, as has been shown, technological advances have considerably
improved the availability of usable broadcast frequencies, demand for access to such
spectrum has also grown, such that the imbalance between supply and demand
continues to exist.
Despite such difficulties, over the first century or so of its existence, broadcast radio has
evolved from an initial handful of single platform, broad-format, mono-cultural
channels, to the present day multi-platform, multi-station, multi-cultural model,
encompassing every possible scale, from the international to the ultra-local. In parallel
with such developments, the nature of broadcast radio content has also changed. The
vast majority of broadcasters no longer seek to provide programming of interest and
relevance to everyone within their coverage area, typically through the provision of a
diverse range of programming. Instead, most of today's radio stations, particularly those
that operate on a commercial 'for-profit' basis, tend to be increasingly formatted, so as
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to serve, or 'super-serve' only a specific sub-section of the total potential listenership
available within their coverage area.
Commercial radio broadcasters identified as early as the 1930s that popular
programming aimed at a lowest common denominator was the best way to maximise
listenership and therefore profits. As a result, commercial broadcasters tend to compete
with each other within a relatively narrow band of popular formats, leaving more
specialist and niche interest programming to others. Thus, a simplistic market-based
approach to the regulation of broadcast radio has its limits, as there are various types of
programming that the 'market', because of its need to maximise profitability, is not
interested in or capable of providing.
Nevertheless, in jurisdictions such as the United Kingdom, it still remains the case that
considerable weight is placed upon the wider social value of various types of broadcast
radio programming, which commercial radio broadcasters lack the will or capability to
provide. It is primarily for this reason that not all of today's broadcast radio services are
privately operated on a for-profit basis. Public Service Broadcasters (PSBs) and, more
recently, Community Radio services, exist, at least partly, to provide services that the
market cannot or will not deliver.
Here then, is the second justification for regulating diversity and plurality of content: a
desire to broaden the range of programming available to beyond that which the market
alone would provide. In some countries, for example the United Kingdom, this
objective has led not only to the creation of a strong PSB provider in the shape of the
BBC, but also to various interventions in the licensing and operation of commercial
radio broadcasting. In some other jurisdictions, such as the United States, where faith
in the market has traditionally been stronger, much smaller market interventions have
been made. Commercial radio there is much more lightly regulated and Public Service
Broadcasting, in the form of National Public Radio (NPR) is a far smaller and more
marginal operation.
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Given such market limitations and the long-standing imbalance between supply and
demand, many jurisdictions have implemented regulatory attempts to broaden the range
of services available and share out limited broadcasting spectrum. There are a number
of ways in which this can be done, ranging from a lottery or auction, to some sort of
'beauty contest', which requires applicants to guarantee certain characteristics of their
proposed service, should it be awarded a licence to broadcast.
Analogue local radio licensing in the United Kingdom is carried out under the
requirements of the Broadcasting Act 1990 (HMG UK, 1990), and section 105 of the
Act requires that the licensing body take into account:
(a) the ability of each of the applicants for the licence to maintain,
throughout the period for which the licence would be in force, the
service which he proposes to provide;
(b) the extent to which any such proposed service would cater for the
tastes and interests of persons living in the area or locality for which
the service would be provided, and, where it is proposed to cater for
any particular tastes and interests of such persons, the extent to which
the service would cater for those tastes and interests;
(c) the extent to which any such proposed service would broaden the
range of programmes available by way of local services to persons
living in the area or locality for which it would be provided, and, in
particular, the extent to which the service would cater for tastes and
interests different from those already catered for by local services
provided for that area or locality; and
(d) the extent to which any application for the licence is supported
by persons living in that area or locality (HMG UK, 1990).
Although this 'beauty-contest' based approach is used for analogue local radio licensing,
alternative approaches are taken for other types of service. BBC radio services are
licensed under the terms of the Corporation's Royal Charter, with each BBC radio
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service (national and local) having its own Service Licence.3 National analogue
commercial services were awarded their original licences by way of an auction process
(HMG UK, 1990: Sections 98-103), whilst national and local digital programme
services are licensed under the terms of the Broadcasting Act 1996. This contains
similar requirements to those concerning local analogue licensing ((a) to (d) (above)),
but allows the multiplex licence holder to sub-contract the provision of the various
individual programme services it carries (provided these meet the requirements of its
licence and are approved by the regulator) (HMG UK, 1996 Sections 47 & 51).
In the UK at least, the current diversity of approaches to broadcast radio licensing is
something of a pick-and-mix affair, and the arrival of Community Radio licensing
further complicated the licensing matrix. In addition to being required to meet the
requirements of Section 105 of the Broadcasting Act 1990 (above), the terms of the
Community Radio Order 2004 (HMG UK, 2004: Section 5), modify this to include a
further three clauses as set out below:
(e) the extent to which the provision of any such proposed service would
result in the delivery of social gain to the public or the relevant community;
(f) the provision that each of the applicants proposes to make in order to
render himself accountable to the relevant community in respect of the
provision of the proposed service;
(g) the provision that each of the applicants proposes to make to allow for
access by members of the relevant community to the facilities to be used for
the provision of the service and for their training in the use of those
facilities.
The inclusion of these additional requirements in the Community Radio licensing
process serves a dual purpose. In addition to ensuring that UK Community Radio
services are focused on the provision of benefits to their target communities, these
clauses also help ensure that such services are effectively prevented from becoming
3
Details of BBC Service Licences are available on-line at:
http://www.bbc.co.uk/bbctrust/our_work/service_reviews/
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commercial radio 'clones' and thereby increase the degree of competition with stations
in the established small-scale commercial sector.
(C) Content and Miscellaneous Regulation
The spectrum planning and content diversity elements of broadcast radio regulation, as
discussed above, can broadly be considered to be positive regulatory interventions,
designed to maximise the effective delivery of a large and diverse range of broadcast
radio services. However, in addition to facilitating access to the airwaves through the
licensing process, regulators are also concerned with oversight of the programming
content carried by individual radio stations. Typically, in a European context at least,
prospective radio stations are required to provide details of their intended programming
content and once on air, they are required to abide by rules concerning content
regulation. The core objective of such regulation is to prevent certain types of content
(as summarised in Table 1.1 above) from reaching the airwaves.
In the UK, content regulation is a further responsibility of the broadcast regulator,
Ofcom, which publishes (and regularly revises) its Broadcasting Code (Ofcom, 2008
and 2015 (d) etc.). Divided into sections, this code sets out a wide range of rules that
cover issues such as: the protection of minors; harm and offence; crime; religion; due
impartiality and accuracy; elections and referendums; fairness; privacy; sponsorship; and,
commercial references. Outside the code, there are other minor regulatory hurdles for
broadcasters to overcome. These include a requirement that any licence must be held by
a "fit and proper" person, for example, not someone who has been prosecuted for
unlicensed broadcasting within the preceding five years (Ofcom, 2012 (b)).
Community Radio services tend to be highly targeted in terms of both their
programming outputs and potential audiences. A key element within Ofcom's
broadcasting code is the section which deals with 'Harm and Offence' (ibid., 14-17).4
4 Previously, such programme content issues were captured under the broader umbrella term of 'taste
and decency'. Present-day terminology is therefore more tightly defined than was previously the case.
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The problem for minority Community Radio operators is that although "context" is
taken into account, such regulation is based on "[g]enerally accepted standards",
(ibid., 14) which may not be relevant to the minority audience involved. The degree to
which certain generic rules concerning the nature of broadcast content may be
appropriate for such services can be a concern for their operators. This is particularly
the case when the target communities involved are marginalised with respect to
mainstream society. How broadcasting regulations are implemented and the degree to
which they accommodate such diversity is an issue that can have a considerable impact
upon the effective delivery of such services.
(D)
Revenue Generation
A key input of any radio broadcasting organisation, large or small, is the revenue streams
available to it. To a certain extent, the nature of these revenue streams impacts upon the
nature of a station's outputs. From a regulatory perspective therefore, defining the
revenue streams available to a given type of radio station can be an effective tool for
achieving various public policy objectives, such as promoting economic growth,
encouraging competition and ensuring a diversity of radio services.
For PSB and commercial broadcasters, the predominant sources of income that each of
them draw upon is clearly defined. In the UK, the Television Licence Fee is also used to
fund BBC network and local radio services, with commercial radio stations being
predominantly funded by the sale of spot-advertising and programme / station
sponsorship opportunities. Stations that depend upon on-air commercial activities for
their funding, by necessity, need to broadcast programmes that attract a large audience.
A larger audience, whilst more economically attractive, may only be achievable with
mainstream programming content. BBC PSB radio on the other hand, funded by a
hypothecated tax, is required to provide a broad range of programming, including
minority content, which would not always be commercially viable.
By comparison, in the UK at least, funding for Community Radio is a rather more
complex affair. At the national level, dedicated public funding is currently limited to
approximately a mere £0.45 million per year (DCMS web-site, 2012 and Ofcom,
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2011). However, as Steve Buckley noted as early as 2009, this fund "has not kept
pace with growth in the number of services" (Buckley, 2009). Indeed, in the
years since this fund was established in 2005, it has not increased, despite the fact that
the number of operational Community Radio services eligible for support has grown
more than ten-fold, from under twenty to approaching 250 (as at April 2012).
Further dedicated funding is sometimes available from individual nations; for example,
in Wales, Community Radio stations can access a £100,000 fund (Welsh Government
web-site 2012) and occasionally, local authorities will provide financial support for
stations in their area (see for example Government Funding web-site, 2012). However,
most Community Radio stations will tend to have to compete for funding from more
general government-related, third sector and charitable funding schemes.
Other popular sources of funding for Community Radio services include donations
from supporters, on-air commercial sales and 'Service Level Agreements' (SLAs) under
which individual stations will deliver particular services for external organisations such as
local government departments, schools or hospitals.
On-air commercial activity (primarily spot-advertising, along with programme and / or
station sponsorship opportunities), whilst permissible for most Community Radio
stations in the UK, is constrained by legislation. The maximum any community station
can generate from all such sources is 50% of their total operational costs (HMG UK,
2004: 7). However, to protect the interests of very small-scale commercial broadcasters,
where the majority of a Community Radio station's coverage overlaps with that of such
a station, the community broadcaster was, until recently, automatically prevented from
generating any income at all from on-air commercial activities (ibid.) and additional
restrictions still apply in such instances.
Ofcom's annual report on the Community Radio sector for 2010 / 2011 (the most
recent available at the time of writing in 2015) makes clear the diversity of funding
sources that stations draw upon, noting that, on average, stations obtain some 37% of
their funding from grant sources, as compared to an average of 21% from commercial
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activities (advertising and sponsorship). Donations and 'Service Level Agreements'
typically comprise 12% and 11% of funding respectively, with various miscellaneous
sources comprising the remaining 6% of income (Ofcom, 2011 (a): 15).
Whilst Community Radio's sources of funding are both diverse and, to a certain extent,
perhaps unpredictable, it would be wrong to assume that this automatically means that
their funding is intrinsically less reliable. Commercial radio stations have no guarantee
of a steady level of income and BBC station budgets, especially for local stations, can be
squeezed from the centre at short-notice.
(E) Ownership Restrictions
Beyond legislative requirements to ensure that radio station owners are considered "fit
and proper" persons for the role (Ofcom, 2012 (b)), ownership restriction can be used
to help promote diversity of content and localness. In other words, this type of input
regulation can also act as something of a proxy in relation to various forms of output
regulation.
Specifically in relation to Community Radio, the ownership limits applied are, in the
UK at least, stringent. Legislation not only limits control through ownership to only a
single Community Radio Licence, but also prevents owners of commercial radio stations
or groups exercising control of community stations.
Although not universally accepted, the single station ownership limit is generally
approved of by the Community Radio sector, primarily because it has seen the decline
in localness and specialist programming, which has occurred in the commercial sector
since mergers and conglomeration into national groups has become the norm there.
It should be noted, however, that the single station ownership rule for UK Community
Radio does not preclude close cooperation between community stations or even between
community stations and commercial ones. For example, various 'BFBS / Garrison
Radio' community stations around the country are all permitted to share the majority of
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their programming aimed at military personnel and their families, even though each
station is independent of the other.
Technological Impacts
Aside from macro-level spectrum and frequency planning, broadcast radio regulation is a
national rather than intentional competency. This can be problematic because radio
waves do not respect geographical political boundaries (as has been demonstrated over
many years by the activities of broadcasters including 'Radio Luxembourg' and the
various off-shore 'pirate' stations). However, before the advent of Internet and satellite
broadcasting, the impact of such interlopers was limited because of frequency availability
limitations.
Today the situation is very different. Internet radio "broadcasting" has emerged, at least
in part, because of the technical limitations of traditional broadcasting technologies.
Current bandwidth issues aside, by comparison with established platforms, Internet
radio broadcasting is practically unlimited in relation to geographical reach and in terms
of the number of services it can carry. Meanwhile, both terrestrial and satellite digital
broadcasting technologies were designed from the outset to address the issue of analogue
spectrum scarcity, and, in the case of satellite delivery, to operate on an international
scale.
Because such border-agnostic technological developments make the delivery of
externally originated content both easier and cheaper, the inevitable result is a
weakening in the effectiveness of regulation at the national level. A broadcaster wanting
to avoid the restrictions of the Ofcom Broadcasting Code can, at least in principle,
establish itself in another jurisdiction and deliver programming from there instead. In
practice, with the continued dominance of traditional broadcasting still in place, such an
approach can have only a limited, peripheral impact. However, as Internet radio
listening increases, the writing may well be on the wall for at least some elements of the
'gate-keeping' role of radio regulation.
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In broader terms, should such delivery methods reach the mainstream in future, then
the long-term frequency scarcity justification behind broadcast radio regulation would
be ameliorated. Given that the original justification for interventionist broadcast radio
regulation rested on perceptions of spectrum scarcity, it is at least possible to conceive of
a future broadcasting environment within which many of the established regulatory
levers are either deemed irrelevant or are found to be no longer functional.
Building on the above, the roll of regulation today as it relates specifically to the
operation of Community Radio services is examined further, later in this thesis.
4.
The Link Between Technology & Regulation
As can be seen from the above, the relationship between wider societal changes,
broadcast transmission technologies, the evolution of broadcast radio and the
development of its regulation is a complex and inter-woven issue. The way in which
radio is changing, and the context within which such change is occurring, may place
contradictory, sometimes even mutually exclusive, demands upon the approaches taken
towards regulation and its implementation. More specifically, there exist various
competing interests, both commercial and otherwise, each wishing to prioritise its own
agenda through access to the airwaves. At its heart, the challenge for broadcast radio
regulators is about balancing competing and sometimes conflicting demands, not just
between competing broadcasters, but also in ways that are, hopefully, of maximum
benefit to the listening public as both citizens and consumers.
Whilst distinct and separate in some respects, inevitably, the two issues of regulation and
technology are particularly closely linked. Technological developments often drive
changes in regulatory approaches and priorities, whilst, conversely; non-technical
developments in policy direction and regulatory frameworks can impact on the
effectiveness and viability of specific technologies. In reality, therefore, the relationships
between technology and regulation are often complex and multi-faceted. Potentially,
they can be either beneficial or damaging, sometimes to the point of being either
symbiotic or, conversely, destructive. The two-way street between regulation and
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technology has numerous intersections, twists, turns and diversions along the way. An
obvious specific example here would be the on-going development and roll-out of
Digital Audio Broadcasting (DAB) and its numerous variants. Such broadcasting
transmission technologies, which offer both advantages and disadvantages for
broadcasters and the public alike, will be explored in more detail, with specific reference
to the requirements of Community Radio broadcasters, later in this thesis.
Despite the best attempts of politicians and regulators, some elements of broadcast radio
regulation do, on occasion, seem to be playing 'catch-up' with the realities of the
broadcast radio technological environment. Here, one obvious example is that of
unlicensed 'pirate' broadcasting in its various forms (both off-shore and on-shore),
which dates back until at least the early 1930s (Clayton, 1933: 31 & Coe, 1996: 35),
and which advances in technology have gradually made increasingly simple and
inexpensive to operate (Martin, 1974).
Conversely, regulation has always had influence over the uptake of particular
technologies. For a broadcast technology to be successful, it needs not only to be
effective in achieving its technical objective, but also to be compatible with relevant
regulatory rules and requirements. In circumstances where either one of these objectives
is not met, the technology in question is unlikely to thrive.
To take an obvious example, FM broadcasting became a popular international standard,
not only because of its technical prowess and advantages over AM broadcasting, but also
because of its inherent flexibility. This not only allowed regulators to use it to target
specifically defined coverage areas, but also, above all, it allowed them to re-use the
frequencies involved more often than was the case for AM transmissions.
Equally, AM stereo broadcasting was never accepted in Europe because it was
incompatible with other ancillary uses of AM broadcast signals and because it required
changes to the engineering regulations surrounding the planning and installation of AM
transmission systems. More recently, attempts to introduce HD Radio to Europe have
also met with strong resistance from regulators because of similar incompatibilities.
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Here again, the application of broadcast radio regulation involves decisions designed to
best facilitate the effective selection and use of technologies in ways intended to help
ensure the most effective use of available frequencies. The primary regulatory objective
remains maximising the number of available broadcast radio services of adequate
technical quality to be easily and reliably received by potential listeners.
5.
The 'Place' for Community Radio Services.
The way in which early radio broadcasting evolved, was, as has previously been alluded
to, dictated, as least in part by the nature of the society into which it emerged.
Although the later arrival of Community Radio was similarly influenced by external
socio-economic factors, it was also emerging into a pre-existing and mature broadcasting
ecology within which ground-rules had already been set and 'territories' staked out by
existing players. The nature, scale and competencies of other pre-existing forms of radio
broadcasting, particularly in terms of programming and economic models, have
undoubtedly exercised a degree of influence over the development of Community
Radio, as it is understood today.
Community Radio has not only emerged into a crowded radio environment in terms of
existing broadcasters; it has also emerged into a medium that has pre-existing and fully
developed regulatory frameworks. However, this is also an environment that is in
something of a state of flux, challenged, not only by demands that it should
accommodate a new 'third-tier' of Community Radio broadcasting, but also, more
profoundly, by such issues as the introduction of new technologies, shifts in the balance
of power between the existing PSB and commercial sectors and, not least, on-going
changes in the attitudes of politicians and the needs and desires of the general public.
In fact, it can be argued that the emergence of Community Radio is a reflection of both
developments in radio broadcasting as a whole and of wider societal changes. The
'grass-roots' demand for locally owned and controlled radio services reflects not only the
importance that people place upon their locale and the 'local experience', but also the
fact that other broadcasters, particularly from the commercial sector, have, over recent
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years, tended to pull back from the delivery of such services. Community Radio services
that broadcast to a 'community of place' develop a deliberately narrow geographical
focus, in part because this is increasingly missing from other forms of radio
broadcasting. Where a 'community of interest' rather than a 'community of place' is the
driver for the operation of such a service, the importance of the shared 'community
experience' changes its form but nevertheless remains central.
As the emerging 'third-sector' of radio broadcasting, Community Radio is playing its
part in contributing to the increasing diversity of radio services. Community Radio
differs from public service and commercial radio both in terms of what it tries to achieve
and through the methods by which it seeks to achieve such objectives. These differences
are at the heart of Community Radio, visible through the range of inputs that it
employs, the structures it creates, the processes it engages in and the outputs that it
generates. Crucially, such services are concerned with more than simply the delivery of
radio programmes. In fact, it could be argued that a successful Community Radio
service is almost always engaged in the delivery of a wide range of community benefits
beyond the provision of broadcast content alone. Nevertheless, the traditional radio
broadcasting element remains central. This is not only because of its ability to provide
an efficient platform for the dissemination of relevant local content, but also because of
the integral role it can play in the delivery of wider social engagement. Radio is a key
tool, not just for the effective provision of information, education and entertainment,
but also for the promotion of engagement and interaction as well as wider community
benefits such as community cohesion and integration.
Part of what makes Community Radio different from other forms of radio broadcasting
is therefore the degree of interactivity and interdependence that such services have with
their listeners and the wider communities within which they operate. Such relationships
are at the heart of the Community Radio ethos. While mainstream debates about the
future of broadcast media tend to focus on issues such as ownership, scale, plurality and
the cost and difficulties of providing local content, Community Radio provides
something of a practical counter-balance. It actively engages at the micro-level and takes
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on the challenge of delivering the types of content that other, larger, broadcasters are
either not interested in or are incapable of producing.
Technologically, the community sector has been generally quick to embrace the benefits
provided by Internet-based web technologies, primarily as adjuncts to their main
analogue broadcasting delivery platforms. By comparison however, the various
emerging digital broadcast delivery platforms, such as DAB, have so far proven to be of
little relevance to Community Radio broadcasters. As will be examined in more detail
later in this thesis, there are two key factors that define the sector's interest in particular
new technologies: specifically, appropriateness and cost. Recent changes to the cost and
regulation elements of DAB are of special relevance here and are explored in detail later
in this thesis.
The structure and objectives of Community Radio services provide them with both
benefits and disadvantages. On the plus side, Community Radio services are flexible
and adaptable, able to choose to provide services complementary to those of their
competitors. Free from the profit-making requirements of the commercial sector and of
the universality requirements that typically apply to public service broadcasters,
Community Radio operators have the ability to target much narrower and more clearly
defined target audiences than is the case for other types of radio broadcaster. Against
such advantages, Community Radio stations are typically far less well resourced than are
their successful commercial rivals and established PSB competitors.
It is precisely because the operations and objectives of community radio services are
more diverse than those of other radio broadcasters that, internationally, the sector
typically seems to require its own unique legislation and regulation in order to survive
and flourish. Earlier experiments in UK-based community broadcasting, such as the
'incremental radio licences' granted by the Radio Authority in the late 1980s and early
1990s demonstrated how, without such protections, such services can be extremely
vulnerable to the risk of commercial pressures not only diluting, but eventually
overwhelming and usurping their distinctive altruistic nature. Part of the problem here
is that, as a consequence of its relative youth, Community Radio has emerged into a
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broadcast radio world already inhabited by an established (perhaps even entrenched)
broadcasting duopoly. In order to justify its own existence, as well as the existence of
specific underpinning legislation and regulation, it is essential that Community Radio is
able to distinguish itself from these pre-existing PSB and commercial operators.
The role, or 'place', for Community Radio is shaped by its distinctive (altruistic / thirdsector) character, whilst the 'space' for the delivery of such Community Radio services is
determined through the application of enabling and defining regulation. The provision
of specific regulations that encompass the operation of Community Radio services, helps
provide such stations with a degree of protection against encroachment by larger, more
well established broadcasters, thereby attempting to create a sustainable 'space' for
community-based broadcasters. However, specific legislation and regulation are not
without their problems, for example in terms of their scope and scale, or in terms of
their ability, or inability, to react quickly to emergent external factors such as new
technological changes and trends. Such issues will be examined in greater detail
throughout the remainder of this thesis.
Conclusions
The purpose of this opening chapter is to provide a broad context within which the
position of Community Radio can subsequently be considered in greater detail. In this
chapter, I have therefore provided an historical overview of the development of radio
broadcasting in the United Kingdom, from its early monopolistic beginning to the
diverse medium that has since emerged. In particular, this chapter has explored what
might, from a Community Radio perspective, be described as the 'pre-history' of
broadcast radio in the United Kingdom, that is to say the period prior to the emergence
of the concept of Community Radio as a separate 'tier' of broadcast radio.
I have also explored the way in which technological advances progressively improved
and diversified the delivery of broadcast radio services, enabling an increasingly number
of broadcast radio stations to operate within available spectrum capacity. Issues relating
to broadcast radio regulation, its objectives and the way in which technological
developments influence its implementation have been examined to demonstrate the
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increasing complexity of this task. The close entanglement between broadcasting
technologies and the regulation of the medium is subsequently highlighted.
Having considered these key contextual elements, I have then drawn this chapter to its
close by moving on to identify some of the impacts such context has had on the
emergence of Community Radio in the United Kingdom. I argue that this context is
critical to the fundamental research question under consideration in this thesis, that is to
say, how the 'place' for Community Radio might be properly defined. Finally, as a
precursor to the next chapter, which considers the situation in the United Kingdom in
more detail, I have drawn this chapter to a close by summarising the environment into
which full-time Community Radio services were finally introduced into the United
Kingdom during the earliest years of the Twenty-First Century.
As set out above, I suggest that the development of Community Radio in the United
Kingdom has been heavily influenced not only by the nature of modern-day society, but
also by the history of the wider broadcast radio medium as a whole. Whereas this
chapter has provided a broad historical context within which to view the arrival of
Community Radio in the United Kingdom, the focus of the following chapter is, by
necessity, narrower. It examines the evolution of the British Community Radio sector
in more detail and traces its emergence to policy debates that date back at least as far as
the immediate post-war period.
(14,039)
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CHAPTER 2:
The Arrival of Community Radio
As has been shown in the preceding chapter, various external factors have played a part
in shaping the current state of Community Radio in the United Kingdom. This chapter
focuses in particular on two key underlying factors, both of which, it is argued, have
been especially strong influences on the emergence and subsequent evolution of British
Community Radio policy and practice.
Firstly, this chapter argues that various local influences, such as the offshore
broadcasting boom of the 1960s and the role of the BBC over the long term, have
impacted both the direction and speed of wider broadcasting development as a whole
and of Community Radio in particular.
Secondly, when tracing the development of Community Radio in the United Kingdom,
it is important to acknowledge from the outset that such development took place later
than in various other parts of the word. Given such temporal delay, much of the UK
Community Radio sector's underlying conceptual framework and policy objectives
were, from the outset, inevitably heavily influenced by perceptions and experiences of
pre-existing structures and practices in other jurisdictions.
Accordingly, this chapter makes reference to various international comparators in order
to place the British experience in a wider context. It explores how, eventually, the
circumstances were such that the sector was provided with the opportunity to draw
upon pre-existing international policies and practice when the time finally came to
develop the legislative and regulatory frameworks for the so-called 'third-sector' of radio
broadcasting in the United Kingdom.
The Emergence of Community Radio in the United Kingdom
In order to appreciate how the distinctive nature and purpose of Community Radio
broadcasting emerged over time, it is first necessary to have an understanding of the
historical context within which such evolution took place. As set out earlier in the
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introduction to this thesis, a fundamental issue has been the relative positioning of
Community Radio in relation to larger, longer established, and typically better funded
PSB and commercial broadcasters.
A primary justification for the existence of Community Radio is that it provides clearly
defined 'additionality', expanding the mix of broadcast radio services available at a given
location. This is particularly the case in Western European jurisdictions, but also, to a
lesser extent, elsewhere, such as in the United States. Thus, the ways in which
Community Radio services add to the mix of broadcast radio provision has always been
a critical concern, inevitably influencing the conceptualisation of the sector as well as its
relationships with other forms of radio broadcasting, as they exist today.
The term 'aditionality' is important here, because although some aspects of community
radio output will be unique to the particular service concerned, other aspects will not
necessarily be so. For example, a geographically-based 'community-of-place' broadcaster
might provide a range of specialist music outputs and local speech-based content that is
unique, but such output might be broadcast alongside other music output and local
speech-based content, which broadly duplicates the types of material broadcast by other
local PSB and commercial stations in the same area.
In a Western European context, Public Service Broadcasters (PSBs) may generally be
said to seek to protect their historical position of privilege whilst commercial radio
operators seek to expand their market share. Over recent years, Community Radio has
introduced another side to this historical conflict between the public and the private
spheres. Much of the following thesis is concerned with the relationships and
boundaries between the three sectors of radio broadcasting, (in addition to considering
the role of unlicensed operators). How rigid might the divisions between the various
players be, and what potential might there be for conflict or for mutually beneficial
collaboration? What role may be played by regulation and technological development
in relation to the relative future strengths and weaknesses of each of the three licensed
sectors?
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Similarities of approach can also be found in other areas of activity, such as for example
engagement with listeners. Although Community Radio services will typically interact
much more widely with individual members of their target audience than might nearby
PSB and commercial stations, all three types of station will tend to employ some
techniques that are similar, such as for example, the use of web-site forms, text messages
and e-mails. Community Radio stations may go much further in terms of their
outreach and listener engagement, but in a variety of operational areas, there will often
be considerable similarities between the activities of such broadcasters and those of other
radio stations. Such similarities are likely to be most prevalent between Community
Radio services and local traditional public service broadcasters (in the UK, BBC Local
Radio), and, perhaps to a somewhat lesser extent, between Community Radio services
and those commercial radio stations that have a relatively small-scale broadcast coverage
area.
However, of itself, the actual provision of additionality is not the key issue here. More
importantly, such additionality must be accepted as such, and be recognised as having
both relevance and value by politicians, regulators and, not least, other non-community
broadcasters. The provision of additionality is closely linked to the fundamental
principles of Community Radio, particularly in terms of its inputs, structures, processes
and outputs. Over the following pages, these factors are examined and discussed in
more detail and contextualised in relation to the aims and objectives of community
media more widely. Particular attention is paid to how the fundamental principles of
Community Radio compare with those of public service and commercial broadcasters.
Given the relatively late emergence of full-time Community Radio in the United
Kingdom, this examination begins with an historical overview, which includes
international as well as domestic elements. It examines the degree to which the
approaches taken in respect of the introduction of British Community Radio were
influenced by preceding, wider, international developments.
As the following paragraphs will show, whilst the British concept of Community Radio
is by no means a 'carbon-copy' of the sector in other jurisdictions, it has however
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benefited from being 'late to the party'. Both those involved in campaigning for the
introduction of Community Radio in the United Kingdom, as well as those involved in
drawing-up its enabling legal and regulatory frameworks were able to draw upon a
wealth of existing international experience and expertise. As a result, the British
approach to Community Radio is based, at least in part, on the 'cherry-picking' of those
pre-existing international elements, which were thought to be both relevant to the
emerging UK concept of Community Radio and which had the advantage of already
having being shown to work within the context of various other jurisdictions.
There are, however, also disadvantages to being a late arrival. The dramatic expansion
of commercial radio throughout the late 1980s and 1990s has led to genuine problems
of frequency scarcity, limiting the opportunities for new Community Radio service,
particularly in some of the larger urban conurbations. The UK's Community Radio
sector has grown fast over the past few years, but opportunities for its expansion in the
traditional analogue broadcasting domain were limited from the outset and are being
further reduced as each new station takes to the air. As will be discussed later in this
thesis, technological developments and regulatory mechanisms may both aid the future
expansion of the sector but, in both cases, potential benefits of substantial scale for the
sector remain, at best, some way off.
The journey towards the arrival of Community Radio in the United Kingdom has been
a long and bumpy ride with numerous false starts, diversions and stops along the way.
Pressure for the introduction of UK Community Radio can long be said to have come
from two sometimes overlapping but nevertheless distinct backgrounds. On the one
hand, a long-running political campaign, largely based around notions of democratic
access to the airwaves, was driven forward by various campaigning bodies, most notably
the Community Radio Association (CRA), later renamed the Community Media
Association (CMA). In parallel, there were also direct-action challenges from a diverse
range of unlicensed ‘pirate’ broadcasters, which, between them, demonstrated some
elements of community broadcasting, by simply ignoring the fact that they had not been
granted broadcasting licences.
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Although unlicensed broadcasting can be said to date back to the earliest days of wireless
radio (there were no licences at the time of its creation), it first came to prominence in
Europe through the activities of the off-shore ‘pirate’ broadcasters of the late 1950s and
1960s (Harris, 1976). Following the passing of the Marine (etc.) Broadcasting Offences
Act (HMG UK, 1967), most of these ship or fort-based broadcasters quickly ceased
broadcasting. However, their influence remained, not only in terms of the changes
made to the radio broadcasting activities of the BBC and the later introduction of
commercial Independent Local Radio (ILR), but also because their broadcasting
activities were mimicked by a growing number of land-based ‘pirate’ broadcasters, which
emerged from the late 1960s onwards and particularly during the early 1980s (Hind &
Mosco, 1985).
Official Policy Debates
Prior to the arrival of the offshore pirate stations, there was little official debate over
non-BBC and local radio services. However, there was some consideration of alternative
approaches to a public service monopoly in both the Beveridge Report of the Broadcasting
Committee (Beveridge et. al., 1951) and the Pilkington Report of the Committee on
Broadcasting (Pilkington et. al., 1962).
Beveridge was not in favour of commercial radio, taking the view that UK broadcasting
should not "become financially dependent on sponsoring" (Beveridge et. al., 1951:
49 (para. 195)), which would, in the committee's view, result in broadcasting ending up
"in the hands of people whose interest is not broadcasting but the selling of
some other goods or services or the propagation of particular ideas" (ibid., 50).
However, considering the opportunities that VHF (FM, Band II) sound broadcasting
was soon expected to bring to the UK, Beveridge noted:
How large a scope there would be in Britain for local stations
broadcasting programmes controlled by Universities or Local
Authorities or public service organisations is not known, but the
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experiment of setting up some local stations should be tried without
delay (ibid., 79 (para. 295)).
By the time Sir Harry Pilkington's Report of the Committee on Broadcasting was
published, just over ten years later in 1962, the debate on alternative approaches to the
provision of local radio services had clearly not made much progress. Indeed, it could be
said to have stagnated or perhaps even, as Briggs suggests in volume five of his History of
Broadcasting in the United Kingdom been effectively closed down by the BBC, which in
its twelfth memorandum to the committee:
put forward a plan to build eighty to ninety stations in five years …
There would be no standard blueprint … the programming of each
station would grow out of the life around it [and] would not be
expected to go for large audiences for their own sake (Briggs, 1995:
285).
Briggs observes that "the BBC hoped to persuade the Committee that it could
provide a better service than any rival" (ibid.). Linfoot puts it in stronger terms,
concluding that "the BBC waged an assiduous campaign to persuade the
Pilkington Committee of its rightful claim to launch and run local
broadcasting" (Linfoot, 2011: 87). In the event, the corporation achieved this
objective. Although the report notes the development of VHF (FM) radio broadcasting
and the arrival of the portable transistor radio (Pilkington et al, 1962: 10-11 (para. 28)),
it is largely complacent about the provision of sound broadcasting services, noting that
"[i]n the main" submissions to the committee "expressed satisfaction with the
service" (ibid., 13 (para. 37)).
Dealing, albeit briefly, with the possible future development of local radio services, the
report expends some twenty pages discussing possible options. Having noted that
"with the advent of VHF services, the BBC has developed the broadcasting
of local news and information to smaller areas" (ibid., 22 (para. 60)), it frames
discussions concerning the possible development of new stand-alone local radio services
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in the context of a choice between BBC or private commercial provision. A mere two
pages of the report (ibid. 222-223 (paras. 804-809)) give scant consideration to
alternative approaches such as local authority or university involvement. The
committee's underlying concern is a paternalistic one, centred on the issues of control
and quality:
Local trusts would have to resist great pressures if they were to
maintain their independence and at the same time put out a service
they thought worthwhile (ibid., 223 (para. 805)).
A mixed funding approach, as put forward by the 'Independent Broadcasting Group' is
considered as a proposal for commercial radio, the committee taking the view that any
such approach would inevitably come to be dependent upon commercial funding: "far
from being merely permitted, the sale of advertising time would be
necessary" (ibid., (para 809)).
Frank Gillard and BBC Local Radio
In addition to the various memoranda provided to it by the BBC, Pilkington's approach
to local radio was undoubtedly also influenced by the then on-going work of Frank
Gillard at the BBC to develop such services for the Corporation. Gillard had been
interested in local radio since at least the early 1950s and is described by Briggs as "the
main advocate of local radio inside the BBC, a very eloquent and
determined advocate and its main organiser" (Briggs, 1995: 624).
When Gillard visited America on a two-month study tour in early 1954, he came back
with mixed views of local radio there, concerned about the amount of popular music
played during peak hours, but nevertheless "most impressed with the focus on local
news stories, and how that bonded with the audience" (Linfoot, 2011: 73).
After at least one other visit to the USA, and despite a lack of senior managerial support
within the BBC, Gillard decided to "preach the gospel of local radio" (ibid., 71).
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By the late 1950s, the BBC was beginning to realise the potential of local radio
broadcasting and, eventually, Gillard "won over the Board of Management to his
belief in local radio" (Briggs, 1995: 628). Having done so, he then organised a series
of sixteen experimental recorded 'broadcast' services, at a variety of locations around the
country (Linfoot, 2011: 90-92).
In campaigning for the introduction of local radio, Gillard stressed the degree to which
the operational costs of small-scale services would be minimised. Writing in the
Yorkshire Post in 1963, he stressed how simple the technology required would be:
The VHF [FM] transmitter, taking up no more room than a
wardrobe and housed in a small hut, is located at some geographically
commanding spot in the city and joined to the studio by landline …
For the rest, the station needs a few tape recorders and a radioequipped car … (Gillard, 1963, quoted in Briggs, 1995: 632).
The article ended with a challenge to those suggesting local broadcasting would be too
expensive; Gillard "asked boldly whether 'the communities of Britain' could
afford to be without this valuable new instrument, available at such modest
cost" (ibid., 632-633).
In practice, Gillard can be said to have been either optimistic, or even somewhat naïve,
when predicting such low-cost operations. Estimates in 1960 that local radio stations
"would cost about £17,500:00 to build and about £28,000:00 a year to
run" (ibid., 628) had risen considerably by 1966, by which time the BBC then
estimated that:
The capital sum required to establish each station would average, it
is estimated, between £30,000:00 and £35,000:00 … and the
operating costs for a programme output of five or six hours a day
would average about £1,000:00 per week (ibid. 635-636).
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Nevertheless, with the benefit of hindsight, it is correct to say that he identified a
genuine trend, which has continued over the intervening decades. For example, the
£104,000 put towards the cost of building BBC Radio Leicester by Leicester City
Council in 1967 (Stirling, 2004: 334) would, even before adjusting for inflation, pay
comfortably for the complete capital technical infrastructure of many a current UK
Community Radio service.
The early pre-recorded local experiments took place in parallel with the work of the
Pilkington Committee. Consequently, the BBC was able to make use of some of the
recordings in order to demonstrate to the committee its proposed approach towards
local radio. Pilkington's final report notes that its members had listened to "recorded
extracts from the BBC's experimental "broadcasts" in six towns in different
parts of the country" (Pilkington et. al., 1962: 225 (para. 816)), as well as to
"extracts from an experimental "broadcast" prepared by the South Coast
Broadcasting Company Limited" (ibid.), a group proposing the introduction of
commercial radio. Questioning how realistic such experiments might be, the committee
nevertheless concluded that "in the end, the viability of any service can only be
proved by practice and not by prophecy" (ibid. (para. 817)).
Ultimately, and perhaps, largely because of the BBC's concerted efforts over the issue,
the Pilkington Committee's approach to the development of local radio was
considerably more conservative than that of the previous Beveridge Committee.
Dismissing the alternatives, Pilkington concluded that:
… one service, and one only, of local sound broadcasting be planned;
that it be provided by the BBC and financed from licence revenue...
(ibid., 232 (para. 846)).
Despite such apparently unequivocal support for the development of BBC local radio,
its relative importance was immediately downgraded in the next paragraph of the report,
which stated that:
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In recommending this, we stress that the development of local sound
broadcasting must not delay the completion of the transmission
coverage, on VHF, of the three national sound services (ibid. (para.
847)).
Following the Pilkington Report, throughout the early to mid 1960s, the BBC kept up
the pressure on government to introduce local radio controlled by the Corporation.
Looking back at the early local radio proposals of the BBC, as summarised in the
Corporation's 1966 pamphlet entitled Local Radio In The Public Interest: The BBC's
Plan, there is much contained within them that would be recognised as familiar by
today's Community Radio broadcasters. Indeed, the document includes a very early use
of the term "community radio" in relation to the type of service that was then being
proposed (BBC, 1966: 12).
BBC local stations, therefore, would devote themselves to local issues
and interests, to provide a service which would … meet a genuine
need in each modern community. Everything of real concern in
community life would be reflected and covered in the programmes news and current events in great variety, local information of all
kinds, sport, entertainment, municipal affairs, local controversies and
talking points, personalities in the public eye, distinguished visitors,
educational, religious, industrial, and commercial matters, the
special interests of women, of children, of sick people and of the
elderly, the activities of voluntary bodies and much more. (ibid., 4)
However, the parallels with current approaches to Community Radio delivery are not
merely limited to similarities in terms of content. The Corporation also stressed the
autonomous and responsive nature of each local service:
… if local broadcasting is to be successful, the service provided by
each station must be designed according to the special needs of its
community, and that those needs could not possibly be assessed and
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met anywhere else but on the spot. Local broadcasting must accept
certain basic common standards of integrity, accuracy, fairness,
responsibility, taste, and purpose. But in its programmes it must
show the greatest possible variety of expression and enterprise. In
every centre it must be free to experiment and to expand its services,
to the utmost limits of the talents of those who are engaged on its
operation and of the resources they have at their disposal (ibid., 10).
Another remarkable similarity between the BBC's early plans and current Community
Radio practice can be found in relation to the issue of scale. Modern Community Radio
stations, such as Future Radio in Norwich, Radio Reverb in Brighton, RadioLaB in
Luton and Sheffield Live!, each provide the sort of coverage that, in the mid 1960s, the
BBC expected would become the norm for its local radio stations:
The range of the local transmitter would depend on the nature of the
community. For a single, compact city it might be no more than five
or six miles. The majority of the BBC’s stations would be of this
order (ibid., 7).
An indication of the paucity and narrowness of debate around direct community
involvement in broadcasting during the mid 1960s is given by the existence of John
Scupham's 1967 book Broadcasting and the Community. In many ways a wide-ranging
volume, it nevertheless fails, despite its title, to discuss Community Radio (or television)
to any meaningful extent. The concept of independent not-for-profit services is not
discussed. Rather the author remains largely in favour of a paternalistic approach to the
state provision of radio services, conceding that: "It is proper that the BBC in
particular should be informed, persuaded, lobbied, and generally pursued
and pestered by the community that it exists to serve" (Scupham, 1967: 60).
Writing before the introduction of local radio in Britain, Scupham is not only
unconvinced of the value of commercial radio, but also doubtful about the BBC's ability
to deliver meaningfully local services. Indeed, the history of BBC local radio over the
intervening years shows just how prescient his views were:
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To reject the claims of the commercial lobby is not necessarily to
accept the bid of the BBC. The whole point of local broadcasting is
that it shall be local. The BBC is a huge national concern with
strong centralising tendencies (ibid., 64).
However, despite recognising the weaknesses of both the commercial lobby and the
BBC in relation to the provision of local radio services, Scupham fails to explore an
autonomous third option. The closest he comes to doing this is by suggesting that:
"The best hope lies in the establishment of partnerships … between the BBC
and those local interests that can participate most fully..." (ibid., 65).
Such partnerships were clearly evident at the start of BBC local radio. The first station,
Radio Leicester, took to the air in November 1967. Indeed, Leicester became the
location because "the local City Council was prepared to contribute £104,000
towards its costs" (Sterling, 2004: 334).
The timing of the launch of BBC local radio was significant, as it came just after the
closure of most of the offshore 'pirate' stations (discussed in more detail below), when
pressure for the introduction of legal commercial radio stations was becoming
significant. As Sterling points out:
It is important to emphasise that the BBC's commitment to local
radio was not simply a romantic celebration of the diversity of local
cultures. Gillard's ambitious plan for a network of more than 90
BBC local stations was a political tactic to head off the clamour for
legalising commercial radio. It enabled the BBC to justify its
monopolistic control of all licence fee funds (ibid.).
Nevertheless, there was undoubtedly a clear commitment to community involvement
within the pioneering versions of BBC local radio:
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The first charter for local radio, written by Frank Gillard, declared:
"Station managers will be free to provide programmes, which in their
judgement best meet the needs of their communities" (ibid.).
According to the BBC, "the stations soon exceeded expectations, especially with
a range of shows aimed at specialist and niche audiences and communities"
(BBC, 2015), although the "fragmented schedule, with a wide variety of
different programmes, made it hard for listeners to find their favourite
shows" (ibid).
With the benefit of hindsight, it is interesting to note the way in which the arrival of
early BBC local radio restored localised content delivery, re-establishing a link between
the Corporation and local communities, which had quickly disappeared after the earliest
days of its radio broadcasting during the mid 1920s. Back then, it was not technically
possible to deliver national networks and, thus, the BBC had initially provided a range
of local relay stations and regional services instead. As broadcasting technology rapidly
evolved, it soon became possible to deliver centralised services to the vast majority of the
United Kingdom. As a result, the early, more localised, BBC services gradually
disappeared.
When the third of the BBC's first local radio stations, Radio Stoke, took to the air, in
March 1968:
… one of the first voices heard was that of John Snagge who had broadcast
for the 1920s relay station 6ST, Radio Stoke's ancestor. He began: 'This is
BBC Radio Stoke-On-Trent. We must apologise to listeners for the break in
transmission, which occurred at twelve o'clock midnight on October 30th,
1928. This was due to circumstances beyond our control. Normal
transmission has now been resumed' (Snagge, quoted in Higgins, 2015: 201).
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Unlicensed Broadcasting
In parallel with the slow-moving deliberations of politicians, broadcasting practitioners
and campaigners during the late 1950s and 1960s, there were those not prepared to wait
for potential new licensing opportunities. As was the case during the earliest period of
broadcast radio development, once again, the pace of change was being driven, at least
in part, by practical developments that were taking place outside the mainstream of
licensed broadcasting.
Offshore 'Pirate' Radio
Driven primarily by commercial interests, offshore, so-called 'pirate' broadcasters began
operating from ships and other structures outside territorial waters and, thus, beyond
the jurisdictions of national legislation or direct enforcement actions intended to
terminate their transmissions (Robertson, 1982).
Although the origins of unlicensed offshore broadcasting can be traced back as far as the
early 1930s off the coast of California (Clayton, 1933: 31), in Europe, the practice really
developed in Scandinavia during the late 1950s, starting with the launch of Radio
Mercur, broadcasting to Denmark in July 1958 (March Hunnings, 1965: 410-411 and
Baron, 1975: 35). The first such broadcaster to target the United Kingdom specifically
was 'Radio Caroline', which commenced regular broadcasting from an anchorage off the
coast of Essex, near Harwich, on Easter Sunday, the 29th of March, 1964 (Harris, 1977:
20).
In practice, beyond challenging the monopolistic broadcasting structures of the day,
offshore commercial pirate radio stations also demonstrated that, by the 1960s, the
technology of broadcasting had become both relatively inexpensive and increasingly
accessible. Government moves to suppress the offshore broadcasters, such as the Marine
etc. (Broadcasting) Offences Act (HMG UK, 1967) and the European Agreement for the
Prevention of Broadcasts Transmitted from Stations Outside National Territories (Council
of Europe, 1965), but which also came into force in 1967, arrived too late to prevent
land-based, small-scale imitation of the original offshore pirates. By the early 1970s, the
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UK's radio broadcasting genie was well and truly out of the bottle and monopolistic
control was beginning to crack.
Just after the introduction of the Marine (Broadcasting) Offences Act 1967, the Home
office allowed a small number of university radio stations to begin broadcasting on
medium-wave frequencies, ostensibly just to their particular campuses. University
Radio York (URY) began broadcasting in September 1968 and claims to be the first
non-BBC radio service to be licensed to broadcast in the UK since the award of the first
BBC Royal Charter in 1927 (Stewart, 1998).
Land-based 'Pirate' Radio
Such developments were tightly constrained and did not provide broadcasting
opportunities for members of the wider general public. Thus, various groups resorted to
unlicensed broadcasting as the only way to gain access to the airwaves. At first, these socalled 'free radio' stations were, like their offshore predecessors, campaigners for
commercial radio licences. For example, in August 1968, as a direct result of the closure
of the offshore radio stations, 'Radio Free London' broadcast for three days in
connection with a Free Radio Association rally held in Trafalgar Square, London (King,
2007: 7-9). Arguably more of a publicity stunt than a prototype for non-BBC radio
broadcasting in the UK, this short-lived station nevertheless had considerable impact in
the longer term, as it contributed directly to the creation of the most serious and longterm, land-based commercial 'pirate', 'Radio Jackie' (ibid., 16). This station began
weekend broadcasting to South West London as early as 1970 and so pre-dates all
licensed UK commercial radio stations. More than 40 years later, it still exists, now
operating full-time, as an Ofcom licensed commercial service, in the same area.
By the early 1970s, however, interest in pirate broadcasting had begun to widen.
Groups with interests other than the profit motive began to realise that radio
broadcasting was not only a potentially useful platform but also one that was becoming
increasingly technologically and economically accessible. Academic interest in the
development and diversification of broadcasting was also growing. Arising from a
symposium at Manchester University's Holly Royde College, the Structures of
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Broadcasting volume paid considerable attention to the development of local radio,
looking beyond the then experimental BBC local radio services. Whilst two chapters,
'Radio for local communities – a chairman's view' and 'Radio for local communities – a
manager's view' are of particular relevance here, the issue of the future development of
local radio is also considered at various points elsewhere in the volume (Wedell, 1970).
Third Sector Campaigning
Outside the established industry and academia, the topic of local radio broadcasting was
also gradually gaining increased prominence. In 1972, David Gardiner, writing in a
pamphlet published with the first issue of the “radical science and people's technology”
magazine, Undercurrents, observed that:
There is still the mystique and the downright ignorance of radio's
potentials, even after the off-shore 'pirates' in the North Sea and the
political 'pirates' of Northern Ireland, Greece, Africa and other
troubled places have given the lie to the theory that living room table
radio can never really operate. A small group or a community might
conceivably operate its own newspaper, but its own radio station....!
(Gardiner, 1972: 3)
Elsewhere in the limited literature base of this period, Nigel G. Turner was another
exception to the general rule. His booklet Community Radio in Britain: A Practical
Introduction (Turner, 1973), whilst still somewhat preoccupied with the technological
aspects of transmission, begins with an opening chapter that discusses the nature of
Community Radio stations, noting that they "can help re-establish a sense of
community; they can be used as tools for the community … It is the
intimacy of radio that makes it such a potentially creative tool" (ibid., 10).
Critical of the wider 'free radio' movement, Turner took the view that "Free Radio is
not necessarily commercial, and commercial radio certainly isn't free" (ibid.,
27).
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Undercurrents magazine maintained a long-standing interest in radio broadcasting. In
1974, it published a pair of articles in back-to-back editions. 'The People's Radio
Primer' (Undercurrents, Issue 7: 25-32), was followed by 'Opening Up The Airwaves'
(Undercurrents, Issue 8: 21-25). Although both articles focus primarily on accessible
technology for analogue (AM & FM) radio broadcasting, they also consider legal issues
and the reasons why groups and individuals might want to consider operating their own
radio services. The second article notes that the pirate radio stations of that time had
"almost without exception … no conception of why they were doing it …
apart from the vague ideal of 'free radio' … i.e. commercial radio" (Martin,
1974: 24). The article goes on to suggest that Community Radio stations should
provide listeners with "the sort of programming they want to hear" and be "non
profit making … and controlled by the listeners" (ibid.).
Within these brief, rather general, proposals, are contained some of the earliest ideas for
a conceptual framework for Community Radio to emerge from the United Kingdom.
Although the author may have come up with these suggestions himself, the ideas
themselves were by no means original even then. Broadcasters, such as the Pacifica
Foundation in the United States, had been operating not-for-profit services since the
late 1940s (Lasar, 2000: 144-145) and, at that time at least, BBC Local Radio, which
had by then moved from its experimental stage to one of gradually expanding
permanence, was a great deal more diverse, locally independent and open to community
inputs than it has become today.
By 1978, this more radical approach to local broadcasting was finding practical outlets
through the operation of land-based pirate stations such as Radio AMY (Alternative
Media for You) in North London and East London Radio. Radio AMY was unusual in
that, despite its 'free radio' background and its pirate broadcasting activity, it recognised
the need for political campaigning. In 1979, it facilitated the publication of One Year
On: An Examination of Britain's Only Community-Access Radio (Rollings, 1979). In this
document, the distinctive nature of Community Radio is more clearly defined than
hitherto. For example, Rollings opines:
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It is time for a brand new structure which is answerable to its
listeners, and encourages them to express themselves without stringent
restrictions, or having to speak through a third party (Rollings, 1979:
3).
Gradually, therefore, the implicit practices of Community Radio were beginning to
become explicitly defined, not only in the light of increasing experience, but also as a
result of being discussed and refined by academics and other interested parties.
In parallel, a political campaign had begun to coalesce around this increasingly clear
definition of Community Radio and, as a result, academic interest in the concept was
further increased.
Much of the academic writing around Community Radio from this period came from
practitioners and those closely linked to the campaign for its introduction, either
through political campaigning, practice or both. As Peter Lewis explained, looking back
at the emergence of Community Radio theory in 2010:
First came practice, a form of direct action that challenged the
assumptions, values, and practices of the mainstream, and in which,
as in all practice, theory was implicit. But the task for observers and
commentators was then to describe and demarcate the field. This had
to be done within mainstream media as well as in academic work.
Within the latter, the task was to make connections within existing
theory and to develop new theoretical perspectives. And all the time,
at other levels, public and media understanding had to be won for
policies that would create an infrastructure both for the object of
study (e.g. regulatory policies) and for study and research itself
(academic policies). Achieving this needs the triad of activists,
practitioners, and academics (Lewis, 2010: 833).
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The Annan Report
The issue of Community Radio had risen up the political agenda with the publication of
the Annan Committee report on the future of broadcasting in February 1977. The
committee had been in operation since April 1974 and, although primarily remembered
for its recommendations for a fourth national terrestrial television channel (delivered in
1980 as Channel 4), it also helped draw out arguments for the possible development of a
so-called third-tier of radio broadcasting. The report's proposal that "there should be
a greater diversity of ownership than is possible under the present under the
present Independent Local radio system" and that "some might be operated by
non-profit-making trusts" (Annan, 1977: 14.3) were ignored by the government,
but sparked a wider public debate and, arguably, helped define the approach taken when
Community Radio legislation was eventually enacted some 25 years later.
Home Office Local Radio Working Party
More immediately, although the Annan Report failed to deliver full-time Community
Radio services, it did nevertheless instigate a period of gradual development towards that
ultimate goal. The government's subsequent White Paper, published in July 1978,
recommended the establishment of the 'Home Office Local Radio Working Party'.
This was subsequently established, going on to publish three reports, in October 1978
(Home Office, 1978), July 1979 (Home Office, 1979) and December 1980 (Home
Office, 1980).
Given that the committee consisted only of representatives of the Home Office, the
BBC and the IBA, it was perhaps not surprising that its first report was preoccupied
with "a choice between BBC or IBA local radio" (Home Office, 1978: para.18).
In the second report, the working party, whilst still failing to tackle the issue of
Community Radio head-on, does express concern that rural and ethnic minority
audiences were not being sufficiently well served by the existing duopoly (Home Office,
1979: paras. 50 & 51).
In parallel with the operation of the Home Office Local Radio Working Party,
campaigners for Community Radio had begun to increase their demands for the
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introduction of third-tier radio services. Particularly effective amongst campaigners at
this stage were the Community Communications Group (ComCom) and the Local
Radio Workshop (LRW) (Lewis, 2008: 8), both of which drew heavily upon preexisting North American experience when suggesting possible developments this side of
the Atlantic (Lewis, 1977: 5-14 and Lewis, 1999).
By the time the third report was published, sufficient political pressure had been
brought to bear upon the Home Office Local Radio Working Party to ensure that
Community Radio was discussed in some detail. Two organisations, ComCom and the
Association of Community Broadcasting Stations (ACBS) gave evidence to the working
party (Home Office, 1980: 1) and part two of the third report was entirely devoted to
an analysis of what might constitute Community Radio in the UK. Of particular
historical interest is the fact that, for the first time in an official document, the report
gave consideration of a possible experiment, to evaluate the potential of Community
Radio services (ibid., 33-47). The report concluded that such an experiment "could be
authorised by the Home Secretary under existing legislation" (ibid., 47: para.
7.37).
The Community Radio Association
With the prospect of experimental broadcasts apparently imminent, and a growing
number of 'pirate' broadcasters operating increasingly openly in major conurbations
across the UK (Hinds & Moscow, 1985: 17), interest in Community Radio blossomed
during the early 1980s. Perhaps the most important development came in 1983 with
the formation of the CRA (Community Radio Association), an organisation that rapidly
came to represent the vast majority of would-be not-for-profit broadcasters in the UK,
as well as a number of 'pirate' broadcasters interested in doing more than simply playing
their favourite music, but nevertheless unwilling to wait for the law to provide them
with an opportunity to broadcast legally.
Specialist Publications
From a research perspective, the early 1980s marks the point at which the development
of community radio in the United Kingdom began to become considerably better
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documented by what is sometimes, perhaps disparagingly, called 'grey' literature. A
particularly well-produced example, Relay Magazine, first published in the Autumn of
1981 and described as "the other magazine about the airwaves", explained its
mission as "an attempt to provide a voice for all those struggling to develop
new forms of radio – imaginative, accountable, democratic" (Relay Magazine,
1981, Issue 1: 1). Early editions of this publication both track the emergence of an
organised campaign for the introduction of licensed Community Radio and explore
wider radio broadcasting issues. For example, issue three (published in the Summer of
1982) discusses the Home Office Local Radio Working Party, explores options for
developing both Community Radio and television, critiques BBC Local Radio and
includes case studies of commercial radio and unlicensed 'pirate' broadcasters. It also
takes on an international element, examining what, if anything, it might be possible to
learn from the effectively unregulated approach to radio broadcasting being taken by
Italy at that time (Relay Magazine, 1982, Issue 3: 8-9).
As an adjunct to the 'fanzine' publishing culture of the time, the early 1980s also saw
the emergence of various radio magazines, which, although focusing primarily on the
activities of 'pirate' broadcasters, also took an interest in the growing campaign for
licensed Community Radio. Soundwaves (mid 1980s) and TX Magazine (1985 – 1988)
are two examples, both produced by individuals and sold via mail-order. Today, the
primary relevance of such titles is the way in which they evidence the wide diversity and
scale of land-based unlicensed broadcasting at that time.
Another particularly useful source of information about the campaign for the
introduction of licensed Community Radio is Airflash Magazine, which was published
initially as a membership newsletter and later as a magazine by the CRA and its later
manifestation, the Community Media Association (CMA). Published in print form (95
issues), between 1983 and 2007, it contains a wealth of detailed material about the
development of the sector, documenting its increasing competence and confidence over
a period of some 25 years.
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Special Event Radio
The formation of the CRA in 1983 coincided almost exactly with the introduction of
short-term Special Event Radio (SER) licences, issued directly by the Home Office and
permitting low-power broadcasts, as the term suggests, to cover special events such as
community or music festivals (Gordon, 2000: 8). There is, however, scant mention of
this significant development in the campaigning literature of the time.
SER licenses became very popular throughout the mid to late 1980s, being taken over
by the Radio Authority in 1991 to become Restricted Service Licences (RSLs). The
remit of the RSL scheme was more flexible than that of the original SER approach,
which it replaced, with individual broadcasts no longer being required to be linked to a
specific 'special event'. However, geographical coverage was still limited to a couple of
kilometres from the transmitter and for a maximum of (typically) 28 days duration.
Despite such limitations, in its first decade, the Radio Authority licensed approximately
350 such services each year (ibid., 5). Even today, with so many other options available,
the scheme (now run by Ofcom) remains popular. In 2009 (the most recent year for
which figures have been published), some 368 temporary RSL licences were granted
(Ofcom, 2010: 3).
Working through the Airflash archive, the first development to be covered in
considerable detail is the proposed Community Radio Experiment of 1985. Although
the experiment itself was eventually abandoned, the level of interest generated by the
application process resulted in a range of subsequent policy developments, such as the
development of the Restricted Service Licence scheme and the 'Incremental Radio'
scheme (both of which are discussed in more detail later in this chapter).
Land-based Pirate Radio
In parallel with the emergence of licensed short-term Special Event Radio broadcasting,
land-based 'pirate' radio began to expand rapidly from the early 1980s onwards. Landbased unlicensed broadcasting had been operating at a relatively low level since the late
1960s, primarily on AM (medium-wave), the most notable example being Radio Jackie
as previously referred to (earlier in this chapter). However, by the early 1980s,
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technological developments had resulted in the availability of high-power, low-cost
transistors (often military surplus), which were perfectly capable of transmitting in the
VHF FM Band II (87.5 to 108 MHz).
Thus it was that by the middle of the 1980s, a confluence of developments saw pressure
for a new third tier of radio broadcasting come from a variety of parallel sources.
Effective lobbying, particularly from the CMA, was supplemented by an increasing
number of licensed, short-term radio services which, as Pilkington had suggested would
be the case back in 1962, were beginning to demonstrate how such services might
operate in practice. Licenced services were also supplemented by 'direct action' in the
form of land-based unlicensed broadcasting. The majority of these 'pirate' broadcasters
were very much focused on specialist music programming (targeting particular
communities of interest or ethnic minority audiences). Their survival in the face of
regular enforcement action by what was (until the arrival of British Telecom in 1984)
known as the Post Office Radio Interference Service (RIS), which was subsequently
taken over by the Department of Trade and Industry's Radiocommunications Agency,
clearly proved two things:
1) That it was perfectly possible to deliver radio programmes over the long-term
at costs much lower than those associated with BBC Local Radio or their
commercial competitors, the IBA's Local Radio Contractors. Crucially, despite
using much lower-cost studio equipment and not spending money on expensive
studio sound treatment and soundproofing, it was often impossible for listeners
to distinguish between stations of different types in terms of perceived technical
quality.
2) Particularly in major conurbations, the existence of large numbers of
unlicensed broadcasters also demonstrated that, despite the protestations of
regulators, it was perfectly possible to find room for additional broadcasting
services on existing broadcast radio spectrum.
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Just as it is today, in the 1980s, 'pirate' radio broadcasting was particularly prevalent in
the Greater London area and its impact did not go unnoticed by the capital's local
government of the time, the Greater London Council (GLC). This powerful local
authority, with an interest in radio broadcasting that dated back to at least 1969, when
it unsuccessfully sought to establish a 'Greater London Radio Authority' (HMG UK,
1969), was Labour controlled throughout the early 1980s until its abolition by the
Thatcher Government in 1986. Not surprisingly, it was strongly politically opposed to
the national Conservative Government of the time and it saw the development of
Community Radio as a potentially useful social tool, putting money into various
London-based projects between 1983 and 1986.
Another reason why 'pirate' broadcasting became so prevalent in the early 1980s was
due to the discovery of a 'loophole' in the Wireless Telegraphy Act (WTA, 1949), the
relevant broadcasting legislation concerned with the prevention of such unlicensed
broadcasting. When closing down 'pirate' stations, the RIS (and the police) had
regularly been confiscating various pieces of broadcasting equipment and other ancillary
items, such as record collections, using clauses in the WTA as justification for such
actions.
In December 1983, barrister, Peter Corrigan discovered a loophole in
the 1949 Wireless Telegraphy Act which implied that radio
transmitters manufactured in the UK could not be seized until the
case had gone to court, or until a specific order was made for the
confiscation of the equipment. A test case … was processed in court
and proved successful on this point of law, a result which heralded
the beginning of seven-day-a-week transmissions by many London
pirate stations from early 1984 (Goddard, 2011: 37).
The Government quickly took steps to resolve this issue and in July 1984, the new
Telecommunications Act (1984) was given Royal assent. The Act "irrevocably
changed the legal status of pirate radio stations" (ibid., 13), allowing the
"seizure of broadcasting equipment without a warrant, powers they had not
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previously enjoyed" (ibid.). However, although some stations did close voluntarily,
the level of unlicensed broadcasting activity did not subsequently decline to pre-test case
levels; indeed, within a few months, it was higher than ever and the 'pirate' genie
remained well and truly out of its bottle.
On the evening of January 14th, 1985, in a House of Lords debate about unlicensed
broadcasting (dominated, incidentally, by numerous peers declaring various interests as
directors of existing commercial radio stations), Labour Peer, Lord McKintosh of
Haringey spoke of the need for "an element of stick and carrot which ought to
be applied" (HMG UK, 2005) in relation to unlicensed broadcasting policy. Having
recognised the importance of the enforcing the law, he added:
At the same time I do not think we should ignore the carrot. If it is
true — and I believe it to be true — that there has been a
substantial expansion of illegal pirate radio in the last few years,
ought it not to be in the interests of Government and of the IBA to
see to it that the attraction of pirate radio is less? Ought it not to be,
for example, that the IBA and the Government should proceed faster
in the licensing of new radio stations in the smaller communities? I
understand that the IBA has been pressing the Government for wider
powers in relation to community radio, but we still have a very
monolithic radio structure in this country. We do not have ethnic
radio stations. We do not really have local radio stations operating,
as they should do, on a shoe-string or in accordance with the very
high technical and engineering standards which may be appropriate
for national radio stations but which I doubt are appropriate for
community radio (ibid.).
Such pressures undoubtedly contributed to the 'false dawn' of 1985, when, soon after
the House of Lords debate concerning unlicensed broadcasting (above), "the Home
Office announced a community radio experiment, but then abruptly
abandoned it" (Everitt, 2003: 16). If nothing else, the aborted experiment proved
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conclusively the demand for small-scale broadcasting. Inviting applications for a
proposed 21, two-year-long, experimental licences (HMG UK, 1985 (ii)), the Home
Office received no fewer than 271 separate applications (Fleming, 2010: 44).
The Community Radio Experiment
Following the House of Lords debate (above), the government first suggested the
possibility of a Community Radio experiment in a written answer to a House of Lords
question later that same month. In those pre-Internet days, the suggestion of "perhaps
starting with some experimental stations" (HMG UK, 1985 (ii)) almost
immediately resulted in the Home office receiving "about 120 letters on
community radio, together with a similar number of telephone inquiries"
(HMG UK, 1985: (iii)) mostly "from persons wishing to set up community radio
stations" (ibid.), including some referring "to the availability and allocation of
frequencies" (ibid.). With no sign of the suggested experiment being announced, by
early June 1985 the government reported that it had now "received about 400
letters on community radio together with a broadly similar number of
telephone inquiries" (HMG UK, 1985 (iv)).
The long hoped for experiment was finally announced in early July 1985, when, in a
written answer to Parliament, the then Home Secretary, Leon Brittan QC, explained
that he had:
… decided to establish an experiment to test the viability of and
scope for a range of different types of community radio, set up and
financed in different ways in different locations (HMG UK, 1985 (v)).
More details were provided in a further statement later that month (HMG UK, 1985
(vi)) and by August 1985, across the country in the various specific locations decided
upon by the Home Office (from The Shetland Isles down to Penzance via various urban
and rural locations in Scotland, England and Wales), numerous groups and individuals
(including the then young author of this thesis) were working to complete their various
applications for experimental Community Radio licences, each to be submitted to the
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Home Office by the 30th of September, 1985 (ibid.). The Home Secretary explained
that in selecting successful applicants he hoped "to have the benefit of advice from
a panel of advisers" (ibid.). Optimistically, he concluded the statement with the
words: "Subject to the number of applications received, I hope to be able to
announce the successful applicants in December" (ibid.).
In fact, the process of awarding the proposed experimental licences dragged on, with no
apparent sign of reaching a conclusion, until the end of June 1986. In part, this was a
result of the high volume of applications made. The Home Secretary did indeed
appoint a panel of advisers, including two members closely linked to the Community
Radio Association (Ray Beaty and Bevan Jones), which, over the New Year 1985 / 1986
"held a number of useful meetings with interested individuals and groups"
(HMG UK, 1986).
Given the high number of applications received, it was perhaps not surprising that the
Advisory Panel found it very difficult to come up with a set of licensing
recommendations compatible with the Home Office's guidelines for the experiment.
Eventually reporting in March 1986, the panel suggested that, in London, where
demand had been greatest, "an additional three stations" (Hebditch, 1986) should
be added to the experiment.
At this point a new Home Secretary, Douglas Hurd, came in, who it's
been reported wasn't entirely happy with the way the experiment was
to be run or the decisions the panel had made. Some of the chosen
stations were judged to be politically "sensitive" (seemingly the ones
with local authority grants) and it seems that the Conservatives were
worried that stations with a left-wing bias, however slight, might
damage their chances at the next election, and possibly some of the
more extreme ones might be able to incite riots. (ibid.).
At the time, however, the change of plan, when announced, appeared to be sudden. On
the 26th of June 1985, the Home Office Minister, Giles Shaw, was still implying in
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Parliament that the experiment would proceed (HMG UK, 1986 (ii)). Then, after leaks
to the national press (HMG UK, 1986 (iii)) leading to complaints in Parliament (ibid.),
on the 30th of June 1896, Leon Brittan's successor as Home Secretary, Douglas Hurd,
announced to the House of Commons that, in spite of the high levels of interest in it,
the experiment was to be abandoned forthwith (HMG UK, 1986 (iv)). As befitted the
attitude of the Home Office at that time, the reasons for the abandonment were suitably
general, vague and opaque, referring to matters that had, by the government's own
admission (HMG UK, 1985 (vi)), already been considered prior to the experiment
having been announced in the first place:
It had been hoped to start this two-year experiment several months
ago. But various difficulties arose and anxieties were expressed about
its exact form. There would have been no regulatory body, and yet
the public would have expected certain minimum standards of
objectivity and decency to be maintained. Even in an experiment in
partial deregulation, some minimum would still be necessary….
(HMG UK, 1986).
The real reasons for the cancellation of the experiment were, perhaps, a little more party
political in character. According to New Society Magazine at the time (quoted in
Goddard, 2011), one element behind the decision was:
The desire of [Conservative Party Chairman] Norman Tebbit to make his
rival for the party leadership look foolish. The ex-Heathite [Douglas]
Hurd was in sympathy with the aims of many community radio
projects to give ethnic groups a voice; but Tebbit, at the last moment
and with [Prime Minister] Mrs Thatcher's backing, persuaded the
Cabinet to turn Hurd down (Quoted in Goddard, 2011: 54).
The then Broadcasting Spokesman for the Liberal Party, Clement Freud MP, was
cynical about the reasons behind the cancellation:
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Could it be that Mrs Thatcher is afraid of the voices of ordinary
citizens: that its alright for Mr Murdoch to take over the Times, but
too dangerous to allow 21 community stations to experiment…
(Quoted in Hebditch, 1986 and Anonymous, 1987: 7).
Writing a year or so later, one member of the Home Office Advisory Panel, Bevan
Jones, observed:
The aborted experiment in CR would … have tested a variety of
styles of station ranging from the democratically accountable
voluntary organisations to the hard-nosed professionally managed
type. But one lesson can be drawn from the experience. It is that
there is real and widespread interest in Community Radio (Jones,
1987).
Former IBA executive, Tony Stoller, writing with the benefit of hindsight in 2010
suggested that back in 1986:
It seems most likely that community radio was a libertarian step too
far. The true instinct of the Thatcher/Blair governing philosophies
has been to liberalise business and individual commercial enterprise,
but to keep personal radicalism firmly in check (Stoller, 2010: 9).
The last word on the botched Home Office experiment goes to the late John Gray
(1918 - 2006), a long-standing Community Radio supporter, with a broad interest in
radio dating back to the early days of local BBC broadcasting in Aberdeen, Scotland. In
a letter to the Scotsman newspaper, published on the 03rd of June 3rd, 1986, he
suggested:
As an example of insensitive incompetence, the indefinite
postponement of the experiment in community radio is a terrifying
example of political ineptitude by the present government. To start a
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scheme, to encourage widespread participation and then, on dubious
grounds, ditch the whole effort at the last moment is almost
incredible (Gray, 1986, quoted in ibid.).
Incremental Radio
It was not until 1989 that the then soon to be replaced broadcasting regulator, the
Independent Broadcasting Authority (IBA), finally succeeded in taking the first tentative
concrete steps towards the introduction of full-time Community Radio services. This
was done through the introduction of a new tier of smaller radio stations, which were
operated under what became known as 'Incremental Radio' licences. In order to meet
the requirements of broadcasting legislation in place at the time (the Sound
Broadcasting Act (1972)) (HMG UK, 1972), these relatively small-scale services were
introduced only into areas that were already served by existing local radio services. In
addition, they were required to provide output that was complementary to that of the
established local radio tier, such as specialist music formats or programming intended to
serve a specific sub-section of the community.
Clearly, the IBA was trying to strike a balance between the demands of the Community
Radio lobby for access to the airwaves whilst, at the same time, seeking to minimise the
impacts that such services might have on its existing station operators. However, the
Authority was struggling with legislation that was recognised, even by the government of
the day, as being less than ideal for non-commercial broadcasters. Speaking in the
House of Lords, before invitations for incremental licences were issued, the Minister of
State at the Home Office, Earl Ferres, said that the IBA's proposals for its experiment
were "a welcome but necessarily limited start with community radio before
the new legislation. But the present framework is, frankly, not ideal for
community radio" (HMG UK, 1988).
Despite this, 21 of these relatively small-scale services were licensed. Several were
operated by ex-pirates, and several, including WEAR FM in Sunderland, Mellow 1557
in rural Essex, For the People (FTP) in Bristol, and Spectrum Radio in London, adhered
to clear community broadcasting principles. However, despite the alternative ideals
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behind such stations, they were each required to operate under legislation intended for
the delivery of commercial broadcasting and, not surprisingly therefore, this legislation
made no provisions to ensure and protect the long-term adherence to elements such as
not-for-profit operation or community ownership and control. Thus, commercial
pressures took their toll and:
What had begun as an exciting attempt to free up the airwaves, to
enable them to carry the full range of values, tastes and opinions that
shape our society, ended in an increase of stations sounding virtually
indistinguishable from one another (Crissell, 1997: 216).
Former Chief Executive of the Radio Authority, Tony Stoller, observes that
"[m]easured in terms of a new foray into community radio - and by other
measures too - many of the incremental stations failed" (Stoller, 2010: 160).
He broadly agrees with Crissell that "[t]hose that survived became largely
indistinguishable from mainstream ILRs" (ibid.) but noted that this was not the
case for those stations that "were focused upon specific ethnic minority
communities where the dynamic was different" (ibid.) and observes that Ofcom
"now dismissively characterises the incremental stations as a "false dawn"
for community radio" (ibid., 161).
When the Broadcasting Act (1990) arrived, despite the on-going campaign of the
Community Radio Association, it "placed no specific community radio
obligations on the new regulator, the Radio Authority … to the continued
frustration of the CRA" (ibid.). In Stoller's view:
It looked at that point as if there would be no third tier of radio in
the UK. The new regulator was almost as doctrinally opposed to the
notion of separate community radio as were the ILR companies and
there was relatively little political support (ibid.).
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Stoller notes that it was at around this point that the CRA transformed itself into the
Community Media Association (CMA). Stoller argues that this was because "it lacked
the political support to bring community radio back to the foreground of
policy discussion" (ibid., 318). An alternative view might be that the CRA was 'ahead
of the curve', recognising the forthcoming convergent realities of media in the TwentyFirst Century:
In 1996, in response to new opportunities for local and community
television and the emergence of the Internet as a platform for
community media, it adopted a broader remit and changed its name
to the Community Media Association (Buckley, 2011: 31).
Restricted Service Licences
Although subsequent legislation in the form of the Broadcasting Act 1990 did not
provide for the introduction of full-time community radio services, it did, however,
make permanent the existing system for the provision of temporary short-term
broadcasting licenses and long-term, very low-power services for closed establishments
such as hospitals and universities. Short and long-term 'Restricted Service Licences'
(RSLs) replaced and enhanced the systems of short-term 'Special Event Radio' (SER)
licensing and longer-term hospital and student radio licensing, which had hitherto been
operated directly by the Home Office.
Years before permanent Community Radio licenses were available, RSL licenses were
used as a form of trial community service, often using a particular local event or activity
as the justification for such broadcasts. A large number of those stations that have, from
2004 onwards, since been licensed as full-time Community Radio services, have a
history of prior RSL broadcasting. Despite the increasing number of such permanent
community stations, interest in the use of short-term RSL licenses continues unabated,
with around 400 temporary broadcasts taking place each year in various locations across
the UK.
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In terms of permanent radio broadcasting services, the 1990s was a period of rapid
expansion in the United Kingdom and this was particularly the case within the
commercial sector. Although a separate specific tier of Community Radio was still some
two decades away, at this time, a number of community-based services did succeed in
taking to the airwaves, working within the licensing framework intended for commercial
radio.
The Scottish Experience
This was most notably the case in Scotland where a confluence of circumstances made
space for community-based services. In particular, the size of some communities,
geography and distribution of the Scottish population made frequency availability less of
a problem (mountains block interfering radio waves very effectively). In parallel,
competition from commercial applicants was less than in other parts of the country,
simply because lower population density (outside Edinburgh, Glasgow and the wider
central belt of Scotland) meant that, very often, the coverage achievable within the rural
terrain was not considered to be commercially viable.
Another factor was that, also outside of the central belt, some established commercial
broadcasters, most notably Moray Firth Radio (MFR) broadcasting from Inverness,
chose to cooperate with community-based groups seeking to broadcast their own
programmes. Such an approach was as unusual as it was practical. MFR offered its own
programming as a sustaining service, along with other practical help, for example with
transmission planning and studio technical support and advice. As a result, throughout
the 1990s, parts of Scotland, for example, Oban (Oban FM), Aberfeldy and Pitlochry
(Heartland Radio), Gairloch and Loch Ewe (Two Lochs Radio), Lochbroom FM
(Ullapool) and the Isle of Lewis (Isles FM), each established fully operational, local
community-based services under the terms of the commercial radio licensing remit of
the Radio Authority. Not only were these working examples of Community Radio
highlighted as success stories by campaigners in other parts of the United Kingdom, but,
more importantly, they also demonstrated to a sceptical regulator that low-budget, noncommercial organisations could reliably deliver adequate standards of programming and
adhere to mainstream broadcast regulations.
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The Radio Authority
The introduction of the Broadcasting Act (1990) saw the abolition of the IBA and its
replacement by the Radio Authority. Although a fundamental change, particularly in
terms of separating the regulation of radio from the often previously dominant presence
of television, behind the organisational change, many of the people involved remained
the same. On the 07th of September, 1989, the Guardian newspaper questioned,
whether the interests of political balance had been properly served by
yesterday's appointment of Lord Chalfont, a belligerently right-wing peer, as
head of the Radio Authority (The Guardian, 1989: 22).
In fact, none of the early appointments to the authority's board "was through any
open or competitive process" (Stoller, 2010: 201) and:
Staffing the Authority was similarly uncompetitive. IBA director of
radio, Peter Baldwin became chief executive of the Radio Authority,
and senior IBA Radio Division figures Paul Brown and David Vick,
joined by others … quietly 'crossed the floor' to radio (ibid.).
Digital Audio Broadcasting
The Radio Authority took over responsibility for broadcast radio regulation at a time of
considerable change, not only in relation to the established use of analogue (AM and
FM) radio frequencies but also in relation to digital radio broadcasting (discussed in
more detail later in this thesis). The BBC carried out the first United Kingdom field
trials of the then emergent Digital Audio Broadcasting (DAB) standard during February
and March 1990 (Shelswell et al, 1991: 1). These tests, from Crystal Palace and Kenley
in London (ibid., 6-8) and which were receivable at the Radio Authority's Central
London offices, took place just weeks after the new Authority was established in shadow
form on the 01st of January 1990 (Stoller, 2010: 201).
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The first public demonstrations of DAB took place at the end of July 1991 in the centre
of Birmingham. During the Radio Academy's annual Radio Festival there, the BBC
demonstrated comparative DAB and FM coverage.
A coach driven round Birmingham was used to demonstrate the
ruggedness of the DAB system in a typical city-centre environment,
where normal FM radio can suffer from poor reception caused by the
many tall buildings. Visitors listening on headphones were able to
compare DAB and FM signals which were being received from
transmitters on 211 and 215 MHZ respectively, carrying identical
programme material (BBC, 1991: 1).
This demonstration (at which the author was present) had a considerable impact on the
attending members of the UK radio industry and, partly as a result of the success of this
demonstration and the subsequent publicity, the Radio Authority moved quickly, to
declare that "DAB is Big News for Radio" (Radio Authority, 1992: 3). Noting that
the technology had "been demonstrated convincingly as the most credible
technique" (ibid., 6), nevertheless, the Authority also recognised from the outset that
DAB would be of limited use to smaller services (including Community Radio), and
noted the system's inherent "degree of planning inflexibility" (ibid., 6), which, as a
result, would mean that:
… for the smaller discrete local station, or where the strength of a
given local market will not support more than, say, three local
services, the current FM system may remain the most suitable delivery
system for the foreseeable future (ibid.).
Expanding The FM Band
Although expansionary impacts of DAB broadcasting were still some years off, one of
the reasons for the expansion of the non-BBC local radio sector during the 1990s was
that, at last, many years later than in the rest of Europe, the FM spectrum between 105
and 108 MHz (vhf / FM) was made available for broadcasting in the UK. The
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government had dragged its heels over this because, at the time, "it was used for
radio communications by some of the emergency services and there were cost
implications in re-equipping those to use other frequencies" (Stoller, 2010:
245). Stoller further notes that "It took a good deal of arm twisting before 105108 was allocated … for commercial radio" (ibid., 246).
Having obtained the spectrum, the Radio Authority was somewhat uncertain as to how
best to utilise it and, in February 1994, it decided to consult on various options (ibid.),
receiving 21 responses, which, according to Stoller, were "predictably mixed and
self-interested" (ibid.).
For technical reasons, relating to the close proximity of frequencies used for aircraft
communications and navigation above 108 MHz, the placing of high power
transmitters close to 108 MHz runs a greater risk of interference problems than is the
case with lower power transmitters. As early as 1987, the Home Office noted in a
Green Paper "the need to minimise interference to the aeronautical radionavigation services" (Home Office, 1987), suggesting that, as a result, frequencies
just below 108 MHz would be "more suitable for low power use" (ibid.) and going
on to observe that room might be found for "over 400 stations" there (ibid.).
Thus, the allocation of the spectrum between 107 and 108 MHz to "small coverage
services, 'equating with what some might call 'community radio', or even
'neighbourhood radio''" (Stoller, 2010: 246) was arguably a sensibly precautionary
approach to take. However, it was also one that had the potential to work in favour of
the Community Radio sector and its drive for the introduction of smaller, more
geographically focused, services.
In fact, the Community Radio Association pushed hard, albeit not particularly
successfully, for the allocation of the entire spectrum between 105 and 108 MHz for use
by Community Radio services. In April 1994, it published a detailed, 28-page
document, responding to the Radio Authority's consultation (CMA, 1994). This
document contextualised the authority's options in relation to prior statements by the
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government, for example by pointing out that, in the run up to the creation of the
Broadcasting Act (1990), it had stated that its proposals were intended to "create an
environment in which community radio, based on a combination of local
identity and cultured diversity, will be able to fulfil its potential" (Home
Office, 1988).
Summarising the arguments in favour of Community Radio, the CRA stated:
We believe there is an unanswerable case for the further substantial
development of community radio services utilising available FM
frequencies in the light of stated Government policy, demonstrable
listener preference and the continuing growth in the number of
aspirant local radio broadcasters (CRA, 1994: 27).
The campaigning body also employed arguments based upon its knowledge of the
situation in other jurisdictions (a technique it was to employ more successfully in the
run-up to the Access Radio experiment some years later) and it also warned of the
consequences of not proceeding with the licensing of community-based services:
There is sufficient comparative evidence of the development of
community type radio services in other European Union countries to
indicate that the demand is unlikely to diminish until a level in the
order of 300 such services are available in the UK. We predict that
failure to respond to this demand will exacerbate the social and
economic problem of widespread unlicensed local radio broadcasting
(ibid).
With the benefit of hindsight, the CRA's observations in these areas have proven to be
correct, at least to some extent. According to Ofcom, by May 2015, there were some
227 Community Radio stations broadcasting in the United Kingdom (Ofcom, 2015:
228). However, as the CRA suggested would be the case, unlicensed 'pirate'
broadcasting has, however, yet to show any serious signs of decline, with, in Ofcom's
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estimation, "about a hundred illegal stations in the UK with around three
quarters based in London" (Ofcom, 2014: 1).
Having considered the various responses, the Radio Authority selected its proposed
"hybrid option" (Stoller, 2010: 246) which it usefully summarised several years later
in a document explaining its licensing award procedures:
The Authority reviewed a number of options and, after a consultation
process involving the radio industry and the public, decided on the
mix of ‘regional’ licences (mainly using frequencies in the 105-106
MHz range), and licences to serve areas usually smaller than ‘first
generation’ ILR areas (mainly in 107-108 MHz) (Radio Authority,
1999).
'Sally Licenses'
The smaller stations introduced following the 105-108 MHz consultation were licensed
under the rules of the Radio Authority's new 'Small Scale Alternative Location Licence'
scheme and were given the acronym 'sally' or 'sallies'. Their relatively small coverage
objectives (only slightly larger than for most current Community Radio services),
allowed the Authority to trial a new approach to licensing. In what was something of a
radical departure from the traditional approach of the regulator, rather than defining a
particular set of coverage parameters (transmitter location, radiated power etc.) in
advance, instead:
In many wider localities it was possible to offer one or more licences
for low-powered transmission, but not to meet all the possible local
demands. In such instances, the Authority invited applicants to
propose, not only what programming they would provide, but [also]
which part of the wider area they would provide it for (Stoller, 2010:
300).
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In spite of the fact that, in some respects, "sallies caused more problems than they
solved" (ibid., 301), this approach to licensing was considered sufficiently successful to
become the basis upon which almost all of the subsequent Community Radio licensing
by Ofcom has been carried out to date.
Following the completion of the Radio Authority's 105 to 108 MHz consultation
process, Community Radio was, once again, left largely out of the regulatory equation,
in effect no further forward than it had been at the start of the Incremental Radio
experiment of a few years earlier. Although new frequency resources were indeed
available for the first time, and community-based groups could still apply for small-scale
licences, this was still only in the face of potential commercial competition and within a
regulatory structure, which still favoured such applicants.
1990s Industry Evolution
Under the auspices of the previous Independent Broadcasting Authority:
From 1973, until the wheel turned in 1990, ILR stations produced a
full range of speech content, including hour-long documentaries,
regular features, extended news programmes and phone-ins. A wide
range of specialist music was also a requirement – with more than
half an ear to musical education – and the stations’ schedules
reflected this. Every station (apart of course from the News/Speech
franchise held by LBC) was expected to broadcast a full range of
separate genre specialist music programmes; typically including
classical, country, jazz, folk, rock, so-called ‘ethnic’ and more (Stoller
& Wray, 2010: 6).
Throughout the 1990s, the full impact of the changes brought about by the
Broadcasting Act (1990) began to be felt. The fundamental shift from 'independent
radio' under the Independent Broadcasting Authority of the 1970s and 1980s to
'commercial radio' under the Radio Authority of the 1990s and early 2000s had
profound effects on the way in which the industry evolved. With the public service
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obligations of IBA franchise holder stations now a thing of the past, simpler,
mainstream, rolling music programming became the norm. In parallel, ownership rules
were also relaxed, so the commercial radio sector embarked on a period of mergers and
consolidation, which has continued unabated since. Today, two main groups, Global
Radio and Bauer Media, own the vast majority of commercial radio stations
broadcasting in the United Kingdom.
The commercial logic of such developments, in terms of staff reductions, and the
centralisation of facilities, through increased networking and automation in particular,
delivered considerable cost savings to the industry. However, combined with the
removal of public service requirements, such developments also resulted in dramatic
changes to local radio programming and, in particular, to a reduction in the provision of
local content, which was "exacerbated by commercial radio's falling investment
in its programming" (Stoller, 2010: 297).
Inadvertently, through its abandonment of commitments to broad format programming
and specialist local content, the commercial sector was, in effect, helping boost the
argument in favour of Community Radio as a way of replacing such content. Stoller
and Wray suggest that: "It is Community Radio … which looks set to be the
true heir to the ambitions of independent radio in the UK" (emphasis in
original) (Stoller & Wray, 2010: 18).
'New Labour' / 'new Labour'
Following the change of government in 1997, pressure for the introduction of
Community Radio continued. Perhaps because it was not burdened by such close ties
to the commercial radio sector as its Conservative predecessors, or indeed the same
'baggage of history' concerning previous attempts at legislative change, the new Labour /
New Labour government soon indicated that it would support the introduction of such
services.
Signs of progress were becoming obvious by 1999, when the CMA was invited to make
contributions to a joint Radiocommunications Agency, BBC and Radio Authority
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investigation into options for re-planning the FM (Band II) spectrum, carried out by
Aegis Systems Limited (Rudd et al, 2000). This report examined options for the
introduction of additional FM stations in urban areas such as Leeds and London,
specifically considering the potential for launching small-scale community-based
services. At around the same time, the Radio Authority, as the then regulator
responsible for all UK non-BBC radio broadcasting, began to develop plans for the
introduction of a limited number of experimental 'Access Radio' stations with which it
intended to develop the concept and structures of Community Radio within the UK
context.
Access Radio
The term 'Access Radio' was in fact an early bone of contention between the Radio
Authority and long-term campaigners for Community Radio. The CMA and others
argued that the term 'Access Radio' already had a specific meaning internationally
(related to open access stations) and that the Radio Authority simply did not wish to
admit that it was finally introducing a tier of radio of which it had historically been less
than supportive.
Such minor spats aside, from the outset, the Radio Authority made a point of liaising
with the Community Media Association in relation to the development of its plans. An
early concrete example of this was the Authority's organising of a one-day seminar in
February 2001; billed as a "great debate on third tier of radio services", it
included no fewer than three speakers from the CMA and heard contributions from the
floor by others and from a number of prospective community broadcasters (Radio
Authority 2001 & 2001a). An invitation for expressions of interest in applying for what
would be know as 'Access Radio' licences was issued by the authority in May 2001, with
the intention of selecting a diverse range of services with differing objectives, structures
and funding models (Radio Authority, 2001b). In early August 2001, the Radio
Authority announced that it was inviting fifteen groups to make formal applications for
licenses:
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The fifteen groups reflect all four of the home nations, rural and
urban areas, including links with urban regeneration projects,
services for ethnic minorities in the Asian and Afro-Caribbean
communities, a wide range of age groups from children to older
people, Christian based stations, and a range of financial models.
The maximum length of licences to be offered is twelve months, but
some services propose shorter durations. Others propose the sharing of
frequencies or shared administration, some intend to broadcast for
only part of the day or week, some services will broadcast on AM and
some on FM. Broadcast wavebands are still to be determined for a
number of these services, as well as the clearance of suitable
frequencies (Radio Authority 2001c).
The majority of the pilot groups had been members of the CMA prior to applying for
their experimental licences, and those not connected with the organisation all chose to
join soon after their licences were awarded, such that all fifteen groups were members of
the CMA from 2002 onwards. A number of meetings were held between the Radio
Authority, the CMA and the various Access Radio pilot stations throughout the
experimental period. For example, the various parties spent all day on the 11th of
September 2001 in a planning meeting hosted by the CMA in Sheffield, oblivious to the
momentous occurrences taking place in New York and elsewhere in the United States.
At around this time, the CMA made its own contribution to the debate about the
eventual nature of the forthcoming UK Community Radio sector. It commissioned and
published a comparative analysis of Community Radio in six other jurisdictions
(Australia, Canada, France, Holland (The Netherlands), Ireland, and South Africa)
(Price-Davies & Tacchi, 2001). This report made a number of concrete
recommendations, several of which found their way into the eventual Community
Radio enabling legislation, the CRO 2004.
Once the various Access Radio pilot projects began to come on air in 2002, liaison
between the Radio Authority and CMA continued and in some respects increased. The
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Radio Authority appointed Professor Anthony Everitt to assess the activities of the
various pilot stations (Radio Authority 2001(d)). Everitt visited the various stations on
an individual basis, but it was the CMA that typically provided facilities when the
various stations met together, often with the assessor and staff of the Radio Authority
also present.
Although the original intention had been to operate the Access Radio experiment for a
one-year period, the original licences were extended on more than one occasion with
most of the trial stations receiving full-time Community Radio licences in 2006. There
were two main reasons for the extensions. Firstly, the thorough nature of Professor
Everitt's analysis of the experiment took somewhat longer than expected, leading to the
publication of two reports (Everitt 2003 & 2003 (a)), rather than one as had originally
been intended. Secondly, the introduction of permanent enabling legislation, The
Community Radio Order 2004 (HMG UK, 2004), took longer than expected to
finalise. Given the complimentary nature of the Everitt reports, which suggested that
the experimental stations were working well, both the Radio Authority and its successor,
Ofcom, took the pragmatic view that there was little to be gained by terminating
licences. Doubtless, the thinking behind such pragmatism was that the only effect of
such a move would have been for the experimental groups to lose momentum whilst offair and waiting to apply for subsequent, full-time, permanent licences.
Various parties contributed to the final makeup of the Community Radio Order 2004.
After, in its White Paper consultation, A New Future for Communications was published
in December 2000, the government invited "views on extending the diversity of
radio service through 'Access Radio'" and on "whether the benefits of
Community Radio would justify greater public intervention" (DCMS / DTI,
2000: 39 & 40).
The Radio Authority set out its underlying thoughts in a document entitled 'Access
Radio: Submission by the Radio Authority to DCMS [Department for Culture Media
& Sport] / DTI [Department of Trade & Industry]' (Radio Authority 2001 (e)). This
response was one of many contributions to the debate, with others coming from the
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CMA and prospective community broadcasters as well as other interested parties, such
as the commercial radio sector.
Ofcom Community Radio
Acting on the various responses received, the UK Government created section 262 of
the Communications Act 2003, which provided powers for the introduction, under
secondary legislation, of radio services that would:
…be provided primarily for the good of members of the public or of a
particular community, rather than for commercial reasons; and…
[which] …would confer, significant benefits on the public or on the
communities for which they are provided (HM Government, 2003:
Section 262(2) a & b).
With such enabling legislation in place, thereafter, attention focused on the creation of
the required secondary legislation, the Community Radio Order, 2004. A further
formal consultation process took place between the 10th of February and the 20th of
April 2004, before this legislation was finalised by the DCMS. During early 2004, the
consultation phase over the eventual wording of the CRO did indeed lead to changes,
some of which were not welcomed by the Community Radio sector. In particular, some
changes had been introduced to strengthen protection for the commercial radio sector.
Early drafts of the order provided limited protection for small-scale commercial
broadcasters, which, it was felt, might be financially damaged by the introduction of
competing Community Radio services. It was at this point that the CRA "decided
that its job was done" (Stoller, 2010: 324) However, the commercial radio sector
body, the Commercial Radio Companies Association (CRCA) (now known as the
RadioCentre) felt that such protection was inadequate and was successful in lobbying
for change, such that the "final order gave them plenty" (ibid.).
Whereas an early draft of the CRO, published prior to the 2004 consultation, simply
stated:
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A community radio licence shall include such conditions (if any) as
appear to OFCOM to be appropriate for securing that the sale of
advertising and sponsorship in connection with the service provided
under that licence does not unduly prejudice the economic viability of
any other local sound broadcasting service (DCMS, 2004: 6).
By comparison, the final version of the CRO included far more concrete restrictions,
namely:
(a) OFCOM shall not grant a licence to provide a community radio
service in any case where the licence, if granted, would overlap with
another local licence for a service, other than a community radio
service, the potential audience of which includes no more than
50,000 persons who have attained the age of 15 years;
(b) every licence to provide a community radio service that overlaps
with any other local licence the potential audience of which includes
more than 50,000 persons who have attained the age of 15 years, but
no more than 150,000 such persons, must contain such conditions as
appear to OFCOM to be appropriate for prohibiting -
(i) the inclusion in that service of any remunerated advertisement,
and
(ii) the sponsorship of any programmes included in that service...
(HM Government, 2004: 7).
The greater lobbying experience and resource base of the commercial radio sector was
clearly used to great effect at this time. The Commercial Radio Companies Association
(CRCA) went as far as publishing a 41-page booklet in support of its assertion that
commercial radio already delivered much of what the new Community Radio services
were seeking to provide. 'Commercial Radio: In The Public Service' was described by
the CRCA as an audit of:
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radio station members [that] collated and submitted statistics about
their news, weather, travel, what's on, charitable, social action and
community information broadcasts (CRCA, 2004: 5).
The above document was prolific in its use of the word 'community' making great play
of activities such as raising money for local charities (ibid., 33), "opening local fêtes
and carnivals" (ibid., 37) and "how station staff participate in local panels"
(ibid.).
Although the audit made much of station involvement in such activities, these tended to
be of a one-way nature: station involvement in local community activities. Notable by
its absence from the audit was any mention of involvement by members of local
communities in the activities of CRCA member stations. However, as a 'marketing
tool' for commercial radio, the contents of this publication certainly seemed to make an
impression and may well have helped in the CRCA's campaign for legislative protection
of its smaller members' interests. Subsequent publications, by the CRCA's successor
organisation, the RadioCentre, have continued, albeit to a lesser extent, to promote
commercial radio's community involvement credentials (RadioCentre, 2008: 22-23).
Lisa Kerr, who was external affairs manager for the CRCA at the time, commented:
We have been concerned that if the funding models of commercial
and community radio became blurred, community stations would
start acting like commercial ones and could take away advertising
revenue. In this legislation, the Government has just about got it
right (Kerr, 2004, quoted in Lindsay, 2004).
Although the above restrictions have had only a relatively minor impact on the
emergence of Community Radio in the UK as a whole, they have undoubtedly impacted
severely on the activities of individual community stations. Early in 2009, Ofcom's
annual report into the activities of the community radio sector stated that some sixteen
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stations were prevented from generating any income from on-air commercial activities,
with a further two being restricted to a lower percentage of income from such sources
(in one case 15%, in the other 25%) (Ofcom, 2009: 1). Of course, the impact of the
first of the two restrictions referred to above is less easy to quantify, but the author is
aware of at least two active community radio groups (WCR in Warminster and Access
FM in Bridgewater) that were prevented from holding a licence because of the presence
of a very small-scale commercial broadcaster's output overlapping their proposed
broadcasting areas.
Unlicensed Radio Broadcasting Today
In spite of the obvious success of Community Radio in the United Kingdom, as
previously touched upon, unlicensed 'pirate' radio broadcasting remains an unresolved
issue. Once Ofcom's Community Radio licensing system was in place, the regulator
decided to look again at the issue of unlicensed broadcasting, publishing its report Illegal
Broadcasting - Understanding The Issues, along with a series of three annexes, in April
2007 (Ofcom, 2007, 2007 (a), 2007 (b) & 2007 (c)).
When Community Radio licensing was first introduced by Ofcom, there had been a
hope within certain sections of the regulator (most notably the Radio Interference
Section) that it would, through its offer of legal routes into broadcasting, lead to a
reduction in the number of unlicensed 'pirate' broadcasters. However, as predicted by
the CRA as far back as 1994, this has not yet proven to be the case. The main objective
for the research was to better understand the drivers that make unlicensed stations
popular, but it also sought to understand why operators were not inclined to take up the
option of applying for a Community Radio licence instead.
Some ex-pirate radio presenters and operators have indeed moved over to present
individual programmes or otherwise work on various Community Radio stations.
However, even though licensed Community Radio services "operate on a protected
frequency which can help in attracting greater audience loyalty" (Ofcom,
2014: 3), only a small number of 'pirate' stations themselves have switched off to apply
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to become Community Radio services in their own right. Ofcom quotes Kane FM in
Guildford, Surrey as being one such station:
Becoming a community radio station has enabled us to reach out to
thousands of people who share a taste in forward thinking music,
culture and society. We are working with youth groups who have
often seen radio as an out-of-reach medium. "It has also helped with
sustainability, securing revenue streams from charitable donations,
trust funds and local businesses" (Kane FM quoted in Ofcom, 2014: 3).
Ofcom's research into land-based unlicensed broadcasting involved qualitative
interviews with 'expert interviewees' and there was consensus amongst them that "that
illegal radio performed a community function which licensed stations could
not, or would not, address" (Ofcom, 2007 (b): 22). Moreover, the research also
determined that "Heavy listeners of illegal broadcasters – refer to them as
'Community Radio'" (ibid., 16).
A particular concern of Ofcom is, not surprisingly, issues of potential interference and in
the regulator's view:
Illegal broadcasters cause interference to safety-of-life radio systems,
such as those used by air traffic control and the fire service. Because
illegal broadcasters use unauthorised frequencies at transmitted
powers which have not been cleared internationally, and because
their transmitter equipment may not comply with the appropriate
technical standards, their signals may interfere with services using
adjacent frequencies or those frequencies which have a technical
relationship to the ones being used by the illegal broadcaster (Ofcom,
2007: 7).
This general concern is amplified in relation to licensed Community Radio services
because interference problems for such services:
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are likely to get worse as more community radio stations - which
Ofcom has been licensing … come on air. This is because community
radio stations are required to transmit at much lower power than
their commercial counterparts (therefore making them particularly
vulnerable to interference) (ibid.).
Frequency Availability
In major UK cities, and particularly in London, the presence of unlicensed 'pirate'
broadcasters already places additional limits on the spectrum available for use by
additional analogue Community Radio services. However, even in locations where
unlicensed broadcasters are not operating, the availability of broadcast radio spectrum
(and of FM frequencies in particular) has placed major restrictions on the development
of Community Radio services. Put simply, the prior development of BBC and, in
particular, commercial radio, which took place before the arrival of community-based
services, has restricted not only the number of stations and their individual coverage
areas but also the locations in which they have been able to be licensed. This lack of
available analogue spectrum has consequently been one of the drivers behind current
plans to develop small-scale DAB capacity, as discussed in more detail later in this thesis.
Recent Legislative and Regulatory Developments
Despite the earlier success of the commercial radio sector in enhancing protection for its
operators in 2004, now, several years later, certain elements of these restrictions are
progressively being reconsidered. During 2009, the DCMS undertook a public
consultation to decide whether or not to remove the restriction that prevents Ofcom
from licensing Community Radio services in areas where a commercial station
broadcasts to fewer than 50,000 adults (aged 15+). It stated that:
The recent John Myers report, "An Independent Review of the Rules
Governing Local Content on Commercial Radio", commissioned by
Government as part of the DBR, recommended that this restriction be
lifted. Therefore, we are seeking views on lifting the rule prohibiting
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a community radio station from being licensed if it would overlap
with an existing local radio service for which the MCA contains no
more than 50,000 adults.
The Myers review also recommended that, should this restriction be
lifted, the advertising and sponsorship restriction should then be
applied to all community radio stations that overlap with local radio
services of up to 150,000 adults. We also seek views on this
(DCMS, 2009 (b): 5).
Following its consultation about the proposals, which, predictably, received general
support from the community sector and opposition from commercial operators, the
DCMS sponsored additional secondary legislation, submitted to Parliament in
November 2009. After consideration by Parliament, the 'Community Radio
(Amendment) Order 2010' (CRAO 2010) (HMG UK, 2010) came into law, relaxing
not only the licensing restrictions outlined above, but also formally granting Ofcom
powers to extend the various initial five-year licences granted from 2004 onwards.
Overall, the CRAO 2010 was favourably received by the Community Radio sector. In
particular, the removal of the restrictions on licensing Community Radio services that
would complete with very small-scale commercial stations seemed to demonstrate the
growing influence of the Community Radio sector, or at least its increasing ability to
make its voice heard in the government and regulatory circles.
More recently, a further iteration of the Community Radio Order has made its way into
the statute book. The Community Radio (Amendment) Order 2015 (CRAO 2015)
(HMG UK, 2015) heralded another incremental relaxation in the funding arrangements
for Community Radio services, gradually shifting the ground away from protecting the
interests of small-scale commercial broadcasters.
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Although it is not possible to prove a causal link to the introduction of more relaxed
funding controls, by the Summer of 2015 (when this thesis was being completed),
Ofcom was reporting that:
For the first time since 2008, … community radio revenues have
increased. While average (mean) income is up by 0.8%, median
income has increased by 6.9% since a year ago. The average
community radio station income is £55,570, while median income is
£35,750, up £2,500 on 2013 (Ofcom, 2015: 228).
Conclusions
In this chapter, I have traced the development of Community Radio legislation in the
United Kingdom and, in parallel, tracked the gradual change in the attitudes of
politicians and regulators concerning the so-called 'third tier' of radio broadcasting.
It is clear from the historical summary provided, that local influences, such as the
activities of the BBC, along with those of both offshore and land-based unlicensed
broadcasters as well as political campaigners have each, in their own way, influenced the
evolution, scope and form of Community Radio as it exists today. This chapter has also
highlighted the way in which, as far back as the earliest days of Frank Gillard's interest
in local radio, another external influence has also been the international context of
broadcast radio theory and practice.
Of particular note in relation to the title of this thesis, is the changing nature of BBC
local radio since its first arrival nearly 50 years ago. Although the scale of BBC local
radio in England is now based on a countywide model, this was not the case in the late
1960s, when the Corporation's prototype stations tended to be city based, not much
larger than many of today's community-based services.
In terms of content, BBC local radio has also changed considerably over the intervening
half-century with station managers being a great deal less independent in terms of
programming decisions than was originally the case. The days of volunteer presenters
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and niche specialist programmes are long gone and oversight from London has
considerably increased, even to the point of embracing the branding of local stations
(which is now similar across the country).
Much of what early BBC local radio was concerned with, in terms of community
outreach and specialist content has been side-lined in favour of broader, more general,
magazine-style programming and, outside peak listening hours, shared content across
multiple stations. However, I would argue that, in terms of content at least, some of the
earliest seeds of what has today become third sector Community Radio in the United
Kingdom were, in fact, sewn by the BBC when it developed its initial local radio
proposals in the early to mid 1960s. The degree to which some of the early BBC
proposals for local radio are now being delivered by Community Radio services today is,
I would argue a somewhat under-explored issue.
Similarly, commercial radio, which in its early days was charged with the delivery of
clear public service objectives, such as high levels of speech-based output and locally
originated content, has succeeded in escaping such responsibilities in favour of cost
cutting and profit maximisation. Local stations have merged into groups, reducing local
staffing levels, losing local branding and local news and information gathering
capabilities; the links between commercial broadcasters and their local communities are
now less strong than they were in earlier years.
In both cases, the logic of the approach taken may, from an economic perspective at
least, be understandable, but there is no doubt that the diversity of programming
provided has been reduced as a result. For Community Radio broadcasters, this is
perhaps no bad thing; in terms of programme content, the space for Community Radio
services in the United Kingdom is undoubtedly greater today than it was in the past.
Moving on from the positions taken by other radio broadcasters, this chapter has also
examined various approaches taken by campaigners and prospective Community Radio
broadcasters as they too attempted to influence the shape of relevant legislation.
Although such debates had been on going for many years in the abstract, they became
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materially a great deal more important once the prospect of full-time licensing became a
reality.
As this chapter has shown, debates begun in the late 1990s in relation to the Access
Radio Experiment evolved into a long-term process, which has continued in various
forms to date. Often the result of on-going tensions between community broadcasting
campaigners and representatives of the other radio broadcasting sectors, both sides of the
debate have, over time, sought to influence the contents of the subsequent enabling
legislation within the Communications Act 2003 and, thereafter the Community Radio
Order 2004 (as well as the subsequent Community Radio (Amendment) Orders of
2010 and 2015). Although the Community Radio sector has grown considerably since
the turn of the century, in size and, arguably, reputation, it has yet to convince much of
the commercial sector in particular that it is not a threat to their broadcasting business
model.
(16,384)
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CHAPTER THREE:
Theories, Practices (and Policies) of Community Radio
Introduction
In parallel with the practical development and expansion of Community Radio, over the
years, a number of theoretical approaches to the sector have gradually been developed.
These have variously sought to define and conceptualise the practice of Community
Radio and to contextualise it both ideologically and in relation to various social
movements and broader theoretical models.
As discussed elsewhere in this thesis, the development of Community Radio in the
United Kingdom came late when compared to the experience in various other
jurisdictions. Thus, the underpinnings of British Community Radio practice have
always been heavily influenced by pre-existing international theories and practices.
Chapter Two of this thesis highlighted how local factors, such as the scale, diversity and
strength of the pre-existing BBC and commercial radio sectors, also played a key role in
the development of local theory and practice in the United Kingdom. However, the
underlying theoretical perspectives discussed in this chapter are fundamentally of an
international nature.
The exploration of theory underpinning Community Radio practice is, therefore,
supported in this chapter by international examples of their implementation, in varying
degree, through law and regulation. Theory may be implicit in practice, but for licensed
Community Radio, as part of a regulated industry, the degree to which it can be
implemented successfully is, to a large extent, defined by the various legal and regulatory
structures that govern its delivery.
Before examining possible definitions, it is important to re-state the diversity of
terminology that is sometimes used. Community Radio and community media are the
preferred terms in this thesis, however when quoting from the works of other authors
here, they may sometimes prefer to use other terms, such as 'alternative' or 'radical', etc.
The differences between such terms are nuanced and, whilst in some cases such
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differences are nevertheless important, there is usually a considerable degree of interchangeability between them. As an example, one author who uses a different term is
John Downing. Preferring the term 'radical media' (the title of the 2001 book of which
he was lead author), he describes the term 'community' as "fuzzy" (Downing et al.,
2001: 39) arguing that:
Terms such as community media or grassroots media may easily
conceal more than they reveal. They are stronger in what they
exclude - mainstream media - than in what they signify (ibid., 40)
(Emphases in original).
Defining Community
Before exploring the theoretical underpinnings of Community Radio, it is helpful to
seek out some definitions and, to begin with, to contextualise the use of the word
'community' as a constituent part of the term as set out below.
"Community is a fundamentally political concept" (Hoggett, 1997: 14), which,
as a result, "is a continually contested term … fought over by different groups"
(ibid.). Furthermore, what is meant by the term "community" rather depends on the
perspective taken, and "the idea of community is one whose popularity conceals
a multiplicity of meanings" (ibid., 3). As Rosie Niven wrote in an article on the
subject: "when it comes to defining the concept of community, things start to
get trickier" (Niven, 2014).
In spite of the vagaries of its meaning, "[n]owhere is the idea of community more
ubiquitous than in contemporary social and public policy" (Hoggett, 1997: 3).
Thus, examining "the notion of community and the role it plays in
contemporary politics", as Rennie puts it, "is essential to any theorisation of
community media and unavoidable for community media practice" (Rennie,
2006: 1).
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In fact, the term 'community' has always been a contested one, both in terms of
meanings attached to it and of various values associated with it. Since the later years of
the Nineteenth Century, the word has tended to be associated with vague notions of
more cohesive and harmonious times past, which, although they may never have existed,
nevertheless, can be said to exercise something of a hold over the imagination.
From a structural perspective, perhaps one of the earliest academic titles concerning the
term was by Ferdinand Tönnies, who explored concepts of the social organisation of
society in Gemeinschaft und Gesellschaft (Community and Society, 1887) (Hoggett, 1997:
4). As its title suggests, this book noted the inter-relationship between community and
society, suggesting that societies, at various levels, always contain communal elements.
Since that time, as Hoggett has observed:
the use of the term community has remained to some extent associated
with the hope and the wish of reviving once more the closer, warmer,
more harmonious type of bonds between people vaguely attributed to
past ages (Elias, 1974, quoted in Hoggett, 1997: 5).
In general, it remains "a much used yet little understood term" (ibid.). Smith
(2013) observes that its history, specifically in terms of social sciences literature, dates
back only a little over a century:
Before 1910 there was little social science literature concerning 'community'
and it was really only in 1915 that the first clear sociological definition
emerged (Smith, 2013).
Quoting Harper and Dunham (1959: 19), Smith notes that C. J. Galpin developed this
first definition "in relation to delineating rural communities in terms of trade
and service areas surrounding a central village" (ibid.) and that it was quickly
followed by a number of competing definitions. In summary, these can be largely
divided into two main subsets, those that consider community in terms of geography
(community of place) and those that consider community in terms of lived experience
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(community of interest). Although, in practice, there may often be material overlaps
between these two types of community, such cleavage in the definition of the term
remains to this day and is even reflected in broadcasting legislation and regulation,
which may identify these two approaches as equally valid, but often separate, elements
of the Community Radio sector as a whole.
The serendipity of timing between the emergence of academic definitions of community
and the arrival of early radio broadcasting was perhaps fortunate. Radio was the first
medium to allow for the creation of real-time communities of interest, free from
geographical constraint (at least to the extent that the early broadcasting technologies
were capable of delivering). Indeed, as the Science Museum in London notes, the
arrival of the BBC was itself driven through the activities of a particular community of
interest:
The creation of the BBC, Britain’s first national broadcasting service
was the culmination of a highly creative period of experimentation
with radio transmission. In the years following the First World War
many former military radio operators became amateur radio
enthusiasts, tinkering with their home-made sets to pick up
transmissions, and transmitting their own talks or music. They used
radio to share their discoveries, forming a community of fellow
experimenters (Science Museum, 2014).
Smith's article also considers community in the context of political discourse, noting,
again, a range of views: "For some it might mean little more than a glorified
reworking of the market. For others, it may be a powerful organizing (sic)
ideal" (Smith, 2013.). Thus, the concept of community is perceived as being valueladen with the resultant possibility of being adopted in support of particular ideological
perspectives.
Values perceived to be associated with community encompass a plethora of elements.
The term is often associated with nouns such as collaboration, cooperation, interaction,
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involvement and participation, as well as commitment, mutuality, solidarity and trust
(ibid.). At the same time as Tönnies was writing about community and society in
Germany, the early socialist William Morris was writing about 'fellowship' in England
(ibid.), perhaps rather dramatically stating that:
Forsooth brothers, fellowship is heaven and lack of fellowship is hell;
fellowship is life and lack of fellowship is death; and the deeds that
ye do upon the earth, it is for fellowship's sake that ye do them
(Morris, 1887: 29).
More recent definitions of community have attempted to merge the physical and valuedriven elements of the term more cohesively. Because it makes no reference to the
requirement of place, a particularly helpful definition in relation to Community Radio
was published in the early 1980s, defining a community as "an informally organized
(sic) social entity which is characterized (sic) by a sense of identity" (White,
1982: 19). Such social entities comprise not only their members (the people involved);
they must also be backed up by resources, both social and material (social and economic
capital as discussed further below).
On a per-station basis, geographical locality may, or may not, still play a role to a
varying extent, but any community will always include the creation of a social grouping,
which includes interpersonal relationships of one sort or another. This factor forms a
key justification for the use of the term Community Radio. Such stations are
intrinsically based on both an internal social grouping of those running the station
(paid, volunteer or a combination of the two) as well as an external, looser, social
grouping of listeners, which may, from time to time and in varying degrees, interact
with the internal social grouping through over-air or online interaction, sometimes
supplemented by face-to-face social engagements.
What underlies most definitions of community is, in modern day parlance, some form
of networked social interaction. Going back to its perceived values, one of the most
useful ways of thinking about the benefits of community in relation to Community
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Radio is to consider its impact in terms of the potential to enhance 'social capital'.
Roberts Putnam's highly accessible work of 2000, Bowling Alone, puts this term neatly
into a wider context:
Whereas physical capital refers to physical objects and human capital refers
to the properties of individuals, social capital refers to connections among
individuals – social networks and the norms of reciprocity and
trustworthiness that arise from them. In that sense social capital is closely
related to what some have called "civic virtue." The difference is that "social
capital" calls attention to the fact that civic virtue is most powerful when
embedded in a sense network of reciprocal social relations. A society of many
virtuous but isolated individuals is not necessarily rich in social capital
(Putnam, 2000: 19).
Specifically in terms of the media, Peter Lewis notes that the concept of community
"can be traced back to sociological interest in the 1950s" (Lewis, in Lewis and
Jones (Editors), 2006: 26). Observing that this early work contextualised community
"as a defender of traditional values" (ibid), Lewis concludes that the authors of
that research "need not be held responsible for the nostalgic connotations
which attached themselves to "community" over the next few decades, but
they undoubtedly exist" (ibid.).
Considering the term 'community' as it is currently understood, Lewis goes on to
suggest that because "in political discourse the term is unthreatening and
respectable" (ibid.), it can be, diplomatically (in the broadest sense), extremely useful:
The canonisation of "community" by, successively, the N FCB 1,
UNESCO and AMARC (all organisations with a need to represent a
miscellany of interests and present an acceptable policy to the outside
world) can be understood in the same political light even if,
1
NFCB stands for National Federation of Community Broadcasters.
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ostensibly, its usage was claimed to be an indicator of organisational
features such as ownership and control (ibid.).
Defining Community Radio
Simon Partridge suggests that the first explicit (British) use of the term 'Community
Radio' appeared in Rachel Powell's 1965 pamphlet Possibilities For Local Radio
(Partridge, 1982: 10), some months before the BBC's apparent first use of the term.
Published by Birmingham University's Centre for Contemporary Cultural studies and
written at a time of high demand for the introduction of commercial local radio to the
United Kingdom, this paper attempts to "give new depth and detail to the idea of
local radio and shows what could be meant by the imaginative use of
broadcasting within small communities" (preface to Powell pamphlet, quoted in
Mowitt, 2011: 157).
Identifying what constitutes Community Radio is, as touched upon at the start of this
thesis, a somewhat difficult task (see also Jankowski, in Jankowski (Editor), 2002: 6).
Depending on the particular perspective taken, a variety of possible differing definitions
may result. An early example of the diversity of the sector is given by the numerous case
studies provided in A Passion For Radio (Giraud (Editor), 1992 & later extended version
as republished, 2001). Lewis, as a Community Radio scholar with a long-standing
interest in the medium, suggests that part of the difficulty with its categorisation lies in
its roots as part of wider alternative media and is, at least in part, due to one of the basic
justifications for its existence:
Alternative media in any particular place and time are a response to
conditions that threaten cultural identity. These threats take
different forms and consequently elicit different responses (Lewis, 1993:
14).
Although the 'different responses', as referred to above, drive the diversity of the
Community Radio sector, the language used here is also important. Community Radio
is typically representative of cultural identities that fall, to a greater or lesser extent,
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outside the mainstream. As the British legislation that currently governs the sector puts
it, the purpose of such stations is to deliver broadcast radio "to individuals who are
otherwise underserved by such services" (HMG UK, 2004: 2). The particular
'threat(s)' involved may be direct or indirect, overt or covert, depending upon the
specific set of circumstances involved. Sometimes the nature of the threat is simply the
overwhelming strength of the mainstream, an obvious example here being the wish of
minority communities to preserve the use of their own language and culture.
To a certain extent, the type of 'threat' involved and the level of resultant tension define
the level of accommodation that may be found between Community Radio and
government authority. It also explains why in most countries "community
broadcasting did not emerge from explicit government policy, but from
continued pressure and activity" (Hollander, in Jankowski et al. (Editors), 1992:
12).
Although now provided with a dedicated legal framework, the history of Community
Radio in the UK, as previously discussed, clearly demonstrates the resistance of
mainstream politics to the accommodation of minority broadcasting interests. In some
instances, 'pirate' radio broadcasters with community aspirations remain unlicensed, not
only because of the, sometimes exaggerated, problems of spectrum availability and risk
of potential interference, but also because it has not been possible to find a regulatory
accommodation acceptable to both parties.
The government might argue that such broadcasters are unwilling to play by the rules
(in terms not only of broadcast regulation, but also of wider legal compliances in terms
of employment law, copyright, etc.). Conversely however, unlicensed broadcasters may
view offers to accommodate them within the regulated fold as being inadequate (for
example in terms of coverage) or, more broadly, as being incompatible with their wider
objectives. The very small number of land-based 'pirate' broadcasters that have chosen
to apply for Community Radio licenses from Ofcom might be said to provide some
evidence in support of this view.
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Given all of the above, the problem of encapsulating a concise definition of Community
Radio is, understandably, a long-standing one. Kate Coyer notes that even the longestablished, Canadian based, international sector body for Community Radio, the
'Association Mondiale des Radiodiffuseurs Communautaires' or the 'World Association
of Community Radio Broadcasters' and always known by its French acronym, AMARC,
prefers to offer "a diversity of responses from member stations rather than a
broad typology" (Coyer, in Mansell and Raboy, 2014: 170).
Whatever its limits, a 'broad typology' of Community Radio is however useful, if not
essential, when it comes developing a suitable policy framework within which to
accommodate the sector.
That said, there can be said to exist a 'general ethos' of Community Radio, which, at its
most basic level suggests that it should, as Brecht suggested (see Dunbar-Hester, 2014: 7
and also Atton, 2004: 135, quoting Brecht, 1979: 24-28), be considered a tool of
communication rather than of distribution and that such communication should be
conceived of as being bi-directional (see also Carpentier and Scifo, 2010: 115).
Radio Regen, the Manchester based development organisation which has been heavily
involved in the development of Community Radio in the United Kingdom since the
Radio Authority's 'Access Radio' pilot at the turn of the century is blunt in its exclusive
definition: "If a station is being run for profit, or it is being imposed from
outside, then it is not a community radio station" (Fogg et al., 2005: 12).
Prioritising access and development, Regen makes clear its view that:
If a radio station is not offering access to voices which are underrepresented elsewhere, and if a station is not of practical benefit to its
community, it is not a community radio station (ibid.).
Coyer, agreeing with the Regen view, also explicitly identifies the problem of definition:
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There exists no single academic or regulatory definition of precisely
what constitutes community radio, but the basic premise of such
broadcast institutions centres around radio that is not for profit, is
participatory and made for and by a local audience (Coyer, 2005: 129).
Despite AMARC's reticence towards providing a precise definition of what is meant by
the term Community Radio (above), for over two decades now, the organisation has
promoted its own Community Radio Charter (AMARC, 1994), which builds upon
such an underlying ethos (See also Appendix (i)). This stable document, originally
adopted by the organisation's European Branch at its Slovenia Conference, held in 1994
(AMARC 1994 (a)), sets out a number of clear criteria, which Community Radio
services are expected to adhere to. The first three points of the charter clearly highlight
the importance attached to social interaction, development and the recognition of
communities, requiring stations to:
1. promote the right to communicate, assist the free flow of
information and opinions, encourage creative expression and
contribute to the democratic process and a pluralist society;
2. provide access to training, production and distribution facilities;
encourage local creative talent and foster local traditions; and
provide programmes for the benefit, entertainment, education and
development of their listeners;
3. seek to have their ownership representative of local geographically
recognisable communities or of communities of common interest
(AMARC, 1994).
The next three points in the organisation's charter focus on the origins of content
broadcast by Community Radio stations, stressing independence, diversity and accuracy,
requiring that stations:
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4. are editorially independent of government, commercial and
religious institutions and political parties in determining their
programme policy;
5. provide a right of access to minority and marginalised groups and
promote and protect cultural and linguistic diversity;
6. seek to honestly inform their listeners on the basis of information
drawn from a diversity of sources and provide a right of reply to any
person or organisation subject to serious misrepresentation
(ibid.).
The penultimate three points of the charter are concerned with operational and
managerial structures, further requiring that stations:
7. are established as organisations which are not run with a view to
profit and ensure their independence by being financed from a variety
of sources;
8. recognise and respect the contribution of volunteers, recognise the
right of paid workers to join trade unions and provide satisfactory
working conditions for both;
9. operate management, programming and employment practices
which oppose discriminations and which are open and accountable to
all supporters, staff and volunteers (ibid.).
The AMARC charter concludes with an overarching reference to the importance of
communications as a valuable tool within a development framework, encouraging
stations to:
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10. foster exchange between community radio broadcasters using
communications to develop greater understanding in support of peace,
tolerance, democracy and development (ibid.).
Although the AMARC charter of 1994 is the best known set of guiding principles for
Community Radio, its origins can be traced back at least as far at 1979, the year in
which the British campaign body COMCOM (the Community Communications
Group) drew up its Community Broadcasting Charter (Partridge, 1982: 14-15), which,
amongst other things, required stations to serve a defined community, operate on a nonprofit distributing basis, be democratically controlled and provide opportunities for
training and access (ibid.).
The AMARC code is not simply a set of guiding criteria for use by Community Radio
operators. Around the world, legislation and codes of practice relating to Community
Radio broadcasting typically highlight a number of core requirements, which can be said
to broadly define Community Radio services. In many instances, these codes are based,
to a greater or lesser extent, on the AMARC code (above).
Sector representative bodies, such as the Community Media Association in the United
Kingdom, the Community Radio Forum of Ireland (CRAOL) in the Republic of
Ireland, Norsklokalradioforbundet (The Norwegian Local Radio Association) in
Norway and the Prometheus Radio Group in the United States have all adopted similar,
albeit not identical, approaches to help define Community Radio within their particular
jurisdictions.
In some jurisdictions, such as, for example, the Republic of Ireland and the United
Kingdom, AMARC's code has, either explicitly or implicitly, also found its way into
official regulation. In the Republic of Ireland, the current broadcast regulator, the
Broadcasting Authority of Ireland (BAI), which took over from the previous
Broadcasting Commission of Ireland (BCI) in 2009, has adopted its predecessor's policy
of explicitly using the code to define the character of Community Radio services:
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In 1994, the Commission adopted the AMARC Community Radio
Charter for Europe, as a statement of the objectives community
stations should strive to achieve. The Irish experience has reinforced
the relevance of this Charter for community broadcasters in Ireland.
The BCI continues to use this Charter as a reference point when
assessing submissions from, and the activities of, relevant groups (BAI,
2009: 3).
Interviewed for this thesis, Ciarán Kissane, the Head of Contract Awards at the BAI
explained the charter's use in more detail. Irish Community Radio stations:
… operate under the model that's set out in the policy which deals
with community ownership, control, programming, diversity of
funding, you know, the standard type model that most people would
recognise. Very much based on the Canadian definition that goes
back into the 80s, but then was adapted for Ireland in terms of
taking up some of the models for community development that were
very prevalent in the mid 90s (Kissane, 2010).
By comparison, in the United Kingdom, the link to the AMARC code is somewhat less
explicit. Rather than adopting the code as a stand-alone document, the British
Government preferred to build individual elements into its Community Radio
legislation (the Community Radio Order (2004) and subsequent amended versions
thereof). So, for example, the Order requires not for profit operation and the provision
of training (ibid.). In some respects, the Order goes further, requiring full independence
of ownership, not just from commercial interests, but also from other Community
Radio stations. Furthermore, it goes into great detail in terms of setting out mandatory
requirements regarding the delivery of various types of 'social gain' (ibid.), as discussed
further below.
A key justification for making use of documents such as the AMARC Charter is that
such an approach provides a basis for differentiation between the third tier of
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Community Radio broadcasting as compared to the earlier first and second tiers of
public service providers and commercial stations. Where such differentiation is not
enshrined in legislation and regulation, survival can be difficult for community-based
broadcasters, as they can be subject to external pressures that make it hard, if not
impossible, for them to stay true to their underlying not-for-profit, community-focused
ethos. This is particularly the case in relation to competition for broadcasting licences,
because the criteria against which applicants are judged can, for example, be slanted
towards narrowly defined economic 'viability', or in favour of maximising audiences.
Very clear examples of what happens without the introduction of suitable legislation and
the application of specific regulation can be found in both the United Kingdom and the
Republic of Ireland. In 2006, tasked with reviewing the new tier of Community Radio
services by the DCMS, civil servant, Moira Goatley, observed:
While the BBC created an FM local radio service in 1967 with a
community based ethos, the catchment areas were expansive and this
inevitably influenced the dynamics of the service. Horizons began to
expand with the Broadcasting Act of 1972, which introduced
commercial radio and by 1980 nearly 30 independent local radio
stations were in existence. Many of these stations were community
based initially, but commercial considerations soon began to take the
upper hand. The BBC recognising the competing force of the
commercial radio stations began to align its local programming
policies with the new independent stations thereby effectively severing
the link with community development (Goatley, 2006: 2).
Even though early independent radio franchisees, operated under the watchful eye of the
UK's Independent Broadcasting Authority (IBA) were not autonomous commercial
operations, in The Radio Handbook, Carole Fleming argues that, whatever their original
community objectives, they were inevitably subject to major financial pressures:
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because there was no financial support for stations, and no legislation
to prevent them being taken over by commercial groups, most of them
found they had to choose between closing down or being bought out
(Fleming, 2009: 43-44).
Whilst this author questions the community credentials of the majority of the UK's
early commercial stations, there is arguably clear merit in Fleming's subsequent
observation that:
This meant that by the 1980s radio in the UK was increasingly the
reserve (sic) of professional broadcasters aiming to maximise their
audience often to the exclusion of minority groups within their
transmission area (ibid., 44).
However, in the United Kingdom, perhaps the clearest (and slightly more recent)
example comes from the time of the 'incremental radio experiment', which was operated
by the IBA during 1988 and 1989. This scheme aimed to provide "new local
community licences to be issued for a range of niche services serving
particular target interest groups" (Carter, 2003: 23).
Licences were offered in three tranches during early 1989 and, in all, applications were
invited for a total of twenty locations across the country. The first of the incremental
radio stations launched later that year, with the remainder following over the course of
the following year. In the event, 23 licences were eventually awarded and all but one of
the stations made it on air by the end of 1990; "half a dozen went to ethnic
services. Others introduced specialist formats such as jazz and dance music
(ibid.).
Incremental stations were, by the standards of the traditional standards of the IBA,
licensed through a relatively 'quick and dirty' process:
It was a rapid process with all contracts advertised and awarded in a
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matter of months. It set a new blueprint, however, for how future
licences would be issued in the N ineties. Written applications were
followed up with additional questioning by IBA staff rather than face
to face board presentations made to Authority members (ibid.).
Of the various incremental stations launched, some, such as Belfast Community Radio;
Centresound (Stirling); For The People (FTP) (Bristol); Spectrum Radio (London);
Mellow 1557 (Tendring, Essex); Radio Thamesmead (South East London) and WEAR
FM (Sunderland) certainly considered themselves as Community Radio services.
Others, such as Buzz FM (Birmingham); Choice FM (South London); KCBC
(Kettering & Corby); Melody FM and KISS FM (both London) were much more in the
vein of traditional commercial radio broadcasters, albeit with rather less mainstream
programming formats.
Whatever their origins and objectives, almost all of the incremental stations soon found
commercial pressures too great to bear and, just as with some of the first generation IBA
stations (above), ended up surrendering their independence and being bought out by
larger, commercial, broadcasting groups as part of the acquisitions and mergers process
on-going at the time. Whilst the takeover of commercially minded radio stations by
other commercial operators can be regarded as simply standard commercial practice, the
takeover of Community Radio services by for-profit commercial companies, due to the
prioritisation of the profit motive, almost inevitably results in fundamental changes to
the nature of the broadcast radio output provided.
Belfast Community Radio maintained its community objectives until 1996, when it was
taken over by commercial radio operator, Owen Oyston, to become Belfast CityBeat.
Centresound (Stirling) also lasted until 1996, but required investment and back-office
support from the established Edinburgh-based commercial broadcaster, Radio Forth
from soon after its original launch. Another small station at about this time was Stray
FM in Harrogate. Established by a local community-based group in 1994, the lack of
ownership restrictions resulted in local shareholders selling to a nearby commercial
station because the return on their investment was simply too great to resist.
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The various problems encountered by community-based incremental operators were
both evident and, in some cases, very recent, when the Radio Authority introduced its
new Small Scale Alternative Location ('Sally' / 'Sallie') licences in 1996. However, with
no other licensing opportunities open to them, various community groups tried once
again to launch new services, once again under commercial radio licensing rules.
Perhaps not surprisingly, the results were similar to those that occurred under the
former regulator's 'incremental radio experiment', with many independent Sallie
stations being taken over and merged into commercial groupings.
Although both incremental radio and the subsequent 'Sallie' schemes did little for
Community Radio and in the case of many of the individual stations involved, ended in
failure, there was nevertheless a silver lining to these experiments. Demonstrating as
they did the high demand for alternative forms of local radio outside the commercial
mainstream, they also provided clear evidence that existing commercial radio regulation
was fundamentally unsuitable for such community-based approaches. For campaigners
and regulators alike, by the end of the 1990s, it had become abundantly clear that, for
Community Radio to be established successfully in the United Kingdom, some form of
separate policy and regulatory oversight would be an essential prerequisite.
Meanwhile, in the Republic of Ireland, a similar situation had arisen. As Ciarán Kissane
observed, prior to the introduction of specific Community Radio focused regulation,
early Community Radio services, not specifically licensed as such, were:
… trying to compete with commercial operations on a commercial
pitch and that was very difficult. So, you know, what they were
expected to pay in terms of royalties and in terms of providing a
service, you know, they won the contracts on the basis of providing a
full service programme offering, you know, including 20% news and
current affairs, self generated, including, you know, significant
current affairs across the day, seventeen, eighteen hour programme
schedules, you know, you had to hire a core staff.
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model, they just could not sustain that without saying, "well, we need
to bring in revenue too, [and] that the only source of revenue was
advertising" (Kissane interview, 2010).
Strict regulation of Community Radio is, however, by no means universal. In Norway,
for example, where local radio in general was only fully introduced in 1988, the
regulator refers to Community Radio as "niche radio". Interviewed for this thesis, Arve
Lindboe at Mediatilsynet (the Norwegian Media Authority) explained that, to begin
with "there were applicants for any kind of radio, [with] any kind of
commercial or non-commercial background" (Lindboe interview, 2010) and that
these were simply judged against broad "local content ambitions" (ibid.). Over time,
the rules have tightened such that "the regime today is based on the need to predefine [the] possibility to make the radio project reliable enough to produce
content for the community" (ibid.). Whilst the Norwegian regulator does require
that "niche radios have limitations concerning economic activity" (ibid.), the
overall regulatory approach is one with a light touch. Lindboe's colleague at
Mediatilsynet, Lars Erik Krogsrud, also interviewed for this thesis, explained:
the kind of philosophy here is that the niche radios, in itself, will
provide for the pluralism, as long as you let them loose, so to speak
and then there are not many hard demands to get them on the air.
It's basically about showing that you have some economy and that you
have some skills, some competence in radio or, yes, yes, radio skills.
So, if you have that and you want to come on the air in an area that
is not full of radio from before, you have, pretty much, a good
possibility to get on the air (Krogsrud interview, 2010).
Listening to Community Radio in Norway, it is often not so easy to identify a strong
strand of community involvement. Some stations, such as Radio Nova, the university
student radio station in the capital city, Oslo, would be immediately recognisable as
community services, others, particularly in remote and sparsely populated rural areas can
be highly automated with little or no content beyond pre-recorded music. A lack of
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clear and detailed policy specifically aimed at enhancing the sector's community
involvement means that this is perfectly permissible under current Norwegian
broadcasting regulations.
Although the history of Community Radio in the United States in one of the longest,
small-scale, community-based services there are by and large a relatively new
phenomenon. Referred to as Low Power FM (LPFM), these services are a relatively new
arrival on America's airwaves, the sector being established broadly in parallel with
Community Radio in the United Kingdom (see Coyer, 2006: 130-142).
Perhaps unsurprisingly, in many respects, the Federal Communications Commission
(FCC) in the United States takes something of a light touch approach to the regulation
of these services. Nevertheless, the influence of international consensus, as driven by the
existence of documents such as the AMARC charter, is still evident. Interviewed for this
thesis, Peter Doyle, Chief of the FCC's Media Bureau Audio Division, set out some of
the unique licensing criteria that are applied to the LPFM sector:
We have a couple of licensing rules that are unique to this service,
one of them is the fact that, well I call it, it's a one to a customer
service, meaning that no entity can hold more than on low-power
licence in the nation and that prohibition extends to board members,
so that, for example, someone could not serve on a board, or a
governing body, wherever the locus of decision making is in that
entity of more than one low-power station, or, for that matter, on a
low-power station and any kind of other radio station. There are
very restrictive rules on the assignment of stations, they can be sold
essentially for depreciated value, there's no profiting on the sales and
we require applicants to be local, which we define in one of several
different ways. A school would be local where the campus is, if three
quarters of your board members live within 25 miles of the station,
we'd also consider that local (Doyle, 2009).
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Although it may not always do so as explicitly as it does in the British Community
Radio Order, as referred to above, legislation, regulation and practice in relation to
Community Radio are often concerned with the enhancement of 'social capital' through
the delivery of 'social gain' or 'community benefits'. Here, the core concern of
politicians and practitioners alike is often not only about 'improving' the lot of
particular communities but also, it is often concerned with differentiating Community
Radio from other forms of radio broadcasting as well as creating clear justifications for
its existence and support.
The American example of LPFM (above) is a clear case in point. The campaign to
introduce LPFM in the United States has clear parallels with the British experience.
Strong opposition from incumbent (commercial) operators, represented in particular by
the National Association of Broadcasters (NAB), successfully delayed and restricted the
launch of LPFM for several years (see Dunbar-Hester, 2014: 15-18), frequency scarcity
and interference risks being the major issues raised in defence of maintaining the status
quo.
As discussed in more detail elsewhere in this thesis, spectrum availability is an almost
universal issue for Community Radio operators. Because of practical issues such as
frequency planning and the importance of avoiding radio frequency interference issues,
as well the existence of less concrete, broad concerns in the area of content oversight,
broadcast radio also has to operate, to a greater or lesser extent, under some degree of
unified regulatory oversight. As has already been noted, there is a competitive edge to
the regulation of frequencies and so it is within such contexts that "the battles over
community access have been fought out" (Rennie, 2006: 4):
Community broadcasting requires that spectrum is set aside for
community purposes. In doing so, governments must endorse
"community" as a sphere of activity outside of the state and economy
that [nonetheless] requires attention, status and resources. Through
this process, communities are named and validated - named as having
a substantial interest, if not a right, to broadcast (ibid.).
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The 'validation' and recognition of communities through the granting of access to
broadcasting spectrum highlights an implicit tension between the relatively ridged
structures of administration and regulation in comparison to the more flexible and
dynamic ways in which individual communities may behave.
Community broadcasting sits at the intersection of the
administratively controlled broadcasting environment (having to
comply to license (sic) conditions and regulation) and the more
random, messy, and "natural" configurations of the community
sphere. In many respects, the institutionalization (sic) of community
media is a means to manage something that has previously managed
itself and this creates a set of dilemmas that are unique to community
media (ibid., 25).
The 'dynamic' of communities means that they can sometime evolve and change more
quickly than bureaucratic models are able to cope with. Providing one community with
the opportunity to broadcast many also encourage other community elements to do the
same. A good example here might be the arrival of Community Radio services in
Belfast, Northern Ireland during the first decade of this century and of which the author
has personal experience through his prior work with both the Community Media
Association and Ofcom.
From the outset, nationalist (broadly Catholic) elements were well ahead here, quickly
launching an Irish language station, Raidió Fáilte (Welcome Radio), as well as a
geographic community-based station, Féile FM (Festival FM), both based in West
Belfast. Soon after both these services launched, Ofcom began to receive various
enquiries from unionist (broadly Protestant) community groups wanting to develop
similar services of their own, both language (Ulster-Scots) and geographical communitybased. Having missed the Ofcom imposed licensing window, these prospective station
operators had to wait for subsequent licensing opportunities and to hope that the
regulator would be able to find what it deemed suitable frequency resources on which
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they might operate. As an aside here, at the time (mid 2000s), it was remarkable to see
the degree to which Féile FM, in particular, began to increase levels of cross-community
involvement as a direct result of interest coming from the other side of the community
divide.
As has been shown (above) the 'community' element of Community Radio, as well is its
broad-ranging objectives, can lead to difficulties in relation to its accommodation within
wider broadcasting policy structures. Rennie identifies this tension and suggests that
suitable policy approaches must include elements originated from both sides of the
regulatory divide:
There is a constant tension between who should gain access, what
level of editorial control stations should maintain, and how to
determine whether stations are representative of the community their
license (sic) was intended for. It is these qualities that make
community media a unique object of study and why it is that
community media not only requires but brings with it alternative
policy approaches (ibid., 25) (Emphasis in original).
From Practice to Theory
As previously mentioned, theory is implicit in practice. However, practitioners
themselves rarely explicitly consider the theoretical underpinnings of their work, leaving
such consideration to academics. Practitioner academics and academic practitioners do
exist, but only as exceptions to the general rule. In the case of Community Radio, its
various theoretical underpinnings were not explicitly defined at the outset. The earliest
operators of examples of what is now considered to be Community Radio, such those
that began in the late 1940s in Columbia and Bolivia (Dagron, 2001: 14 & 16), as well
as the Pacifica Network in the United States (Rennie, 2006: 64-66 and, more generally,
Lasar, 2000), undoubtedly knew that what they were doing was outside the mainstream,
but would probably not have been able to articulate a detailed theoretical underpinning
of their activities.
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The same might be said for the majority of today's practitioners, the difference being
that there is now what might best be described as a Mobius loop of practices, policies
and theories, each informing the others and gradually building deeper and broader
understandings of the sector's activities and objectives. Various theoretical models
attempting to reflect Community Radio practice have emerged over the intervening
years, but as with any developing practice, they must continue to evolve if they are to
reflect the growing history and diversity of the sector.
Diversity of Theoretical Approaches
Given the diverse nature of Community Radio in practice, it is perhaps inevitable that
theoretical approaches to the practice of Community Radio broadcasting (and to
community media more broadly) are many and various (see also numerous
contributions to Jankowski (Editor), 2002). Originally drawn from a range of
underlying academic disciplines (such as development studies, education, politics and
sociology), they have often emerged at the intersections of such disciplines.
Unsurprisingly, the discipline of media studies offers a useful place to start examining
theoretical approaches to Community Radio. In fact, as Kerrie Foxwell points out, it
has been responsible for some of the key framing of understandings of Community
Radio:
Broadly, the key theoretical debates within media studies can be
distinguished by the distinctive approaches associated with political
economy and cultural studies or structuralist and post-structuralist
analyses of the media. Despite the relatively late entry of community
media into media studies, these more traditional debates have
impacted on the ways in which we understand community radio's
function and purpose - within communities, the media and society
(Foxwell, in Gordon (Editor), 2012: 135).
The lateness of theory's arrival in relation to Community Radio is notable. As recently
as 2008, Jonathan Hardy produced the eminently readable title, Western Media Systems
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(Hardy, 2008). Despite his inclusion of specific chapters concerning media theory and
media policy, as far as this reader can see, the author makes no mention of Community
Radio, or even of wider community media as a whole. As Ellie Rennie observes:
Community media has received surprisingly little scholarly attention,
even within the field of media studies itself. If anything, this
deficiency reinforces the assumptions of marginality that surround
community media (Rennie, 2006: 16).
Also noting the fact that "theory was slower than practice in developing" (Lewis,
1993: 21) and using the wider term of 'alternative media', Lewis suggests that particular
theoretical approaches:
can be situated on the axes of specifically communication-oriented
debates, and encountered in other discourses such as those of
development and education (Lewis, 1993: 16).
Providing various examples, such as Paulo Freire's education-based 'conscientisation'
approach, "which aims to create an alternative, more authentic set of
perceptions about the social reality experienced by those taking part" (ibid.)
and development-based conceptions around participation in which "small-scale
media enables people to formulate their own definitions of needs and goals"
(ibid.), Lewis also links the typically small-scale nature of alterative media to McLuhan's
concept of the 'global village', arguing that the term "has been (mis)appropriated to
sell the idea of a global market" (ibid.)
Although radio for development and social change in particular, has a long tradition as
an important strand of Community Radio practice (see, for example, the wide variety of
case studies in Dagron, 2001), in terms of theory, Lewis particularly highlights the
concept of the public sphere "as an important reference point for contemporary
discussion of democratization (sic) in communications" (ibid., 7-8).
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Part of the reason why the theories of Habermas concerning the public sphere are
considered relevant to Community Radio is because of what Paddy Scannell describes as
his "two fold 'distrust of representation'" (Scannell, also quoting John Durham
Peters (1993), 2007: 256). Scannell describes Habermas as having "a deep rooted
suspicion of politics as a theatre on whose stage the powers that be represent
their authority" (Scannell, 2007: 256) and as rejecting "representative democracy
in favour of direct, participatory democracy" (ibid.). A particular problem
identified by Habermas is the sheer scale of mainstream mass media, which, he
suggested, results in "the public sphere [being] swamped by a media flow
passively absorbed by a massified [sic] public" (Outhwaite, 2009: 103).
Community Radio, typically small in scale and participatory in nature, provides an
alternative to such mass media, albeit to an intrinsically limited degree.
The range of theoretical paradigms within which it is possible to frame Community
Radio is, of itself, problematic. Depending on the theory through which the
phenomenon is viewed, particular aspects of its practice will either be highlighted or,
conversely, will assume minimal importance (if they are not ignored entirely).
Furthermore, the particular theoretical approach applied may bring with it a particular
set of inherent value judgements, which could affect the research approach taken, to the
detriment of developing the broadest possible overview and understanding of the subject
matter at hand. To give a generic example, considering Community Radio from a
developmental perspective will, inevitably, mean viewing its objectives in relation to
achieving changes through challenges to the status quo. However, viewing Community
Radio as part of the Habermassian public sphere will, equally inevitably, prioritise
consensus building over conflict.
What is needed, therefore, is some common ground on which to build both theoretical
foundations and, subsequently, appropriate policy frameworks to best ensure such
theory can be applied in practice. In their article entitled Community Media's Long
March, Nico Carpentier and Salvatore Scifo suggest that this basis can be found in the
participatory nature of Community Radio and its potential to transform "radio as a
tool of distribution into a tool of communication" (Carpentier & Scifo, 2010:
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115). Pointing to "the UN SECO debates in the 1970s about the N ew World
Information and Communication Order (N WICO)" (ibid., 116) they note that
"at the centre of these debates was the right to communicate" (ibid.).
As Skinner et al. note, "the McBride Commission's endorsement of the right to
communicate" (Skinner et al. (Editors), 2005: 257) was politically problematic,
causing:
The most vocal advocates of neo-liberal thought at the time, Ronald
Regan and Margaret Thatcher [to go] so far as to withdraw their
countries from UN ESCO in the mid 1980s (ibid.).
However, despite such issues at the highest level, in parallel, the concept had gained
considerable traction, such that the 1980s also:
saw the entrance on the international scene of "grassroots"
organizations (sic) that made it their goal to promote the right to
communicate. These included the World Association of Community
Radio Broadcasters (AMARC) (ibid.)
That 'right to communicate', linked to the long-established concept of radio as 'a tool of
communication' provides, therefore, a clearly defined point, or intersection, at which
the theory and the practice of Community Radio can be said to converge. More
specifically, that common ground can be identified in the requirements set out in the
AMARC charter (as examined above) and which clearly attempt to build an effective
basis for delivering the right to communicate in practice.
Since AMARC's foundation in the 1980s, theories of alternative media (including
Community Radio) have coalesced around concepts such as the right to communicate.
A particularly useful overview of such theories is to be found in Bailey, Cammaerts and
Carpentier's volume Understanding Alternative Media (2008), which explicitly states
that: "A promising starting point for the analysis is given by the working
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definition of community radio adopted by AMARC-Europe" (Bailey et al.,
2008: 6).
The first section of this book, 'Theorising Alternative Media', begins with a chapter
entitled 'Four Approaches To Alternative Media' (ibid., 3-34). Although preferring the
term 'alternative' to that of 'community', the authors nevertheless use Community Radio
as a starting point "a form of local public service type broadcasting, one which
is independent of both state and major commercial interests" (Buckley, quoted
in AMARC / Ruddy (Editor), 1994 (a): 9), and note the "semiotic diversity" (Bailey
et al., 2008: 7) in the variety of ways in which the sector can be described. The authors
take the view that the various terms are by no means mutually exclusive and that this
"shows the diversity of identities and practices" (ibid.) present in the sector.
Bailey et al. begin from the premise that:
to understand (the importance of) alternative media we need to
situate them in the political and democratic theories that have
provided theoretical and intellectual support for their identities and
practices. The participatory models of democracy and the related
broadening of the definition of the political especially have
influenced and cross-fertilized [sic] alternative media (ibid., 4).
Taking the view that "the political is approached here in a broad sense and not
restricted to a specific sphere or system" (ibid.), the authors suggest that:
it follows that the political cannot be reduced to the formal political
system, to institutions or to political procedures. Such a perspective
on the political sees the whole of society in its different aspects - the
school, the family, the workplace, the community and (alternative)
media, as equally valid spheres for political-democratic activities. At
the same time, this widening of what constitutes the political allows
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for the accommodation of sexual, gendered and cultural identities
and struggles within the democratic project (ibid., 5).
Even within such a wide-ranging context, Bailey et al. note that alternative media "are
at the same time characterized by diversity and contingency" (ibid.).
The four theories of alternative media are examined by the authors in some considerable
detail and are summarised briefly below. Three of the four theories are largely selfexplanatory, although the fourth, 'as rhizomatic', is, perhaps, a little less immediately
accessible.
1.
Serving a community
Observing that this approach "uses a more essentialist theoretical framework"
(ibid., 6) than the others (below), the authors focus here on the opportunities that
Community Radio provides in terms of 'access to' and 'participation in' the media by
members of the particular target community concerned. Further distinguishing between
'participation in' from 'participation through' the media, they suggest that alternative
media is structured in such a way as to make it particularly competent in terms of
providing "deeper forms of participation" (ibid. 11) than can be found in
mainstream media.
2.
An alternative to mainstream media
Two types of 'alternative' are considered here. Community Radio may simply be
considered as an addition to mainstream media, or, it can provide more overt challenges
to it. Such challenges are fundamentally about "the relationship between media
and representation" (ibid., 16) and are key, as a justification for the existence of
alternatives to mainstream media:
one reason for the very existence of alternative media is to voice the
'ideologies' of those under - or misrepresented in the mainstream
channels of communication (ibid.).
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At the level of content, alternative media, including Community Radio "can offer
ideologies, representations and discourses that vary from those originating in
the mainstream media" (ibid., 18). However, content output is not the only element
of Community Radio that can be considered as an alternative to the mainstream. The
ways in which Community Radio content is produced, in terms of inputs, processes and
structures, can also be different. For example, structures in alternative media tend to be
less hierarchical and to eschew some of what are often considered to be professional
techniques in favour of experimental approaches.
Thus these media … can rightfully be seen as a breeding ground for
innovation, often to be eventually adopted by mainstream media
(ibid., 20).
3.
As a link to civil society
Community Radio being deliberately established to be largely separate from state and
market actors, it must, nevertheless, be a part of civil society, even though the notion of
civil society itself is "highly contested" (ibid.), it should "not be conceived as being
necessarily separate from, independent of, or in opposition to the state or
market at all times" (ibid., 22). Community Radio, along with wider alternative
media, can be recognised not only as part of civil society, but also as a contributor to it,
through the provision of opportunities for participation and self-representation, which,
it is argued, can maintain and even strengthen the operation of broad democratic
structures (ibid., 25).
4.
As rhizomatic media
The concept of the rhizome, as it relates to forms of alternative media, can be thought of
as a kind of 'catch all', encapsulating a diverse range of activities engaged in by them. As
Bailey et al. suggest: "Like rhizomes, alternative media tend to cut across
borders and build linkages between pre-existing gaps" (ibid., 28). Such
connections are established not only within civic society but also reach towards both the
state and the market (ibid.). Equally importantly, the types of linkages developed by
Community Radio and wider alternative media can be recognised as both bi-directional
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and responsive, adapting to changing circumstances and requirements. Within the
concept of rhizomatic media, the Community Radio station remains structurally
independent but highly integrated with, not just its target community, but also with
wider society. Responsive to the needs of its community, rhizomatic media also seeks to
benefit that community through the development of external linkages.
What is clear from the various approaches taken by Community Radio is that each of
the four theories set out by Bailey et al. have relevance to its practice. Because of the
wide variety of practice that the sector engages in, the relevance of one or other theory
may vary on a case-by-case basis but, overall, some relevance will tend to be present. As
the authors themselves conclude:
Alternative media research has a long theoretical and empirical
tradition that has tried to capture their identity. Due to the
complexity and elusiveness of this identity, this project has proven a
very difficult task. For this reason a multi-theoretical approach is
preferred, combining essentialist and relationist positions within the
general framework. … N one of the four approaches … can be
considered as giving a sufficient overview when applied independently
… the only way to capture the diversity that characterizes (sic)
community media is the simultaneous application of these approaches
(Bailey et al., 2008: 30).
Conclusions
In this chapter, I have attempted to explore the history and contested nature of the term
'community', in particular as it relates to Community Radio, itself a term which brings
with it a diverse range of definitions and concepts. I have also sought to demonstrate
the international origins of the sector as these have evolved since the middle of the
Twentieth Century.
At the core of this chapter is an exploration of the complex entanglement between the
development of theory and practice as it relates to the operation of Community Radio.
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As it typically operates within forms of regulated broadcasting environments, I have also
examined how both theory and practice have influenced the emergence and
implementation of specific regulatory policies designed to ensure the effective delivery of
Community Radio services as a distinct sector within wider radio broadcasting.
In particular here, I have sought to highlight the way in which early non-mainstream
broadcast radio practice, what would now be recognised as Community Radio practice,
led to the creation of a policy void, which required the development of relevant
Community Radio theories before it could be filled with appropriate policy levers and
regulatory approaches.
This chapter has also highlighted the international nature of the Community Radio
sector today and, in particular, the effectiveness of AMARC in building a cohesive
concept of the medium, recognised in various ways by numerous governments and
regulatory bodies around the world.
In discussing the theoretical underpinnings of Community Radio, this chapter has
explored the history, from adaptations of pre-existing theories in other fields to more
specifically targeted multifaceted approaches. The way in which theory seeks to
accommodate the diverse nature of the sector is also highlighted.
In terms of influencing policy development, it is practice that has demonstrated the
viability of Community Media and theory that has provided multiple justifications of
such practices and, consequently, assisted with their encapsulation into policy. The final
word here on the interconnected roles of theory, practice and policy, goes to Peter
Lewis, who recently observed that:
…the role of the academic community should not be overlooked. The
growing volume of international attention and research translated
into a new wave of published studies of community media on both
sides of the Atlantic around the turn of the millennium … all of
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which contributed to a discourse that promoted community radio to a
matter of public debate (Lewis, in Atton (Editor), 2015: 182).
(9,395)
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CHAPTER FOUR:
Methodology
Introduction - Community Radio Research
The preceding chapters of this thesis have shown that, in terms of both practice and
theory, Community Radio services differ markedly from Public Service Broadcasting
and from for-profit commercial radio broadcasting. As has been shown, not only do
such differences encompass the history and objectives of the various radio broadcasting
sectors, but that they are also evident in the makeup of the various operational inputs
and outputs involved, as well as through the ways in which each type of broadcaster
interacts with wider society.
A fundamental difference between community-based services and their, typically larger,
PSB and commercial 'competitors' is the enhanced granularity of their individual
listenerships. The unique nature of each community broadcaster and its relationship
with its target audience is fundamental to the sector and, inevitably, impacts upon the
way in which it can be researched.
When it comes to planning and defining research into Community Radio, the relative
diversity of the sector is a critical factor, which needs to be taken into account. It
follows that the study of individual examples of community broadcasting requires
careful planning if it is to yield conclusions that have wider relevance to the sector as a
whole.
The research in this thesis employs a range of qualitative research methods, which are
summarised later in this chapter. The diversity between individual case studies
exhibited by the Community Radio sector is something that qualitative research
methodologies are specifically designed to take into account. As Uwe Flick points out:
[q]ualitative research is of specific relevance to the study of social
relations, due to the fact of the pluralization [sic] of life worlds. …
Locally, temporally, and situationally limited narratives are now
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required. … Rapid social change and the resulting diversification of
life worlds are increasingly confronting social researchers with new
social contexts and perspectives (Flick, 2009: 12).
Another fundamental difference between Community Radio and other forms of radio
broadcasting is the degree of participation, which is intrinsic to its operation, the use of
volunteers (see for example Ofcom, 2010 (b)), community links and interactions, etc.
As explained later in this chapter, participation is, to a degree, carried forward into this
thesis by the author. However, "[t]he concept of participation has been subject
to lengthy debates regarding its historical origin, its theoretical grounding
and practical applicability, and its critical connotations" (Mikkelsen, 2005:
53), such that it requires narrower definition in the context of this thesis.
The approach taken in relation to participation in this thesis is drawn from the field of
development studies. Although, at first glance, this might not appear to be particularly
relevant to the field of media (broadcast) study, in fact, specifically in relation to
Community Radio, the linkage between these two disciplines quickly becomes apparent.
Beyond on-air broadcast outputs, Community Radio in the UK is obligated to deliver
'social gain', 'access', 'participation' and 'accountability', in relation to its target
community (Ofcom, 2012 (a): 4-6), objectives which, overall, are designed to benefit
members of that target community. Put another way, the UK's Community Radio
legislation is, arguably, as much (if not more) about development as it is about
broadcasting.
Within this thesis, the definition of participation is one of an "empowering process"
(Mikkelsen, 2005: 54), within which some of the research participants, through semistructured interviews in particular, contribute to the analysis of their own projects,
bringing their own opinions, thoughts and ideas to the debate.
As will be seen throughout the rest of this chapter, the approach taken to researching
Community Radio is about much more than the broadcasting element of the sector's
activities alone. The developmental elements of Community Radio delivery are equally,
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if not more, important in defining the 'place' of the sector within the wider broadcast
ecology and society as a whole.
Community Radio - The International Research Context
The context that the wider radio broadcasting industry and its history have provided as
foundations in relation to the development and introduction of Community Radio in
the United Kingdom has already been explored earlier in this thesis. Governments,
regulators, established broadcasters, as well as other interested parties typically hold
particular and often firmly entrenched views as to the relative merits of different forms
of radio broadcasting. As evidenced earlier in this thesis, fundamental concepts
underpinning the theory of Community Radio have international roots. As a result,
these views take into account not only localised factors and self-interest (enlightened or
otherwise), but also wider, internationally established, concepts and norms.
As discussed earlier in this thesis, beyond theoretical concepts of Community Radio,
there exists also a strong international evidence base that demonstrates how the accepted
broad principles of Community Radio have been delivered in practice over a number of
decades. With a particular focus on the role of regulation and how this impacts on the
content and delivery of Community Radio services, chapter two of this thesis provided
examples of the relative position of Community Radio in differing jurisdictions. The
example comparator jurisdictions referred to in this thesis (the Republic of Ireland,
Norway and the United States of America) show how such practice can vary, according
to the particular local context involved.
Thus, international comparators, by their very nature, can only provide part of the
context for Community Radio in a specific jurisdiction. Individual jurisdictions each
have their own unique set of economic, social and cultural variables, which must,
inevitably, influence the design and implantation of media policy in general and, in
relation to this thesis, of community broadcasting in particular. Although the ethos and
underlying principles of Community Radio may exhibit considerable similarity
internationally, the specific values and purposes of the sector will, to some extent at
least, be jurisdiction specific.
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In the case of Community Radio, advocates promoting its introduction within the
United Kingdom were, from the late 1960s onwards, able not only to draw upon
established theory but also, increasingly, a diverse range of practice from a variety of
jurisdictions around the world. Being a relatively 'late adopter' in the field of
community-broadcasting meant that campaigners and later, politicians and regulators in
the UK, were able to adapt and adopt various elements of theory and practice from
other jurisdictions, in order to build Community Radio structures suitable for use
within the British broadcasting environment.
Primarily, for reasons of broad cultural affinity, it was influences from North America,
Western Europe and Australia that tended to be the predominant examples drawn upon.
This was not merely a subconscious process or one carried out solely by academics for
academic purposes. At least in part, pre-existing international constructs were
deliberately sought out to help inform the legislative design process, as in the case of the
work by Eryl Price-Davies and Jo Tacchi in 2001, which was specifically commissioned
for the purpose of identifying pre-existing international practices that might be
adaptable for use in the UK (Price-Davies & Tacchi, 2001).
Community Radio Research - UK Specific Considerations
Throughout the 1970s and 1980s, international theory and practice, increasingly
supplemented by local experience, gradually enabled proponents of Community Radio
in the United Kingdom to articulate a concept of Community Radio within the specific
context of a country already (and increasingly) served by established public service and
private commercial radio broadcasters (BBC & ILR).
In the vast majority of jurisdictions where licensed Community Radio has been
introduced, it has tended to be subsequent to the provision of public service and private
commercial radio. Sometimes, as in the case of Ireland, the gap between the launch of
individual sectors was brief. Although commercial stations and community services
there were both given the go-ahead in the same legislation (Oireachtas, 1988), the then
regulator (Independent Radio and Television Commission - IRTC) prioritised the
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introduction of private commercial stations ahead of community-based services (Day,
2009: 35-36).
In the UK, the gap between the introduction of public service radio and licensed
commercial stations was some 45 years and it was then more than 30 years later that
permanent community-based radio services were finally legislated for. As a result, a
highly diverse range of public service and private commercial stations was firmly
established by the time permanent Community Radio services were finally introduced in
2004.
The presence of so many existing radio broadcasters by the turn of the century meant
that, arguably, the technical, spectrum planning and allocation, capacity for the
introduction of additional services (of any sort) had become considerably limited. In
parallel, existing commercial broadcasters, in particular, were extremely concerned that
the arrival of Community Radio would provide unwanted competition and impact
adversely on their profitability.
Whilst the actual limitations on spectrum availability and the degree to which, in reality,
Community Radio services might impact on the viability of existing radio services might
be contested, what is not in doubt is that such concerns were strongly reflected in the
first version of British permanent Community Radio legislation, the Community Radio
Order (2004) (HMG UK, 2004). This secondary legislation, enabled under the
Communications Act (2003) (HMG UK, 2003) and, later, its subsequent iterations, the
Community Radio (Amendment) Orders (2010) and (2015) (HMG UK, 2010 and
HMG UK, 2015), defines the political and regulatory framework within which
Community Radio in the UK is expected to operate - in short, it defines (and
constrains) a concept of the place for Community Radio.
Research Questions - In Summary
As the title of this PhD thesis suggests, the core issue, which the author seeks to explore,
concerns conceptualisations of the 'place' for Community Radio. What might its
purpose be and where might it fit within the wider cultural and broadcast radio
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environments - how is it situated? Why might this be the case and what does this situation
imply for the sector?
As set out above, Community Radio is typically situated within legislative and
regulatory frameworks, as well as within a set of international norms and conventions.
However, it can be further situated, not only in relation to the activities of the other two
established main forms of radio broadcasting (public service and private commercial),
but also, more broadly, within the specific communities it seeks to serve and within
wider society as a whole.
It should be noted that this PhD thesis does not seek subjectively to 'rank' or prioritise
different types of radio broadcasting, nor does it seek to attach differing degrees of
perceived 'importance' to the outputs of each sector. What it does seek to do, is to
illuminate any potential 'additionality' that might be provided by the Community
Radio sector, not only within the narrow terms of its broadcast outputs, but also in
terms of the wider social benefits that it seeks to deliver.
Research Questions - Development
The issue of place for Community Radio goes well beyond matters of resource allocation
within a crowded media and broadcasting environment. What 'role', or roles, does
Community Radio seek to fulfil and to what degree are these delivered in practice?
Once identified, can such roles be considered to justify the existence of Community
Radio services?
Because examining the position of Community Radio is central to this thesis, it follows
that, as a first step, it is necessary to define the particular ways in which it can be
situated in terms of the research being carried out. As set out below, the 'position' of
Community Radio can be defined in a variety of ways. Positioning can be considered in
relation to other broadcasters as well as in relation to other community organisations. It
can also be considered in the context of political and regulatory support provided, and
in terms of the resource base made available to it.
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Beyond such instances of relative positioning, there are also more abstract positions, or
'roles' to consider for the sector. The place for Community Radio needs also to be
considered, not only in relation to how its processes, inputs and outputs impact on the
communities it seeks to serve, but also in terms of the degree of integration achieved
within those communities.
The author concurs with the view of Zane Ibrahim, the founder of Bush Radio, one of
the most long-standing, prominent, Community Radio services in South Africa, who
often made the point that "Community radio is 90 percent community and 10
percent radio" (Ibrahim, 2004, quoted in Coyer, Dowmunt & Fountain, 2007: 113
and in Mansell & Raboy, 2014: 169). With this perspective in mind, how Community
Radio is situated within the context of community involvement can be recognised as a
key element of this research. Community involvement is a broad, multifaceted term
and its implementation will vary from station to station and community to community.
However, it is the author's belief that it should be possible to obtain useful insights into
broad elements of practice and to learn about elements of sectoral knowledge from the
individual examples studied during the course of this research.
Aside from the broad issues of community involvement, there are also key elements of
broadcast practice to explore. A further essential step for this research is therefore
concerned with the triangulation of the three main types of radio broadcasting in terms
of overlap and separation. This can be envisaged in terms of multiple Venn diagrams,
each exploring particular interactions between the differing radio broadcasting sectors.
Such consideration of the three sectors of radio broadcasting examines not only
broadcasting outputs, but also particular operational inputs and elements of the
regulatory frameworks within which each one operates.
Having positioned the three sectors in relation to each other, it then becomes possible to
consider examples of how two or more of the sectors might compete and under what
circumstances they might be able to collaborate for mutual benefit. Tensions between
the sectors, as well as their potential impacts, can be explored in relation to the on-going
development of Community Radio services.
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The primary purpose of positioning and triangulating Community Radio within the
wider broadcast radio environment is to identify specific relative strengths and
weaknesses of the community sector - what might it do better than other broadcasters
and what might it be poorer at? More importantly, in terms of academic research, how
and why might this be the case? Identifying what the community sector does well
allows for an exploration of justifications for its existence, which may help justify its
position, or 'place' within the wider media environment. Conversely, weaknesses in
current Community Radio structures, once identified, can be evaluated and possible
alternative approaches considered.
The broadcasting environment is by no means static. Thus, research into broadcast
radio needs to take into account on-going trends in society and, more specifically, in the
delivery and consumption of audio content. At the macro, level, such changes can
involve alterations to levels of support provided, or in terms of the regulatory
environment within which the sector operates.
A specific area of interest to the author concerns the issue of broadcasting spectrum and
the technologies used to deliver programme content. Over recent years, this has become
a contentious issue, not only in terms of access to broadcast radio spectrum, but also in
relation to changing patterns of media consumption and the gradual, albeit sometimes
exaggerated, impact of Internet-based delivery mechanisms.
Research Sources
Despite its diverse nature, Community Radio is a subject that, even today, in formal
terms remains somewhat under-researched, particularly when compared to the canon of
works relating to Public Service Broadcasting. Although a range of relevant and useful
UK-specific academic research into Community Radio does exist, inevitably, given its
relatively recent arrival in the United Kingdom, this paucity of material applies
particularly in relation to the British experience. In an attempt to compensate for such
limitations and to enhance the range of materials available, the research carried out in
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relation to this thesis also draws upon a range of non-traditional sources, as set out
below.
Primary Research - Formal Semi-Structured Interviews
At the heart of this PhD are a number of formal semi-structured interviews designed to
obtain primary data for subsequent analysis. These interviews have been carried out
with a range of campaigners, practitioners, regulators and others involved or interested
in the development and delivery of Community Radio broadcasting.
The approach taken in relation to the gathering of primary interviews sought to ensure
that their contents could be triangulated against the content of other primary interviews
and in relation to other research materials. Early primary interviews were conducted
with individuals involved in the operation and management of Community Radio
services. These were followed by further primary interviews with those involved in the
oversight of such broadcasters, primarily regulators and sector support bodies.
A further reason for selecting the specific interviewees involved in this research concerns
the author's own background in, and knowledge of, the sector. As a long-term
Community Radio campaigner and current Community Radio practitioner, as well as a
former Community Radio regulator at Ofcom, the author considers himself to have a
reasonably wide-ranging knowledge of the sector, both historical and current. When
interviewing staff at Ofcom, the Community Media Association, Future Radio, or the
Broadcasting Authority of Ireland, these tended to be former colleagues, selected by the
author because, in his opinion, they were considered to be particularly knowledgeable
about Community Radio.
The technique of gathering semi-structured primary interviews from a range of
interested parties was designed to provide a degree of data diversity, such that, in
conjunction with other data sources (both primary and secondary), a level of "subtypes
of data triangulation" (Denzin, quoted in Flick, 2002: 226) could be achieved. The
main triangulation points of the semi-structured interviews were between the
perspectives of practitioners, regulators and the auto-ethnographic experiences of
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practice obtained by the researcher. Further triangulation was sought through the
inclusion of international comparator interviews, which, in particular, focused on issues
of Community Radio regulation.
Primary Research - Additional PhD Data Collection
Data collection specifically for this thesis includes a range of other material beyond the
core semi-structured interviews (above). Various academic journal articles, historical
and industry-related writings and reports were all acquired with the writing of the PhD
in mind, as were academic and industry conference proceedings and other publications.
Working in related areas, and having other interests connected with the research topic
resulted in various opportunities for informal conversations, note taking and e-mail
correspondence with interested parties. On occasion, a chance meeting would lead to
further discussions and correspondence relevant to the research topic at hand.
Primary Research - Personal Involvement
Since my early adult years, I have been involved in various aspects of radio broadcasting,
primarily in the United Kingdom, but also in Ireland and other parts of Europe. My
interest in Community Radio dates back to the end of the 1970s and includes direct
experience of working on community services in the United Kingdom and elsewhere.
Inevitably, therefore, my approach to this research is, to some extent, influenced by my
proximity to, and direct involvement in, the campaign for the introduction of such
services in the United Kingdom.
My 'lived experience' in relation to the above has provided part of the framework within
which this research has developed, adding as it does, a reflexive element to the overall
thesis. However, first hand personal experience does not constitute research in the
traditional sense; rather, it requires framing within what is known as an 'autoethnographical' approach, which "challenges canonical ways of doing research
and representing others and treats research as a political, socially-just and
socially-conscious act" (Spry (2001) & Adams and Holman Jones (2008) cited in
Ellis et al., 2011). Within such an auto-ethnographic approach, there is an implicit
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recognition of "the innumerable ways [in which] personal experience influences
the research process" (ibid.).
A long-standing involvement within the sphere of Community Radio broadcasting,
campaigning and regulation has also provided me with opportunities to develop research
approaches that take into account some of the elements of 'naturalistic inquiry', through
which "persistent observation provides depth" (Erlandson et al., 1993: 137). This
is particularly the case in relation to both the workings of one particular Community
Radio station (Future Radio in Norwich) and those of the British broadcast radio
regulator, Ofcom.
Primary Research - Informal Sources
My personal involvement in the campaign for Community Radio in the United
Kingdom has included various formal and semi-formal roles. During the 1980s, I
served for several years on the national committee of the Community Radio Association
and I was also a director of the Radio Academy (1991 to 1995). Having worked as the
formal liaison between The Radio Authority and the Community Media Association in
relation to the Community Radio Experiment (2001 – 2003), I later became a director
of Future Projects in Norwich, the charity that holds the current Community Radio
Broadcasting Licence for the Norwich area. As well as being a director of Future
Projects, I have also developed close personal contacts within the Irish Community
Radio organisation (CRAOL), as well as with the Community Media Forum Europe
(CMFE) and with AMARC Europe (AMARC-E).
One immediate impact of such long-term 'personal experience' and involvement in the
research topic is that it provides a variety of opportunities to obtain direct access to
information that traditional research approaches might not unearth or might otherwise
be impossible to find. For example, access to e-mail lists (such as those operated by the
Community Media Association) and to various organisational and individual archives
has often been facilitated through long-established links with the various parties
involved. Most important, however, are the personal contacts developed with both
practitioners and other academic researchers in the field. Meeting with such individuals,
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often on an informal basis, for example on the periphery of meetings, provided multiple
opportunities to discuss key issues and to discover a variety of opinions and experiences
from a diverse range of viewpoints.
Secondary Research - Formal Academic Literature
Formal academic literature used in this thesis has been drawn from a varied range of
areas of study and research. Beyond specific literature about the subject of Community
Radio in particular, books and journal articles focusing on wider community media,
broadcasting and its history and regulation are also referred to. More broadly still, titles
covering such diverse areas as sociology, media theory, community development and
communications technology, not forgetting research methods, have also been referred
to.
Secondary Research - Industry Literature
The main source of industry literature, which this thesis draws upon, is publications by
Ofcom, the UK broadcast and media regulator. Additional materials from other
regulators have also been referred to, as have historical publications from previous
regulators. Publications by national campaigning bodies and responses to official
enquiries and consultations have been used, as have documents from supranational
bodies such as the European Broadcasting Union and AMARC (the World Association
of Community Radio Broadcasters).
Secondary Research - 'Grey' Sources
The term 'grey literature' "traditionally covers three categories of documents –
conference proceedings, reports and doctoral theses – often printed in small
numbers" (Farace et al. (Editors), 2010: 2). However, this definition is perhaps rather
too narrow and, today, is often taken to encompass "a body of materials that
cannot be found easily through conventional channels such as publishing"
(Huffine, 2010). Often falling outside formal categorisation systems, such materials can
comprise a rich source of information. This is particularly the case in relation to
subjects such as Community Radio, which have tended to develop outside the
mainstream. Individual examples used in researching this thesis include various personal
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archive papers, acquired over the years at meetings and events and materials rom other
specialist archives, such as the Peter Lewis Collection, now held by the London School
of Economics library, or the materials available on-line from TX Magazine (Hebditch
2014).
The primary benefit of using such grey literature and other grey sources, such as audio
recordings, videos and web-sites is that they can often provide alternative viewpoints
concerning the theoretical and practical development of the subject matter under study.
Indeed, in some cases, grey materials can provide the only recorded source of evidence
concerning particular developments in the field. A useful example here would be the
emergence of unlicensed proto-community services, such as Radio AMY (Rollings
1979).
More generally, the plethora of grey sources available can provide alternative viewpoints,
which can help to triangulate particular arguments and to confirm (or counter) evidence
and opinions that have arisen from other, more traditional, research sources.
Research Sources - Categorisation Issues
It should be noted that the categorisation of individual items of research material might
not always be absolute. For example, some of the research materials published by
Ofcom concerning Community Radio may well include materials written by me during
my time working for the regulator. In general, it is Ofcom's policy not to publish the
names of individual authors who worked on particular projects or documents.
A specific example here involves research commissioned by Ofcom concerning the
degree to which the listening public value the outputs of Community Radio services
(and of small-scale commercial stations) (Essential Research, 2011). Although this
report, entitled The Future of Small Scale Radio, was written by the staff of Essential
Research, it was ordered by and planned in conjunction with Ofcom. Being, for a time,
in 2010 / 2011, the primary radio team member at Ofcom for this research, the author
was responsible for leading discussions about its structure, and concerning the selection
of the individual stations surveyed. Thereafter, the author also helped in the design of
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the core questionnaire and in the collection of raw data, specifically at the workshops for
listeners to Future Radio in Norwich.
Selection of Primary Research Interviewees
The range of interviewees selected for inclusion in the set of semi-structured interviews
conducted for this research was designed to ensure a diversity of views and experience.
Because this PhD thesis is concerned with the practice of Community Radio
broadcasting, a prime constituent of the semi-structured interview cohort is that of those
involved directly in the delivery of Community Radio services.
Examples of such interviewees include: Tom Buckham, the first Station Manager at
Future Radio in Norwich; Andrew David, ex BBC local radio and the first Managing
Editor of SIREN FM, the Community Radio station based at the University of Lincoln;
Taari Sian, founder and Managing Director of NuSound Radio, an ethnic minority
Community Radio service for East London; and David Hatherley, the Station Manager
at rural Community Radio service, Wayland Radio in Norfolk.
Rather than select interviewees from various positions within individual Community
Radio services, it was a deliberate decision to focus on those involved in their
management. Typically, it was felt that such individuals would be expected to provide
an overview of the particular services that they managed, as well as some degree of
broader sectoral knowledge or relevance to this research.
A second cohort of interviewees came from the regulatory sector, those involved in the
design and implementation of regulation required by statute law. Such interviews
included not only individuals with direct responsibility for Community Radio
regulation at the micro level, but also senior regulators responsible for driving high-level
policy decision making.
Examples of such interviewees include: Ed Richards, former Chief Executive Officer at
Ofcom, responsible for the development of Community Radio policy following its
earlier introduction during the term of his predecessor, Stephen Carter; Philip Graf,
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Member of the Ofcom Board and Member / Chair of the organisation's Radio
Licensing Committee, responsible for approving licensing policy and for the licensing of
individual Community Radio services; and Susan Williams, Senior Radio Executive
with long-term overall responsibility for the development, implementation and delivery
of Community Radio licencing and sector liaison.
Further to the two central sets of semi-structured interviews, there is another group of
interviews with individuals who bring an international perspective. These include
broadcasters and regulators from The Republic of Ireland, Norway and the United
States of America. These are further supplemented by interviews carried out with
practitioners who have an international perspective, for example, Steve Buckley, the
long-standing former Chair of the Community Media Association in the UK and, more
recently, President of the international Community Radio campaign body, AMARC
and consultant to the World Bank.
The selection of interviewees is intended to provide a broad range of viewpoints and
expertise. For example, those selected because of their involvement in the management
of Community Radio services were chosen from a diverse range of community services,
including, those serving a community of place (urban or rural etc.), specific age
demographic or ethnic grouping. Meanwhile, regulators were chosen for their particular
involvement in oversight of Community Radio operations, whilst other interviewees
were selected for their perceived knowledge base and particular perspectives.
Research Hypothesis
This PhD is fundamentally about the relationship between Community Radio and
wider society. My hypothesis is that, the role of legislation and regulation is crucial in
facilitating the ability of Community Radio services to pursue their stated objectives.
This PhD explores how such legislation and regulation frames Community Radio and
its relationship with wider society. Because Community Radio is a technological
medium, the impacts of technological developments also play a role in framing this
debate.
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Exploring the process by which Community Radio developed and the factors that
influenced such development has the potential to reveal much about the sector's nature
and its relationship with the government, as part of a regulated medium. Exploring
current practice has the potential to provide opportunities for examining where
legislation and regulation appear to be beneficial to the sector and where they may
constrain its ability to act.
At the macro level, this PhD is concerned with the ability of the sector to deliver against
its perceived socio-economic and cultural objectives. At the micro-level, it is concerned
with the embedded nature of Community Radio services and the degree to which
individual services are able to integrate with their target communities.
As a central tenet, at both levels, this hypothesis considers the importance of community
as being dominant over that of radio. In other words, the success of any Community
Radio service needs to be judged first and foremost by the degree to which it benefits
members of its target community.
Contribution to Knowledge
This research is intended to help contribute to an improved understanding of the
relative positioning of Community Radio, both within broadcasting and, more widely,
within the communities that such stations seek to serve, and wider society as a whole.
The following chapters of this thesis seek to make an original contribution to knowledge
through, in particular (although not exclusively), the analysis of the various primary and
secondary research sources detailed earlier in this chapter.
Specifically, this PhD seeks to demonstrate the crucial role played by legislation,
regulation and technology in defining the 'place' for Community Radio. In part, this is
done through the research of historical and current literature and other research sources
(as set out above), drawing on some sources that have not previously been explored or
have not been explored in such detail in relation to the emergence of Community Radio
in the United Kingdom.
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The main contribution to knowledge is intended to be analytical. Drawing on primary
and secondary research sources this thesis seeks to answer the following research
questions:
•
What role has been played by broadcast radio history in shaping the current form of
Community Radio in the United Kingdom?
•
How do broadcast radio policies in general and Community Radio policy in
particular impact on the delivery of Community Radio services in the United Kingdom?
How is the sector (a) facilitated by such policies, or (b) constrained by such policies, and (c)
how might policy developments influence the sector in the near future?
In addition to primary materials gathered specifically for this PhD, the broad range of
regulatory documentation (from Ofcom sources in particular) as well as the author's
professional knowledge of both broadcast regulation and Community Radio
campaigning and operation, provides opportunities to obtain new perspectives in this
area.
Ethical Considerations
The various interviews carried out in relation to the completion of this thesis were all
arranged, in advance, in person or by either telephone or e-mail. Approval was also
sought and obtained in advance of visits to individual Community Radio stations and
other organisations.
Funding for my research came in the form of a scholarship provided by my research
institute (CAMRI), supplemented by my own resources. I neither sought nor received
any other financial support for the work involved.
All interviewees were aged 18 or over at the time they were spoken with. In some cases,
for example in relation to interviews with senior Ofcom staff and Board members, I was
asked to check with them before publication of any material obtained during formal
one-to-one interviews. Whilst this was agreed to and implemented, it did not result in
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any requests for amendments to my original wording, which, as a result, remains
unaltered in this thesis.
Conclusions
The purpose of collecting additional qualitative research data, alongside the gathering
and collating of a variety of existing research materials, is to provide the author with
opportunities to explore the delivery of Community Radio from a variety of
perspectives. In particular, this approach is intended to provide data relevant to our
understanding of the development of media policy (particularly concerning the
emergence of Community Radio in the UK) and in relation to the historical
development of this most recent type of broadcast radio delivery.
As a relatively small and relatively young sector, the author is of the view that
Community Radio in general, and its various UK based incarnations in particular,
remains under researched in comparison to other forms of broadcast radio delivery.
Although various recent titles have begun to pay more attention to Community Radio
(such as Mansell & Raboy, 2014), it remains the case that some generic textbooks,
which purport to discuss broadcasting theory, policy and practice in detail, still fail to
include specific references to the Community Radio sector, or even to wider alternative
media (see, for example, Hardy, 2008 and Mills & Barlow, 2012).
The remaining chapters of this thesis are concerned with the practice (and theory) of
Community Radio in the United Kingdom, and two specific elements that impact
directly on the delivery of such services: regulation and technology are examined in some
detail. Whilst the chapter concerned with regulation attempts to contextualise official
oversight of the sector in terms of both its internal viability and its external impacts on
the wider broadcast radio ecology, the chapter concerned with technology pays
particular attention to recent developments in both broadcast and non-broadcast
delivery systems. Although specifically focused on the United Kingdom experience,
where considered appropriate, some international elements are also introduced.
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Chapter Five explores the development of Community Radio policy, legislation and
regulation as these relate to Community Radio in the United Kingdom. It considers
particular factors that have influenced the development of policy and how such policy
has both facilitated and constrained the Community Radio Sector.
This chapter also considers the importance of the relationship between the Community
Radio sector and its regulators, exploring the changing nature of this relationship and
how this impacts upon the activities of both parties.
Chapter Six examines the technologies that underpin the broadcasting element of
Community Radio and the wider delivery of programming content to members of
target communities. Inevitably linked to particular regulatory issues, it considers factors
such as relative spectrum availability and, in particular, the issue of digital broadcasting
opportunities on DAB.
The recent Small Scale, Low Power DAB trials are explored within the wider context of
radio broadcasting's planned migration to digital, and the possible eventual closure of
analogue AM and FM radio broadcasting.
In terms of the changing patterns of audio consumption, this chapter also examines the
impact of non-broadcast Internet audio delivery. Attempting to assess the relative
importance of such platforms, it considers how these might impact on the relationship
between Community Radio stations and their listeners as well as between such
broadcasters and their regulators.
Chapter Seven draws elements of the preceding chapters together, providing a
summary of the research carried out and an opportunity for overall conclusions to be
drawn in the context of this thesis. The conclusions drawn are supplemented by
observations concerning opportunities for possible additional research in future.
(5,998).
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CHAPTER FIVE:
Regulation in the Community Radio Sector
Introduction
So far in this thesis, I have examined the positioning of Community Radio at the macro
level, that is to say in terms of how the sector as a whole is triangulated in relation to
legislation and regulation as well as in relation to the public service and commercial
broadcasting sectors. In this chapter, I will be examining the positioning of the sector at
the micro level, that is to say, in relation to the activities of individual stations.
For individual Community Radio stations, broadcast regulation and the underlying
legislation upon which it is based helps define various operational parameters. These
include, not only station outputs (primarily in terms of programming, although
additionally including other non-broadcast elements, such as the delivery of 'social gain'),
but also the various inputs required to deliver such outputs (such as licences and sources
of funding).
In order to explore the impacts of Community Radio legislation and regulation on
individual Community Radio stations, this chapter includes references to various
individual stations and examples. These help explain both the input and the output
elements of such regulation and help to demonstrate how these have the capacity to both
facilitate and constrain the activities of individual stations.
Fieldwork Stations
A number of factors were considered when selecting the various Community Radio
stations to be used as primary research sources for this thesis. Each was chosen to be
representative of a particular type of service and for having particular characteristics. The
author was particularly concerned to include stations, which (a) had differing audience
foci (in particular geographic, ethnic and special interest); (b) represented between them
services based in various types of location (for example rural or urban); and (c)
represented between them both self-supporting (stand-alone) organisations, and services
operated as part of larger, multi-focused, organisations. Although such criteria were the
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uppermost considerations, the practical issue of access to relevant personnel also played a
part in the selection of stations as case studies.
Four stations are at the core of this research, namely:
1.
Future Radio Norwich 1 - Suburban / urban location, geographically focused
and part of a larger organisation;
2.
NuSound Radio (East London) - Urban location, ethnic minority focus and a
stand-alone organisation;
3.
SIREN FM (Lincoln) - Urban (campus) location, special interest focus and part
of a larger organisation;
4.
Wayland Radio (Norfolk) - Rural location, geographically based and a stand-
alone organisation.
More information about each of the four core stations is provided below. However, in
addition to these stations, the author also visited or otherwise engaged with a range of
other Community Radio stations to help inform this thesis. These included:
1.
All FM (South, Central & East Manchester) - Dense urban location,
geographical focus, previously linked to a second Community Radio service
(Withenshawe FM), through third sector body, Radio Regen (Former 'Access Radio'
pilot scheme station);
2.
BCB (Bradford) - Urban location, geographical focus, stand-alone organisation;
3.
NEAR FM (Dublin) - Urban location, geographical focus, and a stand-alone
organisation;
4.
RadioLab (Luton) - Urban location, special interest focus and part of a larger
organisation;
5.
Raidió Fáilte (West Belfast) - Urban location, special interest (language) focus
and a stand-alone organisation;
1
The author of this thesis is a Trustee of the NR5 Project Limited (trading as 'Future Projects').
He has worked closely with Future Radio, the station operated by that organisation, since 2004.
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6.
Resonance FM (South Central London) - Dense urban location, special
interest focus and a stand-alone organisation;
7.
Radio Reverb (Brighton) - Urban location, geographic focus and a stand-alone
organisation;
8.
RINSE FM (East Central London) - Dense urban location, specialist music
focus and a stand-alone organisation (ex-unlicensed 'pirate' broadcaster);
9.
Sheffield Live! (Sheffield) - Urban location, geographical focus and a stand-
alone organisation;
10.
SoundArt Radio (Dartington (near Totnes), Devon) - Rural Location, special
interest and a stand-alone organisation;
11.
Warminster Community Radio (WCR) (Wiltshire) - Rural town location,
geographical focus and a stand-alone organisation;
12.
Worthy FM (formerly Radio Avalon2 ) (Pilton, Somerset) - Rural location,
geographical focus and a stand-alone organisation (annual temporary RSL service at the
Glastonbury Festival of Music and Performing Arts).
I will now expand briefly upon each of the four stations that constitute the core case
studies in this thesis (above):
Future Radio Norwich (107.8 FM & DAB)
Future Radio began broadcasting in May 2004. Using short-term Restricted Service
Licences, the station completed six 28-day broadcasts on 105.1 MHz, a frequency
allocated for temporary transmissions in the Norwich area. These early transmissions,
which provided limited coverage of the West Norwich area, nevertheless allowed the
station to develop "strong linkages within its target community and with
statutory and other bodies in Norwich as a whole" (Ofcom, 2005).
The parent body of the station, the NR5 Project, a registered charity with social
development objectives in the West Norwich Area, had a founding Chief Executive
(Dawn Jackson MBE), with previous experience of unlicensed broadcasting, who, early
on, saw the potential of Community Radio as a useful adjunct to the charity's initial
2
The author of this thesis was the co-founder of Radio Avalon in 1983.
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primary purpose of providing education to teenagers excluded from mainstream
education in the Norwich and wider County of Norfolk area. At the time of writing
(September 2015), the station had just started broadcasting on DAB, using the Future
Digital Norfolk multiplex, which was set up specifically to take part in Ofcom's smallscale DAB trial scheme.
NuSound Radio, East London (92.0 FM & DAB)
Based near Stratford, in Forrest Gate London N7, NuSound Radio began life some
seventeen years earlier, in 1989, as Star Sound Radio. The station operated a number of
RSL broadcasts as well as providing programming for the community cable radio station,
Radio Thamesmead in South East London, before it was offered a full-time Community
Radio licence in February 2006 (Ofcom 2006(a)). According to the regulator, the
group's Community Radio licence application demonstrated that it:
has gained much broadcasting experience in its target area by
broadcasting on RSLs over many years … [and] has strong links with
local community groups and is actively involved with local community
events, … [a] commitment to training, and previous experience in
training volunteers, is [also] evident (ibid.).
After Ofcom's offer of a Community Radio licence, the station took just over a year to
start its full-time broadcasts, which commenced in early March 2007 from above a shop
on the Romford Road between Stratford and Ilford. More recently, the station has
moved to larger premises nearer to Stratford Broadway and, at the time of writing
(September 2015), is just about to start broadcasting on DAB using the U-DAB
multiplex, which is part of Ofcom's small-scale DAB trial scheme.
Siren FM, Lincoln (107.3 FM)
Broadcasting since August 2007, from purpose-built studios on the University of
Lincoln's Brayford Pool campus, Siren FM is intended to serve the young people of
Lincoln between the ages of nine and 25 (Siren FM, 2015). Although this includes
university students (some elements of its broadcast output are heavily integrated into the
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university's teaching curriculum), the station nevertheless makes a point of encouraging
volunteers from the wider local community. When offered a licence by Ofcom in March
2006, the regulator noted the applicant's "well-resourced proposals … which are
carefully focused on the interests of students, school children and young
people in the City of Lincoln" (Ofcom, 2006 (b)).
Managed by a former BBC Radio and local television presenter, the station benefits from
financial and material support provided by the university. Since its launch, the station
has developed close links with the nearby BBC local radio station and with the main
commercial radio station in the county, 'Lincs FM'.
Wayland Radio, Norfolk (107.3 FM)
Also managed by an ex BBC local radio employee and based in the village of Ashill, near
Thetford in Norfolk, Wayland Radio broadcast to the rural market towns of Swaffham
and Watton in Central Norfolk. After several short-term, temporary 'RSL' broadcasts,
the first in early 2006, the station was awarded a full-time Community Radio licence in
March 2009, taking to the air just over five months later, at the end of August the same
year. In the event, the station only managed to maintain operations for a period of
exactly two years, closing down towards the end of August 2011.
The station broadcast programmes designed to be of specific interest and relevance to
those living and working in the Breckland area and relative to the lives, interests and
opinions of those local listeners. In addition to magazine and speech-based programming
during the day, a variety of specialist music programmes were broadcast after 7:00 pm
each evening. The station also had wider social gain objectives:
Having a focus on social integration and cultural awareness, the
station … also broadcast programmes in other languages, serving the
needs of migrant workers in the area (BBC, 2009).
Although Wayland Radio did not survive, the idea of a Community Radio station to
serve the Breckland area of Norfolk has not gone away and in June 2015, Ofcom granted
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a new licence for part of the area, this time to 'Brecks FM' (formerly operated on-line, as
'Watton Radio'). The new station:
will provide a locally-focused service for the town of Watton in
Norfolk, and surrounding villages, targeting mainly the general
population of the area but also providing programmes appealing to
local groups that are otherwise underserved (Ofcom, 2015 (b)).
Regulatory Issues
During the course of completing fieldwork for this thesis, a wide variety of issues arose in
relation to the regulation of the sector and of individual stations within it. In general the
regulatory topics raised can be grouped together under a number of broad headings,
namely:
•
Economic - Resource availability (in particular concerning legislative
requirements for a diversity of funding sources and restrictions on available sources of
funding) / Revenue Sources (availability and diversity thereof - including the DCMS /
Ofcom Community Radio Fund);
•
Operational - Management (for example of volunteers) / Delivery (of 'social
gain' as well as in terms of programming);
•
Licensing Related - Coverage policy / Equitable treatment (for example in
relation to licence duration) / Regulatory liaison (annual reports etc.);
•
Technical - Spectrum availability / coverage / digitisation etc. (covered in more
detail in the next chapter of this thesis).
When such issues were discussed with station staff and volunteers, it was evident that
although the relative priority of certain concerns varied according to the specific
circumstances of the individual stations involved, the majority of stations tended to have
particular concerns across more than one of the above groupings. As will become
apparent, there are clear inter-linkages between several of these listed issues. For example,
economic considerations are not separate from licencing, or indeed from operational
issues. Coverage impacts on both operational and economic capacity and is, of course,
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dictated by licensing criteria. By necessity therefore, the various issues are somewhat
intertwined below.
Service Delivery
Community Radio services broadcast to a diverse range of communities and, between
them, they create a broad range of programming, both speech- and music-based. For
traditional commercial broadcasters in particular, programming outputs are, almost
exclusively, the only outputs that their operators are concerned with. In fact, arguably,
the programming created by such stations is important, not for its own sake, but for its
ability to create an audience for the various advertising messages that are integrated into
such programming output.
For Community Radio, however, whilst programming outputs may be important, they
can also be secondary to wider objectives in relation to the delivery of social gain. For
both types of output, Community Radio stations require appropriate resource inputs to
provide for their delivery and it is here where one of the greatest tensions between
Community Radio operation and regulation can often be found. To deliver outputs
effectively, and to meet social gain commitments in particular, requires adequate
resources, not just in terms of volunteers, but also in terms of finances. Where such
funding can be obtained from, and, indeed, where it cannot be obtained from, is a major
concern for the Community Radio sector.
Generating Income
Viability of the Community Radio sector has always been a major concern, not just for
stations within the sector itself, but also for politicians, regulators and, not least, other
broadcasters, particularly those in the commercial sector, concerned that communitybased services might 'poach' revenues from sources that previously contributed to their
operational revenue streams.
The BBC as a public service broadcaster has access to a reliable core income stream in the
form of the licence fee. A little less secure in terms of its income sources, the commercial
radio sector has nevertheless managed to survive and, to some extent, prosper over recent
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years, albeit in the face of growing commercial competition from other, mostly Internetbased, audio providers. Whatever the shortcomings of their funding streams (and this
author does not doubt that funding pressures on both public service and commercial
broadcasters are genuine), such broadcasters do at least have clearly identified core
revenue sources, which are easy to determine as a constant, across the operation of the
individual sector concerned (PSB or commercial).
For Community Radio broadcasters, the picture is somewhat less clear. Between them,
the various stations researched for this thesis had a variety of funding models. These
differed in terms of both the range of sources involved and scale of income generation
achieved. The legislation governing the funding of Community Radio in the UK
requires that when considering Community Radio licence applications:
Ofcom needs to consider whether an applicant either has, or is likely
to have, access to sufficient financial and other resources to establish
and maintain the proposed service. The application form includes
questions on what broadcasting and off-air activities are planned, the
cost and resources required, how the applicant intends to fund these,
and what human resources are involved, as well as the group’s and
individual member’s relevant experience and what appropriate
linkages the applicant has already established (Ofcom, 2015 (c): 6).
Restrictions on Income
However, the legislation is not only concerned with ensuring the viability of any new
Community Radio service, it is also concerned with maintaining the viability of existing
commercial radio operations, because:
Ofcom must have regard to the need to ensure that any community
radio service does not prejudice unduly the economic viability of any
other local (commercial) radio service (ibid.).
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When Community Radio services were first introduced, one of the ways in which the
terms of the original secondary legislation, The Community Radio Order (2004) (a
Statutory Instrument under the Communications Act (2003)), sought to differentiate the
sector from commercial broadcasting, was to ensure that a diversity of funding sources
were employed to operate these services. The original Community Radio Order (2004)
required that:
OFCOM [sic] shall not grant a community radio licence to any
applicant who proposes to receive from - (a) any one person, or (b)
from any one person and any other persons connected with him, taken
together, more than 50 percent of the income that would be required
in each financial year of the applicant to provide the proposed service
in that year (HMG UK, 2004: 6-7).
The order also provides specific rules in relation to on-air commercial activities, namely:
(a) the inclusion in the service provided under that licence of any
remunerated advertisement, or
(b) the sponsorship of any programmes included in that service
(ibid., 7).
Again, the rules in relation to such income require Ofcom to ensure that the amount
generated is "50% of … [total] income or some lesser proportion" (ibid.).
The particular effects of this funding restriction are two-fold. Firstly, a restriction on
traditional forms of commercial radio type funding generation automatically requires
Community Radio stations to explore and develop alternative income strands. Secondly,
this approach automatically provides some protection for the commercial radio sector,
concerned about the potential transfer of advertising revenues from its stations to
Community Radio services.
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Being a 'broad church', the Community Radio sector embraces a diverse range of
opinions in relation to how its services might be delivered to best effect. Some operators
create programming output that, in many ways, might sound somewhat similar to that of
existing commercial broadcasters, whereas others shy away from such an approach in
favour of delivering more specialist content and a greater diversity of output overall.
Understandably, commercial radio companies generally perceive the former approach as
more 'threatening' than the latter. Commercial operators create their particular on-air
programming approaches primarily to maximise listenership, and are, perhaps
understandably, concerned when similar sounding services appear. Community Radio
services may not necessarily consider the maximisation of total listenership to be their
primary objective, but some will still use commercial radio broadcasting techniques,
believing these to best help deliver their wider social gain and other community-based
objectives.
Such concerns were highlighted by the commercial radio sector in its response to
Ofcom's Regulation Of Community Radio Services consultation in 2008 (Ofcom, 2008
(a)). Formed in 2006, the RadioCentre (sic), as the successor industry body to the
Commercial Radio Companies Association, is tasked with maintaining and building "a
strong and successful Commercial Radio industry - in terms of both listening
hours and revenues" (RadioCentre, 2008 (a)). From its starting premise that
commercial radio was "was naturally concerned about the possible impact of
Community Radio on existing local services" (ibid.), it argued that regulation of
the sector should ensure its unique position is maintained:
We believe that Community Radio's role should be that of a distinct
third tier, focused on social gain, participation and community
involvement. This will ensure that it makes a contribution to UK
life, rather than undermining the economic wellbeing of existing local
commercial stations (ibid.).
In spite of such trenchant views from the commercial radio sector, over time, the general
direction of travel in terms of Community Radio financial regulation has been for the
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government to gradually relax the funding rules for the sector. There are arguably a
variety of reasons for such developments, as set out below:
Firstly, given the high levels of demand for Community Radio licences, the government
has faced resultant calls for increases in the sector's central funding support (see, for
example, Buckley, 2010). Given the general state of the economy since the mid 2000s,
successive governments have been disinclined to accede to such demands. The
alternative of making commercial funding more easily accessible is one way of being seen
to be supportive of the sector but, importantly, one that comes without a cost overhead
for the government.
Secondly, since the launch of the permanent Community Radio sector in 2004,
commercial radio broadcasting has continued the process of acquisitions and mergers,
which started in earnest in the early 1990s. Larger groupings and networked outputs
have seen the continuation of cuts to locally produced outputs and a reduced importance
of local commercial revenues. Hence, the perceived 'threat' of Community Radio from a
commercial radio perspective has tended to reduce.
Thirdly, there is the evidence of practice. With very few exceptions, Community Radio
broadcasters have not attempted to duplicate small-scale, local commercial radio. The
regulation applied to the sector undoubtedly helps to ensure that this remains the case.
However, Daniel Nathan, involved in both commercial and community-based
broadcasting in Brighton, thinks the key here is the gradually evolving culture of the
sector. As this becomes more established and defined through practice, he suggests that
the level of detailed scrutiny that Ofcom may feel is necessary to apply to the
Community Radio sector may gradually reduce (Nathan, 2015). At the time of writing
however, the blank application form for a Community Radio licence remains detailed,
running to 21 pages (Ofcom, 2015 (l)).
Although most stations visited, or otherwise engaged with, during the research for this
thesis sought, to a greater or lesser extent, to generate commercial revenues (through the
sale of spot-advertising and / or sponsorship opportunities) as part of their overall
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operational funding mix, some, such as Siren FM and BCB proactively chose not to
generate any such income.
Mary Dowson, the long-serving station manager at BCB in Bradford, explained to the
author that this position was taken as a matter of principle and in relation to practice.
Giving the example of a campaign run by the station to keep open a local supermarket,
she questioned what might have happened had the station been carrying advertising from
competing retailers, suggesting that, at the very least, income from such sources might
have tempered the way in which the station ran its campaign.
The Warminster Example
By comparison, Warminster Community Radio (WCR), a station that is not
ideologically opposed to generating commercial revenues, was until recently prevented
from doing so by legislation. The story of WCR's quest to obtain a full time
Community Radio licence, as summarised below, highlights the direction of travel in
relation to Community Radio legislation in the United Kingdom, in particular in
relation to the impacts of legislation on potential service viability.
Now a registered charity and originally founded in 1996, the station carried out a
number of short-term Restricted Service Licence broadcasts to the Warminster area
between 1996 and 2009. It has also been providing a full time service via the Internet
since May 2007 (Mole, 2015). The organisation started to pursue the idea of a full time
licence when the Radio Authority's Access Radio experiment was announced in 2000
(ibid.). As the first RSL broadcast had generated some £14,000 of advertising income,
the station believed that it could use such commercial revenues as a major contributor to
its modest operational costs, which today total between approximately £20,000 and
£24,000 per year (ibid.).
When asked about the early licensing attempts of WCR, the station's founder, Barry
Mole, now Managing Director of WRC Community Radio Limited, as well as
Chairman of Trustees at the organisation's charitable body, the Friends of WCR,
explained that:
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WCR pushed for a licence for the area in 2000, when we were the
only show in town and only commercial licences were available - sadly
the big commercial boys came out of the woodwork and pulled the rug
from under our limited funded enterprise. When, [in 2004], the law
changed to allow the third tier of radio, we were ready to apply, [but
were] foiled yet again by an eleventh hour spoiler by the CRCA
banning a licence in areas where a [small-scale] commercial station
existed (Mole, 2015).
The legislative restriction, as referred to above, which prevented WCR being licensed in
2004 was contained within the first Community Radio Order, which came into force
that same year. Lobbying by the Commercial Radio Companies Association (CRCA)
resulted in a restriction, which stated:
OFCOM [sic] shall not grant a licence to provide a community radio
service in any case where the licence, if granted, would overlap with
another local licence for a service, other than a community radio
service, the potential audience of which includes no more than 50,000
persons who have attained the age of 15 years (HMG UK, 2004).
However, when the original Community Radio Order (2004) was replaced by the
Community Radio (Amendment) Order (2010), this particular restriction was removed
and WCR was at last able to apply for a full time Community Radio licence, which it
was subsequently awarded in September 2011 (Ofcom, 2011 (c)), taking to the air
towards the end of March 2012. At this point, however, the station's new licence still
prevented it from generating "income from the sale of advertising or programme
or station sponsorship" (Mole, 2015).
The legislative restriction carried over in modified form into the Community Radio
(Amendment) Order (2010) states:
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[E]very licence to provide a community radio service that overlaps
with any other local licence for a service, other than a community
radio service, the potential audience of which includes no more than
150,000 persons who have attained the age of 15 years, must contain
such conditions as appear to OFCOM [sic] to be appropriate for
prohibiting -
(i) the inclusion in that service of any remunerated advertisement,
and
(ii) the sponsorship of any programmes included in that service
(HMG UK, 2010).
Thus, when WCR began broadcasting as a full time Community Radio service, it had to
rely on sources of income that were not related to broadcast commercial activities. In
particular, the station managed to negotiate a 'Service Level Agreement' with the
Warminster Town Council (approximately £20,000 per annum) promoting council
information and events, also generating additional off-air commercial revenues through
the provision of "CD recordings, PA system hire, DVD production and
broadcaster training courses" (Mole, 2015).
Whilst clearly an unsatisfactory position from the broadcaster's perspective, it could be
argued that the imposition of such restrictions on the income generation opportunities of
WCR may, in some ways at least, have benefitted the organisation in the longer term.
The development of a mutually beneficial relationship between the broadcaster and its
local authority as well as the expansion of commercial and training activities, all of which
might broadly be considered to strengthen the station's links with its target community
and to strengthen its delivery of 'social gain', resulted, at least in part, from the urgent
need to develop alternative funding streams.
When discussing the issue of financial viability, Barry Mole noted that, despite the
various restrictions placed upon the commercial activities of WCR, the local commercial
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broadcaster (currently operating as 'The Breeze') has had something of a chequered
history both financially and in terms of changing ownership and on-air identity. He
noted that when discussing radio in the area with members of the local community, they
tended to appreciate the fact that "WCR were here before commercial radio came
along" (ibid.) and that the station has continued to maintain a very clear local focus,
even as the commercial station has come to rely increasingly on networked programming
from outside the local area.
Early in 2015, the Community Radio (Amendment) Order (2010) was replaced by a
further revised Community Radio (Amendment) Order (2015). The various
amendments in the new statutory instrument are complex, but its accompanying
explanatory notes are clear, stating:
The amendments also permit a community radio licence which
overlaps with a small commercial station to raise up to £15,000 per
annum from remunerated advertising or sponsorship (HMG UK, 2015).
As a result, WCR has now begun to add on-air commercial revenue generation to its
range of revenue streams. However, the opportunity to develop such income streams
may come at the cost of decreased support from the local authority, anxious to reduce
expenditure at a time of declining central government support.
The above example clearly demonstrates how the direct legislative restrictions on
Community Radio funding have been gradually reduced in the decade or so since the
sector was established on a permanent basis. In Barry Mole's view:
[W]e are now where we wished to be in 2000 but due to continued
interference tactics from the commercial sector, our progress has been
delayed, not halted and now, 12 years on, all of the feared
implications the CRCA were so adamant about have proven to be
groundless (Mole, 2015).
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It should be noted here that during the course of my fieldwork, it was rarely, if ever, the
case that Community Radio broadcasters were arguing for the freedom to generate all
their income from traditional commercial radio sources. Overall, the feeling was that the
50% limit on such income was acceptable, but that it should have been countered by the
provision of a larger Community Radio Fund. Soo Williams at Ofcom agrees:
I know that many people in the sector feel that they’ve, [the]
government’s pulled a fast one, in that it introduced restrictions on
advertising and areas where we could license community radio stations
and they felt that in return, they would have a fund that would really
help to get community radio stations…to keep them funded for a small
period of years anyway, at a decent level, to help them get started with
a station manager or whatever, and that’s just not happened. That’s
just not happened, so I feel that the sector has – to some extent – been
let down there. But it’s not just the DCMS funding for the
Community Radio fund that is the issue. It’s public funding in
general (Williams interview, 2010).
Funding concerns for Community Radio are not limited to the United Kingdom alone.
In the Republic of Ireland, the situation is, in many ways, similar. Obtaining operational
funding remains a constant concern. Jack Byrne, a long time campaigner for
Community Radio and founder of the well-established NEAR FM in North Dublin, is
blunt about the issue, observing that, even for a long established service, such as his:
a lot of the weaknesses that are inherent in our operation, and I'm
sure in all the other community stations, is [due to] this constant
scrambling for funding (Byrne interview, 2010).
British Community Radio legislation is, as previously discussed, strict about ensuring a
diversity of income sources, in particular limiting on-air commercial advertising and
sponsorship (taken together) to a maximum of 50% of income. The result of this rule is
that some stations find their total income limited because they are unable to obtain other
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sources of income to match that which can be generated as a result of such traditional
commercial activities. As well as including grant support and so-called 'Service Level
Agreements' (SLAs), alternative sources of income can also include a monetary value
attached to volunteer inputs, both managerial and programming related (Ofcom, 2010
(b)).
The Wayland Radio Case
One station, which encountered problems with such regulations, was Wayland Radio.
When it launched in 2010, this station was fortunate enough to obtain some £24,000
worth of funding from the local council (Breckland, Norfolk) (Hatherley interview,
2010), which it could then match against advertising and sponsorship revenues that, even
during the recession, it found reasonably easy to obtain (ibid.), perhaps because there is
no small commercial station to be found operating in the immediate vicinity.
David Hatherly, interviewed for this thesis before the station he managed was forced to
close after just two years on air, envisaged a future of mixed funding from a variety of
grant and SLA sources, balanced by commercial revenues. Stressing that Wayland Radio
was not a commercial radio station, but taking the view that small-scale businesses are
part of the local geographical community, he recognised that achieving a diverse mix of
funding would always be something of "a balancing act" (ibid).
In the event, it was a balancing act that could not be maintained. Non-commercial
revenues declined and the value of volunteer inputs was too small, such that the knockon effect was to constrain commercial revenues to an unsustainably low level. Although
the station successfully delivered against its licence objectives, in terms of programming
and social gain, in the year 2010 - 2011 (Ofcom, 2011 (f)), it was clear that, after a wellmanaged start, the economic recession was beginning to cause serious problems. Under
the heading 'Significant Difficulties', which the station chose not to keep confidential, it
was noted that:
The current financial situation has caused us difficulties in two areas.
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Firstly Financial: As grants are fewer in number, the competition for
them has become greater. In the past our local district council (and
other agencies) have been financially supportive, but now there is no
money to spare. Cash flow is an on-going issue.
Secondly Communication: As local government agencies try to reduce
their budgets, through staffing changes and reductions, many previous
links have been lost. We are having to work hard to re-establish lines
of communication, many of which had been in place for several years
(ibid.).
In the Warminster example (above), changes to the licensing regime under the revisions
instigated by the Community Radio (Amendment) Order 2015 (HMG UK, 2015) were
explained in the context of Community Radio in areas where small-scale commercial
stations operate. Of particular relevance here is the rule allowing the generation of a
baseline amount of commercial funding (currently £15,000) outside the established 50%
limits as set out above (DCMS, 2015). This applies to all Community Radio stations
and is a clear example of how regulation is, to some degree, becoming more appropriate
to the sector's needs and less driven by the concerns of commercial operators. Although
impossible to prove, were this rule to have been in place in 2011, it is entirely possible
that Wayland Radio could have generated enough income to continue broadcasting.
Sector Funding Support
Another finance-related policy area of interest to individual radio stations is that of
centralised funding support. When Community Radio was provided for, under the
terms of the Communications Act, 2003, the same legislation also provided for the
provision of Community Radio Fund. The Act states "Ofcom may make such grants
as they consider appropriate to the provider of any [Community Radio] service"
(HMG UK, 2003: 316).
Each year, since the financial year 2005 / 2006, the government, through the
Department for Culture, Media and Sport (DCMS), has made available approximately
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£500,000 (Ofcom, 2014 (a)) to be dispersed by Ofcom through an awards process
established in 2005 (ibid). This fund is, theoretically at least, available to all Community
Radio Licence holders, with invitations to apply for funding typically being made twice
per year (Ofcom, 2015 (m)).
The Community Radio Fund has very specific objectives. Having "been established to
give grants to help fund the core costs of running community radio stations"
(ibid), the fund is specifically focused on providing help with "the essential core work
[for which it is] the most difficult … to find funding" (Ofcom, 2014 (a)). Noting
that some things, such as training can be easier to fund from other sources, Ofcom gives
examples of the types of things that are considered appropriate to fund, namely:
•
fundraising to support the station (e.g. grants, commercial funding)
•
management
•
administration
•
financial management & reporting
•
community outreach
•
volunteer organisation and support (ibid).
In bold type within the notes of guidance from Ofcom about the fund, the regulator
stresses that the panel responsible for funding decisions "considers promoting longterm sustainability a critical, core activity" (ibid).
Future Radio has made various applications for support from Ofcom's Community
Radio Fund, but has met with limited success. Tom Buckham argues that this is because
of the station's relative stability and successful track record:
[Y]ou think perhaps it is in the sense that if you're a bigger
organisation perhaps, um, producing more outputs, social gain wise
and otherwise, involving more volunteers, you're deemed to be,
perhaps deemed to be successful and therefore not, um, you can't apply
[successfully] for the grant, which is understandable in the sense that we
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know there are places that operate on a lot smaller budgets with less
staff, but, at the same time, should you really be penalised for over,
over, you know, achieving (Buckham interview, 2010).
The fact that that Community Radio Fund has not increased since 2005 (and in real
terms, after inflation has been taken into account it has, in fact, reduced) must also be
taken in the context of how much the sector it serves has grown over the intervening
years. As Buckham puts it:
I mean, you just need to look at the facts and see that the fund hasn't
increased from when it was initially kicked off for about twenty
stations, fifteen Access Stations, or something like that, um and now
you've got, you know, almost ten times the amount of stations and it
hasn't increased (ibid.).
Since the interview with Buckham was completed, the total number of full-time
Community Radio services operating in the United Kingdom has expanded further still,
with over 230 being operational in September 2015 (Ofcom, 2015 (a)), which means
that, divided pro-rata, the amount of direct government funding available to each
Community Radio station would be under £2,200 per year as compared to well over
£30,000 available per station for the initial fifteen services back in 2005.
When Professor Anthony Everitt reported on funding as part of his review of the Access
Radio experiment, his recommendation was that:
[T]he government should establish an Access Radio Fund, which
would support the fund-raising capacity of Access Radio stations and
the employment of a station manager at a level of £30,000 per annum
(Radio Authority, 2003).
Former CMA Director, Steve Buckley, who also has direct experience of the management
of Community Radio station, 'Sheffield Live!', has been particularly vehement in his
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criticisms of government policy towards funding for Community Radio services. His
central argument, that the legal limits placed on the availability of commercial funding
should be countered by the provision of alternative sources of funding, has considerable
currency within the wider Community Radio sector. He observed, when interviewed for
this thesis, that:
[T]he size of the funding mechanism at the moment is very small; it
has become very small from starting off at a reasonable level …
Professor Anthony Everitt recommended a fund that would provide
round about 30,000 a year per station. So we started off at more or
less that level and what went wrong is that it was not increased in
line with the growth of the number of services (Buckley interview, 2010).
In a paper published in 2010, which discusses the funding of Community Radio in some
detail, he noted that the:
Growing concern at the lack of adequate public funding for
community radio has been reflected in the support of 152 MPs for a
Parliamentary Early Day Motion in 2007; in repeated calls by
Ofcom’s Community Radio Fund Panel for an increase in government
support for the Community Radio Fund and, in 2009, a joint letter
signed by 60 station managers (Buckley, 2010: 1).
When it was suggested to Buckley that the limitation on the size of the Community
Radio Fund was primarily an economic issue, at least in part due to the impacts of the
global recession, which began soon after the sector began to grow substantially in 2006,
he disagreed:
Actually, I don’t think so. I think it's political. I think the sums of
money involved are really rather small, and very small, compared to
the – I would say – social benefit and public interest, in having a
good, viable, community broadcasting sector. What [we] are talking
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about – at £30,000 a year, times 200 stations, [is] six million quid a
year, compared to three billion for the BBC. It's not a lot; it's really
not a lot. Per head of population, what does that come to? About ten
pence per year, something like that. So these are not large sums of
money, really. The problem, I think, is one of political will, rather
than economic ability of the government to invest in this sector. I
think if you made an objective cost-benefit analysis of this sector,
alongside many other broadly similar areas of public investment, a
fund at a proper level would be perfectly justifiable. The difficulty
appears to be persuading politicians to properly fund it and that may
be a case of needing there to more pressure on the government to put
more money into the fund, but I think it's perfectly affordable, even
in this present economic climate (Buckley interview, 2010).
From an operational, regulatory perspective, when interviewed for this thesis, Soo
Williams MBE, Ofcom's Community Radio Manager, was of the view that Community
Radio is "in a strong place, generally speaking, but I do worry about the
funding side" (Williams interview, 2010). When it comes to a thorough
understanding of the day-to-day operation of, and issues with, Community Radio
services, Williams is perhaps the most experienced and knowledgeable person at Ofcom.
After moving from the Independent Broadcasting Authority, she became responsible for
RSL licensing at the Radio Authority during the 1990s and was heavily involved in
developing and implementing the Authority's Access Radio pilot scheme from 2000
onwards. Her involvement in Community Radio at Ofcom has been consistent and
dates back to the sector's pre-launch phase, when the regulator took over the tail end of
the Access Radio experiment in 2003.
Specifically, considering the Community Radio Fund, Williams was not optimistic that
it would be increased in the foreseeable future (and indeed, since the interview, to date,
this has proven to be the case): "We don’t know what’s going to happen to that
fund, but I can’t see it increasing. I cannot see it increasing. That is a
very, very great shame" (ibid.).
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At board level, within Ofcom, inevitably somewhat distanced from day to day interaction
with individual Community Radio stations, support for the Community Radio Fund is
tempered by a similar view of the current economic circumstances. Ofcom's Chief
Executive, Ed Richards, describes Community Radio as "one of the greatest and most
important innovations that we've had in the sector over the last decade"
(Richards interview, 2010) but is nevertheless not optimistic about possible
improvements in the funding regime:
It's not a good time to be asking for loads more money, umm, but I
think that Community Radio is regarded as a success. Whenever I get
asked about it by ministers, I trumpet it and say this is a huge success
that's very exciting and I support it. So it's in reasonable, a
reasonably good position, but probably not in a position to advance
claims for a huge increase in funding (ibid.).
Speaking in a personal capacity in 2010, when holding the positions of Ofcom's Deputy
Chairman, Chair of the regulator's Content Board, and most importantly of all in this
context, Chairman of the Radio Licensing Committee, Philip Graf was careful to define
the objective of the Community Radio Fund as a provider of seed-corn funding rather
than long-term operational support:
I think there's an argument for having a fund, provided that fund is
about teaching people how, you know, is, you know it's the old story
about, you know, teaching people about how to plant seeds, rather
than supplying them with the stuff, right? And I think that's what,
what any fund has got, has got to be about and I think there's still a
case, a case for having, for having it … effectively first year seed
money for people to, to build capacity rather than subsidise, umm,
services (Graf interview, 2010).
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Beyond current funding from the DCMS, Graf did suggest that more support might be
forthcoming from the devolved administrations within the United Kingdom (ibid.) but it
is clear that, from the perspective of all three Ofcom interviewees, the possibility of
obtaining additional central government support for the sector is, for the moment at
least, considered highly unlikely.
The observation from Philip Graf that the Community Radio Fund should be seen as a
provider of short-term set-up and capacity-building finance, rather than as a provider of
recurrent operational support highlights a key difference of opinion between the
regulator and the majority of those operating Community Radio services. Steve Buckley,
who has also served as President of the international Community Radio organisation,
AMARC, noted how some other jurisdictions are much more supportive of the sector,
particularly in terms of providing long-term support:
The main difference between the UK and countries which have a more
supportive enabling environment, is the existence of structural funding
mechanisms to support the sector. So, for example, in France, there is
a large fund called 'Fonds de Soutien à L'Expression Radiophonique',
which accounts for something like 50% of the revenue of the
Community Radio stations in France, and [this] helps to sustain round
about 600 community radio stations. Similarly, in Denmark, there is
also a large fund drawn principally from the licence fee, collected for
the purpose of funding public service broadcasting, but also part of it
is used to fund community broadcasting. Again, it's fairly generous
and it guarantees a certain level of income, plus there is a competitive
funding mechanism that stations can also apply to for some extra topup funding, but again, it accounts for a significant part of their
income. In this country, there is almost no such thing. There is a
fund, provided for in the law, but it's not adequately financed to
provide any significant degree of structural support to the sector, at
the moment, in terms of the relationship between the size of the fund
and the number of stations (Buckley interview, 2010).
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Even though Future Radio has received only minimal support from the Community
Radio Fund, Soo Williams takes the view that it is an example of the type of station
perhaps best able to survive an economic downturn and public spending squeeze:
The ones that have been most successful in raising funding up to now
are the bigger stations that are part of a larger operation that might
be offering lots of different ways of engaging with their local
community: Shmu FM up in Aberdeen, Future Radio in Norwich are
examples where there were pre-existing organisations [that] had
already built up expertise, connections, track record with the local
community, for offering various, different opportunities for training –
that kind of thing, and they have therefore been successful in
attracting large grants from various organisations. So they feel like
they have got the expertise in-house and the experience and the
background and the track-record to continue to attract funding, but
on the other hand, they are reliant on public funding, so they will be
subject to a squeeze on their spending, I suspect, but they may be able
to ride it out (Williams interview, 2010).
As for the wider Community Radio sector, Williams thinks that it is the medium-sized
station that is perhaps the most vulnerable:
At the other end of the scale, we do have some stations that really
operate on some very, very small-scale funding models, entirely run by
volunteers and low overheads and maybe they will be able to ride it
out. Maybe it’s the ones in the middle that are going to be more
vulnerable (ibid.).
As Steve Buckley also observed in his 2010 paper, in spite of the limited availability of
centralised funding, the government nevertheless does recognise that if it is to facilitate
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the development of a mature and stable Community Radio sector, this does have to be
done on some sort of stable footing:
if the community radio sector is to grow and prepare itself for a more
fundamental role in the future radio landscape it must also be given
the certainly to invest in its future (DCMS, 2009: 101).
To achieve this successfully, Buckley argues for core funding support for the sector:
If the UK community radio sector is to have the certainty needed to
invest in its future, then the regulatory restrictions on commercial
funding need to be complemented by adequate public funding
investment to assure core costs can be met and to reward community
radio stations that are most effective in providing public service
content (Buckley interview, 2010).
Under the 2010-2015 Conservative and Liberal Democrat Government, no progress was
made in this area and, politically, it seems highly unlikely that a fully Conservative
government would be willing to countenance such an approach, particularly off the back
of a major recession. However, the government has at least recognised the difficulties
being encountered by the sector, stating in 2013 that:
We are … very conscious of the position of the community radio
sector. More than 200 community stations operate around the UK
and they have a very positive impact on local engagement and
volunteering. However, financial pressures have left many stations
struggling to survive. There are a variety of reasons why the sector has
seen a fall in revenues, but the complex and restrictive financing
regulations, which were put in place to ensure community radio
remains distinct from commercial radio are particularly damaging.
These restrictions need to reflect the more challenging climate in
which community radio now operates (DCMS, 2013: 30).
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Being conscious of the problem is a useful start, but it remains to be seen how this
problem might be solved in the future. The fact that the Community Radio
(Amendment) Order (2015) was relatively cautious in its approach to relaxing the rules
around the funding of Community Radio services is perhaps indicative of the degree to
which the sector still has battles to fight in relation to its long-term sustainability.
Volunteer Inputs
Although many aspects of running a Community Radio service are similar to those
encountered in other forms of radio broadcasting, as we have seen above, there are
marked differences in relation to income generation. Another area of difference results
from the sector's use of, and reliance upon, volunteer support. If obtaining funding is a
time-consuming and on-going exercise, for many Community Radio stations, managing
volunteers can be equally resource intensive.
A fundamental element of British Community Radio broadcasting is its use of volunteer
inputs in relation to its operation. In some cases, stations may be operated on an entirely
voluntary basis, whilst in others, the volunteer base might be supported by a number of
paid staff. Where this is the case, there can be an economic dynamic at play, with the
number of paid staff varying in accordance with available financial resources.
Some stations, such as WCR in Warminster operate without any paid staff at all, whereas
other stations such as Wayland Radio in Norfolk and Radio Reverb in Brighton are (or
were) able to provide a very limited amount of paid support for their volunteers. At
stations such as Future Radio in Norwich, the number of paid staff was found to be
higher, but so was the number of volunteers regularly involved in the station's operation.
Elsewhere, as in the case of Resonance FM in London, the ratio of volunteers to paid
staff was also noted to be particularly high. Educational stations, such as Siren FM in
Lincoln and RadioLaB in Luton were unusual in that the volunteer base was supported
not only by paid staff, but also by students required to produce programmes or be
otherwise involved as part of their educational studies.
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As with other elements of Community Radio practice, the model of volunteer use was
found to be elastic, varying in light of local circumstances and over time, as Tom
Buckham, the former Station Manager at Future Radio, explained:
It’s changed, changed over the years. I mean, we started off with,
when it was RSLs, with just myself and then when we went full-time,
we moved to four, four members of staff and there’s been some sort of
movements around that but now we have three full-time staff and two
part-time [staff] and that seems to be a quite an optimum amount for
us, basically, by having enough flexibility and cover (Buckham interview,
2010).
Having access to a willing volunteer base is, however, not the only issue. For volunteers
to get the maximum out of their involvement, effective training is required. Some larger
stations, such as NEAR FM in Dublin have formalised an induction process for new
volunteers. According to the station's founder, Jack Byrne, "every year we have
about 30, 40 new volunteers and we do a ten-week induction course" (Byrne,
2010). Future Radio in Norwich trains volunteers in batches throughout the year and
operates a mentoring scheme whereby new volunteers are given the opportunity to
'shadow' more experienced colleagues, building up competence and confidence as a result
(Fisichella, 2015). The station has recently begun offering specialist training in areas
such as local news, editing, sports and production support (Future Radio, 2015 (a)).
Some other stations were a great deal less formal in their approach to volunteer training
with smaller stations in particular tending to have more ad-hoc arrangements, partly as a
result of smaller volunteer numbers and partly because of limited resources. Despite
having a formal induction process in place, Byrne was also clear that there exists "a need
for on-going training, more advanced training" (Byrne, 2010). Despite its
relatively large volunteer pool, at Resonance FM, Ed Baxter, the station's Managing
Director explained that the station's preferred approach is individualised, "responding
to the needs of individual volunteers as they come through the door" (Baxter,
2015). Operating with a full-time staff of four, each week some 150 volunteers are
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involved in operations at Resonance, this number including some twenty volunteer
engineer / producers who work with the 50% or so of programme makers who are not,
or not yet, capable of producing their output material unassisted (ibid.).
The roles that volunteers can fulfil also vary, not only according to requirements, but also
in terms of what individual volunteers are willing to commit to. Perhaps because it has
been operational for longer than any UK-based Community Radio station, in Dublin,
NEAR FM has proactively 'shaped' its volunteer body:
You get a lot of young men with their collections of CDs of dance
music and, … so you have to beat some of them away with a stick!
You know, there, there's just too many of them, you cull them, we
always cull them. Er, I, I'm gratified lately, over the past couple of
years the people coming forward have heard the sort of tenor of the
station, the sort of programming it's putting out and we're not getting
as many … young men, young women seem to be more practical about
these things… (Byrne interview, 2010).
As Buckham explains, a key issue for Community Radio station operators is one of
balance, of trying to ensure an adequate return on training investment:
We’ve got about around 160, 170 volunteers, [a number] which is …
fluctuating all the time and obviously, in terms of ratio, that amount
of volunteers to the staff we have, is, is quite high, so we have to have
systems in place, to try and manage that. … You need to gauge
whether these people are, sort of, going to be sort of fairly transient or
whether they’re going to stick around, because obviously the more time
you expend on them, [the more] you really want something back
(Buckham interview, 2010).
Volunteering at a Community Radio station can also provide long-term benefits for
individuals. Not only do some volunteers end up in paid staff positions at the
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Community Radio station involved, some also end up employed by public service and
commercial broadcasters. Former volunteer at Resonance FM, Chris Weaver, became
employed as the station's Production Manager (Baxter, 2015), whilst former volunteer at
Future Radio, Greg James, is currently the afternoon presenter on BBC Radio 1 (Lee,
2014). These are but two examples of many similar ones that the author encountered
during research for this thesis; others include former volunteers working in BBC local
radio, commercial radio and even as producers at the BBC World service.
Volunteer inputs are not only a critical pre-requisite for the delivery of Community
Radio, they are also a clear manifestation of the way in which the sector delivers 'social
gain' to individuals at a variety of levels. Outcomes are dependent upon individual
circumstances and attitudes and on the particular support mechanisms that the
Community Radio station is able to provide, but it is obvious from the above that
managing volunteers and attempting to ensure that their involvement returns mutual
benefits is a key concern.
A final example of a volunteer now working at Future Radio shows just how much effect
volunteering at a Community Radio station can have:
I had had zero experience in not only the field of radio but media in
general. Zero. My studies were not media related. I had never
considered entering this domain, because it had never previously
occurred to me. Upon volunteering at Future Radio I realised I had
discovered something that I loved to do. I made it clear that if an
employment opportunity surfaced I would love to be considered. One
did and I was (Nomvula Smith, 2015).
Licensing-related Issues
British Community Radio licences are unusual. In particular, they are effectively
protected from commercial takeover by the terms of the Community Radio Order
(HMG UK, 2004) and its subsequent amendments, which state "No body corporate
may hold more than one community radio licence at any one time" (ibid.).
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Legislation also requires that the operator of such a licence "does not do so in order to
make a financial profit" (ibid.). Taken together, these two requirements provide a
robust defence against commercial takeover, which had previously been missing.
However, such licences are not without their problems. When full-time Community
Radio services were given the go-ahead in 2004, the legislation provided for a single fiveyear broadcasting licence, but did not include measures to permit subsequent renewal
(DCMS, 2004). From the outset, two issues have therefore been at the heart of concerns
around licensing: licence duration and licence renewal.
Whereas Community Radio licences are issued for an initial period of five years, local
commercial radio licences by comparison have traditionally been issued for an initial
period of twelve (Ofcom, 2010 (c)). John Mottram, formerly responsible for radio
broadcasting policy at DCMS, justified the difference in licence durations on the basis
that commercial stations need longevity precisely because of the commercial nature of
their activities (Mottram, 2010). By comparison, when Community Radio was first
licensed, there seemed to be little understanding of the sector's own need for long-term
stability. Indeed, as Soo Williams at Ofcom noted, there was a belief that some
Community Radio stations would operate within a shorter, pre-defined, operational life
span:
I think there was a feeling that in some cases, we would get specific
projects that had a finite life span, maybe because of particular
funding or some other particular reason, and so that we might get
some projects for which the shorter license period might be suitable but
I actually haven’t really seen any evidence of that (Williams interview,
2010).
Having responsibility for, what was in 2004, a completely new sector of broadcast radio,
it is perhaps not surprising that both the government and the regulator took such a
cautious approach. Had the sector not lived up to expectations, or if it had been
considered a failure in some particular respect, the initial five-year licences could have
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simply been allowed to expire and the sector closed. That said, such an outcome was, in
the light of pre-existing international experience, highly unlikely.
However, one unintended outcome of such an approach was that Community Radio
stations encountered difficulties in securing long-term funding deals and have since had
to go through one or more re-licensing process(es) (Ofcom, 2015 (k)) in order to
continue broadcasting. Taari Sian at NuSound Radio in London felt that it took some
three years for the station to become properly established, by which time it was already
becoming concerned about the end of its first licence period (Sian, 2010).
Summarising the strategic position in 2010, which, small-scale DAB trials aside, remains
materially similar today, Steve Buckley highlighted the key issue:
Existing five-year licence holders will be able to apply for another
five-year extension, but beyond that, we’re still in a great deal of
uncertainty about what happens next. So, there are some risks, … at
some point in the future, in a different political context, we might
find ourselves squeezed off the FM spectrum, without a digital place
to go [to instead] (Buckley interview, 2010).
When the Community Radio (Amendment) Order (2010) was finalised, it included the
opportunity for a single renewal of Community Radio licences; it did not provide for any
subsequent renewals (HMG UK, 2010). Seven years, later the next iteration of the
legislation, the Community Radio (Amendment) order (2015) did the same, still not
providing for 'rolling' repeat renewals (HMG UK, 2015).
The key issue here is the government's wider uncertainty as to the longer-term future of
broadcast radio services, in particular its long-term ambition to migrate the majority of
stations to digital broadcasting platforms. This topic has been extensively discussed by
both DCMS (see, for example, the Digital Britain Interim and Final Reports (DCMS,
2009 and DCMS, 2009 (a)) respectively, as well as, more recently, the latest Digital
Radio Action Plan (DCMS, 2014)) and by Ofcom (see, for example, the various 'Future
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of Radio' documents, including Ofcom, 2004 (b), Ofcom 2005 (b), Ofcom, 2006 (d),
Ofcom, 2007 (e) & (f), Ofcom 2008 (b), Ofcom & Essential Research, 2010, as well as,
more recently, the various Annual Digital Radio Reports, up to and including Ofcom
2014 (c)).
In spite of all the above research and preparation, speaking earlier this year (2015), the
Minister responsible for radio policy, Ed Vaizey, said "it was too early to put a
precise date on 'digital switchover'" (reported in Sherwin, 2015), which, in any
event, is not intended to be total, as the definition provided by the government clearly
states:
Digital Radio Switchover is the point at which all national and large
local stations broadcasting on both DAB and analogue frequencies will
cease to broadcast on analogue, and small local and community
stations will populate the vacated FM spectrum (Ofcom, 2014 (c): 38).
The plain language of the above definition plays down the political significance of smallscale broadcasting, recognised specifically, by the Minister at the GO (sic) Digital
conference at the end of 2013:
We all know how much people love their small local commercial and
community radio stations. That is why we have always said that we
will reserve a part of the FM spectrum for as long as it is needed for
those stations that are too small to make the switch to digital (DCMS,
2013 (a)).
Even though this is the case, for the government, the question raised is how to regulate
the remaining analogue radio broadcasters. At the time of writing however (Autumn
2015), this question remains largely unanswered. The Digital Radio Action Plan requires
the completion of work to "Assess the role and character of the small local and
community stations remaining on FM and make recommendations on the
future regulatory regimes" (DCMS, 2014: 12). However, the final version of the
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plan (January 2014) also stated that: "Further work would be needed to assess
what small local and community stations require in terms of a regulatory
regime in event of future switchover" (ibid.).
Although, in the Foreword to this document, Vaizey declared that "The work of the
Digital Radio Action Plan is complete" (ibid., 3) the work required on post digital
switch over analogue broadcasting is one of many items left outstanding for completion,
nearer to as and when such a switchover may eventually occur. Some items have been
partly completed (see for example DCMS, 2013) and others may need to wait until
closer to such time, but for Community Radio broadcasters (and indeed for small-scale
commercial stations) the lack of clarity over their future is not helpful.
Steve Buckley at AMARC takes the view that, for the moment at least, Community
Radio is fortunate not to be centrally involved in debates over the future of broadcast
radio transmission platforms:
In the main, community radio broadcast[ers] are going to [be] happiest
sitting around on FM and developing their Internet presence, in the
knowledge that most of their current digital broadcasting technologies
on offer are going to be obsolete long before the Internet becomes
obsolete (Buckley interview, 2010).
The current work on small-scale DAB transmissions (dealt with in more detail in the
next chapter) has at least the potential to change the way in which the sector considers its
future. However, in some respects at least, it also further complicates an already unclear
time ahead.
Coverage Issues
Arguably, the issue of geographical coverage lies at the heart of Community Radio policy
and at the intersection between regulatory ambitions and technical opportunities. The
regulatory approach here is one that strives to achieve a balance between what, in broadly
political terms, is desired and what, in broadly technical terms, is achievable. Although
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policy must eventually accommodate the technical realities of frequency availability, such
availability is not absolutely fixed. In part at least, it is also defined by political decisions,
past and present, about how best to distribute limited spectrum resources.
The Future Radio Case
When Ofcom first offered permanent Community Radio licenses, the NR5 Project
backed an application by Future Radio and the station was awarded a permanent
Community Radio licence in September 2005 (Ofcom, 2005). The group applied for a
small-scale licence for parts of West Norwich, focused on the North Earlham and
Larkman districts of the city. However, when interviewed for this thesis, the station's
former Station Manager, Tom Buckham, who worked for the station from its earliest
temporary broadcasts through until 2012, explained how Ofcom had foreseen that its
coverage proposals were inadequate:
We were such a fledgling group and we actually applied for a NELM
licence and in the space of getting set up we'd gone, we'd journeyed so
far already that, you know, that we, we needed a bigger licence, and
fortunately, they actually gave us a West Norwich licence, 'cause I
think they, Ofcom actually had the foresight to, the way we didn't at
the time, to see that we needed a bigger coverage area (Buckham
interview, 2010).
The result was the award of a wider West Norwich licence, with the station starting its
full-time broadcasts in August 2007 (Future Radio, 2015) on a new FM frequency of
96.9MHz and from a different transmitter site, such that coverage of West Norwich was
somewhat improved over that previously achieved during the station's earlier temporary
broadcasts.
Although Ofcom provided some additional coverage for Future Radio, due to the
application of Ofcom rules designed to protect a recently launched local commercial
station, additional limitations were, however, placed on the technical characteristics of
the new permanent transmissions, beyond those that define the typical coverage of all
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such services across the United Kingdom. As a result, the coverage provided by the new
licence was still less than that which it would have been technically possible to deliver
from the new transmission site. Although Future Radio was granted the standard
transmission power for Community Radio services, this was attenuated towards the
commercial City Centre of Norwich.
In 2005, Ofcom had awarded a new commercial radio licence for the Greater Norwich
area to '99.9 Radio Norwich' and this station had commenced broadcasting in June
2006. Section 105 (3) of the Broadcasting Act (1990) as amended by the Community
Radio Orders (2004 onwards) states that:
Ofcom shall have regard to "the need to ensure that any service
provided under [a community radio licence] does not prejudice unduly the
economic viability of any other local service" (quoted in Ofcom, 2007 (e):
146).
Because this station had only been broadcasting for just over a year when Future Radio
was due to launch, the regulator decided, in line with stated policy, to place additional
technical restrictions on the coverage that the station would be able to achieve. Although
Future Radio was granted the standard transmission power for a Community Radio
service, these technical restrictions deliberately downgraded Future Radio's coverage
towards the commercially important centre of the city (Ofcom, 2007 (d)). Moreover,
Ofcom engineers also selected a less than optimal frequency (96.9 MHz) for the service
(ibid.), meaning that the signal was often further degraded by incoming interference from
high-power commercial radio transmissions on the same frequency in the Hull area
(Viking FM).
By 2009, 99.9 Radio Norwich, the local commercial station, which had launched in
2006, had been on air for long enough that, were a new Community Radio station to be
licensed in Norwich, Ofcom policy would no longer have required the imposition of
additional restrictions upon its coverage. However, because Ofcom's licencing
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regulations provided no mechanism by which the regulator could remove the additional
restrictions that had been placed upon Future Radio earlier, these had to remain in place.
Ofcom's assumption that Future Radio would need greater coverage than it originally
asked for proved correct:
So, we got the West Norwich licence, um, but, in reality, that, even
by the time we were, sort of, launching, very soon after that, we were
working with people across Norwich anyway, do you know what I
mean, we, even though we have the NELM NR5 bias, we've always
said community radio for Norwich really, um, 'cause that's what we're
trying to do (Buckham interview, 2010).
In August 2008, Ofcom offered a further opportunity for additional Community Radio
services to be licensed in the East of England (Ofcom, 2009 (a)). By that time, as
Buckham suggests (above), Future Radio was increasingly working across the whole city
and in surrounding areas. Because of the increasing impact of problems caused by poor
coverage of central and East Norwich on its original permanent frequency, and because
of Ofcom's inability to modify the station's original technical parameters, (or, perhaps, its
unwillingness to create a potentially difficult precedent), this resulted in Future Radio
deciding to apply for a completely new Norwich-wide Community Radio licence, as
Buckham explains:
So the re-applying process was really just about trying to be
acknowledged as a Norwich-wide service, to remove the restriction on
the transmitter and ideally to have some more power, because
ultimately it's very frustrating to, sort of, be on a restricted power
output when other services in our area are not, even though they're a
city wide service as well, essentially (ibid.).
The application satisfied the regulator, which, in March 2009, noting that the station
had "provided evidence of local demand for the service including the findings
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of a detailed survey" (Ofcom, 2009 (a)), awarded it a new licence with all the previous
additional coverage restrictions removed. The new licence was also allocated to a new
frequency (107.8 MHz), which, because of its close proximity to aircraft band
frequencies, is not used by high-power commercial services and, as a result, was (and
remains) far less susceptible to problems caused by incoming interference.
Despite the improvement in coverage achieved through the revised conditions of its
second licence, Future Radio still takes the view that its coverage is less than optimal.
When interviewed, Buckham was, as suggested above, particularly concerned about the
imbalance of frequency resources allocated to community services in relation to
commercial stations:
… a commercial station which is deemed to be a city-wide service will
be given more power. Now, if you were to put that on the table to
someone who had no knowledge of radio, or anything like that, who
wasn't involved in the sector, I can guarantee you they would
immediately say, "Well, why is that the case?", because, it's that
simple, it doesn't, it shouldn't be the case, if, if you've got two
stations operating as city-wide services, why should one get more power
than the other? (Buckham interview, 2010).
Another issue identified by Buckham is the way in which Ofcom's current approach to
Community Radio licensing fails to take into account the actual situation regarding
frequency availability in a specific area. Reflecting a widely held view across the sector,
he questioned why Ofcom does not take a more nuanced approach:
… it's quite restricting to be honest … I don't really see why that has
to be the case. … I don't think you can have a one size fits all policy
… at the end of the day, Ofcom [is] responsible for licensing, [its]
engineers should be able to look at an area and say, "This amount of
power is available for this area" (ibid.).
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This example highlights a key concern for individual Community Radio stations, and a
source of continuing tension between the sector and the regulator caused, as previously
discussed, by the imbalance between demand and supply for broadcast radio frequencies.
Although Ofcom's policy for Community Radio stations is that "stations on FM in
urban areas will generally be licensed for a coverage radius of up to 5km"
(Ofcom, 2004(a): 8), this does not always lead to a service for what station operators
consider to be the totality of their target community. As noted above, there can also be a
further difficulty where a community broadcaster's own definition of what it considers to
be its target community varies over time (as in the case of Future Radio (above)), with a
consequent impact on the appropriateness of the coverage provided to serve it.
In fact, Ofcom finds itself in an intrinsically difficult situation when it comes to
allocating analogue frequencies for Community Radio, primarily because of the limited
spectrum resources remaining available to it. Limiting typical coverage to a fivekilometre radius both allows individual frequencies to be used a greater number of times
across the country and provides some additional frequencies which can only be used for
such very limited coverage services. To Buckham's point about a 'one size fits all policy',
it is undoubtedly also the case that such an approach reduces engineering overheads and
has the advantage of being extremely clear. As a result, it minimises potential issues of
precedent, where providing greater coverage where frequency resources do permit could
lead to demands from other broadcasters that it would not be possible to meet.
Ofcom's policy makes clear where Community Radio comes in the hierarchy of
broadcast radio services, that is to say, firmly towards the bottom of the 'pecking order',
using only those frequencies "which could not support commercially sustainable
services" (Ofcom, 2004(a): 7). The nub of the issue here is that, in Ofcom's view,
frequencies that "are not likely to be able to support economically viable
commercial radio services" (ibid.), are nevertheless in the opinion of the regulator
considered to be "suitable for community radio services" (ibid.). As can be seen
from the comments of Buckham (above), such an approach is not always favourably
received.
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The tension between policy objectives and finite frequency resource availability is
particularly highlighted by Ofcom's approach to the allocation of such resources to
Community Radio services. As discussed in more detail in the following chapter, in
order to maximise its ability to re-use frequencies for as many Community Radio services
as possible, Ofcom has chosen to reduce what are known as the protection ratios for these
services (ITU, 1998: 2-5). As a result, Ofcom has effectively increased the maximum
levels of incoming interference that it considers acceptable for such services. In effect,
this means that a signal that Ofcom now considers to be capable of delivering what it
deems to be an acceptable service over a five-kilometre radius for a Community Radio
service would only be considered acceptable over a smaller radius for a commercial radio
station (Ofcom, 2011(b): 7 & 11).
Recognising that, in many areas, there is a level of excess demand over supply for such
services, in effect therefore, Ofcom's policy in relation to the licensing of analogue
Community Radio services is a case of 'something is better than nothing'. Were Ofcom
to apply its commercial radio planning rules to Community Radio, the total number of
services it would be able to licence would be further reduced, particularly in major
conurbations, where demand for such services is typically at its greatest.
Conclusions
In this chapter, I have demonstrated the importance of specific regulation for the
Community Radio sector and highlighted some of the problems that can be caused as a
result of prior policy decisions and resource allocations.
In relation to the use of volunteers, the difficulties relating to their training and day-today management are countered by examples of participation changing preconceptions of
self-identity and changes to the life path of individuals.
It is clear from the examples given, that, although Community Radio legislation protects
stations, for example by preventing their takeover by commercial competitors, such
protection comes at a cost in terms of restrictions placed upon their ability to generate
income or to provide coverage for geographically disparate communities.
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Although community-based operators can be critical of particular limitations placed
upon their activities throughout my fieldwork, it was clear that the majority of those in
the sector broadly agreed with the general thrust of sector regulation. Campaigns for
additional core funding may, in the current climate at least, be unrealistic, but the
gradual relaxation of income generating rules is providing at least some additional
opportunities to obtain financial support from other sources.
(12,640).
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CHAPTER 6:
Transmission in the Community Radio Sector
Please Note
Parts of this chapter were previously presented in, or are adapted from, the paper entitled
"Democratising Digital Audio Broadcasting" (Hallett, 2014), presented by the author at the
International Association for Media and Communications Research (IAMCR) conference in
Hyderabad, India in July 2014. The chapter also draws upon materials researched and
written by the author in the paper "Community Radio: Collaboration & Regulation (Hallett
& Wilson, 2010) and presented at the Media Communication & Cultural Studies
Association (MeCCSA) Conference at the London School of Economics in January 2010.
Parts of the section on small-scale DAB are adapted from an article written by the author
and published under the title "UK Small Scale DAB Trials Move to Next Phase" in Radio
World International Magazine, August 2015 (Hallett, 2015). Other elements of this
chapter, particularly those that focus more on issues of online delivery and consumption, draw
upon the author's chapter "Community Radio In Transition - The Challenge Of Digital
Migration" in Digital Radio in Europe, Technologies, Industries and Cultures (O'Neill et al.
(Editors), 2010: 175-191).
Introduction
Since around the turn of the century, broadcast radio has experienced a period of
fundamental technical change. Internal developments, such as the gradual emergence of
digital transmission systems (e.g. EUREKA 147, Digital Audio Broadcasting, usually
simply referred to as DAB, and others) (ETSI, 2005, 2009 and 2010) have, arguably,
been somewhat over-shadowed by external developments, such as the impact of Internet
radio and various music streaming services, most recently including Apple's 'Beats1'
(Hepworth, 2015). The 'mixed ecology' of future digital broadcasting, including
various methods of Internet delivery, was recognised as early as 2004, for example in the
Independent Review of the BBC's Digital Radio Services (Gardam, 2004: 12 & 106).
At the same time as preparing for the introduction of permanent Community Radio
services, Ofcom was already looking at the way in which Internet audio was beginning
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to have material impacts on traditional radio broadcasting activities. In July 2004, the
regulator published The iPod Generation, a report that noted how quickly listening
habits had begun to change and how radio was being left behind in terms of features
and flexibility (Ofcom / The Knowledge Agency, 2004). Over the first decade of
permanent Community Radio services in the United Kingdom, for the vast majority of
radio broadcasters, online simulcasting of radio services moved from being something of
an optional extra to an essential part of the increasingly complex platform mix for
content delivery.
Thus, Community Radio launched at a time of considerable insecurity for the wider
broadcast radio industry and this was reflected in the attitudes of the BBC and the
commercial radio sector. Commercial radio, in particular, sought to restrict the capacity
of community services prior to the sector's launch. For example, calling for stronger
operational oversight and the imposition of greater externally defined social gain delivery
and other requirements, the Commercial Radio Companies Association (CRCA) took
the view that: "the policy towards Community Radio as set out in the DCMS and
Ofcom documents has been based entirely on the views of the community radio
sector" (CRCA, 2004(a): 1). Although considerably less confrontational in its
approach, the BBC also expressed concerns "about the possible impact of Community
Radio services on the reception of existing BBC services" (BBC, 2004).
Analogue Frequency Resource Limitations
One factor that delayed the introduction of permanent Community Radio services into
the United Kingdom was the alleged limited availability of analogue radio broadcasting
frequencies. As previously discussed, use of this issue as justification for maintenance of
the status quo has long-standing and questionable 'form'. However, there had been a
period of rapid and considerable expansion of analogue broadcast radio from the early
1980s onwards (New Scientist, 1983: 151). By the late 1990s, there was a general
recognition that analogue broadcast frequency usage levels were genuinely reaching
saturation point and, in early 2000, the author was directly involved (as the Community
Media Association's representative) in the development of a report commissioned for the
government by the Department of Trade and Industry's Radiocommunications Agency.
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Taking London and Leeds as case studies, and using existing planning standards, the
report highlighted the difficulty in finding frequency resources suitable for providing
commercially viable (> 5 kilometre radius) coverage in urban and suburban areas.
The report concluded that there is scope to introduce a number of services
with a radius up to 5 km with little or no impact on existing services.
However, it is unlikely that new larger-scale services could be introduced
under current planning criteria in the areas examined, without impacting to
a greater or lesser extent on existing services, notably by way of the need for
frequency changes and / or the loss of coverage (Rudd et al., 2000).
When, soon after, permanent Community Radio services were first introduced in the
United Kingdom, in 2004, the broadcast regulator, Ofcom, having already made it clear
that there was no room for additional commercial stations in many areas of the country
(Ofcom, 2004 (c)), also made it abundantly clear that in terms of remaining frequency
resources, the new services would use:
… frequencies which could not support commercially sustainable services but
which should be usable for non- or partly-commercially funded stations.
Ofcom considers that frequencies that cannot deliver a coverage area of more
than a 5km radius are not likely to be able to support economically viable
commercial radio services but however would be suitable for community
radio services (Ofcom, 2004 (a): 7).
Although it could be seen as the result of 'first mover advantage' on the part of the BBC
and commercial radio, the implication that Community Radio was considered to be of
secondary importance was not lost on the community sector. In a briefing paper
prepared for politicians, considering the wider provisions of the draft Community Radio
Order, (2004), the Community Media Association described its position as one of being
"deeply concerned" about the "restraining provisions that impose restrictions on the
viability of Community Radio" (CMA, 2004).
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Exploring the theory and practice of analogue broadcast spectrum planning in material
detail is outside the scope of this thesis. However, the core objective of such planning is
always to maximise the availability of a broad range of broadcast radio services and to
minimise interference between such services and between broadcast radio services and
other users of the wider radio spectrum. The latest version of Ofcom's document
'Coverage & Planning Policy for Analogue Radio Broadcasting Services' (Ofcom, 2011
(b)) usefully summarises the overall regulatory approach. It makes clear that the
Communications Act 2003 requires Ofcom:
… to secure the optimal use for wireless telegraphy of the electro-magnetic
spectrum (section 3(2)(a) of the 2003 Act) and the availability throughout
the United Kingdom of a wide range of radio services which (taken as a
whole) are both of high quality and calculated to appeal to a variety of tastes
and interests (section 3(2)(c) of the 2003 Act). This requires and enables
Ofcom to plan and manage frequencies to form a ‘virtual infrastructure’ out
of the finite and common resource that these frequencies represent (HMG
UK, 2003).
By 2004, particularly in non-rural areas, broadcast radio spectrum (AM and FM) was
generally heavily occupied. With considerable demand for additional commercial
services remaining high, Ofcom felt it necessary to make clear that, following a formal
consultation process, the arrival of Community Radio services would not adversely
impact on the already severely limited options for licensing additional new local
commercial stations (Ofcom, 2004 (c): 2 & 9). In the event however, after working
through the list of additional commercial services proposed in 2004, Ofcom has not
licensed any further new analogue commercial radio stations since 2007:
Ofcom is not currently undertaking any new commercial analogue (i.e. FM
or AM) licensing, and has not been since 2007. This is because of the
proposed migration of radio listening in the UK to DAB (Digital Audio
Broadcasting), and because, in the case of FM, there are no new frequencies
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available in areas of the UK where we think further new commercial radio
services could be financially viable (Ofcom, 2015 (e)).
In light of the above, defining typical Community Radio coverage by radius is not as
straightforward as it might first appear. Providing effective analogue broadcast coverage
of any location is dependent upon a wide range of factors, the most vital of which are
summarised below:
•
The relative position of the transmitter site used in relation to the desired
coverage area;
•
The height of the transmitter antenna above average local terrain - "height is
might" (Ofcom, 2015 (c): 42 & Ofcom, 2015 (i): 9);
•
The directional and gain characteristics of the antenna system;
•
The radiated power of the transmitted broadcast signals;
•
The interference environment on (and around) the broadcast frequency
employed.
Not only are Community Radio services typically limited to an arbitrary coverage radius
of five kilometres, but Ofcom also notes that, when it licenses Community Radio
services, the "levels of incoming interference may often exceed those considered
acceptable for commercial radio" (ibid., 17). Primary research for this PhD has clearly
identified how this approach has been adversely received by the Community Radio
sector, which feels that it impacts adversely on the operations of individual Community
Radio services. Speaking in a personal capacity, Bill Best, Operations Manager at the
CMA in Sheffield, who has witnessed the development of the sector since the time of
the Radio Authority's 'Access Radio' pilot scheme, summed up the general view of the
sector, stating:
This is a difficulty that does come up from time to time. The Community
Media Association understands and agrees with Ofcom's stated position that
stations should target a defined community. However, by definition a "one
size fits all" policy is not always going to deliver the best solution. Ideally, in
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areas where sufficient spectrum is available that would provide enhanced
coverage and would better serve a geographic community, it would be helpful
if a more bespoke approach to licensing could be taken. However the
problem is two-fold: it is recognised that such an individual approach would
be more resource intensive and then there is the issue of precedent - it would
make the task of licensing very difficult for the regulator if it had to make
different decisions about transmission parameters in differing locations (Best,
2015).
In spite of the technical restrictions placed upon the licensing of permanent Community
Radio services, the sector grew much faster than the regulator originally envisaged. The
regulator's prediction that it would "expect to licence anything up to 50 services in
2004 / 2005" (Ofcom, 2004 (d)) proved unduly pessimistic and by the time the first
licensing round was finally complete, in early 2006 (running between November 2004
and May 2006), the number of licensed services was in fact 107 (Ofcom, 2006 (c)), a
total which clearly exceeded earlier expectations. Recognising the high levels of demand
for Community Radio services, even before the first round of licensing was completed in
May 2006, Ofcom had already invited 'expressions of interest' for a second round of
licensing, receiving some 184 responses by the closing date of Friday, 21st April 2006
(ibid.).
Over subsequent years, the Community Radio sector has continued to grow and, by
mid 2015, over 230 were operational across the country (Ofcom, 2015 (a)), in addition,
approximately 10% of all Community Radio stations (23) had closed between February
2007 and December 2014 and various other community groups have been offered
licences but have yet to launch. However, the number of areas where Ofcom considers
there are no suitable spectrum resources available, even for additional small-scale
Community Radio services, continues to increase (Ofcom, 2011 (d), Annex 2).
With the available analogue spectrum at capacity in many areas, options for addressing
the imbalance between demand and supply require access to alternative resources,
primarily in relation to spectrum allocated to digital broadcasting and, potentially at
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least, consideration of alternative (non-broadcast) platforms.
Digital Audio Broadcasting
Digital Audio Broadcasting (more specifically, Eureka147 DAB) (Bower, 1998) has now
been in use for nearly 30 years. From its earliest beginnings, as a European research
project, started in 1987 (ETSI, 2010: 4), it has gradually obtained some degree of
acceptance within specific jurisdictions (for example, Denmark, Norway and the United
Kingdom). However, it has failed to live up to the high expectations of its developers
who, for large-scale radio broadcasting at least, clearly envisaged it as a possible
international replacement technology for analogue (AM & FM) broadcasting (O'Neill et
al. (editors), 2010: 18).
Competing or Complementary Technologies?
Over the years, DAB has evolved to encompass the revised DAB+ standard (ETSI,
2010), but it has also faced considerable competition not only from competing digital
broadcasting systems (such as the DRM family of standards (ETSI, 2009)) and the
American In-Band-On-Channel (IBOC) 'HD' Radio system (Ibiquity web-site, 2015
and Schofield, 2014) but also from Internet delivered radio and 'radio-esque'
technologies (streamed audio, podcasting, etc.) discussed in more details later in this
chapter. Although the original DAB technical standard, using MPEG 1 Layer II audio
compression, pre-dates the delivery of audio over the Internet, its later development into
the DAB+ standard was effectively aided by the development of more effective audio
coding algorithms, specifically MPEG 4 HE AAC+ v2, (ETSI, 2010). This standard
evolved from systems originally developed for the reliable delivery of high-quality audio
over limited bandwidth Internet connections.
Expanding Demand for Radio Services
In parallel with the emergence of the various Internet-based methods of audio delivery,
traditional radio broadcasting practice has continued to expand and evolve. In the
United Kingdom for example, between 1994 and 2012, the number of broadcast radio
services increased from some 150 stations to approximately 550 (an increase of well over
350%) (Hallett et al., 2014: 4-5). Not only did the overall number of broadcast radio
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services increase, but there was also an expansion in the types of service provided.
Although the high watermark of public service broadcasting expansion was past by the
time DAB arrived on the scene, commercial broadcasting and, in some countries at least,
particularly, new Community Radio services were still emerging and expanding, filling
the last corners of the analogue FM band in various European jurisdictions, the United
States and elsewhere. In the UK, the number of such stations rose from zero at the turn
of the century to well over 200 today (ibid., 4). In some jurisdictions, such as the
United Kingdom, part of the reasoning behind the drive towards digital broadcast radio
delivery was therefor a desire to solve the decades-old perceived problem of demand for
frequencies exceeding supply, which, as noted above, by the early years of the TwentyFirst Century had become much more of a reality than hitherto.
Benefits of DAB Technologies
When DAB first emerged, it was arguably at the cutting edge of digital broadcasting. Its
1.536 MHz wide-band multiplex (ETSI, 2005: 14) Coded Orthogonal Frequency
Division Multiplex (COFDM) approach to transmission (Bower, 1998), not only
allowed a number of services to use the same infrastructure to serve a nominally identical
service area, but also provided enhanced operational flexibility (for example through the
addition of temporary, supplementary stations) and the ability to re-use the same
frequencies time and again within a single transmission network. Compared to
analogue systems (AM & FM), it also provided enhanced data carrying capacity and
improved resistance against interference (ibid.).
System Parameters
The Eureka 147 DAB approach to broadcasting is, however, markedly different from
traditional analogue implementations, in which transmission facilities are typically
stand-alone individual installations, each with its own specifically tailored coverage area.
Although, even critics of DAB may argue that there is nothing wrong with the
underlying technology itself (Goddard, 2010: 8), there are clearly some issues that arise
from the use of the 'wide-band multiplex' approach. Whilst they retain various digital
benefits, the fact that second-generation digital broadcast transmission systems, such as
DRM, DRM+ and HD Radio, more closely emulate established analogue approaches to
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transmission would seem to indicate a clear recognition of the operational benefits and
simplicity such approaches have traditionally provided.
Historical Objectives
Because DAB was developed by the EBU, perhaps not surprisingly, its main objective
was to provide spectrally efficient coverage for multiple national and wide area regional
services, typical of those offered by national public service broadcasters. Although
governments and regulators have previously attempted to use DAB for more localised
services (for example by using L-Band microwave frequency allocations (between 1,452
and 1,492 MHz), which, by dint of physics, achieve intrinsically smaller coverage areas),
it should be noted that the technology was not originally specifically designed with such
smaller-scale implementations in mind. Indeed, in the UK, some of the harshest
criticisms of DAB come from the small-scale, independent commercial sector (Goddard,
2010: 226- 232) and from potential, new, community-based services concerned about
an apparent lack of DAB-carrying capacity for themselves and other small-scale services.
Broadcast Network Planning
Wide area broadcast radio coverage is almost always achieved by using a number of
geographically distributed transmitters, typically a grid of widely spaced, high-power
installations, supplemented by a higher number of lower powered sites, used to fill in
gaps caused by terrain blocking or densely packed buildings in urban areas. However,
without careful planning, mutual interference will result from two or more analogue
transmitters operating at, or adjacent to, the same frequency but from different
locations. This is the case even if both are broadcasting exactly the same programming
outputs. In many situations, it is impossible to 'plan out' such problems, as they are a
function of issues such as the scale of the overall coverage required, the relative distances
between the transmitters involved, their required operational power levels and the nature
of the intervening terrain to be covered (Ofcom, 2011 (b)).
Analogue Broadcast Networks
The solution, in terms of analogue broadcast radio network planning is to use a number
of separate frequencies to provide blanket coverage with the minimum of interference
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between transmitters operating on the same frequency. To deliver national FM
coverage to a large nation state requires multiple frequencies per service. On FM (Band
II), a single transmitter occupies 200 kHz of spectrum, but for wider area coverage, that
spectrum, and, to a lesser extent, adjacent 200 kHz slices of spectrum, cannot be reused
until sufficient geographic distances and in some cases, physical obstructions have
intervened. By using 'terrain blocking' (using mountainous terrain to shield
transmissions from each other) and other techniques, it can be possible to reduce the
required re-use distances involved. Nevertheless, numerous 200 kHz wide spectrum
allocations are needed to provide effective national coverage. For example, in the
United Kingdom, BBC national (PSB) services and the national commercial radio
network, Classic FM, each occupy some 2.2 MHz of FM spectrum in order to achieve
the required level of nationwide coverage (Rudd et al., 2000).
DAB Multiplex Networks
By comparison, a DAB multiplex can carry several national services, all within the same
1.536 MHz wide piece of spectrum across the whole of a country; hence the system's
much vaunted relative spectral efficiency. However, such benefits are perhaps more
limited than they might at first appear, because frequency re-use can only occur if all the
programming carried on all services across the multiplex network are identical to each
other all of the time. It is not possible to deliver 'opt-out' services on selected
transmitters in the multiplex without 'breaking' the network and causing interference
between overlapping DAB transmissions.
Areas of Low Demand
Where insufficient services exist to fill a complete DAB multiplex, or in areas where the
coverage requirements of individual services diverge considerably, the effective spectral
efficiency of DAB multiplexes inevitably declines. Because the spectral occupancy of a
DAB multiplex is always 1.536 MHz, unless a sufficient number of services are using it,
in any given area, it might remain more spectrally efficient to stick with traditional
analogue FM delivery instead. For services covering divergent geographical areas, a
DAB multiplex has to deliver all services to the entirety of the geographical area
concerned, occupying spectrum unnecessarily and delivering services beyond their
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required service areas at an inevitable additional cost to each of the broadcasters
involved.
Other Issues with DAB Technologies
Despite its various apparent advantages, the wide-band multiplex approach of DAB is
not therefore without its problems. The multiplex approach, which forces all stations
into achieving similar coverage, can variously result in the creation of both regulatory
and competitive economic issues.
For example, in a major analogue broadcasting market, some stations will typically have
benefitted from better frequencies (less impacted by interference) and achieved better
coverage than others (due to greater permitted transmitted power and / or higher
site(s)), facts often reflected in such stations achieving a larger share of the available
audience and consequently, for commercial stations in particular, creating a greater
market value for themselves. Were this analogue market to be replicated in the digital
domain, using DAB, it would result in a complete change in the established order
within it. Those established technical competitive advantages, based primarily on the
relative scale of individual station coverage, would be removed at a stroke, 'levelling the
playing field' to the benefit of previously smaller stations. It is perhaps primarily this
issue that made the American National Association of Broadcasters (NAB), after
originally expressing an interest in DAB, eventually come out against its introduction in
the USA (Anderson, 2011: 40).
Where it has taken place, the introduction of DAB was, at least in part, often driven by
the need for additional broadcast radio carrying capacity. However, although DAB can
increase the number of services available in a given area, its introduction does not make
availability of frequencies unlimited. From a regulatory perspective, because of
competing demands from non-broadcast spectrum users (mobile phone companies /
Internet service providers / television broadcasters / safety of life systems / military
communications etc.) the number of DAB multiplexes available in a given area will
inevitably be constrained by wider spectrum allocation policy.
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Although it may be possible to provide some new local licences beyond those that
traditional analogue systems could provide, delivering these stations precisely towards
their individual target audiences within the overall geographical areas served by the
multiplex becomes impossible. Because every station in a multiplex serves a similar
service area, coverage can be either inadequate or overspill into unwanted areas. In some
cases, it can be weak in some wanted areas and overspill into conversely unwanted areas,
sometimes encountering both such issues at one and the same time.
DAB 'Gatekeepers'
Another regulatory concern is often described as the 'gatekeeper issue'. Because all
stations broadcast within a particular multiplex, their signals must first be combined
into a single stream of data for onward transmission, typically by a third party
transmission provider or multiplex provider. This party has direct control over the
programming content of the individual broadcaster before it reaches the transmitter
site(s).
Not only do such gatekeepers ultimately have the ability to control access to the
airwaves, but they may also use their position to impose additional operational costs
onto individual broadcasters. Although it would be possible for broadcasters, on a
shared basis, to be the owners and operators of their own DAB transmission facilities, in
relation to existing DAB multiplexes, the standard practice in the UK is that a thirdparty technical service provider typically plays both such roles. Such operators have
advantages of scale and capacity, which are difficult to replicate within smaller
organisations.
Contracting out technical support to a third party certainly has its advantages (for
example, in terms of reduced in-house technical capacity requirements), but it inevitably
comes at an added recurrent operational cost for the broadcaster concerned. This is
particularly the case where circumstances result in a single such entity dominating the
market. In the United Kingdom, following a review of the market by Ofcom during
2004 and early 2005 (Ofcom, 2005 (a)), in 2008, the Competition Commission
allowed the merger of National Grid Wireless and Arqiva (Arqiva, 2015), bringing the
former BBC transmission network and other former public sector communications
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network infrastructure under the same ownership as that which already controlled the
former Independent Broadcasting Authority's technical networks. This despite the fact
that the commission had concluded that:
the merger of the two companies would lead to a “substantial lessening” of
competition in broadcast transmission services [and] would lead to a
worsening in the price and non-price factors … in the provision … to radio
broadcasters (OTA - BTS, 2008).
From a systems perspective, multiplex DAB transmission technology is inherently more
complex than are the stand-alone analogue transmission platforms it is intended to
supplement, or, eventually, replace. Individual broadcasters (especially smaller ones) can
often lack the required technical competencies and financial capacities to own and
operate such systems themselves, preferring instead to 'contract out' such
responsibilities. As a result, facilities providers (such as Arqiva) are in a strong position
to be able to operate such systems at considerable profit. In some cases, as a result, the
third-party transmission provider may, potentially, become the de facto single point of
profit extraction in the value chain.
Thus, this provision of transmission facilities on a for-profit basis to individual
broadcast stations and radio groups can result in the broadcaster running at a loss, but
the transmission provider can always ensure its income stream is prioritised because no
alternative delivery solution is available to the broadcaster. Even when scaled down for
reduced geographical coverage, this traditional approach is still considered by many
operators to be too expensive for their smaller scale commercial or community-based,
not-for-profit, operations.
Audio Quality
Leaving to one side, arguments about the relative merits of analogue and digital sound
outputs, even using the original MPEG 1 Layer II audio standard, it is perfectly possible
to deliver very high quality audio programming over DAB. However, because
commercial transmission providers will typically change per bit-rate used, broadcasters
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will often attempt to save money by reducing the bit rate at which they broadcast at the
expense of received audio quality.
"The promise of DAB was that it would provide better technical quality than FM"
(Pickering, 2002: 27), and early documentation envisaged DAB multiplexes carrying
most stereo services operating at 192 k/bits per second, with mono services consuming
up to 96 k/bits per second (Bower, 1998). Today however, the typical bit-rates used are
considerably lower. For example, in the United Kingdom, Ofcom will permit the use of
128 k/bits per second for full-bandwidth stereo services and will allow restricted
bandwidth speech-based services to operate using as few as 48 k/bits per second (Ofcom,
2012: 6).
The Digital Cliff Edge
One final fundamental difference between DAB and analogue transmission systems is
the existence of the so-called 'digital cliff edge'. Traditional analogue radio services
deliver what is known as a 'graceful fade', which means that as a radio signal becomes
weaker, it typically becomes noisier and noisier before fading completely into the
background noise (hiss) on its operating frequency. All forms of digital transmission
system (including DAB) do not exhibit such behaviour. The received quality of digital
transmissions typically remains consistently high (without audible background noise) in
all locations where the transmitted signal strength is greater than a specific minimum
level and where unwanted levels of interference are below a specified maximum level. As
soon as that transmitted signal strength, or field strength, falls below the required
minimum level, reception fails very rapidly – the signal falls over the 'digital cliff edge'
and is no longer audible.
For broadcast planners, this fundamental difference in behaviour creates specific
practical difficulties, particularly on frequencies that are used to deliver separate sets of
programming to different geographical areas. As previously noted, separate transmitters,
each broadcasting an identical set of programming within a DAB multiplex, can all
operate on the same 1.536 MHz block of frequencies. If the same block is used to
broadcast different sets of programming to different geographical locations, the
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unwanted signals from one area need to be very weak within the coverage area of the
wanted signals or interference and signal degradation will result.
The problem for planners is that the level of unwanted signals that can damage a set of
wanted signals is significantly lower than the signal level at which DAB signals become
impossible to receive on a standard DAB radio (the useable reception radius is smaller
than the signal's impact radius). In practical terms, this means that a given block of
frequencies can only be re-used to broadcast different programme content a significant
distance from the original transmission coverage area. Once again, therefore, the
spectral efficiency of the DAB model becomes degraded as a result of this requirement.
Intellectual Property Issues
When the original DAB standard was introduced, the MPEG 1 Layer II (MUSICAM)
Audio compression system it uses was considered advanced and was covered by
intellectual property rights, which required a royalty to be paid for its use by
broadcasters. This royalty was recovered through a charge paid by transmitter
manufacturers and through a levy on each individual receiver chip-set. Although the
more modern MPEG IV AAC+ audio compression standard used in DAB+ remains
protected through intellectual property rights, this is no longer the case for MPEG 1
Layer II audio. More broadly, the last patent relating to the original Eureka 147 DAB
standard expired in January 2013; as a result, transmitter manufacturers can now build
DAB equipment royalty free (WorldDMB, 2013).
Maturing Technology
Not only can DAB transmitters be manufactured without intellectual property
overheads, in the twenty or so years since its introduction, DAB signals have become
substantially easier to generate, largely due to various advances in the wider field of
computing. Taken together, these factors have substantially reduced the economic and
technical barriers to entry for those interested in implementing DAB transmissions.
Continued Demand
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Although radio broadcasting continues to face an increasing number of challenges in
terms of alterative methods of audio delivery, as a medium, it remains stubbornly
popular. For example, between 2007 and 2012, levels of weekly listening, or 'weekly
reach' (the percentage of the total population listening to radio in a week), reduced from
89.8% to 89.6%. In 2010 and 2011, it was actually higher at 90.6% and 90.8%
respectively (Radio Joint Audience Research (RAJAR), quoted in Ofcom, 2013: 213).
Specifically in relation to DAB, listening to services via the platform accounted for
22.5% of all UK radio listening during the first quarter of 2013 (ibid., 227), whilst
receiver ownership in the UK has increased from 8.1% in early 2005 to 44.3% in early
2013 (ibid., 228).
New Approaches to DAB Broadcasting
It is clear from the above that the environment in which DAB broadcasting operates has
changed dramatically over the lifespan of the technology to date. Demand for access to
broadcast radio frequencies remains strong and DAB technology in its basic form is now
both mature and devoid of intellectual property rights issues. As a result, new
approaches to the use of DAB have emerged, both in terms of technical and policy
approaches.
Small-scale Digital Audio Broadcasting
By 2004, DAB was well established across the United Kingdom, with a considerable
number of both BBC and commercial radio services available to the vast majority of the
population (Ofcom, 2004(e): 28-38). However, given the various limitations discussed
above, there were no clear opportunities to employ the technology effectively for smaller
scale broadcasters. As a result, from the outset, Community Radio found itself limited
to what little broadcasting spectrum remained available within the analogue
broadcasting domain.
Legislative Approaches
In legislative terms, because the Community Radio Order (2004 and subsequent
iterations) is secondary legislation amending the Broadcasting Act (1990), it only
permits the initial licencing of such services on analogue spectrum. This is because the
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1990 act provides the legislative framework for UK analogue radio broadcasting only;
the parallel Broadcasting Act (1996), which provides the equivalent legislative
framework for the licensing of digital (DAB) broadcast radio services, has not, to date,
been amended to facilitate the licensing of digital Community Radio services.
That said, because of the way in which DAB licencing operates in the United Kingdom,
any Community Radio broadcasters (with or without an analogue Community Radio
licence) could still apply to operate on DAB. The interrelated practical barriers to takeup have always been in relation to availability, cost and scale, gaining access to available
DAB capacity on a multiplex providing appropriate coverage and at a realistically
sustainable cost. If these can all be overcome, obtaining the required Digital Sound
Programme Service (DSPS) licence is a relatively simple administrative process, merely
requiring the completion of a short application form and the payment of a minimal
application fee and subsequent annual licensing fee.
Practical Obstacles
In practice, however, such opportunities as exist have rarely been taken advantage of
and, at the time of writing, only three Community Radio stations were broadcasting on
permanent DAB multiplexes in the United Kingdom. As Ofcom recognises,
historically, DAB capacity has been limited, coverage has been of large-scale areas
(typically county-sized and above) and annual rental costs have typically been in the
range of £3,500 to £5,000 per month (GetMeOnDigitalRadio, 2015), far higher than
the equivalent cost of achieving similar coverage using analogue, FM, transmissions.
The various limitations and issues intrinsic to traditional approaches of DAB delivery (as
summarised above) have, to date, made its application to small-scale commercial and
community-based broadcasting problematic. However, from a regulatory perspective,
the result is a tranche of stations with no apparent access to digital broadcasting
spectrum:
There are currently around 350 licensed community and small scale local
commercial radio services in the UK that are not currently broadcasting on
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DAB. This is primarily because either there is no capacity available on a
local multiplex, or the cost of carriage is beyond the means of small stations.
In addition, the coverage facilitated by the existing local multiplexes is
usually significantly greater than the existing analogue coverage areas of
smaller radio services. As such, these stations do not currently have a viable
means to access the DAB platform, should they wish to do so
(Ofcom, 2014 (b): 1).
With analogue frequency resources virtually exhausted and the traditional approach to
DAB transmissions proving an unpopular and impractical option for the vast majority
of smaller scale broadcast providers (both community-based services and private
commercial stations), demand for broadcast radio licences nevertheless continues to
show no sign of abating. Looking for ways of satisfying such demand, in 2011, Ofcom
began experimenting with possible alternative approaches to DAB delivery, exploring
options that might be more cost-effective for small-scale broadcasters.
New Technological Approaches
Over recent years, the military, along with licenced radio amateurs and others have been
experimenting with so-called 'Software Defined Radio (SDR) systems. These allow a
computer, often a laptop, typically running a flavour of the Linux operating system, to
act either as a radio receiver or as a radio transmitter (or both).
In receiver mode, an analogue to digital convertor, connected to a suitable antenna,
would convert incoming radio frequency (RF) signals into a data-stream for onward
decoding into audio, etc. One of the key benefits of the SDR approach is cost. In terms
of receivers, for UK £10.00 (under US$20.00), it is already possible to purchase a USB
'dongle' capable of receiving DAB and FM signals (along with DTV) on frequencies
anywhere between 64 MHz and 1.7 GHz (Antoniewicz, 2012). Because, in spite of its
low cost, this is a genuine SDR, it can be reconfigured through software alterations, to
perform a variety of different tasks.
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In transmission mode, a digital signal processor would convert audio into a stream of
numeric data that would then be sent to a digital to analogue convertor. This would
then output a very low-power RF signal, which would then be amplified to a useful level
and filtered to remove unwanted frequencies before being radiated from a suitable
antenna. There exist a variety of SDR hardware capable of creating low-power DAB
signals suitable for amplification and subsequent broadcast. For example, the US-based
company, Ettus Research (a subsidiary of National Instruments), offers a variety of
hardware that can be used to generate DAB signals (Ettus Research, 2014).
SDR DAB Experiment - Brighton
Between late 2012 and early 2013, the UK broadcast regulator, Ofcom, allowed one of
its engineers, Rashid Mustapha, to operate experimental DAB transmissions from a
single transmitter in Central Brighton under a non-operational Test & Development
Licence (Ray, 2013 and Mustapha, 2013). Taking an open-source technology, software
radio-based approach, the equipment used was primarily based on software originally
developed by the Canadian Government-funded Communications Research Centre and
released under a GPL in 2009 (Mustapha, 2013: 6). Although the CRC project is now
defunct, its work has been taken over and further developed by Open Digital Radio
(ODR, 2015) (www.opendigitalradio.org/) a non-profit association based in Geneva,
Switzerland, which has also worked closely with the European Broadcasting Union to
take the project further forward (EBU, 2010).
Hardware Considerations
The objective of the experiment was "to inform policy makers of the practicalities of
low cost DAB solutions when used to serve small areas, particularly from a single
transmitter" (Mustapha, 2013: 1). Beyond the use of low-cost SDR equipment,
crucially, the experiment also considered the wider transmission infrastructure required,
right through to the antenna and including traditional high-value capital items, such as
power amplifiers and RF filters (ibid., 8-10).
Regulatory Compliance
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International regulation requires that all DAB transmissions must fit within a defined
'spectral mask', in other words radiated RF energy must be constrained to specific
maximum levels across a range of frequencies. Any energy radiated outside the spectral
mask makes the installation non-compliant. Energy radiated outside the confines of the
spectral mask is deemed to risk causing interference to other licensed spectrum users.
High-power DAB Compliance
By their very nature, high-power transmission systems inevitably have the ability to
cause greater levels of unwanted interference to other spectrum users than low-power
installations are intrinsically capable of. Again, by their very nature, high-power
transmission systems also consume more power than smaller installations, so system
efficiency becomes a key consideration. In traditional high-power DAB transmission
systems, it is therefore essential to employ efficient amplification followed by complex
(and therefore expensive) RF filtering. However, the 'law of diminishing returns'
applies, and the capital costs associated with maximising efficiency, whilst still
minimising the potential for interference, are inevitably high.
Low-power DAB Compliance
In a low-power context, there are, as the Brighton experiment showed, ways to reduce
the capital costs involved. Operating RF amplifiers at considerably below their rated
power output minimises unwanted RF signals; however, it is inefficient in terms of
power consumption. In high-power systems, such an approach would be very expensive
in terms of both the capital costs involved (building power amplifiers with considerably
greater maximum power capacity than would be used in practice) and in terms of
electrical supply consumption in use. However, at lower power levels of, say, below
approximately 100 Watts, the extra capital costs are not particularly great and overall
power consumption not too high either (ibid.).
Transmission Site Considerations
The experimental installation was co-sited with a local FM commercial radio transmitter
on top of a large residential tower block in the Centre of Brighton on the South Coast
of England. The transmitter was fed at different times via either a low-cost Wi-Fi link
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or via a public Internet connection (ibid., 12). One of the key conclusions of the report
published after the experiment was "the importance of 'site over might'" (ibid., 1):
Low power transmitters sited in urban population centres can often deliver
the field strengths required for reliable indoor reception much more
effectively than might be achieved with a higher-powered site on the
periphery of the population centre (ibid.).
Because the site was in the centre of a built-up urban area, there were concerns that the
presence of this new DAB signal might degrade local reception of existing DAB services
being broadcast on near adjacent frequencies, resulting in Adjacent Channel Interference
(ACI). However, the report into the experiment found that although such issues were:
… anticipated and thoroughly checked for, … none was (sic) found. It seems
that ACI 'holes' are not created by low power DAB transmitters sited in an
area where the wanted signal levels from other multiplex services transmitted
from elsewhere are sufficiently high (ibid.).
Cost Considerations
In terms of operational costs (incorporating initial capital outlay over the period of
operation), the Brighton study notes that:
Small scale FM stations spend circa £10,000 per annum on FM transmission
which is many times less than the current DAB network carriage costs - even
for a low quality monophonic digital service
(ibid., 22).
The study goes on to suggest that using similar techniques to those employed in
Brighton, a complete single-site, low-power DAB installation should be able to operate
at similar cost to an equivalent FM installation (ibid. p 23). Taking such a softwarebased approach results in the capital costs of DAB installations becoming dramatically
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lower than was previously the case when using traditional bespoke hardware
implementations.
Typical costs of a software-based multiplexer, transmitter, filters and antenna for a
simple, single-site installation are now estimated to total only around UK £6,000 (under
US$10,000). Ofcom estimates that the total annual operating costs of a small-scale
DAB multiplex (using a single 100-Watt transmitter) total just under UK £9,000
(under US $15,000) (ibid., 23). If these costs were to be shared across a number of
stations, they could result in per-station annual costs of around UK £1,400.00 per
annum (approx. US $2,000.00) for a relatively high quality service (at, say, 160 k/bits
per second) (ibid.).
Critically, the initial Brighton test gave Ofcom the confidence to state that:
The experiment demonstrated that a stand-alone Software Defined Radio
approach to DAB multiplexing and transmission can deliver high
availability and high quality results at costs that are near to parity with an
FM transmitter system carrying a single service (ibid.).
Further Testing
Although these early tests "demonstrated that it is feasible to deliver DAB
transmission infrastructure at much lower cost than currently required" (ibid., 1)
and could work reliably, there were elements of the prototype system that required more
work in order to meet the operational requirements of professional broadcasting.
Importantly, aside from the technical developments achieved by building on the
international development of open source approaches to DAB transmission, the 2012 /
2013 Brighton Experiment also successfully interfaced such work with the interests of a
national broadcast regulator. The report is clear that more regulatory work also needed
to be done in various areas (for example in relation the availability of suitable spectrum
(ibid., 1)). As a result, in early June 2014, the UK broadcast regulator, Ofcom,
announced at a 'Small Scale DAB Stakeholder Event' that such further work would be
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carried out over the coming two years, through into 2016. The regulator formally
consulted on the issue four months later, in October 2014 (Ofcom 2014 (b)).
At the 'Small-Scale DAB Stakeholder Event', the objectives of the next stage of research
were stated as being:
(1) To further test the practicality of implementing the approach used in the
Brighton trial.
(2) To design an appropriate licensing framework which would enable smallscale DAB services to be broadcast (Ofcom, 2014 (d): slide 3).
After completion of the consultation process and discussions with the Department for
Culture, Media and Sport (DCMS) (the government department responsible for overall
broadcasting policy), early in 2015, Ofcom gave the go-ahead for a further series of ten
public trails of low-cost, small-scale DAB across the UK (Ofcom, 2015 (f)). The trials,
carrying a range of community-based services and commercial stations, were initially
expected to operate for a period of nine months, through into early 2016. Noting that
"There's been huge interest in these trials, which are another step in bringing new
local services to digital radio listeners", Peter Davies, Ofcom's Director of Content
Policy, observed that "Ofcom is helping unlock the potential of this new approach
and, if it proves successful, millions of radio listeners could benefit right across the
UK" (ibid.).
In order to move forward with the possible development of permanent small-scale DAB
services quickly, Ofcom wanted to evaluate low-cost approaches to its delivery, on a
time-limited basis. The regulator therefore took the view that even at the minimal levels
of capital outlay required (as above), it would be unreasonable and economically
unviable to ask potential operators to invest in equipment that might only be used for a
brief period of time.
In order to expedite the establishment of the trials, Ofcom will provide
licensees of the trial with the majority of the equipment needed to establish
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the multiplex and each transmitter. … we want to ensure that small services
are not prevented from applying to participate in the trials by the cost of
procuring the radio equipment (Ofcom, 2014 (b): 21).
This move certainly provided Community Radio broadcasters with a greater confidence
to become involved in the trials, but it was only made possible due to the fact that the
proposals for these trials fitted neatly within wider government objectives to promote
the uptake of digital broadcasting technologies. As a result, the DCMS provided
"funding to Ofcom over two years to build on the work of a trial of low cost DAB
technology conducted in Brighton" (ibid.). This financial support was dispersed
through Ofcom, to cover the vast majority of capital infrastructure costs, as well as
contributing to one of the most significant on-going operational costs, that of reliable
Internet streaming connectivity between individual broadcasters and their DAB
multiplex transmission site(s) (Ofcom, 2015 (g)).
When, in 2014, Ofcom first proposed additional trials of small-scale DAB, the intention
was that these would take place at only three locations. The increase to ten came as the
result of industry pressure in response to the formal consultation undertaken by the
regulator:
The most frequent comment from respondents was that three trials are not
sufficient to constitute a robust evidence base, … In light of the responses and
interest from stakeholders, we agree that conducting more trials would
strengthen the sample size and provide us with more data (Ofcom, 2014 (b):
7).
Increasing the number of trial installations not only provided the regulator with greater
opportunities to gain more experience of the operations of software-based DAB
transmission systems, but also, it provided more opportunities for Community Radio
operators to become involved and learn from the experience. Some, such as Future
Radio in Norwich and NuSound Radio in East London 'contracted out' their DAB
delivery to a third party. Others, such as Angel Radio in Portsmouth and British Forces
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Broadcasting Service (BFBS) in Aldershot, chose to take direct control of the multiplex
themselves.
Since the completion of the original Brighton test, considerable technical improvements
have been made in the transmission software used. For example, it is now possible to
operate the software to deliver single frequency network (SFN) operations, using
multiple transmitters on the same frequency at diverse locations, to enhance overall
coverage. Technically, the expansion in the number of trials also provided greater
opportunities to test such operations as well as the use of on-channel repeaters. In
addition to the various single transmitter systems being used, the trials operated by UDAB in London and Scrimshaw's Information Directories in Glasgow both broadcast
via a two-transmitter SFN. Meanwhile, in Cambridge, the trial operated by UK Radio
Developments (UKRD) employed an on-channel repeater to fill specific gaps in
predicted coverage from the main transmitter (Ofcom, 2015 (h)). For small-scale DAB
to be successful in the longer term, the robust operation of such operational techniques
is an essential prerequisite.
Technical developments aside, Ofcom also had to consider longer-term approaches to
the licensing of smaller scale DAB services. Part of the reason for running a diverse
range of trials was therefore to explore alternative operating structures and financial
models. For example, the trial in Portsmouth (Hampshire) is being operated by the
local Community Radio service, Angel Radio. Conversely, along the coast, in Brighton
(Sussex), the tests are being operated by the local, small-scale commercial radio operator,
Brighton and Hove Radio. Meanwhile, the tests in Norwich (Norfolk) are being
managed by a separate, not-for-profit company, Future Digital Norfolk Limited,1 set up
specifically to operate small-scale DAB facilities in the East of England (ibid.).
The core, underlying justification for completing these trials is the degree to which
demand for small-scale broadcasting opportunities continues to outstrip supply. As
previously discussed, with analogue (FM) spectrum now filled to capacity in most urban
1
The author is a Director of Future Digital Norfolk Limited, the not-for-profit company set up to
provide DAB services for Norwich as part of the Ofcom small-scale DAB trials.
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and suburban locations across the UK, small-scale DAB offers at least the potential to
help redress the balance, by improving supply-side capacity. According to Ofcom, "If
the trials are successful, UK listeners could benefit from hundreds more local and
community radio stations on digital radio in the future" (ibid.).
Across the ten DAB trials, Ofcom expected some 60 individual radio services to be
broadcast. This means an average of six services per multiplex, an occupancy rate
notably below the average number of services carried on the majority of established
multiplexes. For example, the national BBC multiplex typically carries between nine
and twelve services (depending upon programming demands). The lower number of
services carried provides opportunities for broadcasts at higher bit rates, improving audio
quality as a result. In discussions with the author, Future Digital Norfolk's Managing
Director (and Chair of Future Projects, the charity operating Future Radio), Mike
Stonard, explained:
Because we're a not-for-profit company, using low bit rates to squeeze in as
many services as possible is not our objective. We believe that listeners
appreciate high quality audio. All of our permanent services will typically
operate at between 128 and 192 kilobits per second (Stonard, 2015).
From the date on which Ofcom offered licences, in mid June 2015, operators were
given a maximum of twelve weeks to launch their respective trial services. Installations
were carried out by individual licence holders, typically with the aid of third-party
engineering support and inputs from Ofcom engineers. Each of the multiplex operators
is reporting to Ofcom on a regular basis and the regulator is also running a series of its
own independent technical compliance checks, for example to ensure that reception of
existing DAB services is not impacted by receiver overload or adjacent channel
interference (ACI) close to any of the new transmission sites. A decision on how best to
move forward with long-term, small-scale DAB licensing is expected to be taken after
the trials are completed, in 2016.
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In structuring the current DAB trials, Ofcom has clearly been mindful of not appearing
to prejudice them in favour of either Community Radio services or private commercial
radio stations. The stations' broadcast across the ten trail multiplexes are split quite
evenly between these two types, supplanted by a variety of new services (e.g. Angel Xtra
and Future Plus), established Internet stations (e.g. Solar Radio and CDNX) and
student broadcasters (e.g. Brighton City Student Radio) (Ofcom, 2015 (h)). From a
Community Radio perspective, the trials have not only benefitted various current
stations already broadcasting on FM; more fundamentally, if successful, the trials offer a
potential route for a wider expansion of the sector and a way out of the potential
'analogue backwater', should DAB become the dominant broadcast radio platform in
years to come.
DAB Summary
Since its emergence in the mid 1990s, DAB has made material progress in a number of
jurisdictions. A limiting factor has been the fact that 'bolting on' DAB to network
topographies originally designed for use by traditional analogue FM transmissions
inherently limits the availability and suitable spectrum, and the flexibility in its use.
Taking a more 'cellular' approach to the provision of small-scale DAB transmissions
looks as though it might overcome some of these limits and finally allow low-power,
community-based and independent commercial services to find space on a broadcast
digital radio platform.
The work being carried out in the UK, as well as more widely internationally, will help
both define the degree to which small-scale DAB services may be implemented in the
future and will continue to enhance the performance and cost effectiveness of low-cost,
alternative methods of DAB transmission. Spectrum availability issues remain of some
concern, and there is no suggestion that the possible introduction of low-power DAB
transmissions would be a panacea for the Community Radio sector, or for independent,
small-scale commercial broadcasters, currently unable to access a digital radio
broadcasting platform. However, in some cases at least, it may create additional
broadcasting opportunities, which would not otherwise exist for some such operators.
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The transition to digital technologies "creates both opportunities and challenges for
community broadcasting" (Hallett & Hintz, 2010: 159); however, changing
technologies "may also create space for new regulatory regimes that could benefit
community radio and grassroots media practices" (ibid.). The established mainstream
approach to DAB radio has tended to "contradict the low-cost, bottom-up and
participatory approach of community radio" (ibid.). Now, however, it appears that
circumstances have the potential to change, perhaps making a modified form of DAB a
great deal more suitable for use by the Community Radio sector.
Online Delivery
Alongside the development of platforms specifically designed for broadcasting purposes,
new media technologies have also been impacting on the operation of broadcast radio.
Not only do the Internet and the mobile phone provide alternative platforms for the
delivery of linear radio in real time, but they also provide opportunities for the delivery
of radio, which is directly linked to other types of media content, and which include
'on-demand' elements that can be both time-shifted and non-linear, such as 'listen
again' services and 'podcasts'.
Although the use of such non-broadcast platforms can provide broadcasters with
additional flexibility, they do not yet constitute a replacement for traditional broadcast
platforms. There are several reasons why this is the case. For example, unlike one-tomany broadcasting platforms, both the Internet (as currently constituted) and the
mobile phone networks are primarily designed as one-to-one communications
platforms. In addition, for radio station operators, the economics of broadcasting are
fundamentally very different from those associated with alternative (non-broadcast)
platforms. Whereas broadcasters pay for range regardless of listenership, delivery via the
Internet and mobile phone means paying on a per-listener basis regardless of where a
particular listener might be in the world.
For the listener, at present, mobile phone and mobile Internet platforms lack
universality, and tend towards end-user cost models, which discourage the consumption
of large amounts of data. However, it is clear that as the carrying capacity of mobile
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phone networks is enhanced, and as improved methods of mobile Internet delivery such
as 4G and 5G are implemented fully, this situation will eventually change. In some
jurisdictions 'all-you-can-eat' data tariffs are already becoming available (although
connectivity and capacity both remain potential stumbling blocks to reliable portable
and mobile reception). Nevertheless, convergence between broadcasting and both wired
and wireless communications platforms is already happening and as a result, after a long
period of relative inertia, radio broadcasting is currently experiencing a period of ongoing change.
Although online broadcasting (streaming audio) has increased in popularity over recent
years, it remains very much a minority pursuit. According to the latest Ofcom survey
figures available for the United Kingdom:
In the 12 months to June 2014 the most widely-used method of listening to
digital radio was via a DAB set (65.3% of digital listening), while 16.3% of
digital listening was online or via apps (Ofcom, 2014 (c): 4).
Over the same period, "digital listening (including DAB, DTV and online) accounted
for a 36.3% share of all radio listening hours" (ibid.), thus 16.3% of digital listening
equates to just 5.9% of all measured UK radio listening (analogue and digital). That
said, the amount of online listening had almost tripled since Q1 of 2009, when it stood
at 2.2% of all radio listening hours (Ofcom, 2010 (a): 10) and the latest Radio Joint
Audience Research Limited (RAJAR) data estimates that by Q1 of 2015, this figure had
increased to 6.8% of all listening, the equivalent of some 69 million listening hours
(RAJAR, 2015).
Earlier data is not in the same format but, according to RAJAR, between March 2000
and June 2004 (the earliest dates for which information is available), the percentage of
people who had ever listened to radio online grew from 3.3% to 15% (RAJAR, 2004).
However, one thing that all these figures for online listening do not take into account is
the arrival of music streaming services, such as Pandora, Last FM, Spotify and, most
recently, Apple Music:
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Some 14.8 billion tracks were played in 2014 – almost double the level
recorded in 2013 – and in the first six months of 2015 the total has already
reached 11.5 billion (BPI, 2015).
The above figures show how the establishment of permanent Community Radio services
in the UK since 2004, occurred in parallel with the emergence of online radio listening.
Specific figures relating to consumption of Community Radio content via the Internet
are less easy to come by. However, an analysis of community stations in the United
Kingdom, carried out in relation to this thesis, showed that of the 135 full-time
community radio stations broadcasting as of May 2009, all but two had websites and no
fewer than 120 (89%) were streaming their output in real time. Despite UK copyright
restrictions, which prevent community stations from providing 'listen again' services or
'podcasts' that include copyrighted music content, 47 of these stations (35%) also
provide some of their output either in 'podcast' form or as streamed 'listen again'
output. These figures clearly demonstrate that, despite the costs involved and the legal
limitations placed upon certain aspects of Internet programme delivery, at least in a UK
context, Community Radio stations are committed to the use of new delivery media
alongside traditional analogue broadcasting.
Internet streaming, listen again services and podcasts are fundamentally more than
additional ways of delivering broadcast radio audio. Firstly, they provide the potential to
enhance the 'listening' experience through the delivery of additional textual and visual
materials alongside the original audio content. More importantly, however, because
they allow the delivery of broadcast audio beyond the range of the traditional broadcast
transmitter, they also change the nature of the audience involved.
Post Switch-over
Working towards the migration of larger radio services to digital radio platforms, such as
DAB, the government and Ofcom have been somewhat vague about the exact timescale
for such a move, although it is expected within the next decade. However, a 'switch
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over' for major broadcasters certainly does not equate to a 'switch off' of analogue radio
broadcasting as a whole:
It is anticipated that all large scale radio stations will migrate to digital and
eventually cease to broadcast on analogue FM radio. Smaller stations are
expected to remain on FM. … This is expected to free up as much as 50% of
the capacity currently used to deliver FM radio services and has raised
questions as to what this capacity will be used for (Ofcom, 2011 (e)).
Pressure for a total switching off of all analogue radio broadcasting is limited because,
unlike in the case of the spectrum released following the digital switch-off of analogue
television when all such services became digital, the spectrum used for analogue FM
(and AM) broadcasts falls outside the 'sweet-spot' range of frequencies of greatest utility
(and therefore value) to mobile operators. Although this does not mean that there are
no alternative uses for the spectrum, it does mean that the opportunity costs of
continuing to use it for broadcasting purposes are much reduced.
There are, however, other drivers behind the move to migrate major services to digital,
not least pressure from major broadcasters wishing to reduce their operating costs
resulting from the concurrent 'simulcasting' of identical outputs on both analogue and
digital platforms. Additionally, such organisations are anxious to avoid the capital
investment required to replace existing, old (often life expired), high-power analogue
broadcasting transmission infrastructure.
One other potential use of the FM spectrum in particular might be for 'white space'
devices, which could "work along side existing smaller FM radio stations" (Ofcom,
2011 (e)), "to deliver innovative applications such as mobile broadband in very
sparsely populated areas" (ibid.).
Compared with other forms of wireless technology, such as Bluetooth and WiFi, White Space Devices are being designed to use a much wider range of
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frequencies, including the lower frequencies that have traditionally been
reserved for TV and radio (ibid.).
Pirates Ahoy?
So far in this chapter, the issue of unlicensed, or 'pirate' broadcasting has not been
discussed. However, it is already clear that should more FM spectrum become available,
there will be those seeking to occupy it without first obtaining a broadcasting licence.
Although somewhat presumptive in its use of language in the present tense, there is no
doubting that there is some truth in the observation that:
Pirates, however, have refused to go quietly, instead racing to repopulate the
FM dial as traditional stations continue to close down (Callaghan, 2015).
Perhaps demonstrating a slight degree of 'regulatory capture', Ofcom's Chief Executive,
Ed Richards, also tacitly acknowledged this issue in 2011, observing that such
technology could help ensure that it was less likely for the FM band to be:
… backfilled with new commercial and pirate radio stations. … White
Space Devices offer a creative solution that would not only use spectrum to its
full capacity, but would also work along side existing smaller FM radio
stations. This could be done without causing interference and without any
commercial conflict (Ofcom, 2011 (e)).
As part of the process of developing an approach to the future use of the FM spectrum,
post a possible 'digital switchover', the fundamental capacity shift will need to be
considered carefully. Allowing a large number of new, small-scale commercial stations
could damage the viability of some existing services as a result of increased competition
for finite advertising revenues. However, if, instead, spectrum capacity were to be
allocated to additional Community Radio services, the relevance of a licensing regime
originating in a time of spectrum scarcity might be open to question. Coverage areas
could potentially be expanded, for example benefiting stations such as NuSound Radio,
with its geographically spread ethnic minority target audience. Alternatively, there may
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be a case for relaxing licensing rules further and allowing other forms of 'alternative'
provision to emerge, perhaps bringing at least some of the current unlicensed
broadcasters into formal structures more suited to their approach.
Governments in many parts of the world are now predicting a future in which the vast
majority of broadcast radio services will have migrated to digital. For the foreseeable
future at least, talk of a complete 'analogue switch off' is wide of the mark, but there is
no doubting the sincerity of those in industry and the government, who foresee the
closure of expensive high-power AM and FM transmission networks. The net result of
any such moves would be an increased availability of FM spectrum for other uses,
including, for example, additional Community Radio services as Ofcom noted in 2011:
There must be certainty for smaller and community stations, that do not
move across to DAB. These will continue to play their important role, and
FM is an appropriate technology for the scale at which they operate (ibid.).
Due to its relative success in rolling out DAB radio services and in building listenership
for them, the United Kingdom is one of the countries in the vanguard of digitising its
broadcast radio services. The vast majority of jurisdictions have yet to make similar
material progress in moving towards digitising their broadcast radio services, but in
Norway, the government has articulated a similar approach to that of the United
Kingdom, migrating larger scale services, such as NRK and commercial networks, but
leaving local and community-based services on FM for the foreseeable future.
Conclusions
This chapter has shown how, from a technical perspective, existing patterns of usage
have limited the growth of Community Radio in the United Kingdom during the first
years of this century. It has also examined on-going attempts to make the dominant
digital radio platform (DAB) more suitable for use by small-scale broadcasters and has
additionally explored the impact of non-broadcast delivery methods. Finally, it has
attempted to outline how current broadcasting policy may, eventually, make room for a
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greater number of Community Radio services using a combination of analogue and
digital frequency capacity alongside supportive, secondary non-broadcast platforms.
A multi-platform future for broadcast radio is, primarily, not simply the result of ongoing competition between alternative delivery platforms and the undecided results
thereof. More importantly, it is a reflection of the expanded scope and diversity of
broadcast radio services. It should not come as any sort of surprise that the technical
needs of major national broadcasters are, inevitably, different from those of local and
Community Radio broadcasters. Just as AM and FM analogue radio systems have
complimented each other over several decades, in the transitional hybrid analogue and
digital future, one digital platform is unlikely to meet the needs of such a diverse range
of broadcasters.
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CHAPTER SEV EN :
Conclusions
In the preceding chapters of this thesis, I have examined the emergence of Community
Radio in the United Kingdom, tracing its development in terms of both theory and
practice and putting this into a wider historical context. I have used various examples to
highlight particular issues and, more generally and where considered appropriate, I have
also drawn upon my own professional practice and auto-ethnographic research to make
specific points and in support, or denial, of particular arguments.
Although the underlying objective of defining the position of Community Radio in
terms of its broadcasting and wider operational objectives remained unchanged,
throughout, during the process of researching and compiling this thesis, the priorities
originally proposed at the outset gradually evolved. As a long-standing practitioner of
Community Media and a former regulator of the sector, I was aware of a variety of core
issues affecting the sector; however, work in relation to this thesis has allowed me to
better understand the relative priorities attached to these by others working in the sector
and to more fully understand some of their impacts on other Community Radio
services.
Community Radio in Context
As with any other medium, Community Radio does not operate in a vacuum; as well as
exploring relevant facets of radio broadcasting history, theory and practice, I have
therefore also attempted to contextualise this research in relation to wider socioeconomic factors.
Chapter one of this thesis provided a broad historical overview of the emergence of
broadcast radio as a technological and social phenomenon. Although concerned with
broadcast radio at a time before the arrival of Community Radio, I have sought to
demonstrate how developments in practice and policy during the early part of the
Twentieth Century have contributed to shaping the wider operational environment
within which Community Radio now operates.
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Chapter two of this thesis continued the historical analysis, but now with a narrower
focus, examining in particular the path taken in the run up to the arrival of Community
Radio, considering in particular the earlier debates over the arrival and development of
BBC and commercial local radio. Once again, I have sought to focus on the way in
which the emergence of practice and policy in relation to local radio, in the period
between the mid 1960s and the late 1990s in particular, helped define the approach
taken to the introduction of Community Radio in the United Kingdom. Also in this
chapter, I have looked more closely at the various unsuccessful attempts to introduce
Community Radio either overtly (as in the case of the abandoned 1985 experiment) or
as part of wider local radio development (as in the case of the IBA's 'Incremental Radio'
experiment a few years later).
A further key focus of this chapter is on the practice of the Community Radio sector
itself in the UK, as this relates to the 'community' element of Community Radio in
particular. It considers how, more generally, the sector developed in the years leading
up to the introduction of permanent Community Radio, examining how earlier, shortterm, community broadcasts, in particular, provided opportunities for the development
of diverse approaches to community involvement.
Chapters three and four of this thesis have covered the theoretical and methodological
aspects of this research. Whereas chapter three outlined the development of Community
Radio theory, arguing that this has been driven by international practice as well as by
local circumstances, chapter four looks at the specific research approach taken in relation
to this thesis, in particular the sources that have informed this thesis, both secondary
and primary.
As I have attempted to show, the theory of Community Radio largely emerged from the
development of practice. The practice of Community Radio warrants theories of its
own because of the way in which it is so markedly different from that of PSB and, in
particular, commercial radio. Thus, from beginnings embedded in other fields of study,
it has gradually evolved into a multifaceted and independent area of academic research.
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Recognising the contested nature of the concept of 'community', theories of
Community Radio continue to develop, taking into account not only the diverse nature
of the sector but also seeking to define its core identity and purpose(s).
Methodologically, this thesis was, perhaps, saddled with too many preconceptions at the
outset. Although my long-standing involvement in the Community Radio sector and
my professional work with Ofcom as the sector's regulatory body were both
undoubtedly useful, they were also problematic, bringing with them various opinions,
which it might have been better not to have held at the outset of the research process. A
good example here might be in relation to my views about commercial radio, which
were not as neutral as they perhaps should have been. Having said that, carrying out
analytical research has revised and informed my views on the sector, adding a dimension
of academic knowledge to my experience as a practitioner and former regulator. I feel
that this experience stands me in good stead, for conducting further research, in the
future.
Chapter five of this thesis was primarily concerned with regulation. It discussed issues
relating to the practice of Community Radio as it has developed in the UK since
permanent services were introduced in 2004. Issues such as individual station funding
and volunteer inputs as well as capability limitations of individual stations were
examined, along with wider sector-related issues, such as relationships with regulators
and other broadcasters.
In particular, this chapter focused on the interconnectedness of regulation to the various
inputs and outputs of Community Radio. For example, issues of viability (input
availability) and output delivery (programmes and 'social gain') are largely dictated by a
combination of regulatory requirements and local competences. Because of the
fundamental impacts they have on the operation of the sector, elements of Community
Radio practice that are more specific to it, such as its unique and diverse funding model
as well as its use of volunteers, have been particularly focused upon.
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Some clear (and interconnected) tensions are apparent in these areas. For example, the
lack of secure funding may impact on the ability of a particular Community Radio
station to provide adequate resources for its volunteers, such that the benefits derived by
those volunteers (be they personal or professional) are not as great as they might be.
However, volunteers are key to a station's ability to deliver its required outputs both in
terms of programming and in relation to the delivery of social gain. Economic issues are
also interconnected with licensing parameters. Coverage and licence duration issues
were explored in terms of how these can limit the degree to which a target community
may be adequately served and in terms of the economic uncertainly that can result
where coverage is considered inadequate or where licence duration makes the mediumto long-term future of the broadcaster appear insecure.
As has been shown, developments in the various iterations of the Community Radio
Order have gradually provided Community Radio services with greater access to
potential commercial advertising and sponsorship income. Whilst this may benefit
some stations greatly (as in the case of Warminster Community Radio) such a policy
shift also brings with it the potential for greater conflicts of interest with small-scale
commercial broadcasters competing for a finite amount of available commercial revenue.
Moreover, in the longer term, changes to the input regime of Community Radio creates
at least a degree of risk that this may be reflected in the sector's outputs. Should
commercial revenue generation become dominant in the future, might this not be
reflected in changes to programme outputs in order to make these more attractive to
advertisers?
Chapter six of this thesis was concerned with delivery platforms, examining the use of
traditional analogue broadcasting platforms, digital broadcasting platforms and nonbroadcast, primarily Internet-based, alternative content delivery mechanisms.
Beginning with an examination of analogue broadcasting, this chapter identified how
prior policy decisions constrained the ability of the regulator to accommodate
Community Radio and how the sector has been required to make use of spectrum
deemed unsuitable for other types of broadcast radio use.
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The limitations of established approaches to DAB broadcasting were also explored in
this chapter, which then went on to investigate Ofcom's on-going, small-scale DAB
trials, which provide the potential to break the current 'log-jam' of frequency availability
for Community Radio in the future, provided the current tests prove successful.
Finally, this chapter explored the impact of non-broadcast delivery mechanisms and the
way in which these are gradually impacting on radio broadcasting. The increasing
importance of such mechanisms since the introduction of Community Radio was noted,
as were some of their weaknesses. Taken together, the overarching conclusions of this
chapter concerned the way in which the technical future of radio broadcasting remains
somewhat unclear, but likely to be more complex than hitherto.
Throughout this thesis, I have also attempted to consider wider socio-economic factors
that have impacted the sector. Although the international element of this research has
been limited, the influence of pre-existing Community Radio theory and practice, as
developed in various other jurisdictions, has also been recognised and taken into account
within this thesis.
Although permanent Community Radio services in the United Kingdom are still
something of a relatively recent phenomenon, this research argues that it is, in fact,
possible to trace elements of its origins back to the earliest days of radio broadcasting.
The research has therefore attempted to trace some of the, somewhat complex, variety of
external factors that have influenced British Government policy and the regulation of
broadcast radio, as these have developed throughout the lifetime of the medium to date.
Historical Considerations
As has been shown, broadcasting policies in different jurisdictions diverged early in the
history of the medium. I argue that the broadcasting policy path set out upon by the
United Kingdom in the mid 1920s provides, in part, an explanation of why it then took
some 80 years for the government to agree to the introduction of Community Radio
services. In addition, I have examined some of the various subsequent twists and turns
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along that path of broadcast radio development, which I suggest have also played a part
in defining the current scope and scale of the United Kingdom's Community Radio
sector.
The Impact of the BBC
When considering the various influences on broadcast radio policy in the United
Kingdom, the dominant constant has to be the existence of the BBC. From its earliest
beginnings, the Corporation has contributed to the development of the government's
thinking. Sometimes, such influence has been deliberate, for example, through its
contributions to official policy debates. At other times, influence has resulted from its
operational practices or through the pursuance of aspects of its own development agenda
(an appropriate example here might be the Corporation's desire to maintain exclusive
radio broadcasting rights within the United Kingdom, something it succeeded in
achieving for nearly 50 years).
Spectrum Availability
A second constant throughout the history of radio broadcasting in the United Kingdom
has been the issue of the radio spectrum; how it is used and who may be given access to
its various resources. Elsewhere in this thesis, I have noted the way in which the
'spectrum scarcity' argument has been used over many decades. Increasing demand for
spectrum from its non-broadcast users has long been a constraint on the expansion of
broadcasting, but it has also been a driver of increased efficiency, improving the diversity
of services that can be delivered within a given block of frequencies. Although sceptical
about early usage of the 'spectrum scarcity' argument, I have also noted that, in more
recent times, this has become a more justifiable argument and one that has clearly
impacted on the capacity available to develop Community Radio services, in the
analogue domain across the United Kingdom.
Commercial Radio
A third and more recent addition to the range of those seeking to influence wider
broadcast radio policy is the commercial radio sector. Particularly since the early 1990s,
through its various trade bodies, it has maintained trenchant views concerning how
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broadcast radio, as a whole, should be developed. Campaigning strongly for greater and
greater relaxation of its own regulatory regime, it has tended to hold trenchant views
about Community Radio, being opposed to its introduction for many years. However,
once recognising that such services would arrive, it then changed tack to argue, initially
at least to considerable effect, for strong and distinctive regulation of the new third tier
of radio broadcasting.
Whilst the commercial radio sector's views about Community Radio are understandable
on the grounds of 'unfair competition', it is my view that its concern over Community
Radio has largely proven to be misplaced. Greater threats to commercial radio lie
outside traditional broadcasting. Recent examples of collaboration between the
commercial stations and Community Radio, for example in relation to the on-going
Ofcom small-scale DAB trials, is perhaps indicative of the way in which the relationship
between the two sectors may, to a limited extent, gradually be beginning to thaw.
The Wider Policy Environment
At the core of this thesis is the hypothesis that although facilitated by a generally benign
legislative framework and regulatory oversight, the current position of Community
Radio in the United Kingdom has, to a large extent, been constrained by both wider
policy considerations and by the effective application of pressure by third parties with
particular interests in broadcast radio.
BBC Radio and Commercial Radio
Before the early 1970s, UK Government policy was to maintain the BBC's monopoly of
broadcast radio in the United Kingdom. Thereafter, this policy gradually evolved to
support a dual sector approach, firstly at the level of local services and then, later, at the
level of national services as well. Crucially for potential Community Radio operators,
the rate of expansion (particularly in terms of the growth in the number of commercial
radio stations) was such that, by the time such services were introduced, the availability
of analogue broadcast radio spectrum was very limited indeed.
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From the late 1960s through until the mid to late 1980s, the BBC's approach to the
delivery of its local radio services allowed for a high degree of local independence and
resulted in the provision of services that involved a variety of elements, which would be
familiar within the context of current Community Radio practice. However, budgetary
constraints and the centralising tendencies of the Corporation resulted in such practices
gradually becoming increasingly side lined in favour of greater corporate branding and
more standardised programming approaches.
Similarly, commercial radio, under the auspices of the Independent Broadcasting
Authority (IBA) during the 1970s and 1980s, was required to deliver a wide range of
programming beyond today's typical fare of mainstream, music-based programming.
Again, this approach was eventually abandoned as the sector successfully persuaded the
government to allow it greater operational and commercial freedoms. Attempts by the
IBA to develop a sub-tier of incremental services including 'community-lite' type
stations proved unsuccessful, not least because of a lack of a suitable underlying
legislative framework.
The key point here is that the activities of both the BBC and the commercial radio
sector, right through until the late 1980s, was such that, from a political perspective, it
was possible to argue that the introduction of a third tier of community-based services
was unnecessary. Put another way, up until around 1990, the 'space' for Community
Radio was perceived to be limited, already occupied by the existing BBC and
commercial radio of the day.
The changes to both BBC local radio and to local commercial stations as the Twentieth
Century drew to a close meant that the 'space' for new Community Radio Services, to
deliver programming no longer provided by existing providers, expanded noticeably.
With the BBC concentrating on older local audiences and commercial stations
withdrawing from speech-based programming almost entirely, it became increasingly
possible to argue for the need for alternative delivery of genuinely localised content.
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The Community Radio Order
Once the decision to proceed with the introduction of Community Radio services was
made, the introduction of suitable legislative foundations and an appropriate regulatory
framework was required to further facilitate the emergence of the new sector. As set out
earlier in this thesis, the new legislation (the Community Radio Order (2004)), was not
without its flaws, but it did provide a clear definition of Community Radio, marking
out a clear 'space' for it in terms of programming and the delivery of social gain, clearly
distinguishing it from both the BBC and the commercial radio sector. From the
Community Radio sector's perspective, the legislation was however seriously flawed, by
its failure to provide a source of guaranteed funding, able to support the core activities of
the new stations.
Funding-related Issues
The degree of cross-party support for the introduction of Community Radio has
continued as the sector has expanded since. However, both within the government and
without, this does not run to the provision of core funding at a level that might, to a
material extent, provide an operational base of support for the sector as a whole.
Instead, subsequent amendments to the original Community Radio Order of 2004
(HMG UK, 2004) have gradually relaxed funding rules to allow Community Radio
services to generate commercial revenues more easily (HMG UK, 2010 and HMG UK,
2015).
On the one hand, by placing various limits on the operational funding of Community
Radio services and by requiring that they obtain funding from a diversity of sources, it
could be argued that the legislation placed restrictions on the ability of the nascent
sector to fund itself adequately. Optimists, on the other hand, might argue that such
restrictions force a more open-minded approach to the development of funding support
from other than traditional commercial sources. However, particularly as the sector has
emerged at a time of economic recession, this has proven to be, at best, a difficult task.
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Spectrum Limits Today
Another key limitation on the development of the sector has been its limited access to
suitable analogue broadcasting spectrum, the result of earlier policy decisions, which had
previously allocated the vast majority of such resources to the BBC and to the
commercial radio sector on a long-term basis. However, the pattern of radio
consumption is changing, with analogue radio listening in reasonably gentle decline as
listeners migrate to other platforms, both broadcast and Internet based.
The 'first mover advantage' of established broadcasters over Community Radio
operators on primary broadcast platforms may also be further ameliorated by more
recent developments in broadcasting policy as the government seeks to migrate services
to digital platforms. It is perhaps a mark of how far Community Radio has come that,
with the government's support, Ofcom is now developing the technology and associated
regulatory structures to support its migration to DAB.
Small-scale DAB
On-going attempts to increase digital radio listening via DAB, including the 2015 Small
Scale DAB experiments in which a number of Community Radio services (including
Future Radio in Norwich as researched for this thesis) have taken part, have the
potential to provide considerable additional opportunities to deliver Community Radio
services, particularly in areas where current analogue broadcasting frequencies are fully
occupied.
Furthermore, as in the case of Future Radio in Norwich, access to DAB spectrum has
not only provided opportunities to duplicate existing FM outputs but has also allowed
stations to develop additional programming streams (such as Future Radio's
'FuturePlus+' service) and additional sources of income (such as Future Radio's 'Future
PopUp' service) by offering dedicated temporary channels in support of local events and
organisations.
Fears that Community Radio might be left in some kind of 'analogue backwater' may,
therefore, yet prove to be unfounded. However, it is too soon to say if this could be the
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case due to a successful migration to digital platforms including DAB, or because the life
expectancy of analogue broadcast radio platforms (particularly FM) proves to be longer
than hoped for by the government and the regulator.
Contribution to Knowledge
The particular contribution to knowledge of this PhD thesis centres on the way in
which it contextualises the emergence of Community Radio in the United Kingdom in
relation to the operational practices of other broadcasters. In addition, this research has
also discovered and made use of historical materials relating to early Community Radio
development in the United Kingdom and which, to the best of my knowledge, have not
previously been made use of in academic research.
The potential of Ofcom's on-going, small-scale DAB trial to now open up opportunities
for Community Radio broadcasting should be treated with some caution and it is too
early to predict what policy changes might result from the development of such low-cost
digital broadcasting opportunities. This research, I feel, offers something hitherto little
explored in academic research, by combining prior experience in and knowledge of the
sector from a variety of standpoints and covering a significant historical scope, from the
earliest notions and practices of what we would recognise as Community Radio today,
to the latest attempts to move to, or add DAB services. From a research perspective, I
believe that, at the time of writing, my work in this area is unique and forms a
contribution to knowledge in its own right.
Further Research
At the start of my PhD research, I optimistically expected to be able to integrate the core
objective of exploring Community Radio development in the United Kingdom into the
wider context of Community Radio theory and practice around the world. Although
this was achieved to a limited extent, there is more work that could be done, particularly
in terms of further comparing regulatory regimes and their impacts.
In terms of technological impacts, my research has highlighted some of the complexities
involved in the distribution of frequency resources, inherent in the increasing diversity
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of delivery platforms. The pace of change in this area shows no sign of decreasing. For
example, the idea that small-scale DAB delivery might be found to be technically and
economically viable was considered highly unlikely at the time work on this research
began in 2008 (if indeed it was being seriously considered at all). Now, in late 2015,
not only has it been proven to work, but it is also being used operationally (albeit on a
trial basis) in various locations across the country.
In addition, the relationship between the BBC and Community Radio is certainly
worthy of further study. As this thesis has shown, over recent years, Community Radio
has provided the Corporation with various pre-trained employees. However, the
relationship has also been strained at times, with some Community Radio operators
unconvinced that the relationship works equally for both parties. Nevertheless, in terms
of ethos, Community Radio undoubtedly remains closer to the PSB ideals of the BBC
than it does to the market-orientated approach of commercial broadcasting. The impact
of the Memorandum of Understanding between the BBC and the Community Media
Association on behalf of its Community Radio membership is certainly an area that I
consider worthy of specific further investigation.
Whilst British Community Radio has come a long way since the launch of permanent
services in 2004, the unpredictability and insecurity of its funding means that the sector
remains in a potentially fragile state. Individual stations have prospered, but others, as
for example shown in this research, have failed. Nevertheless, it appears that, over time,
as the sector continues to grow in number, it is gradually becoming a more accepted part
of the wider broadcast radio sector.
In terms of both programming outputs and the delivery of social gain, there is no doubt
that Community Radio provides something additional, outside the remit of other radio
broadcasters. As this thesis has shown, the history of wider radio broadcasting has
contributed to creating the current space for Community Radio. How that space
develops will also depend on future developments of radio broadcasting as a whole.
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What Frank Gillard would make of modern-day BBC local radio is open to question,
but there can be little doubt that he would recognise some of what he was seeking to
achieve within the wide range of Community Radio services broadcasting across the
United Kingdom today.
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