RESPONSE TO OFCOM CONSULTATION

EAST SUSSEX RADIO SOCIETY

RESPONSE TO OFCOM CONSULTATION: "The Licensing of Community Radio"

1. East Sussex Radio Society is a not-for-profit Society formed in 2001 to put on community radio in and around Lewes, the county town of East Sussex. The membership embraces all ages, some with little previous experience, through hospital radio people to veterans with a career in local and/or national radio. We have broadcast each autumn for the last three years under a restricted service licence (RSL), in all a total of seven weeks on air. Nearly all of our resources in terms of time and equipment are donated or lent by the local community.

2. We answer the eleven questions raised in the Consultation below but first wish to make a few preliminary points:

(1) By far the most important consideration will be the cost of the licensing regime. It is difficult for a community group such as ESRS to find the money to get on air for three weeks in a year, in terms of paying a daily rate to the former Radio Authority and now Ofcom. Unless the new licences are to be made available at a modest annual flat fee, in our view it will be difficult for genuine community groups to take part in the new radio sector. The licence fee is our highest overhead in mounting an RSL.

(2) We have noted that Ofcom will consult on a new 'Statement of Charging Principles'. In our view that consultation should take place as soon as possible. Certainly, we will not be in a position to contemplate applying for a community radio licence until we know what the new regime will be and believe the general response form similar groups will be delayed.

(3) The same considerations apply to licencing by PRS and PPL. At present, these organisations also charge at a significant daily rate and their fees are our second-highest RSL overhead. We propose that Ofcom consults with these bodies as soon as possible.

(4) Some communities might benefit considerably from a station but be unable to resource or finance year-round 24/7 broadcasting. In these cases, will Ofcom consider part-time applications and will there be reduced fees for such licences?

(5) We have made enquiries of the Community Fund and the New Opportunities Fund and are given to understand it is unlikely that either will provide grants for community radio services. If no resources from Government or the Lottery are provided to the new Community Media Fund to make grants then there may be little demand in the event for the new licences. Could any such grants be annual or recurring?

Annex 3: Summary of questions posed in this consultation

Question 1:
What role should Ofcom have in respect of community radio, beyond the licensing of new services?

We agree that the functions mentioned in the Consultation are not as such those of a regulator or licencing body. However, advice and guidance to the applicants, being in the main small voluntary organisations, would be welcome, both during the application process and afterwards.

Provision of information eg the identity of other applicants would be useful.

Some of these functions might pass naturally to a new trade body in time.

Question 2:
Do you agree with our proposed policy for the allocation of spectrum and the size of coverage areas for community radio services?

Yes. We would be content with a 5 km radius. We would be keen to stay on the FM band owing to the Downland topography.

Question 3:
Do you agree that community radio should be an applicant-led process with an annual 12-week period when applications can be submitted for any neighbourhood or community in the UK?

Yes.

Question 4:
Do you agree with Ofcom's proposal to invite submissions from commercial radio operators if they consider that their economic viability might be affected by the provision of a community radio service, based on the application proposals?

Yes. However, in our view, the local advertising market is multi-layered. Community stations would not necessarily take advertising revenue from the larger stations. A local shopkeeper would not be able to afford the rates of eg Southern FM and a community station would in effect expand the market without hitting the income of the larger station.

Question 5:
Should there be a general limit of 50% of annual income that community radio stations are permitted to obtain from the sale of advertising and sponsorship, or should this be decided on a case by case basis?

A case by case basis would lead to considerable uncertainty for potential applicants and we would prefer to see a general limit.

We are also concerned to know whether funding from local councils and similar bodies can form part of the non-commercial element.

Question 6:
Are you content with Ofcom's proposals for the submission of applications?

Yes

Question 7:
Are you content with Ofcom's proposals for the order in which it will consider applications in the first year?

Yes

Question 8:
Aside from the Government's selection criteria, what other criteria should Ofcom use when deciding between applications?

We strongly agree that 'neighbourhood services' should have priority over 'community of interest' services.

Question 9:
Are you content with the proposal for listing a station's key commitments in its licence?

Yes

Question 10:
Are you content with Ofcom's proposal that each station should produce an annual report?

Yes, provided the format is simple.

Question 11:
Do you have suggestions on how we might research the impact of community radio services on target communities or on other methods of seeking feedback from communities?

In the past we have successfully used college students to carry out a brief 'on-the-street' survey of awareness and opinion of the RSL station. If money had been available, we would have placed a suitable advertisement in the local paper as well.

SIGNED
(A. Thomas)
Chairman
East Sussex Radio Society