Re: Written Submissions regarding Review of Radio Licensing.
In response to the invitation to respond to the Consultation Paper “Review of Radio Licensing in Ireland” I wish to make the following submissions-
Reference Paragraph iv-Section 3- A Citizens Voice: The radio listener must be a key stakeholder in any consideration of radio licensing, but currently, no structured mechanism exists to allow the Public to feed into the regulatory system on an ongoing basis.
Recommendation: That an Audience Council or similar body be established to allow for the direct input from the Public on all relevant issues e.g. Quality, Format, Impartiality/Objectivity, etc..
The provision of Surveys from a Listeners’ Panel may also be appropriate.
Reference Paragraph v- Section 3-Licensing-Application: The Licensing process as currently structured regarding the payment of a fee of 600 Euro could act as a barrier to entry for some potential Community Radio Station applicants. Such a fee does not take into account the huge voluntary commitment of volunteers to secure a radio station for their local community, and , indeed, could act as a deterrent to pursuing an application in some cases e.g. socially deprived areas.
Recommendation: That consideration be given to eliminating such application Fee , or that in the event of a successful Application that the Fee, in full or part, be refunded to the Applicant , as a goodwill gesture by the State towards the vital work such volunteers do.
Reference Paragraph ix-Section 3- Enforcement: There could be a conflict of interest between the role of B.C.I as (1) a Licence award body, and (2) an Enforcement body; such conflicts can arise for various reasons.
Recommendation: That two distinct Bodies be provided to conduct the Award and Enforcement aspects.
Miss, le meas,
B. Quinn, Vice Chairperson/Director Liffey Sound FM.