Response to the Review on Radio Licensing in Ireland
While we all recognise and appreciate the role of RTE, the Commercial sector and Community radio, Special Interest radio has been largely ignored and there is currently no Christian radio station in Ireland. This contrasts with the situation in the UK, where there are a number of Christian broadcasters on digital satellite, AM and Freeview. UCB operated 4 satellite digital radio stations as well as a TV channel and has recently granted a DAB licence.
In Ireland UCB has a large database of supporters, who listen to their satellite radio services and this I believe is indicative of support for and interest in Christian radio. While introduction of Digital Radio will increase available spectrum and increase diversity of programming, careful consideration should be given to the allocation of remaining analogue spectrum for special interest radio.
Policy Objectives for the Independent Sector
Plurality of ownership and diversity of content are important policy objectives. However, diversity of content needs to be broadened to include religious and other special interest groups to “best serve the needs of the people of the island of Ireland, bearing in mind their languages and traditions and their religious, ethical and cultural diversity”. Many of the Africans and other natioalities now living in Ireland are Christians and are active supporters and listeners to UCB. If necessary, ministerial policy direction should be given to ensure this kind of diversity is achieved.
The remaining requirements regarding character, expertise, experience and financial resource should remain a requirement for any broadcasting activity.
Diversity and Plurality
As above.
A Citizens Voice
While an Audience Council might go some way to address this, I believe that ongoing Quantitative and Qualitative Market Research should be commissioned by the Regulator to ensure that their licensing decisions and the programmes of their licensees are meeting with the approval of their audiences. The JNLR ratings are a good indicator of listenership but don’t tell us why people did or didn’t listen.
Licensing Application, Evaluation and Duration.
Increased transparency in the application and evaluation process is essential and a scoring system for the key policy objectives of character, expertise, experience and financial resource should be considered. Where there is clear researched evidence (see A Citizens Voice) that the policy objectives have been achieved, automatic re-licensing without competition should be considered provided there is transparency in the process.
Licensing- Appeals Body
While I believe that an Appeals Board would be helpful, I would suggest that if the process was more transparent there might be less disputes about results
Enforcement
There should more than the two current penalties and a ‘points’ system should be considered.
Financial Return and Administration Cost of the Independent Sector.
This is effectively a form of taxation and should be seen in the overall taxation of business and in particular the radio industry and should be on ‘an ability to pay’ basis. Community and non-profit Special Interest radio should excluded and care should taken that financial ‘clout’ is not seen as more important the ability to produce good programmes. A combination of market-based spectrum fees and ‘windfall profits’ clawback is infinitely preferable to auction licence to the highest bidder, but taxation of profits would be the fairest and best.
Digital Radio
Digital satellite radio is already available, but unfortunately, no content licences have issued by the BCI under the 2001 legislation.
DTT, like Freeview in the UK, could provide carriage for digital radio services, but unfortunately it has never come on-stream. Given that many of the transmitter masts have already been erected, this project needs to resurrected and brought to completion.
Unfortunately, neither of the above can provide radio in listeners’ cars and DAB is the only real option. There are, however, issues surrounding the continued use by RTE as well as the cable companies of Band III for television broadcasts could presumably mean that the L Band will have to be used as well as Band III for DAB. It is extremely important that major manufacturers of DAB receivers are involved to ensure an adequate supply of suitable receivers for home and car at attractive prices. DAB will be successful if it real choice and diversity through special interest radio.