Based on the responses received, in addition to the wider-thoughts from the CMA Council and advisors, the CMA would make the following suggestions:

• The CMA will offer to work with Ofcom to give guidance, examples, and raise awareness of the ‘50% rule’ - particularly to ensure there is a clear understanding of the £15k unrestricted advertising revenue, and the use of ‘volunteer hours’ as a source of income.
  
• The CMA will campaign for the £15k unrestricted advertising revenue to be increased, loosening income restrictions on stations, whilst also being future-proofed by linking with inflation.  This campaign would be linked with the CMA’s response to the next community radio amendment order, which DCMS are likely to consult us on later in 2023.
  
• The CMA will campaign for AM and FM licenced community radio stations to remain on analogue frequencies for the foreseeable future, whilst there is still clear evidence of analogue listenership.
  
• With regard to other broadcasting platforms, we will offer assistance to our members who are applying for carriage on SSDAB. We will continue to support Ofcom in their communications with regard to the roll-out of SSDAB areas.  
  
• The increase in popularity of IP-based solutions (we note ‘internet radio’ is increasingly being used in new cars, as well as ‘Alexa’ technologies) is something that we will continue to monitor. The CMA believes provision should be made to ensure that all Ofcom-licensed community radio stations are guaranteed affordable and reliable simulcast transmission over IP platforms in the future. Services like ‘UK Radioplayer’ have given community radio a platform to share with professional radio output – we are concerned by the recent decision from BBC radio to remove their own services from this platform.  
  
• The CMA believe the Community Radio Fund (CRF) should be index-linked to grow in line with inflation. We will campaign for this ahead of the next community radio amendment order, expected later in 2023.
  
• In addition, the CMA believe provision should also be made to increase the size of the CRF in line with the increase in the number of stations that can now access the Fund, such as the new C-DSP stations.
  
• We feel a wider scope of project should be considered by the CRF. Community radio is a comparatively quick, low-cost and effective method of delivering outcomes for the Government. Projects could focus on social benefits such as employment and training, education, social cohesion, media literacy, health, and intercultural communication.
  
• Currently the CRF does not fund any projects that cover a duration longer than one year. The CMA urges decision-makers to question if this rule needs to be place. Longer-term projects could potentially have a stabling influence on community radio.
  
• The CMA will continue to support those stations applying for the CRF with their applications. In 2021, the CMA launched the ‘CRF Assistance Scheme' to support potential applicants who were applying for the fund. The vast majority of those applicants who were helped by the scheme, overseen by former CRF panel member Richard Hilton, were awarded money.
• We will work with members to highlight examples of excellent social benefits that can be attributed through community radio, especially if they were in-part of wholly funded via the CRF.
• The CMA would welcome changes in analogue community radio licence extensions from 5 to 12 years. We will campaign for this ahead of the next community radio amendment order, expected later in 2023.
• We note that, should a national ‘switch-off’ of analogue frequencies occur in that 12 year period, there would need to be further consideration as to how quickly this would affect community radio stations (this would also affect commercial radio stations).

50% Rule

We offered 2 statements pertaining directly to the ‘50% rule’ (https://www.gov.uk/government/news/government-announces-boost-for-community-radio-stations). With both statements, we offered a scale to indicate the level of agreement, with 1= strongly disagree and 5= strongly agree.  We also offered the opportunity to comment further on each statement.

The first statement was: ‘The '50% rule' enables UK community radio stations to find the right financial balance of being a viable-business & community-led.’

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Sample of those who disagreed:

"It’s pointless and has no standing in the current climate of radio. It doesn't protect big companies, and simply hurts the little guy. In 2023 there should be no restrictions on revenue for any radio station. Be that big or small."

"When it's hard enough to run a business in the current climate, this is just another burden and I personally believe this will force some to fail soon."

"This rule cannot be allowed to continue after the mergers which allowed the big groups to network large swathes of output. CR has become the local radio that was once ILR."

"This was designed to protect small commercial stations. This has largely gone and stations should be able to raise funds by whatever legal means they wish."

"We have two restrictions that will never go away and they are all the restrictions we need. We operate with Volunteers and Rookies and our Transmitters only broadcast between 7 and 10 miles .... what other restrictions do we need apart from those??"

"Community radio should be able to compete freely for market share for local advertising revenue as well as potential local listener share. With the cull of BBC local programming it's never been more important for community radio (media) to serve its community. CR that can earn revenue and make use of grant funding could provide an opportunity of a mixed approach of financial stability while supporting community focus and values."

"For those operating with the traditional community radio licence I believe there are sufficient stipulations, such as the Key Commitments and non-profit status, that protect the character of the community audio broadcast sector. The argument that removing the restrictions could lead to calls to end the Community Radio Fund needs to be considered."

Sample of those who agreed:

"Perhaps 60/40 (60% advertising)"

"It is important to stay focussed as a community led project and not try to become a commercial radio station!"

"It is a good way to clarify a key difference between commercial and community radio"

"The 50% rule obliges stations to match income either with volunteers or grant funding which will have its own social gain checks in place. It was always planned these would be the primary test of social gain, not Ofcom. Without the 50% rule many stations I know for a fact would ditch half their volunteers and grants in favour of advertising. "

"There are flexibilities in rules like ignoring first £15,000 and volunteer time which help"

"You are what you eat! Stations pursuing commercial revenues are forced into programming decisions that result from the need to drive up audiences and / or not offend particular advertisers."

"Community radio stations should have no problems meeting the 50% rule if they provide enough opportunities for volunteers to participate in the community radio station. The 50% rule keeps community radio distinct from other sectors of the radio industry."

Response Summary:

The CMA notes the split in the responses to this statement. Although 29% ‘strongly disagreed’, the broader picture is one of a division on this point (44% disagreed & 38% agreed).

A factor for some of those who disagree appears to be the idea that the rule was introduced to protect local commercial radio stations – with most of them since replaced by networked commercial radio. Some have also highlighted that other conditions, such as the bespoke key commitments stations are adhering to, are enough to protect the character of community radio

Some key arguments in support of the ‘50% rule’ is that it offers a clear distinction between community and commercial stations, whilst also being relatively straightforward in ‘meeting’ should the station be volunteer-based – because of the value attributed to volunteer hours.

Some respondents highlighted a wider radio-industry perception that a cap on advertising revenue is one of the distinguishing features of community radio. Some alluded to the ‘rule’ as a justification for the existence of the ‘Community Radio Fund’ – which only accepts applications from FM licenced community radio and CDSP licenced stations, financed by DCMS.

The uncapped £15,000 advertising income was also mentioned by a number of respondents – with some suggesting this amount be increased.

Sample of those who disagreed:

Feel that the term "from commercial sources" is vague, is this purely limited to "on-air" activities for example?

I'm not entirely sure about the value of volunteer hours - apparently it is a source of income?

Sample of those who agreed:

This is rule is a ridiculous anachronism from a time before the internet existed and should be scrapped.

It’s restraint of trade - running a professional radio station properly, even when the presenters are volunteers, needs paid staff to administrate it and needs sufficient funding to meet overheads and that requires revenue.

These rules don’t allow for that revenue to be generated- the argument that each station can generate what it likes from charitable donations is naive in the extreme - grants are not available - lottery funding for community radio bar one or two exceptions doesn’t happen - stations simply don’t have that money.

It was put in to safeguard commercial radios that do not exist anymore

I don’t agree with the rule’s premis.

It just needs simple accounting that will allow most CR stations to take nearly £90k of on air advertising today. It seems that isn't appreciated.

More can be done to explain the rule to community radio stations.

Ofcom's published advice on the 50% rule gives clear examples of how this applies to community radio stations. However new entrants to the sector will need help with this, and existing practitioners will need periodic retraining - therefore Ofcom should partner with the Community Media Association to provide training and support in this area and others.

On the £15,000 part, how come this doesn't increase with inflation?

Response Summary:

Perhaps unsurprisingly, the majority of respondents were confident they understood the 50% rule. With hindsight we maybe should have worded the question differently. But the CMA is often approached by members who are looking for clarification on their advertising income limits, particularly since the introduction of the uncapped £15,000 advertising revenue for each station.

Those who expressed a lack of understanding of the ‘50% rule’ referred to confusion surrounding the ‘on air’ and ‘off air’ advertising revenues. There is also some confusion around how volunteer hours are valued and used as a source of income in Ofcom annual monitoring forms.

Most who expressed an understanding of the rule highlighted that more could be done to educate newer stations and practitioners on the nuances of the ‘50% rule’.

50% Rule CMA Conclusions:

Based on the responses received, in addition to the wider-thoughts from the CMA Council and advisors, the CMA would make the following suggestions:

• The CMA will offer to work with Ofcom to give guidance, examples, and raise awareness of the ‘50% rule’ - particularly to ensure there is a clear understanding of the £15k unrestricted advertising revenue, and the use of ‘volunteer hours’ as a source of income.
• The CMA will campaign for the £15k unrestricted advertising revenue to be increased, loosening income restrictions on stations, whilst also being future-proofed by linking with inflation.  This campaign would be linked with the CMA’s response to the next community radio amendment order, which DCMS are likely to consult us on later in 2023.

Future of FM/ AM (Analogue)

We offered a statement pertaining directly to community radio’s future on AM and FM frequencies. We offered a scale to indicate the level of agreement, with 1= strongly disagree and 5= strongly agree.  We also offered the opportunity to comment further on the statement.

Sample of those who disagreed:

We live in a digital age and therefore all community stations should be able to transfer to digital for the same price as fm/am licensing.

If DAB carriage can be more affordable in the medium term, we should embrace digital and assign FM and AM to the history books - lets look forward.

The way we consume media has vastly changed in the last number of years and I believe that FM is a small part of the listenership. The costs associated with FM licencing is a major cost of Community Radio stations and should be looked at on balance!

Sample of those who agreed:

Not every generation has internet access, some still prefer an old fashioned radio set. These are still being sold in supermarkets showing a continuing demand for FM/AM.

It is important that these frequencies are kept for community radio especially as many of the large stations are becoming mainly networked.

Internet is growing more than DAB, the high cost of DAB and the way the areas are carved up is also excluding us from joining.

The SSDAB reception here is Winchester is disappointing at the licensed transmitter power.

We will in the near future broadcast on a small scale DAB Multiplex. However, the proposed coverage area does not serve the entirety of our local communities. Not broadcasting on FM also prevents us from providing a resilient local service in times of emergency.

FM is king even today in 2023, there are still a large amount of cars who only have FM radios and lots of our listeners have a radio set at home which is still going strong.

Even though our service will be extended on SSDAB in the summertime, our most recent listener’s survey (January 2023) indicates that there is still a huge appetite for FM‍

I actually can’t even believe that this is being considered. There are huge amounts of people that still only listen on FM and until recently that included myself and I have worked in radio 30 years!‍

FM/AM are cheap, established, and accessible technologies that are mature and easy to use. But community radio should also be available on all platforms where the audience wants to listen. However there is a danger of creating a two-tier radio broadcasting sector with a digital tier and an analogue tier.

Many cars still only have FM radios.

Whilst DAB should be important, in my experience I've found the signal strength of DAB not as strong or reliable as FM and we're clearly a long way off from being able to 100% rely on DAB to enable FM to switch off.‍

Response Summary:

Most respondents (82%) felt that analogue frequencies should remain for the foreseeable future. Understandably, many of those who agreed were part of stations who broadcast on an analogue frequency. Conversely, some of those who disagreed or who were indifferent do not broadcast on analogue frequencies.

Many used this section to offer opinions about the key role FM played with their stations engaging with their audience. There were multiple comments alluding to analogue car radios, older audiences using analogue radios, and even analogue-only radios being sold in shops.

Some comments on this statement referred to unreliable Small-Scale DAB (SSDAB) signal strength. This is a particular concern for community radio stations if analogue frequencies are, at some point, shut off. Some highlighted that the cost of SSDAB carriage was prohibitively high.

There were responses that made specific mention of the future of IP broadcast solutions, specifically the rise of the popularity of smart speakers for radio listening. Broadly speaking, it would appear that most community radio practitioners are keen that their station is able to access the same platforms that BBC and commercial stations are using.

AM/ FM CMA Conclusions:

Based on the responses received, in addition to the wider-thoughts from the CMA Council and advisors, the CMA would make the following suggestions:

• The CMA will campaign for AM and FM licenced community radio stations to remain on analogue frequencies for the foreseeable future, whilst there is still clear evidence of analogue listenership.
• With regard to other broadcasting platforms, we will offer assistance to our members who are applying for carriage on SSDAB. We will continue to support Ofcom in their communications with regard to the roll-out of SSDAB areas.  
• The increase in popularity of IP-based solutions (we note ‘internet radio’ is increasingly being used in new cars, as well as ‘Alexa’ technologies) is something that we will continue to monitor. The CMA believes provision should be made to ensure that all Ofcom-licensed community radio stations are guaranteed affordable and reliable simulcast transmission over IP platforms in the future. Services like 'UK Radioplayer’ have given community radio a platform to share with professional radio output – we are concerned by the recent decision from BBC radio to remove their own services from this platform.  

Community Radio Fund

We offered 2 statements pertaining directly to the Community Radio Fund. With both statements, we offered a scale to indicate the level of agreement, with 1= strongly disagree and 5= strongly agree.  We also offered the opportunity to comment further on each statement.

Sample of those who disagreed:

We'd apply any time we needed it regardless.

Any funding has to be explored to help finance the business and sustain it. More is needed in the pot but we will apply to it nevertheless.

Sample of those who agreed:

We've benefitted twice from funding from the CRF and are aware of the changes that are possible through extra funding.

We have made multiple applications to the fund and been unsuccessful. These funds can help sustain a station especially during times of hardship (pandemic/cost of living crisis).

The cost of running a quality service, meeting varied local needs costs. As BBC become even less local there’s a growing role to play. I believe a small annual ‘grant’ to Stations meeting agreed criteria should be made. Support those making a difference.

Anthony Everitt in his report suggested each station should have and be funded for station manager - broadcast assistant and admin person.

I see the future where a Community Media Fund available to any group to apply for activities of social gain. That would be a far greater and larger fund which would be open to any group.

My opinion has always been it should be about 3 Million and doled out equally each January to a tune of about £8000 pounds per Station so we can pay our Licence Fees, Streaming Fees and Operating Fees

People bidding against each other in the wider ethos of what we are about is totally unacceptable, we are each aiming for the same goals.

The pot has not really grown since the start of community radio but the number of community stations on air has with over 300 now licenced plus with the start of CDSP's being able to apply as well the chance of being successful is drastically reduced.

A larger sum could be more evenly spread across the spectrum.

I wouldn't want to take potential funds from those stations more desperate/ struggling to survive.

The size of the Community Radio Fund has not significantly increased for many years - apart from some extra funding that was found during the pandemic. This must change.

Strongly agree. Community Radio needs all the help it can get.
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Response Summary:

Our survey suggests the majority of community radio stations (68%) would be more likely to apply for Community Radio Fund (CRF) funding if the size of the fund were increased. Many of those who disagreed with the statement commented that they would always apply anyway. A number of responses alluded to their station not wanting to dilute funding away from stations on the brink of financial-based closure, despite their own needs and aspirations.

Some respondents suggested an index-linked CRF to grow in line with inflation otherwise a de facto cut in the size of the Fund is being implemented year on year. Additionally, many argue provision should be made to increase the size of the CRF with respect to the increase in the number of stations that can now access the Fund, such as the new C-DSP stations. The CMA would highlight that when the CRF first opened, stations could expect to receive around £30,000 which would be worth around £45,000 now due to inflation.

Ultimately, any considerations about how the CRF is currently allocated are restricted by the limitations of £400,000 annually. Considering that hundreds of licenced stations are now able to apply, if each licence were given an equal share of the fund the impact would be largely insignificant.

Sample of those who disagreed:

Business development and sustainability is the key for most CR stations. In the past we've seen money awarded to projects unrelated to broadcasting that do nothing to ensure the long-term viability of those stations.

Without financial support to promote business development and support related business costs, stations will be forced to close putting an end to all potential social benefits from broadcasting.

Sample of those who agreed:

I think that the decision to support business development directly is likely to lead to short-term-only and mainly financial gains. This is not the same as sustainability. A non-profit organisation's development is very much more than income generation.

One aspect that the Fund was sped to cover was volunteer support. This has been pushed aside by the Fund's emphasis on business, but it is part of building a strong organisation, which is central to sustainability.

It should allow for an element of Core funding, to allow stations to concentrate on their content, rather than how to fund the station. This happened in the pandemic and needs to happen again now.

We are rurally isolated and a lot of our volunteers struggle with travel/access funds. It would be a great help to assist those volunteers if possible.

We have just been awarded the PRTA (Princess Royal Training Award) for our successful Arts Awards Programme. We have an excellent, qualified tutor and wish to retain her services and so have applied for a part-time salary for her. This is vital to the programme, which also brings in substantial revenue from eager funders who recognise the benefits it brings. Without the Ofcom fund we may well lose this person to a more lucrative paid position.

Perhaps a rethink of the fund, pooling reserves from a variety of Govt departments. More schools/ education project funding? Or health awareness projects?

I’d strongly urge Ofcom to pay for Rajar infrastructure for each radio station to prove its listenership and so that each station can attract radio advertising/sponsorship accordingly.

To take the question further, it feels like more should be done to encourage community radio to engage in projects that encourage social benefits. We all know that education and health could do with the support right now - why not via community radio!

A precise definition of 'social benefits' would be needed to contemplate introducing this. It should probably be skewed towards educational functions.

Response Summary:

There is a clear sector view (78%) that a wider scope of project should be considered by the CRF.

There were several comments from responders supporting the statement also stressed their support for commercial revenue-based roles. ‘Business Development’ roles have broadly been very successful since the fund was formed, and we have since followed up with some of our members to provide Ofcom and DCMS some case studies of where the CRF has had significant impact.

A number of responses alluded to the need for a definition of ‘social benefits’ in this context.

Community Radio Fund CMA Conclusions:

Based on the responses received, in addition to the wider-thoughts from the CMA Council and advisors, the CMA would make the following suggestions:

• The CMA believe the CRF should be index-linked to grow in line with inflation. We will campaign for this ahead of the next community radio amendment order, expected later in 2023.
• In addition, the CMA believe provision should also be made to increase the size of the CRF in line with the increase in the number of stations that can now access the Fund, such as the new C-DSP stations.
• We agree with the broad view from responders that a wider scope of project should be considered by the CRF. Community radio is a comparatively quick, low-cost and effective method of delivering outcomes for the Government. Projects could focus on social benefits such as employment and training, education, social cohesion, media literacy, health, and intercultural communication.
• Currently the CRF does not fund any projects that cover a duration longer than one year. The CMA urges decision-makers to question if this rule needs to be place. Longer-term projects could potentially have a stabling influence on community radio.
• The CMA will continue to support those stations applying for the CRF with their applications. In 2021, the CMA launched the ‘CRF Assistance Scheme' to support potential applicants who were applying for the fund. The vast majority of those applicants who were helped by the scheme, overseen by former CRF panel member Richard Hilton, were awarded money.
• We will work with members to highlight examples of excellent social benefits that can be attributed through community radio, especially if they were in-part of wholly funded via the CRF.
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Analogue Licence Extensions

We offered a statement pertaining directly to community radio analogue licence extensions. We offered a scale to indicate the level of agreement, with 1= strongly disagree and 5= strongly agree.  We also offered the opportunity to comment further on the statement.

Sample of those who disagreed:

Why not campaign for a smother renewal process? The renewal is important as Ofcom has already said this is the only mechanism for checking the licences are all correct and proper.

CR stations are not commercial stations - the business model is completely different. A 5-year licence gives Ofcom the opportunity to check sustainability more frequently. A lot can happen in 5 years, let alone 12 years!

Whilst we agree that re-application is a tedious business it does mean that there are checks and balances in what is being broadcast. There would seem to be some fairly spurious statements of intent and provision of service.

Sample of those who agreed:

Makes sense to fall in line but all stations need to provide sustainable evidence every two years.

Community radio stations often have limited resources and applying for licenses can be stressful and time consuming. Extending the licenses to match commercial radio is fairer, creates a more competitive landscape, and frees up community radio to focus on social benefit and supporting their communities.

This would bring CR in line with other broadcasting and save Ofcom a great deal of work and expenditure.

There shouldn't be one rule for one and another for someone else. Also from the practical side it would be much easier for Ofcom to do this.

This would be much better for business planning. It is a separate issue that I consider analogue will phase out over the next 10 years.

Whilst there is still analogue radio, a 12 year licence seems sensible - perhaps with a caveat of a potential 'switch-off' date (assuming the service is broadcasting elsewhere, eg. SSDAB) cutting the agreement short if required.

Community radio has all but replaced local commercial radio so the rules need to reflect that.

5 yrs is quite a short time.

Response Summary:

There is a clear sector view (80%) that a 12 year analogue licence extension would be a positive change. The comments on the statement offered interesting insight into the wider views of our membership.

Those who disagreed highlighted the need for checks and balances with regard to community radio licences. The CMA would counter this by highlighting how community radio licenced stations can be found in breach of their licence by Ofcom for failing to meet their key commitments.

Many who agreed with the statement highlighted the easing of admin-burden that would occur by extending the licence from 5 to 12 years, emphasising benefits for both radio stations and Ofcom. Some suggested that community radio stations could still be asked to provide some evidence of meeting the terms of their licence every couple of years or so.

Others suggested that it was difficult to justify a difference in licence extension rules between commercial and community radio. Some went a step further with this argument by suggesting that, in the absence of local commercial radio services, community radio was fulfilling the role these commercial stations once had.

Analogue Licence Extensions CMA Conclusions:

Based on the responses received, in addition to the wider-thoughts from the CMA Council and advisors, the CMA would make the following suggestions:

• The CMA would welcome changes in analogue community radio licence extensions from 5 to 12 years. We will campaign for this ahead of the next community radio amendment order, expected later in 2023.
• We note that, should a national ‘switch-off’ of analogue frequencies occur in that 12 year period, there would need to be further consideration as to how quickly this would affect community radio stations (this would also affect commercial radio stations).
  

CMA Festival

We gave respondents a number of suggestions for topics and themes that could be presented on at the next CMA Festival. We also offered the opportunity to comment further on the CMA Festival.

Response Summary:

The CMA suggest that these responses would broadly indicate the concern and interests of those practitioners who answered our survey, as well as what they are interested in seeing at the CMA Festival.

Finances and funding are, by far, the most popular selection from our list, with 83.5% choosing this option. This reflects the challenging financial situation community radio stations are facing.

Examples of successful radio projects and case studies are the second most popular selection. This would suggest to us that the CMA Festival has a role to play in disseminating community radio best practice. The CMA would also highlight that there has long been a healthy appetite for community radio stations to learn from each other’s successes, which helps to explain the popularity of the Community Radio Awards.

Interestingly, the third most popular selection was PPL/ PRS. This likely coincides with recent sector concerns about the increase in ‘joint licence’ performing rights fees in 2023. The CMA is in dialogue with PPL and PRS with regard to the costs of the joint licence and future communications about it.

Sample of further comments:

Should be free to members. It used to have the AGM included which was good for members to understand the CMA better.

I feel it would be beneficial to have a session on brand, marketing and sales. Potentially how to develop a robust sponsorship or advertising package, and opportunity for stations to share their costing structure. This would help others to ensure they are pricing appropriately. Sessions on best practise for social media and other marketing techniques. I also suggest a session on Station Management, including best practise on how to encourage and manage volunteers.

BAME representation - always low but there are literally tens of BAME broadcast organsiations around the UK.

We think its a great way to keep members and local Community radio stations abreast of the ever evolving and changes in radio community as well as the chance of meeting other radio stations and people involved. We appreciate the work done by the CMA in the past and present.

For me the stories of social impact should be the keystone of the Festival. Last year the Sound Vision training and Steph Hirst presentations were distinctive highlights.

Let's hear from a top business person - Deborah Meaden, Lord Sugar, Sir Jim Ratcliffe et al.

Create little stations for people to try out equipment, reach out to other community stations even if they are not members, university stations, get involved with other radio awards (Charles Parker award).

CMA Festival CMA Conclusions:

We would always welcome further thoughts and feedback from our members on what they would like to see at the CMA Festival. Email office@communitymedia.uk.

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