[cr-india] May 2004 meeting in Delhi: issues emerging

[Frederick Noronha (FN)]

Designing an Enabling Framework for Community Radio in India

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5 May 2004 - Plenary Session
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The plenary session addressed both expectations and concerns about Community Radio in India, and the main speakers shared experiences from other Asian countries. The government believes in the potential of community radio, stated a senior official, adding that the most important issue is its potential for empowerment. This view was endorsed by the public service broadcaster, Prasar Bharati, which saw community radio in a complementary role, by addressing the 'last mile' problem and reaching the remote, rural and marginalized communities which could not be reached by All India Radio.  

International experience of community radio ranged from Nepal, where 22 communities have community radio managed by cooperatives, local government bodies and non-governmental organizations, to the newly independent East Timor which has 16 community radio stations. There are similar initiatives in Sri Lanka, Thailand and the Philippines.

The view was reiterated that community radio responds to the cultural and information needs of remote, non-literate and marginalized communities, it is closest to oral cultures and lends itself to focused local topics. 

Issues 

1.Technical issues: including frequency allocation and other spectrum issues.

2.Content: On appropriate programme content on community radio, including developmental and cultural programmes.

3.Eligibility criteria: On the entities that could be considered eligible to own and operate a community radio station.

4.Defining a 'community': Whether communities, in the context of radio, could be geographical communities or interest-based communities, or both.

5.Role of intermediaries: Whether there is a role for intermediaries in the ownership and operation of community radio.

6.Regulation and monitoring: On the possibility and/or desirability of monitoring a large number of widely dispersed community radio channels.

7.On-air commercials: Whether advertisements or sponsorships should be permitted on community radio.

8.Funding: Issue of external funding, especially funding by international agencies.

9.Safeguards: On the safeguards to be built into the system - from allotment of licenses to monitoring of content - in order to address issues of national security.

10.Commercial interests: To ensure that community radio does not succumb to commercial interests.

11.Scarcity of spectrum: To address the issue of frequency allocation and spectrum sharing in locations where there is greater demand on the spectrum.

12.Code of practice: To evolve a code of operations for Community Radio.

13.'Last Mile' issue: To ensure that community radio reaches remote and isolated communities that are presently un-reached by the public broadcaster. 

14.Ownership and management: To guarantee that community radio is owned and managed by community groups, and not by elites or commercial interests.  

15.Indigenous models: To evolve suitable models of community broadcasting to suit Indian conditions.

Conclusions & Recommendations

1.Synergies with New Media: Role of new technologies like Satellite Radio, datacasting etc to be studied in relation to community radio.

2.Reaching the un-reached: Community radio's potential lies in reaching remote, rural and otherwise un-reached populations, in their own language or dialect, and addressing local issues.

3.Encouraging pluralism: Community radio promotes pluralism, and strengthens public service broadcasting.

4.Eligibility: Eligibility of applicants and allotment of licenses can be modeled on tried-and-proven practices of other countries, eg., ABA, the Radio Authority of UK etc.

5.Accountability: The four basic aspects for a community radio policy: (a) obtaining the community mandate (b) creating a system of management that is accountable to the community (c) credibility of the community station and (d) constant monitoring and review by the community.

6.Campus radio: While campus radio is an important aspect of broadcasting, it is not a substitute for community radio.

7.Sustainability: Issues of sustainability of community radio are important, but can be modeled on policies and practices from other countries.

8.Frequency allocation: Frequency allocation can also be based on existing models; for instance, that of Thailand where 20% of broadcast frequencies are allocated to community radio.

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5 May 2004 - Session 1
The Current Framework
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Under the current policy on 'Community Radio', campus radio stations are being licensed. The possibility of Access Radio (i.e., offering time slots for the broadcast of community programmes on All India Radio's platform) was also considered. However, it was concluded that, though these initiatives could serve a complementary function, they could not be a substitute for Community Radio.

Regarding campus radio, it was stated that about 55 applications have been received, but processing of applications was time-consuming. While frequency allocation has been speeded up, other clearances were taking time to process since a large number of agencies were involved. Anna University FM has become the first and only campus radio station to become operational, from 1 February, 2004.
 
It was observed that 'community radio has moved from the opportunity phase, to the aspiration phase, and then to the frustration phase', and consequently, an enabling framework was urgently required. The use of alternative platforms like AIR's transmitters was discussed, but community broadcasters from the Kutch region of Gujarat, who are presently buying air-time on AIR Stations, pointed out that the costs involved were unsustainable. It was also stated that, while the public service broadcaster generally broadcasts in the State language, the community broadcaster broadcasts in the local dialect, using local talent and volunteers. Sufficient capacity has been built up by the community broadcaster to manage its own radio station.

On the issue of using AIR's platform, it was pointed out that it could not be a substitute for community radio, even if it was offered free of charge. It could be an additional channel for local broadcasting, though issues of ownership and control would still remain.

Issues:
	
1.Current policy: The current community / campus radio policy is overtly cautious and needs to be reviewed.

2.Processing of applications: Processing of applications for campus radio is proving to be time consuming, involving several agencies. Consequently, only one campus radio station has got on air, and there is a need to expedite the process of licensing.

3.Eligibility criteria:  More clarity is required on the eligibility requirements to be set, institutions or groups that would be eligible to apply for a CR license, suitable content for community radio, safeguards etc. This would be essential for liberalizing community radio policy.

4.Agenda for development: The primary purpose of community radio is to serve a developmental function, which is not being met under the present policy.

5.Time-slots on AIR: Buying air-time on the All India Radio network gives a wider reach, but it is not cost-effective. 

6.Community Radio vis-à-vis other media: While there is little or no regulatory control over the exchange of information via satellite TV, satellite radio, cable, internet or newspapers, stringent control over radio is hampering the growth of the medium.

7.Content over campus radio: Campus radio has been mandated to do a variety of developmental broadcasting, which may not be appropriate for all educational institutions. 

Conclusions and Recommendations: 

1.Licensing procedure: Time limits need to be set for the processing of applications. A clear time frame has been proposed for frequency allocation and SACFA clearance, but other clearances - including security clearance - needs to be expedited. This can be achieved by initiating dialogue with the concerned Ministries and Departments.

2.Single window clearance: It was noted that the present process of seeking clearances from at least 6 ministries and departments was cumbersome and time consuming. In the interest of expediting the process, it was recommended that the process should be simplified, there should a single window clearance system and that the procedure should be time bound.

3.Alternative platforms: Campus radio and the public service broadcaster (AIR) have been suggested as alternative platforms for community radio programmes. However, these platforms are not a substitute for community owned and managed stations. Community radio stations need to be considered as unique institutions in their own right. 

4.Campus radio: While campus radio is a relevant concept, it should be considered as an alternative to community radio.

5.Ensuring diversity: There is a felt need to ensure the diversity of voices, opinions and ideas on the airwaves, by promoting a variety of channels, especially in cases where there is no shortage of spectrum.

6.Building on experience: Experimental, pilot and demonstration projects have established themselves, and should be permitted to operate and manage their own stations. Agencies with a proven track record in developmental work could be encouraged to address their communication needs through community radio.

7.Reach of campus / community radio: The present campus radio guidelines permit a 50 watt transmitter, with a reach of approximately 6 kms. While this may be appropriate for most campuses, it is clearly inadequate for sparsely-populated rural and remote areas, where it may cover only a village or two.

8.State support: Ministries and government departments (eg., Ministry of Rural Development), which are already using radio to promote their schemes, could extend their support to community radio on issues of rural development, women empowerment etc. Government could also offer support funds for Internet links to community radio, to encourage value added services like radio browsing and exchange of programmes between stations.

9.Sustainability: The issue of sustainability of individual community stations should not be a pre-condition for licensing, or a matter of concern for the government. If anything, the government should upon community broadcasting as an issue of freedom of expression.

10.Access to campus radio: Australian experience suggests that campus radio, too, could be opened up to communities. Campuses are privileged to have licenses, and they could share their spare capacity with others for a social and developmental purpose. Clarification is needed on whether campus radio is open to community groups 

11.Participation by governmental or quasi-governmental institutions:  Urban local bodies and panchayati raj institutions could be granted CR lisences on behalf of communities, and CR should be used as a medium for capacity building of PRI representatives.

12.Policy framework for CR: Community-based organizations should be eligible to apply for CR lisences provided it is established that they represent the community by providing a proper an enabling policy framework.

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5 May 2004 - Session 2
The Scope of Community Radio
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A decade after the land-mark Supreme Court judgment on public ownership of airwaves, an enabling policy is being framed for community radio. Elsewhere, there are illustrative examples of successful community radio movements, including South Africa and Australia, where were represented on the panel for this session.

Community radio has three main characteristics: it is non-profit making in nature, it is community owned and managed, and operates with community participation. Community radio groups in India have produced a set of Draft Recommendations, which defines the 'community' as a group of individuals who are territorially bound and share a common socio-economic position or interest. These were shared at the Workshop. For the purpose of community radio, the 'community' is constituted by those who reside within the coverage area of the radio station.

The draft recommendations emphasize the 10th Plan requirement of FM radio penetration in rural and remote areas, to extend FM coverage to 60% of the population. For instance, in the two community radio initiatives of Boodhikote (Karnataka) and Pastapur (Andhra Pradesh), the nearest radio station is over a 100 kms away. These community broadcasting initiatives are already capable of sustaining CR stations of their own.
 
A basic requirement for receiving a license is that the licensee must demonstrate that it has a proven track record of having worked with the community it claims to represent. A case was made for addressing the eligibility issue in the licensing procedure rather than in the policy framework. There are excellent examples from neighbouring countries as to what constitutes eligibility to run a community radio. This session also addressed the possibility of holding 'public hearings' prior to sanctioning licenses, as is the case in countries like South Africa, and the issue of state support for community radio initiatives.

Issues:

1.CR vis-a-vis PSB and commercial FM: Community Radio stations are qualitatively different from public service and commercial broadcasters. 

2.Empowerment/ The Role of Volunteerism: Many CR stations around the world have non-literate volunteers who are engaged in producing and broadcasting programmes.

3.Building awareness: Community broadcasting can increase awareness within the community and bring about behavioural and social change.

4.Local relevance: The most effective community radio programmes use language and characters that the local community can identify with.

Conclusions and Recommendations:

1.Types of licenses: General licenses and special-interest licenses (like, for instance, Ethnic radio) could be issued, on the Australian model. In South Africa, two types of licenses are permitted for community radio -- either as a geographic entity, or as a community of interests (institutional, campus, universities, cultural, youth, music etc).

2.Eligibility: It was recommended that the new CR policy makes a commitment to promote pluralism and inclusion by opening the field for community radio licenses to diverse representative bodies of rural and urban local self-governance

3.Capacity building: Campus radio can act as training ground for other types of radio, including community radio. Training also plays an important role in demystifying the medium of radio.

4.Commercials: Limited advertising on community radio channels is permitted in many countries, thus ensuring sustainability. Australia allows five minutes of commercials in every hour of programming on community stations, In South Africa, the limit is four minutes per hour. As a means of financial sustainability, the government should permit a mix of government and non-government sponsorship and limited advertising on CR, with emphasis on local services and products.

5.Sustainability: Membership fees and donations could be other sources of income for community radio. Community radio in South Africa, for instance, is sustained by donations, grants, subscriptions, sponsorships or a combination of these. In Australia, the government subsidizes special categories of radio like aboriginal radio, ethnic broadcasting etc. 

6.Support Fund: A support fund could be formed by the government to help communities set up CR stations, as well as to support capacity building efforts.

7.Commercialisation: Checks and balances would have to be built into policy to ensure that community radio stations are not over-commercialised.

8.Representative body: An Association like CBAA (Community Broadcasters Association of Australia) could be formed to support community radio initiatives, by acting as a conduit for funding and assistance, for sharing content, capacity building, liaising with Central departments etc. 

9.Monitoring: International experience suggests that there are sophisticated ways to prevent the misuse of community radio stations. Three decades of community radio experience in Australia indicate that monitoring is done on a voluntary basis by the public, and that the government does not have be a monitoring agency. Since broadcasting is a public activity, people tend to complain if they find anything wrong. In South Africa, it is compulsory for every CR station to advertise - on air - that if the public has any objections to its programming, they should phone in with their complaints. 

10.Code of Practices: Special codes of practice are applied to community radio. For instance, 'hate speech' is banned on S. African community radio and no political office-bearer can be a Board member or in a management position on a community radio station. The Election Commission lays down special conditions for community radio stations regarding election broadcasts. 

11.The Co-operative model: If individual NGOs or other groups have only limited broadcast requirements and limited resources, they could form a coalition to own and manage a community radio station, as done in Nepal.

12.Regulation: An independent broadcast regulator, as envisaged in the 1995 Supreme Court judgment, could be set up to address regulatory issues. Some form of non-intrusive supervision by an autonomous regulator is preferable to over-regulation.

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5 May 2004 - Session 3
Technical and Regulatory Issues
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Issues of frequency allocation to community radio stations, the transmitter power and antenna height required to reach a sustainable number of listeners, and the issue of de-licensing ultra-low power transmitters (of a few watt) came up during this session. The possibility of value-added services on community FM, like data-casting, was also discussed. It emerged that in many countries, neither transmitter power nor the height of the tower are fixed. These technical parameters are decided on a case to case basis, depending on the desired coverage area. Customization is seen as being essential to address the requirements of the community.
 
Issues: 

1.Frequency allocation: Frequencies of 90.4, 90.8 and 91.2 MHz have been set aside for community radio. However, 91 MHz has been given to commercial FM operators in certain cities, where it would potentially interfere with community radio frequencies. This frequency should either be blocked, or alternative frequencies should be made available for CR. However, review of National Frequency Plan is currently underway, with comments being sought from the public.

2.Value-added: Data-casting and other value-added services are currently not permitted on private FM. However, such services would be valuable for information-deprived communities.  

Conclusions and Recommendations:

1.Technical parameters: Technical parameters such as transmitter power and area of coverage for Community Radio stations have to be different from those in place for campus radio. Coverage area for community radio stations must be consistent with the geographical area in which the community being served is located, and the dispersal of listeners. 

2.Other parameters: In setting up a CR station, the costs should be kept as low as possible. Choice of the right frequency may make all the difference. 10-15 kW will give ample coverage of any town or city, which is as high as community radio requires in most urban contexts. However, transmitter power should not be overtly prescriptive, and a range of power may be a better choice.

3.Technical clearance: Community radio applicants can apply for frequency and SACFA simultaneously.

4.Transparency: In many countries, to ensure transparency, spectrum plans are developed in public. Spectrum needs to be allocated in an equitable manner.

5.Data Broadcasting: Data-casting is an important developmental tool for communities, and it should be permitted on Community Radio stations.

6.Community Radio Council: An umbrella body needs to be set up to act as an interface between the government and Community Radio applicants / licensees, since small communities with limited resources may not be able to deal routinely with central government departments.

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6 May 2004 - Session 4
Content, Sustainability and Capacity Building
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Eligibility criteria for issuing a community radio license again came up for discussion in this session, and the necessity for ensuring that the applicant actually represents the community. The nature of programme content on CR was also discussed, along with the capacity building necessary to sustain community radio. 

Related issues of funding, acquisition of hardware, running costs, financial requisites for CR etc were also discussed. These included the kind of agencies that could be permitted to fund CR stations, the issue of foreign funding, the possibility of internal funding by CR stations themselves, and the kind of linkages and partnerships that could be formed to promote community radio stations.

Issues:
	
1.Need for an enabling framework: The government, by its own admission, is moving cautiously in creating a policy for community radio. However, it is time to formulate an enabling policy for CR, in the light of international experience. 

2.Security issues: It is observed that countries with far greater political and civil strife have opened up CR as a tool for development. From international experience, it is clear that the security implications of CR are minimal.

Conclusions and Recommendations:

1.Mission statement: It is important that any CR project develops a clear mission statement, to define the philosophy and purpose of the station and its target audience. The station should articulate the interests of the community: health, culture, development, etc.

2.Community participation: Community radio is characterized by the participation of the community, especially the marginalized, in station management and content creation. The structure of community radio should be as democratic as possible. This could be achieved through an elected Board that selects the members of the Management Committee, each with a clearly defined role.

3.Eligibility criteria: Eligibility criteria should not be overtly exclusive. Instead of defining eligibility, it may be more logical to define who is not eligible for a CR license. Religious and political entities should not be permitted to hold CR licenses. The licensee should preferably be a registered entity, though this should not be a precondition. They may be required to register themselves within a suitable time-frame. 

4.Programme content:  Content policies will flow out of the activities of the community, and cannot be prescribed in the policy.

5.Quality of content: For community radio to be sustainable, the quality of programmes must be good, which will also ensure high listenership and the generation of sufficient revenues.

6.Programme Code: The existing Programme Code of All India Radio is a valid model for community radio also.

7.Capacity building: Capacity building is a crucial aspect of the sustainability of community radio, and it needs immediate attention.

8.Umbrella body: Community radio stations must create a suitable forum to address issues of self-regulation, mutual cooperation, training etc.

9.License fee: License fee and spectrum usage fee for CR need to be kept at affordable levels.

10.Funding: Community radio should be allowed to access funds from all legitimate sources. However, safeguards should be built in to ensure that funding agencies do not influence programming. 

11.Monitoring: Monitoring should mainly be about how the station's profits are used. Books need to be audited once a year. It is desirable that public hearings are organized, where the licensee has to state the mission of his CR station. Programme monitoring could then be left to the community and audience. 

12.Role of Community Radio: Community radio can be an excellent early warning system for the government. Issues will be ventilated in public, and can be monitored and acted upon long before they become matters of public discontent.

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6 May 2004 - Session 5
Accountability
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Issues of accountability and state security were discussed during this session. It was stated that enabling community radio by itself is a key factor of accountability in a democracy.

Accountability parameters could be built into the management structure and day-to-day programming of a community radio station. However, international experience suggests that community radio is not likely to become an instrument of social or civil unrest. Countries like Sri Lanka and Nepal, with a history of civil strife, have successfully promoted community radio. 

Conclusions and Recommendations:

1.Accountability parameters: Accountability parameters could be built into the management structure of CR, its implementing structure, and content creation. At all these levels, participation by the community, the station management and the advisory body has to be ensured.

2.Representative body: It was recommended that the proposed national body representing CR could also ensure codes of conduct, facilitate public hearings in the community and act as mediator between the regulator and the community station.

3.Trial period: Based on Australian experience, one option would be to have a trial period or short term license, which in turn would address some of the regulatory and security concerns. The trial period would also allow for examination of related issues such as who represents the community, the degree of community participation that has been achieved etc. 

4.Code of Conduct: It was felt that having a code of conduct would not only facilitate good programming practices and editorial independence, it would also act as a shield from interference by vested interests. 

5.Restrictions on funding: NGOs feel that restrictions on funding can be a serious constraint. Funds can be legally accessed through many channels, and since the poorer communities cannot afford the initial high cost of setting up a CR station, such funds may be vital for the success of the station. 

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6 May 2004 - Session 6
Final Recommendations - additional
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While summing up the Recommendations of the workshop on "Designing an enabling framework for community radio in India", a few supplementary issues came up for discussion.

1.Eligibility of Panchayats: The question of issuing CR licenses to Panchayats was discussed, but it was felt that this would be counter-productive. One of the functions of Community Radio was to assess and report on the achievements and failures of the local administration, and a CR station owned by the Panchayat would not be able to perform this function in an impartial manner. 

2.Intermediaries: The issue of offering licenses to intermediaries like NGOs was addressed. It was pointed out that it would be difficult for an amorphous entity like a community to apply for a radio station in India, and intermediaries - like NGOs -necessarily had to be involved. However, Community Radio was not necessarily NGO Radio, and hence the need to widen the range of eligible entities. 

The sessions were summed up by a Ministry official: "What we have understood here in the last two days is that there are no given truths, or rules written in stone. Each country must frame its own policy. A clear, successful policy does not come by government fiat, which translates into successful community radio on the ground. We must learn from other experiences and build a policy stone by stone for a successful and democratic community radio movement.
 
We need to put into place enabling frameworks which facilitate the creation of such stations, but also ensure their sustainability. As far as regulatory frameworks are concerned, we have to go by the innate decency of the communities than overt regulation of the government. 

This is not the last time we will be consulting stakeholders. We will meet from time to time, and every time there will be some movement forward. And soon we will be able to put in place a policy framework with which we can be satisfied."

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