[cr-india] Answers to TRAI

[DRISHTI]

we [drishti & kmvs] will not be able to make it to the TRAI consultations on 18th and 20th. but hopefully some of will be there. most of the questions this consultations seeks to address have been raised by our group time and again..yet i am putting down answers to some of them so that those going to the consultation can raise it on our behalf. HERE GOES...

Issues for consultation 

 Eligibility:

a)     What should be the eligibility criteria or would it be better to lay down non-eligibility criteria?
THE CR STATION SHOULD BE OWNED, CONTROLLED AND MANAGED BY THE COMMUNITY WITH NOT-FOR-PROFIT MOTIVE
b)     Whether Gram Panchayats and other local bodies should be eligible?
YES.
c)      Whether nationality of persons controlling the applicant organization should be an eligibility criterion?
INDIAN CITIZENS
d)     Whether financial  condition  of  the  applicant  organization, its  ability  to  raise  resources  and overall financial 
sustainability should be  an  eligibility  criterion?
NO
e)     Whether the applicant should be a legal entity?
NON-LEGAL APPLICANTS SHOULD BE ALLOWED TO APPLY WITH THE CONDITIONS THAT THE APPLICANTS REGISTER THE PROPOSED CR STATION IN THE INTERIM PERIOD OF APPLICATION AND THE ACTUAL LICENSE BEING GRANTED.
f)     Whether Co-operatives engaged in commercial activities should be eligible?
  YES. INFACT THE FOCUS SHOULD BE NOT ON THE TYPE OF ORGANISATION APPLYING BUT THAT THE APPLICANT OPERATES THE CR STATION FOR NON-PROFIT AND COMMUNITY DRIVEN PURPOSES.

Licensing Process: 
a)     Whether the applicants may be given temporary permits to operate for the time taken to grant a regular license?
YES. IF THE APPLICANT SO DESIRES
b)     Whether an Independent Licensing Body should be set up to examine, evaluate and decide on the applications for Community Radio License?
THAT MAY BE A GOOD IDEA TO EASEN THE PROCESS. INFACT THERE SHOULD BE A SINGLE WINDOW FOR CLEARING APPLICATIONS
c)     Whether the requirement of furnishing a Bank Guarantee be done away with?
YES. 
d)     Whether any of the clearances required today can be dispensed with?

e)     Whether time limits for individual clearances should be laid down, beyond which the department may be deemed to have given consent?
YES. 6 MONTHS
f)     What should be the period of license?
3 YEARS MINIMUM
g)     What should be the maximum permitted transmitter power and antenna height?
50 KILOMETER RADIUS. 
h)     Should separate frequencies be earmarked for Low Power Commercial Radio or should they be part of the same licensing process of community radio?
IT WOULD BE A GOOD IDEA TO ALLOCATE FREQUENCIES FOR THE EXCLUSIVE USE FOR CR STATIONS
i)     If frequencies are to be earmarked, then should the licensing framework follow the parameters of larger commercial services of phase-II?

Funding:
a)     Whether Community Radio Stations should be given grants by the Government? If so, whether this should be given by 
the Government of India or State Governments? If not, what possible arrangements could be allowed funding the operations?
THE PROPOSED CR STATIONS SHOULD BE ALLOWED TO ACCESS ANY 'LEGAL' GRANTS, WHETHER FROM THE STATE, CENTRE OR FOREIGN AGENCIES
b)     Whether commercial advertising should be permitted? If yes, then with what restrictions, if any?
YES. OUR INTENTION SHOULD BE TO ALLOW FOR SUSTAINABILITY OF THE STATION WITH A PURPOSE NOT-FOR-PROFIT. SO ALL REVENUES WILL HAVE TO PLOUGHED BACK INTO RUNNING THE COMMUNITY DRIVEN STATION UNLIKE PRIVATE FM RADIOS WHERE PROFITS GO INTO PRIVATE POCKETS.
c)     Whether  Community  Radio  Stations  should  be permitted  to accept  funds  from  foreign  donors?
YES. THE CR STATIONS SHOULD BE ALLOWED TO ACCESS ALL 'LEGAL' SOURCES OF MONEY
d)     Whether any license fee and spectrum use charges should be levied by the Government?
NO. WE NEED TO KEEP REMINDING OURSELVES THAT CR STATIONS ARE NOT-FOR-PROFIT VENTURES FOR AND BY THE COMMUNITY. THE GOVERMENT CANNOT DISCOURAGE OR PENALISE THIS VENTURE WITH A FEE!
e)     Whether any relaxation should be given in customs duty for import of equipment?
YES. THATS THE MINIMUM THE GOVERMENT SHOULD CONTRIBUTE IN THIS WHOLE VENTURE CONSIDERING THAT THEY ARE NOT GOING TO INVEST ANY MONEY IN SETTING UP THESE STATIONS.

Regulation & Monitoring:
a)     Whether there should be a separate programme code for community radio?
CR STATIONS CAN FOLLOW THE EXISITING AIR PROGRAMME CODE
b)     Whether the ban on broadcast of news and current affairs programmes should continue?
WHY SHOULD IT CONTINUE? WHY IS IT THERE IN THE FIRST PLACE?? 
c)     Whether Community radio stations should be required to keep recordings of their transmission? If yes, then what should be the specified period?
YES. FOR A PERIOD OF 6 MONTHS
d)     Whether the existing guidelines need to be revised, especially with regard to religious programmes? 
WHAT DO THEY MEAN BY RELGIOUS PROGRAMMES? THERE CAN BE NO OBJECTION WITH PROGRAMMES WITH RELIGIOUS [OR POLITICAL] CONTENT. WHAT WE NEED TO WATCH OUT FOR IS PROGRAMMES THAT MAY HARM COMMUNAL, RELIGIOUS HARMONY OR IS AGAINST ANY CONSTITUTIONALY ENSHRINED PRINCIPALS OF DEMOCRACY.

Hope and wish that consulation is meaningful and fruitful!!

In harmony,
Stalin K.
For, Drishti Media Collective & Kutch Mahila Vikas Sangathan
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