[cr-india] TRAI endorses ban on independent news on CR

Ram Bhat ram at maraa.in
Fri Sep 5 06:07:27 CDT 2014


Dear All,
Please find below a short opinion piece attempting to interpret the TRAI
recommendations on CR. Thanks to Geeta Seshu for publishing this on The
Hoot.
You can read the piece directly on the Hoot website as well with this link
-
http://thehoot.org/web/Trust-deficit-persists-on-news-on-Community-Radio/7753-1-1-3-true.html
best,
Ram


Trust deficit persists on news on Community Radio
*But TRAI recommendations make some headway on licencing and advertising on
community radio *RAM BHAT and VINOD PAVARALA decode the recommendations
Posted/Updated Friday, Sep 05 11:22:48, 2014

The last time TRAI recommended something on Community Radio (CR), the year
was 2004. Both activists and government have leveraged those
recommendations to open up the policy for community radio in 2006. After a
decade, TRAI has now issued recommendations
<http://www.trai.gov.in/WriteReadData/Recommendation/Documents/CRS_-_Reco_-_final_29_Aug_2014.pdf>
on
29th of August 2014.

Here are some comments on the implications of what TRAI has recommended:

*1.* *License Renewals*

The 2006 policy guidelines released by I&B ministry have no procedure or
mechanism for operational radio stations to renew or extend their license
beyond the initial period of five years. The key issues here are two-fold:
A relatively smooth and easy administrative process that can facilitate
renewal of license of community radio stations; how to balance interests of
incumbents (who want renewal) with interests of new comers (who want entry
into market)

*Recommendation*

TRAI has recommended that after the initial license period of five years,
community radio stations should be able to get a renewal of five years
provided they have basic compliance with terms of license. In order to get
a second extension, community radio stations should fill a self-evaluation
report that will then be compared to the applications forms filled by
prospective newcomers.

*Implications*

TRAI has taken a reasonable and balanced approach to the issue. It has
incorporated the interests of the incumbents and virtually guaranteed them
a minimum of ten years presence in the market. However, it has also taken
care to represent the interests of the newcomers by allowing them to
compete with incumbents.

The only problem, and it can be quite a significant problem, is that of the
actual decision maker. TRAI has not explicitly mentioned it, but one can
assume that I&B Ministry will decide whether the incumbent will continue or
a newcomer will be favoured.

This is a classic, discretionary mode of decision-making. If the government
is not careful, this could lead to favouritism, or worse corruption.
Ideally, an independent regulator should make these kinds of decisions but
TRAI has stayed away from this contentious issue.

Further, the self-evaluation that TRAI recommends as a precursor to the
second renewal after 10 years raises some apprehension that the ongoing
peer review process initiated by MIB for community radio may become the
standard measure for renewals in the future. It would be contrary to the
spirit of self-assessment, co-learning and continuous improvement, the
principles espoused by the Ministry for the peer review.

*2. News and Current Affairs*

The 2006 policy guidelines explicitly prohibit community radio stations
from broadcasting news and current affairs. The same goes for commercial FM
radio. News and current affairs is not defined. Many community radio
stations feel vulnerable since anything they do could be defined as news
and invite censure from government.



*Recommendation*

TRAI has only repeated what Mr. Javadekar has said across various fora
since he assumed office. Community radio stations will be allowed to
re-broadcast news from All India Radio without altering the content.
However, TRAI has gone a step further and recommended that CR stations be
allowed to translate into local language/dialect without distorting the
content.

TRAI has not said anything new, but in fact further damaged the cause by
providing some deeply flawed analysis. There are three main threads to
TRAI’s arguments. One is that providing permission for news is premature
because the Ministry is on the verge of setting up an Internet based
monitoring system. Permissions can be reviewed once monitoring system is
operational.

Second, if CR is allowed news, then there is scope for misuse and
misleading information may be broadcast in guise of local news.

Third, since commercial FM is not allowed news, it would be unfair to
recommend that CR be allowed news.

*Implications*

It is a mistake to think that monitoring systems will influence the
production and broadcast of FM radio in any way, except perhaps
psychologically. Most of the community radio stations do not have reliable
internet connection to provide upload of audio feed. It is impossible to
know whether the feed uploaded on the internet is the same as what is being
broadcast on FM.

Lastly, by the time the audio stream is processed online, it has already
been broadcast on FM and thus too late to prevent. Further, community
radios broadcast in a wide variety of languages and dialects. How will a
team sitting in Delhi understand all these dialects and languages? Thus,
monitoring is, at best, a psychological experiment designed to create some
fear and hesitation that Big Brother is listening. In reality, it is a
waste of public money.

It is baffling that TRAI thinks that there is scope for misuse or
misleading information could be broadcast in guise of local news. After
all, these very communities have been broadcasting other programmes for
several years.

Is TRAI thus supporting community radio and trusts communities to make
other programmes, but when it comes to news, these communities are seen as
untrustworthy?

The simple truth of the matter is that it doesn’t matter what TRAI thinks
or anticipates. Such anticipatory logic exceeds the reasonable restrictions
under Article 19 (2) of the Constitution. Some community radio stations
have been on air for seven to eight years and not once have they given
reason to believe that any reasonable restriction of Article 19 (2) could
be applied to them.

Lastly, TRAI has invoked the fairness principle in recommending that
community radio should not be allowed to broadcast self-generated news. The
implication is that while commercial FM is not allowed news, it would be
unfair to allow community radio. This is a relative and narrow
interpretation of fairness. In reality, this interpretation is unfair to
both commercial and community radio.

The right thing to do is to recommend that both sectors be allowed to
broadcast news and current affairs. In any case, the Supreme Court is
currently hearing a public interest litigation filed by Common Cause
questioning the ban on news on commercial and community radio. One hopes
that the Court will uphold the constitutional right in this case, as it has
done in many other recent instances.

*3. Advertisements – Duration and Rates*

The current policy guidelines cap the duration of advertisements to five
minutes per hour of broadcast. The major advertiser for community radio in
practice is the Directorate of Advertising and Visual Publicity (DAVP).
DAVP pays 4 rupees per second for any advertisement that it releases for
community radio, but insists that this rate should be the lowest ad rate
held by the radio and be exclusively offered to DAVP.

*Recommendation*

On the basis of limited evidence submitted by stakeholders in the
consultation period, TRAI has surmised correctly that most community radio
stations are unable to even fill the five-minute advertisement limit
proscribed by the government. In such a situation, it would be pointless to
even consider increasing the duration of time allowed for advertisements.
Further, TRAI has also recommended that DAVP should relax the stipulations
that their rate (4 rupees/min) be the lowest or that this rate be exclusive
to DAVP.

*Implications*

TRAI is right in saying that there is no point in considering increase in
duration of advertisements. Firstly, the data indicates that community
radio caters to an audience that advertisers are not interested in.
Secondly, to increase duration of advertisements would provoke a severe
response from commercial broadcasters who would then question the
concessions CR stations get on other fronts (nominal spectrum fee, no
license fee). Thirdly, it is a wake-up call for the CR sector.

Even in the best of cases or in top radio markets, it would be unwise for
CR Stations to continually depend on the ad market given that objectives of
the CR station, the genres of programming, and profiles of the target
audience are mostly unfriendly or irrelevant to the market. There is an
urgent need to brainstorm around other ways to sustain CR stations – either
by changing the ways in which CR Stations spend money, or changing the ways
in which CR Stations can earn money.

*4. Single Window Mechanism*



The current policy guidelines require applicants to submit applications to
I&B, and then to approach MoCIT for frequency, then to go back to I&B to
sign a Grant of Permission Agreement and then go back to MoCIT for the
Wireless Operating License. The process inevitably takes in excess of 18
months and has discouraged many from applying.

*Recommendation*

TRAI has recommended an e-governance enabled single window mechanism
thereby cutting red tape and considerably easing the process of application.


*Implications*

The main problem so far has been the division between the CR cell in the
I&B Ministry and the WPC cell in the MoCIT Ministry. Typically, I&B handles
radio and TV licenses, while MoCIT handles spectrum allocation for radio,
TV, telecom and internet. The latter handles more work as well as more
revenue, while the former is focused on broadcast and deals with
administrative licenses.

There is very little incentive for MoCIT to create a special case for
Community Radio, given that there are fixed systems of licensing for
telecom, television, public radio and so on. The political masters at both
ministries have to acknowledge that a minor issue of administrative process
has created major damage to the plans that government has for community
radio.

If there is political will in the system, then a separate administrative
process can be carved out for the unique situation of community radio. If
the Ministers do not take notice, it is unlikely that this recommendation
from TRAI will have any major impact on the current process.

*(Ram Bhat is with the Community Radio Forum of India and Vinod Pavarala is
the UNESCO Chair on Community Media, University of Hyderabad)*

---
Ram


On Mon, Sep 1, 2014 at 6:26 AM, Vinod Pavarala <vpavarala at gmail.com> wrote:

> Dear Ram:
>
> Thanks for your detailed comments.
>
> On the *renewal of licenses*, the feeling I have is the scrutiny/review
> that TRAI suggested for the first-time renewal would be a basic one, with
> the Ministry just ensuring that they have been on air all these years and
> keeping up the commitment made under the GOPA.  The second-time renewal
> process (i.e. starting in the 9th year or so) is meant to be a little more
> rigorous, with some evaluation thrown in. But we should be happy that it
> also says self-evaluation. There is always enough flexibility in
> interpreting TRAI recommendations, and I hope the Ministry will be more
> accommodating than restrictive in implementing this method.
>
> On the *news* issue, I completely agree with you that bringing in the
> commercial players into the argument is specious. Of course, they should go
> ahead and give them the right to broadcast news as well. It is ridiculous
> that someone in the mainstream press thinks that we should be rejoicing
> about the TRAI recommendation to allow CRSs to broadcast unaltered AIR news
> content. It is about the constitutional right, and I too hope the Supreme
> Court will come up with something decisive.
>
> On the *ad rates*, following the TRAI Consultation in Delhi, One World
> did conduct a quick survey to collect data from a number of stations about
> advertising. And, the results reinforced our perception that hardly any
> station is able to meet the five-minute limit, and many were struggling to
> raise any advertising at all. There was a feeling that if they were not
> tied down by DAVP rates, then they can be a little more competitive in the
> local market. So, I think, TRAI is in the right direction on this one.
> However, in the end, the advertising challenge for rural, community radio
> stations is a *non sequitur*. Philosophically, you are expected to reach
> out to the most marginalized in the community, groups that would be a
> marketing nightmare. This is the paradox of advertising in CR. Advertisers
> are not interested in reaching people that you as a community broadcaster
> are mandated to reach! The CR stations are, therefore, forever doomed to
> struggle. There ought to be other pathways to sustainability.
>
> On the *single window*, as someone else pointed out, MIB is already doing
> some kind of a single window through its own mechanisms such as the CCFC.
> But, without integrating the WPC functions, which, currently, are the
> source of all delays. Any such integrated single window, without any hidden
> doors, trellises, and moats (thanks, Sajan!) would be a big step forward.
> It will, necessarily, have to be an inter-ministerial, collaborative
> effort, not something that MIB can do by itself, despite its good
> intentions.
>
> best,
> Vinod
>
>
>
>
>
>
> On Sun, Aug 31, 2014 at 9:06 AM, Ram Bhat <ram at maraa.in> wrote:
>
>> Some comments on the TRAI recommendations:
>>
>> Renewal of Licenses:
>> Licenses will be renewed for a period of five years (with request for
>> renewal to be made in the 4th year)
>> Second extension and subsequent extensions to be made on basis of
>> self-evaluation - format of which will be prepared by I&B Ministry; fresh
>> applications to be considered in comparison with self-evaluation report of
>> incumbents.
>>
>> This is along expected lines and seems more or less fine. The problematic
>> aspect of this is the self-evaluation format which will be spearheaded by
>> the Ministry. Supposing CR station X is operational for the first 5 years,
>> seeks extension and is granted another 5 years. In the ninth year of its
>> existence, it will have to fill in a self-evaluation report. The obvious
>> problem is how a generic format prepared by I&B will address questions of
>> renewal, sustainability, performance etc for a particular CR station - the
>> problem is exacerbated if the radio station is located in a remote area
>> with a unique local context. Further, this self-evaluation report will be
>> compared to an application made by a prospective newcomer. TRAI has not
>> mentioned who will do the comparison and make this crucial decision - of
>> favouring the incumbent to continue or favouring the newcomer. Unless there
>> is a strong decision on independent regulator, these kind of issues will
>> continue to fester. Needless to say, these kind of critical decisions will
>> involve significant conflict of interest if I&B people are to be involved.
>>
>> News and Current Affairs
>> TRAI has recommended that CR stations be allowed to re-broadcast AIR news
>> with a provision to translate without distorting the news.
>>
>> There are two aspects of the analysis which are troubling. One is that
>> this permission to re-broadcast AIR content may be reviewed when monitoring
>> mechanisms are in place since CRs can 'misuse' the power to broadcast news.
>> Second is the perceived unfairness to commercial players. The logic seems
>> to be that since commercial players, even though they have auctioned for
>> licenses, are not allowed news, it would be unfair for CRS to be allowed
>> news.
>>
>> Taking the monitoring aspect first, we have already discussed that I&B
>> has spent about 280 crores in setting up a Electronic Media Monitoring
>> Centre. The annual budget for EMMC is 13.75 crores. This money is ill-spent
>> in attempting to monitor a bunch of terrestrial analogue radio stations.
>> Firstly, it is doubtful whether each and every one of these stations will
>> have broadband capabilities to enable uploads of audio feeds. Secondly, if
>> by some miracle, each and every CR station has broadband internet, the
>> question remains on how I&B plans to monitor all the various programmes
>> produced and broadcast in diverse languages and dialects. Does this mean
>> that the Ministry plans to hire one or many persons for each language and
>> dialect spoken in the country? Thirdly, as our CR stations increase the
>> amount of air time, it will be impossible to monitor the content
>> practically. At best, the people sitting in EMMC can object to a program
>> some time after it has already been broadcast. In such a situation, the
>> best possible scenario can be to send warning notice or in a more drastic
>> scenario, suspend the license (temporarily or permanently). The damage
>> would already have been done on the field. Clearly, this whole line of
>> thinking, i.e. an attempt to monitor hundreds of analogue terrestrial
>> services in real time is not only impractical, but also expensive and
>> impossible to execute. Further, there is no clarity about the independence
>> of the EMMC. If a station is politically active and then in the near
>> future, EMMC deems some content objectionable, wouldn't many of us assume
>> that this is indirect censorship? Again, there are potential conflict of
>> interest issues, not to mention dangerous regulatory powers given to a
>> political entity, namely I&B Ministry.
>>
>> Secondly, if we consider the unfair to commercial players line of
>> argument, it is indeed circular logic that TRAI has applied to the
>> situation. After all, it is possible that TRAI and/or I&B may say that it
>> is unfair to allow news on commercial FM because CR stations are not
>> allowed to broadcast! No, the frame of reference must be constitutional
>> rights. The second and more practical frame of reference can be an attempt
>> to create a level playing field. A level playing field can be created by
>> allowing both sectors the right to broadcast news. Instead, TRAI has
>> unfortunately chosen to create a level playing field by denying both
>> sectors the right to broadcast news. In any case, as several of us have
>> mentioned previously, the matter is sub-judice and in my personal opinion,
>> it is highly doubtful whether the restriction on news and current affairs
>> will survive judicial scrutiny. It would have been useful if TRAI had
>> endorsed the more liberal and more common-sensical point of view, i.e. to
>> remove restrictions on broadcast of news and current affairs including
>> political programming. It is all the more ironical since the commercial
>> sector representatives have themselves come out strongly in favour of
>> permitting news on FM.
>>
>> Duration of advertisements
>> TRAI has recommended that 5 minute window of advertisements per hour of
>> airtime is sufficient. However, it has 'requested' DAVP to relax the
>> stipulation that DAVP approved rate is the lowest rate and exclusive to
>> DAVP.
>>
>> Although TRAI may well be right that 5 minutes per hour is sufficient, it
>> is unfortunate that TRAI has arrived at the decision without any evidence,
>> much less a reasoned analysis based on evidence. On the contrary, TRAI has
>> highlighted that 5 minutes cap was set keeping in mind the 'impact' on
>> commercial FM sector, and further states that 'the situation has not
>> changed warranting a relook'.
>> It is worth reiterating that the most significant competition between
>> commercial and community radio takes place in A+ and smaller urban areas,
>> and not at all in rural areas (even after FM-Phase III). Therefore a
>> blanket decision affecting CRs across urban, semi-urban and rural is
>> actually unfortunate. To decide that 5 minutes is sufficient because they
>> are not currently fulfilling it is an old sarkaari logic (Note how govt
>> budgets get slashed if they are underutilized). At this rate, if an
>> unfortunate CR station does not get any advertising, then TRAI will
>> recommend that there is no need for advertising at all! The time duration
>> for advertising should not be based on whether a few stations can fulfill
>> the limit or not. Instead the time duration should be based on what is the
>> average amount a particular CRS needs to raise to cover operating expenses
>> in a urban, semi-urban and rural area (respectively) by renting airtime on
>> an average rate (benchmarks for this need to be worked out depending on
>> category of urban, semi-urban and rural).
>> Also, it would be worth pointing out that it is also unfair to compare
>> commercial and community radio in terms of advertising rates. The other
>> variables are highly skewed in favour of commercial radio. The first factor
>> is the transmission power where CR is capped at an extremely low power of
>> 100 Watts ERP when compared to commercial radio. The second factor is that
>> community radio stations are given to non-profit organizations and all
>> surplus revenue is to be ploughed back in to the CRS operations.
>> In spite of this, it is possible that in a few markets, the rates will
>> come plummeting down if CR ad rates become the benchmark for the FM market.
>> However, there is no evidence of this happening where there is direct
>> competition. We can look at the top radio markets of Bombay, Delhi,
>> Bangalore, Kolkata and Chennai etc. In no top radio market has the CR
>> station influenced the ad rate- even to a minor degree. The coverage of the
>> CR station is so small that it has no real influence for ad rates for a
>> city wide audience.  It might be interesting to study if CR stations have
>> distorted as rates in smaller cities, e.g. Kanpur, Jhansi etc
>>
>> Disaster and CR
>> TRAI has basically left the whole thing to NDMA, requesting the latter to
>> come up with guidelines for relocating existing CRs in disaster areas, and
>> guidelines for new CRs in disaster areas.
>>
>> NDMA representative had come to the 2014 Sammelan on invitation by I&B.
>> He was very clear that NDMA had no authority to enforce anything and can in
>> fact only present guidelines. If NDMA gets its act together, at best it
>> will only add to its illustrious and long list of guideline documents -
>> which then are roundly ignored by all other stakeholders. To the best of my
>> understanding, the disaster and communications issue can only be handled
>> with some authority by MHA and MoCIT. If these are kept out of the policy
>> decisions, then it is likely that they will be unaware of the whole effort,
>> much less engage with it meaningfully.
>> I also believe that the issue of disaster/emergency and CR is much wider
>> than the scope TRAI has outlined. There is also the question of ongoing
>> alert-based information to existing CRs. Then there is the question of
>> interconnecting CRs (not just with each other but also with public radio
>> network) in case of wider regions being affected. Lastly, there needs to be
>> a strategy where local authorities (District Collector, state authorities)
>> need to be made aware of CR presence (especially in areas which are deemed
>> vulnerable). Unfortunately TRAI has ignored all these aspects with the hope
>> that NDMA will look at it in the future.
>>
>> Single Window Mechanism
>> TRAI has recommended a online single window mechanism for CR applicants.
>> While this is well intentioned it is unfortunately almost impossible to
>> implement.
>> I&B can absorb paperwork wherein it has to send copies of applications to
>> other ministries (Law, Defence, MHA etc) and to its credit, this system is
>> already converted into a single window mechanism. Today, an applicant has
>> to submit 7 copies of the application only to I&B, and I&B in turn
>> circulates copies to other ministries.
>> The real issue comes with the separation of I&B and MoCIT. The WPC has
>> its own way of doing things and so far I&B has not successfully managed to
>> convince WPC of the need for single-window mechanism. It is unlikely that
>> TRAI's recommendation will improve this situation although it must be said
>> that it is the right thing to recommend.
>> The SACFA, GOPA and WOL processes does most of the damage - and this is
>> distributed between the two ministries. I hope that the TRAI recommendation
>> is taken up by the two ministers (Mr. Javadekar and Mr. Ravi Shankar
>> Prasad) as an issue that can be sorted out with political will.
>> It is perhaps for the first time that TRAI has explicitly acknowledged
>> concerns of the commercial radio sector in a recommendation paper dealing
>> with Community Radio. The concerns have been cited for duration of ads as
>> well as on news and current affairs. It is very unfortunate that the
>> commercial radio association AROI and the community radio associations CRF
>> and CRAI have not formally spoken to each other. We need a platform where
>> both (in fact we can add public radio to that list) sectors can talk about
>> issues common to each other. Since all three kinds of FM radio operate in
>> the same geographical area, there are bound to be common concerns,
>> perceived conflicts and concerns about level playing field. If they are not
>> addressed between ourselves offline, then these issues find their way into
>> TRAI papers, policy decisions etc doing untold damage to one sector or the
>> other - often to all sectors more often than not.
>>
>> Apologies for the long email, and looking fwd to more responses,
>>
>> best,
>>
>> ---
>> Ram
>>
>> >
>> >
>> > On Sat, Aug 30, 2014 at 1:08 AM, Kanchan K. Malik <
>> drkanchan07 at gmail.com> wrote:
>> >>
>> >> Only unaltered AIR news on CRS is a big disappointment indeed! People
>> can tune in to AIR for that - they do not need a CRS.
>> >>
>> >> Also not sure why they think CRSs would 'misuse' this facility? Has
>> all the 'monitoring' of news channels by MIB ensured that all news in the
>> public domain is not 'misleading'?
>> >>
>> >> However, I liked their analysis of the duration of advertisements (and
>> the ensuing recommendation of flexibility to offer lower rates to the local
>> businesses).
>> >>
>> >> The section on Sub-categorisation of CRS also sums up some of the
>> crucial issues related to the distinction in the 'focus, objectives,
>> content, funding, and outlook' of community, campus and KVK radios.
>> However, the low numbers in each category is the reason stated not to carry
>> out this exercise at present. Hope it will happen in good time…
>> >>
>> >>
>> >> On 29 August 2014 23:46, Arti Jaiman <arti at trfindia.org> wrote:
>> >>>
>> >>> Extremely disappointing.
>> >>>
>> >>>
>> >>> Sent from Samsung Mobile
>> >>>
>> >>>
>> >>> -------- Original message --------
>> >>> From: Vinod Pavarala
>> >>> Date:29/08/2014 18:48 (GMT+05:30)
>> >>> To: cr-india at sarai.net
>> >>> Subject: [cr-india] TRAI endorses ban on independent news on CR
>> >>>
>> >>> Dear all:
>> >>>
>> >>> The TRAI recommendations on community radio are now out in the public
>> domain. Here is a quick summary of the key points:
>> >>>
>> >>> TRAI has expressed its reluctance to recommend broadcast of
>> independently produced news by CR stations. This is based on fears of
>> 'misuse' and 'lack of monitoring'. It, however, endorses broadcast of AIR
>> news. This is indeed a setback, although TRAI says the issue can be
>> re-visited after MIB puts a monitoring mechanism in place. TRAI's 2004
>> recommendations were actually more liberal.
>> >>> On other issues, it reinforces the current issue of licenses for a
>> period of 5 years, and recommends renewal for five-year periods, with the
>> requirement, for first time renewal, of verification of adherence to terms
>> of the original license, and, for a second-time renewal (at the end of 10
>> years) of a systematic evaluation mechanism (including self-evaluation).
>>  This sounds fair enough.
>> >>> On advertising, TRAI is of the opinion that the current 5-minute time
>> limit is adequate. It has, however, heeded to the pleas by stations that
>> they be allowed to offer rates lower than DAVP fixed rates to attract
>> local, small-time advertisers.
>> >>> On emergency broadcasting during disasters, TRAI sounds sympathetic
>> to the long-standing request from the sector that the Government needs to
>> demonstrate some flexibility in relocation of transmitter of a station
>> already functioning in the region or to set up emergency transmitters where
>> none exist at present. However, TRAI has stopped short of recommending
>> anything concrete, except for asking NDMA to develop detailed guidelines.
>> >>> On various types of CRSs under the current licensing regime (campus,
>> community, KVK/AU, etc), TRAI felt that as the sector is still growing,
>> this may be too early to create sub-categorization of licenses (although it
>> may become necessary in the future).
>> >>> On our usual complaint about licensing procedures, TRAI took
>> cognizance of the delays at the WPC end resulting in much frustration and
>> suggested that MIB set up an online single window by integrating all the
>> steps up to the signing of the GOPA. If this can be done, many potential
>> applicants will find the process much smoother.
>> >>> Please share if you think I have missed anything significant in the
>> recommendations.
>> >>>
>> >>> best,
>> >>> Vinod
>> >>>
>> >>> --
>> >>> Dr. Vinod Pavarala
>> >>> Professor of Communication &
>> >>> UNESCO Chair on Community Media
>> >>> Sarojini Naidu School of Arts & Communication
>> >>> University of Hyderabad
>> >>> Gachibowli, Hyderabad 500046
>> >>> Phone: +91-40-23135501/23011553
>> >>> http://www.commuoh.in/
>> >>> http://www.uccommedia.in/
>> >>> http://www.communityradioindia.org/
>> >>>
>> >>>
>> >>> Join the Community Radio Forum.
>> >>
>> >>
>> >>
>> >>
>> >> --
>> >>
>> >> Dr. Kanchan K. Malik
>> >>
>> >> Associate Professor, Department of Communication
>> >>
>> >> Faculty Fellow, UNESCO Chair on Community Media
>> >>
>> >> Sarojini Naidu School of Arts & Communication
>> >>
>> >> University of Hyderabad
>> >>
>> >> Gachibowli, Hyderabad 500046
>> >>
>> >> Phone: +91-40-23135506 (O)
>> >>
>> >>            +91-990-858-2613 (M)
>> >>
>> >>
>> >> Join the Community Radio Forum.
>> >
>> >
>>
>>
>> Join the Community Radio Forum.
>>
>
>
>
> --
> Dr. Vinod Pavarala
> Professor of Communication &
> UNESCO Chair on Community Media
> Sarojini Naidu School of Arts & Communication
> University of Hyderabad
> Gachibowli, Hyderabad 500046
> Phone: +91-40-23135501/23011553
> http://www.commuoh.in/
> http://www.uccommedia.in/
> http://www.communityradioindia.org/
>
>
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