Funferal

No new community radio for Galway

I haven’t been involved with any of the applications for a new community radio station in Galway, or had I previously reviewed the details of the applications. However, the news that both applications have been rejected deserves comment.

The BCI Press statement is brief, if not terse:

Two applications were received for the provision of a Community of Interest service in Galway City. Both applications were considered by the Commission but were not deemed to be of sufficient standard to merit further consideration or the award of a licence. Michael O’Keeffe, Chief Executive, commented: “We would like to thank both groups for their interest in the provision of a community of interest sound broadcasting service in Galway City.”

Both the Culture FM (pdf) and Flame FM applications are currently online (though they may be removed later).
Having browsed the applications there are two areas on which comment seems appropriate. First, the application process, and the philosophy behind it. Second, the details of the applications made.
To deal with the first first (and the second later): this was a call for Community of Interest stations. The term is an unusual one, and dates from the 1988 Radio and Television Act (Sec. 6 (2) (i)). One of the criteria to be used in decided whether, and to whom, to issue a sound broadcasting contract was the extent to which the proposed service served either a local community (and was supported by elements within that community) or served a recognisable community of interest. As it turned out, all of the stations approved in the first round were commercial (though some ‘integrated’ groups who had been operating unlicensed community stations). The IRTC later licensed a ‘special interest’ station – the privately-run public-service Anna Livia FM – and a ‘community of interest’ station Irish language Raidió na Life, both in Dublin.
The purpose of mentioning all this is to point out that the wording of the 1988 Act seems to have been intended to nod towards issues of community service, but not allow them to stand in the way of commercial interests. If anyone doubts me, remember that the Minister responsible was Ray Burke. (As an aside, Fianna Fáil, the party then in government, had previously included a promise to eradicate pirate radio in their manifesto in the same election in which they themselves ran a pirate station to promote themselves, as documented in Radio Radio.) So the distinction is really between ‘general interest’ in a geographical area, and ‘special interest’.
Subsequently, when the MDH appointed IRTC moved to rectify the imbalance in radio services, they ran two application processes – one for community services in specific (smaller) areas, and another for ‘community of interest’ services run by educational institutions. Following suggestions from those involved in the new licensees, both sets of stations had the AMARC Community Radio Charter for Europe incorporated into their broadcasting contracts. So here we see the emergence of recognition of community radio as a distinct sector – with a non-commercial ethos, and inclusivity in operations – and with community of interest services being grouped under this rubric.
I mention all this to clarify that there are two (possibly conflicting) understandings of ‘community of interest’ that emerge from this history. The first is simply ‘special interest’ and could cover the blind, those involved in education, those involved in the arts, technophiles etc. The second privileges ‘commmunity’ and sees the heading as either a special type of community radio, or a synonym for community radio, with all the various connotations that can cascade from that. [I should also mention in passing that there are two conflicting understandings of ‘community radio’ with one seeing the ‘community’ as an audience to be served, and the other seeing the ‘community’ as a group to involve in production and management].
So into this process an applicant dives, hoping to make a proposal that hits the right notes. The BCI (the renamed IRTC) doesn’t pretend, as the FCC does, to just fill empty slots on the spectrum, but openly attempts to push applicants and licensees to provide a ‘quality’ service – especially those licensed as community or community of interest operations. [The BCI tends, in my experience, to fall on the ‘community as audience to be served’ end of the spectrum, though it is not a dichotomous divide.]
So why did the two applicants fail? Without insider knowledge, my initial impression is that one concentrated on the individual details, at the expense of an overarching vision, and the other on the vision, at the expense of the details. Let me explain. The BCI tender documents (I speak from previous experience – I don’t think I looked at the documents for this application process) run through the headings to be covered under a range of headings – programming, finances, operations, ownership and control – using numbered paragraphs to list the issues to be addressed in each area.
One of the temptations is to prepare your application by running through each heading, responding directly to each point raised. While this is part of what is necessary, it misses some stuff. For example, in finance, the BCI are looking, not just for the various details as to whether you will have a debt, and what your share capital will be, but to find out whether you have a realistic financial plan. So they don’t just want a list of numbers in response to each heading, but a sense that these numbers have some grounding in reality. They also want to see a commitment from members and supporters, to show that the station won’t fall over if things don’t go exactly as planned. So the application should demonstrate a unified vision and sense of purpose that can’t be demonstrated through direct answers to the questions asked.
On the other hand, a vision and sense of purpose isn’t enough if you don’t demonstrate an understanding of what makes sense on a micro level, and what the BCI is getting at in questions about commitment to Irish music/culture, scheduling, and community links.
Now, I should say that I know little or nothing about either applicant, other than is demonstrated in their applications. I do know one of the board of the proposed Culture FM – he was a presenter on Flirt FM when I was there, and was involved in political activity with me. Also, some of the – many – supporters of the proposed ‘Flame FM’ are also friends and acquaintances of mine. Neither of which is surprising in a town the size of Galway – it would be more surprising if I knew nobody in either application. But I speak in general as someone divorced from the process, and with no affiliation with, or ax to grind in relation to, either group. I provide the caveats because I don’t intend to cause offence with any of my criticisms, below, but merely to provide guidance for anyone going down this path in the future.
First, Culture FM, who are the proposal with more concentration on ‘micro’ issues than on vision. The main weaknesses I note are:

• No justification for their figures for revenue generation are provided. The plan for 100 members contributing EUR30 per annum seems reasonable. But no justification for the proposed EUR10,000 per month in donations (for the 6 months prior to going on air) is provided. They don’t mention whether this will be from individuals, arts groups, or businesses. No details of how advertising will be generated – they include a figure for sales commission, but I don’t see mention of who will be doing this work. I don’t understand the difference between donations and community fundraising.
• There are various inconsistencies in the document, insofar as training will be in-house, so no one need be hired, but a (substantial) cost is set aside – what will this cost cover? I should stress that I see this as a shortcoming in envisioning and articulating what will be happening, as opposed to being ‘wrong’.
• There is no room in the proposal for the membership of the board to change, and each member serves in their individual capacity. As the structure is a co-operative society, the contract will be with the individual members of the board. I’m unsure if co-ops have previously been licensed, but the BCI has, in the past, preferred to contract with corporations, for various reasons. While other people can become ‘ordinary’ members of the society, they will not have a power to elect members of the board. There is a mention at some point of two volunteers being appointed to each committee working under the board – so who will the other members of such committees be? This is an example of answering the question (presumably about volunteer involvement in structures, in line with the AMARC charter) but missing the point – a desire for and accountible, fair and inclusive structure.
• The members of the board do not propose to make any particular (e.g. financial) contribution to the station, other than to serve on the board and hold the license, nor do they represent (or have affiliation with) groups that commit to make contributions (other than vague plans to work with the Access Music Project on training). Although section 4.2 lists groups that have expressed ‘interest in and support for’ the proposal, there is no more detail, nor is such support integrated into structures, solid funding plans, or other aspects of the submission
• While I admire the reference to recent immigrants to the city, I don’t see a sufficiently integrated and theorised articulation of what this means for the ethos of the station. There is reference elsewhere to a proposed ‘Asian Underground’ programme, and I think the reference is more than pandering, but a more integrated approach throughout the proposal would have benefited it, I think. To foreground the interrogation of cultural development, in an intercultural context – perhaps including representatives of non-national groups in the governance/advisory structures – would have made the proposal stand out [though frankly I think the financial aspects were what doomed the application]. Again, I think the ideas are worthwhile, I just don’t think they were seen to weave throughout the proposal – from operations, to structure, to programming, to finance.
• The proposal promises 5% Irish music. This seems low for a station based on local culture (and below the 30% the IRTC set as a general target for stations in 1996 or so). As a side note, in order to comply with EU legislation (and not be a restrictino on business/trade) the IRTC note of the time referred to ‘music based in, or arising out of, the Irish cultural experience’ or some such. Similarly, while they promise 40% talk, they specify that 1/4 of this will be advertising (you never spell out that you’re including advertising in your talk quota!) and list only 10% of time to be news/C.A. – while legislation requires that 20% of output be news/C.A. [More on news below]

And now Flame FM. They presented, generally, a unified vision of “a life-affirming broadcast station with a message of faith and hope for the people of Galway.” There is a little bit of prevarication as to the extent to which the station is a Christian station. Essentially this point is beyond doubt:

It is anticipated that the Board of Trustees will consist initially of five members drawn from faith-based organisations active in Galway. Membership will include three Catholic members and two non-Catholic members, two of whom will be female. The Board of Trustees will be chaired by a Roman Catholic priest, who will be one of the three Catholic members.

and the applicant is “Foundation in Christ Ministries, Ltd.” but there is a way in which try to position themselves as not exclusively being Christian:

Recognizing that there is an overwhelming Christian orientation to the audience it will serve, the programming portfolio will reflect Christian spirituality. However, FICM strongly emphasizes that it intends to survey a broad range of representatives in its market analysis, including representatives of religious groups, government, education, agriculture, business, labour, the professions, racial and ethnic groups, and eleemosynary organisations.

“eleemosynary” by the way means of or for charity (who knew!).
However, overall there is a strong sense of what is intended – backed up by the supporting letters (some of which forget the ‘vague and inclusive’ approach and specify a belief that the station might lead to a fall in teen pregnancies, another specifying that the role of FICM is to ‘proclaim the word of the gospel’). So where do they fail?
In the past the BCI has avoided licensing religious stations (or allowing religious advertising), in part I understand because of a (narrow?) reading of the objectivity requirement in section 9 (1) (b) of the 1988 Act. While IANAL, glancing at Section 18 of the 2001 Broadcasting Act suggests that this section remains in force. So there may be a remaining reticence towards licensing such an operation (or a continuing policy – but if so, there is no mention of this in the press release, or elsewhere that I can find).
What else might have seemed problematic? The document, while showing local support also shows that much of the financial support, and formal control, for FICM lies outside the state. In particular, the included (extensive) financial documentation for the company shows that its local operations (shop, restaurant) are losing money, and being heavily subvented by ‘Street Corner Ministries Matthew 22:9 Inc.’ When I say heavily subvented, the total ‘turnover’ (income from operations) was EUR79k in 2003 (YE 21/1/04), with subvention of over EUR300k, and a net profit of EUR209k. (There was also income from investments of EUR55k, a good turnaround from the previous year’s loss of EUR61k.)
Here, therefore we have the opposite of Culture FM – a strong source of funds, but one derived largely from outside the community. Given that 2 of the 7 directors of the station are living in the United States (and two others are US nationals currently living in Ireland) this may have been a negative factor for the commission.
At several points throughout the document it appeared to be drafted by someone outside the country, or someone anxious to dispel any sense of the station not being based in the community. ‘Máire Brennan’ was mis-spelt. Daniel O’Donnell was referenced as someone who would be played on air in order to attract young Irish listeners.
Also, in terms of staffing while their plans to rely totally on paid staff, if needed, while impressive, does not mesh with community/community of interest radio as it has developed in Ireland. They planned to spend over EUR250k per annum on staff alone. Funding would have come from a combination of ‘subscriptions’ advertising, and sales of airtime. While it’s difficult for me, as a non-accountant, to pull out some details from the figures provided [since they bundle the station with their other on-going operations] they do show the station growing to be 46% of their overall revenues. One of the obvious questions to ask is whether the station is seen to become a means to subvent their other operations (so is this seen as a commercial operation). A quick calculation (looking at the Year 5 figures) shows radio expenses as 48.3% of total operating expenses, so this does not appear to be the case.
The next question is whether the figures are reasonable. It seems to me that they are not. First, I am unsure whether ‘sale of airtime’ would be acceptable to the BCI. Second, EUR350,000 of advertising is a lot of cash to raise. Despite this, none of the seven staff positions listed (Table 3.4) are sales related. They may plan to have staff on commission, but I don’t see mention of or provision for this.
Both applications gave break downs of air-time that struck be as ill-advised, and both planned 3 hours or less of ‘live’ programming a day. They both broke down the figures in a manner that made it difficult to understand what their overall plan was. In the case of Culture FM they plan 6 hours of programming, of which 3 hours will be live. What will the other three be – repeats, or pre-recorded, or automated music programming? Looking at the programme schedule grid doesn’t easily reveal an answer. Within 5 paragraphs on page 15 (sections 5.2.2.3 to 5.2.4.2) they manage to give many details about their news programming that just can’t add up:

• News will account for 10% of output
• Galway is adequately served by local radio news bulletins. Culture FM will present a daily news bulletin of six minutes and twelve minutes daily exclusively devoted to community notices, with additional notices spread through general programming. In keeping with the ethos of the station, the news will attend to events of artistic and cultural relevance.
• There will be fourteen news bulletins of three minutes duration for a total of fortytwo minutes and fourteen community information broadcasts of six minutes duration for a total of eighty-four minutes.

So news will be 0.6 hours per day (36 minutes), there will be a daily six minute bulletin, there will be a total of 42 minutes of 3-minute news bulletins, there are already enough news bulletins, there will be over two hours of regular information/news bulletins.
In the case of Flame FM, they promise 10% of output to be live, initially – but it is unclear whether they mean that other programming will be repeats, pre-recorded, or imported. They also promise 1/4 of talk (itself 40% of time) will be news and current affairs. Maybe the tender document mentioned that 10% was the target, or I’ve missed a change in law/policy. They promise news on the hour, every hour, and plan to go on air from 7am until 11:30pm – with music and repeats on air during the overnight section. While they provide a detailed schedule, it is sometimes difficult to know which programmes will be produced in house, and which imported, and it is difficult to see how they plan to ‘build out’ their live capability.
So that’s my overview. I don’t mean to be overly critical – I know the effort that goes into putting together a proposal of this nature – but hope that the analysis may prove of interest and use to people.