That is a helpful intervention. I will go on to indicate the Community Media Association’s concerns. It says that a

“commercially operated small-scale radio multiplex operator may be inclined to populate available capacity with content from those providers prepared to pay the highest rate, rather than content of the greatest public value.”

It says as an example that

“content providers that have very low fixed costs such as those providing semi-automated predominantly music services may be better placed to afford high costs of transmission, than content providers who invest in original local content including speech and local journalism.”

The Community Media Association would have liked to propose—it certainly seeks the promoter’s views about this—that

“small-scale radio multiplex services be required to operate for public and community benefit rather than for commercial reasons in order to favour existing community radio providers or consortia of small-scale local and community media to come together to operate the multiplex.”

It says that that

“would not preclude a…local commercial radio service from playing a lead role in establishing a not-for-profit vehicle to hold the multiplex licence and to operate it on such a basis that local radio services, including small-scale commercial radio services, are provided with free or low cost carriage, and that any surpluses generated are invested in local content production.”

That is the association’s first concern.

Its second concern—again, in another world, this might have been dealt with by adding a new subsection after subsection (4)—is another a “must not” concern. The association would have liked the Bill to say that the Secretary of State must not

“make an order under this section in relation to small-scale radio multiplex services except where the order provides that no individual or body corporate may hold or control more than one small-scale radio multiplex licence at any one time.”

In the association’s view, it

“would be preferable for no person or entity to be permitted to hold or control more than one small-scale radio multiplex service licence in order to encourage local ownership and the establishment of local non-commercial consortia or a local non-commercial operator (such as a community radio service provider) to become small-scale radio multiplex service owners.”

It thinks that it is likely that such a multiplex service

“will have an effective local monopoly in the provision of digital sound broadcasting services for its particular area of coverage. The owner will therefore be in a dominant position in the market for carriage of local digital content and there is a risk that this position could be abused to favour some content providers over others.

Multiple ownership of small-scale radio multiplexes is likely to lead to uniformity of content, a higher proportion of non-local content and the use of multiple small-scale multiplexes for the provision of quasi-regional services or, at the national level, the cherry-picking of the most profitable locations by a limited number of operators.”