WHEN "SMALL" IS "BEAUTIFUL" A COMPARATIVE ANALYSIS OF LOCAL RADIO POLICIES IN EUROPE TOM EVENS STEVE PAULUSSEN Abstract In this article, the focus is on how policy makers in Flanders (Belgium) can be inspired by the implementation of local radio development strategies in three neighbouring markets (the Netherlands, Great-Britain, the French-speaking Community in Belgium). More specific, the article concentrates on the questions of which options policy makers have at their disposal in supporting local radio and what lessons they should learn from foreign experiences in boosting the sector's development. The final aim is to come up with policy recommendations for reorganising local broadcasting and strengthening its economic and social value. To do this, document analysis was combined with seventeen local radio expert interviews in all markets involved. Next, a cross-country analysis was performed to identify structural conditions and propose policy options for a proactive media policy regarding small-scale radio. Tom Evens and Steve Paulussen are (senior) researchers at the Research Group for Media & ICT (MICT) affiliated to Ghent University and the Interdisciplinary Institute for Broadband Technology (IBBT); e-mail: Tom.Evens@UGent.be. rN rN ■ LO si ro o rN oo £ £ 3 a 0 £ * 1 * (R 0 C s LO Introduction During the last three decades, local radio has established its position in the European media landscape. It seems that, in response to the ongoing globalisation, liberalisation and digitisation of cultural production, local-based practices are increasingly gaining importance in media cultures. Consequently, community radio is increasingly getting more attention both from national and European authorities. This type of non-commercial media is gradually being recognised and funded as third tier media sector at the national level while European policy makers have considered their contribution to the promotion of media pluralism and democracy. After thirty years of campaigning for institutional support and funding, it seems that community media have finally found their place in European media policy (Jiménez and Scifo 2010). Despite these promising policy and regulatory developments in Europe, the sector faces a lot of upcoming challenges regarding the switchover to digital broadcasting platforms and the sector's further consolidation in European policy making. Furthermore, many national states still fail to provide a sustainable basis for a mature local radio sector that can play a significant role in the pending issues of media literacy, media pluralism and digital democracy. As Cammaerts (2009) argues, community radio is under threat in some of these countries as it experiences difficulties in establishing itself between the state-controlled broadcasting system and the market. In Flanders (North of Belgium), for example, local radio is facing structural handicaps to be economically viable and to secure its future due to a lack of cohesive policy. Whereas local radio had an audience share of 34.7 percent in 1991; this share has fallen to about 7 percent in 2010. While many non-commercial stations were pushed out of the market by the rise of large-scale networks, the overall financial performance of these networks and the remaining local stations has dramatically deteriorated as well. Furthermore, the ongoing competition for listeners and rey sources has driven stations to a market conformity approach, which has induced homogenisation of programming strategies and a decrease of local content (Saeys and Coppens 2007). The story of local radio in Flanders clearly illustrates a number of conflicts that explain some of the current thresholds for the sector's development. Although these conflicts are to some extent unexpected consequences of the legal framework, they have driven up ruinous competition in the market and have negatively affected the economic performance of local radio in Flanders. In brief, the sector suffers from overcrowded airwaves, limited geographical coverage and inadequate funding, but policy makers get stuck in path dependency (Evens and Hauttekeete 2009). analysis of similar European countries and regions shows that government can act more proactively in local broadcasting and implement innovative approaches that fully support the development of local and non-commercial radio (Price-Davis and Tacchi 2001; Peissl and Tremetzberger 2010). This article draws upon a research project carried out in 2008 for the Flemish Ministry of Culture, Youth, Sport and Media that aimed to map "good practice policies" in three adjacent markets including Great-Britain, the Netherlands and the French-speaking Community (South of Belgium), and to explore policy options for the support of a sustainable and diverse local radio scene in Flanders. In this article, the focus is on how policy makers in Flanders can be inspired by the implementation of local radio development strategies in three neighbouring countries and regions. More specific, this article concentrates on the questions of which options policy makers have at their disposal in supporting local radio and what lessons they can learn from foreign experiences in boosting the sector's development. This overview of strategies should result into a framework with major policy recommendations for reorganising local broadcasting and strengthening its economic and societal value. In the first stage, a literature review and document analysis were done, and combined with seventeen interviews with local radio experts. This expert panel consisted of scholars, radio professionals and representatives from regulators and radio federations, coming from the Netherlands (5), Great-Britain (2), and the Flemish (8) and French-speaking Community (2) in Belgium. In the second stage, a market prospect of the considered countries was executed, structural problems were identified and possible remedies were analysed. Eventually, this inspired to develop a set of policy options and recommendations regarding four domains (cultural, economic, technological and regulatory issues) for reorganising and supporting the local radio landscape in Flanders. As these options were not strictly defined in the topic guide, this set of policy perspectives were derived from the interviews and market prospect, and did not really function as a concrete framework during the empirical stage. As mentioned, the article compromises a cross-country analysis of three neighbouring local radio markets, which each belong to a specific (and later discussed) local radio development model: the Netherlands (North-European policy model), the French-speaking Community (South-European policy model, in transition to the North-European policy model) and Great-Britain (pragmatic policy model). These radio markets are not only adjacent to Flanders, but have specific particularities to be included: the Netherlands serve as a textbook case for local radio policy, Great-Britain has a pioneering position in community radio policy and in digital broadcasting platforms while a fresh regulatory wind, partly based on the French model, is currently reshaping the local radio scene in the French-speaking Community. Hence, this cross-country analysis of good practices can provide some food for thought both for policy makers and scholars to develop a strategic framework for the support of local radio in Flanders and elsewhere. The article is structured as follows. First, a historical overview of how local radio developed across Europe since the 1970s is briefly sketched. Then, a cross-country analysis of four local radio markets is made resulting into a set of policy options and recommendations. The final section discusses the way forward for local radio policy and research in Europe. Models of Local Radio Development Driven mainly by the increasing availability of low-cost recording and transmitting equipment, and the growing demand for cultural self-expression and community-based media services, local radio stations grew like mushrooms in the late seventies (see Jankowski et al. 1992). Because the radio landscape in each country is shaped largely by the government's approach and reaction time to the emergence of these local stations, the process of development and maturity strongly varies from one country to another (Cammaerts 2009; Jiménez and Scifo 2010). Despite this variety of historical contexts and policy approaches, the advent of local radio stations all over Europe has in common that it blew a new wind into the broadcasting scene forcing policy makers to develop a legal framework. Initially, governments preferred to implement these new radio stations only locally and to preserve the nationwide public broadcasting monopoly, but the commercial lobby saw opportunities for generating advertising revenue and for competing with established radio channels. Apart from particular national experiences, this interplay between market (private) and government (public) is a constant factor in the development of the European local broadcasting scene (Jauert 1997; Skogerbo 1997; Dunaway 2002). In analogy with similar models of media system development and policy (e.g. van Cuilenburg and McQuail 2003; Hallin and Mancini 2004), three policy models for local radio development were identified, each affecting the maturity and sustainability of the sector to date. According to the "free market" (De Bens and Petersen 1992) or "South-European" model (Kleinsteuber and Sonnenberg 1990), local radio developed as a reaction against the public broadcasting monopoly. Its aim was to provide open access for local communities and alternative radio programming in addition to that of the public broadcaster. Although local stations emerged in a spirit of idealism and clandestineness, often supported by social movements in order to mobilise local communities for specific actions, they were soon persecuted by public authorities (as in Belgium, France, Italy and Spain) who aimed for stifling this emerging pollution of the airwaves (Drijvers 1992). During this "radio war" between governments and amateurs, many of the newly launched local stations were shut down as a result of legal uncertainty or went bankrupt due to financial chaos. Eventually, government was forced to change over to legalisation and to develop a framework that was strongly based on the pioneering ideals. A limited transmission area and a ban on y advertising had to guarantee the non-commercial nature of these stations. However, the ban on advertising and the lack of public funding drove amateur radio stations into the hands of private investors such as press groups, which were eager to set up large-scale advertising chains with impunity. Since governments were likely to legalise these illegal situations, commercial networks quickly gained ground. As a result, airtime is increasingly filled with hit music and advertisements instead of local information while the few remaining non-commercial stations are struggling to survive (Glevarec and Pinet 2008; Evens and Hauttekeete 2009). In the "Scandinavian" (De Bens and Petersen 1992) or "North-European" policy model (Kleinsteuber and Sonnenberg 1990), a legal framework was soon developed ing local radio, governments aimed to create a "third tier sector" providing open access for citizens, widening freedom of speech and increasing the level of local information (Jauert and Prehn 2003). This type of local broadcasting was seen as complementary to the public broadcaster; it even became a local or regional division of this public broadcasting system in particular countries. In some countries (as in the Netherlands and later Denmark) a subsidy scheme was introduced to financially support the sector. This financial support to non-commercial stations 00 and the legal recognition of their societal and cultural value are an integral part of this media policy model, which assumes an interventionist government that sup- ^ ports the development and sustainability of non-commercial local broadcasting. Given the recent emergence of commercial local radio in this model, government is taking measures to counter the effects of commercialisation. This interventionist approach strongly contrasts with the market model, where advertisement lobbies have forced the government to gradually deregulate the sector in order to establish a commercial radio market (Crookes and Vittet-Philippe 1986). Third, De Bens and Petersen (1992) identify a more "pragmatic" development model, which is, unlike the North and South-European models, characterised by little idealism. Radio regulations in this model typically show a large measure of realism and pragmatism, especially with regard to financing issues (Kleinsteuber and Sonnenberg 1990). Rather than political ideology the emphasis of regulation is on economic sustainability in order to assure that local radio stations can operate without financial chaos and frequent shutdowns. Hence, countries like the United Kingdom, Germany and Switzerland have allowed advertising as income source from the beginning and have considered networking as a creative means to reduce operational expenses. Media regulators have also limited the number of available frequencies per region in order to reduce competition and to guarantee the financial sustainability of the sector. Historically, countries in this pragmatic model have in common a less centralised public media system since the public broadcasting monopoly was broken already in the sixties or even earlier. As these countries have a long tradition in private radio, there was no need for a "local revolution" and non-commercial broadcasters could develop slowly while their complementary status was recognised by law. In the following section, each of these three development models are further explored by comparing the particular radio market and policy approach in the countries and regions selected for this study. Local Radio Policies in Europe In this section, radio markets in the selected countries are briefly sketched with particular attention to their historical context and the role of the government in the development of local radio (for a more factual overview, see Table 1). This development of broadcasting markets has been marked by a distinction between two types of local radio. On the one hand commercial local radio stations aimed at attracting large audiences and advertisers, on the other hand non-commercial local stations, often called community radio, aimed at creating strong bonds with local communities and providing open access for citizens. The tension and choice between these two types of local radio, squeezed between market and government, has proved problematic in several European countries (Jauert and Prehn 2003; Cammaerts 2009). The Netherlands Since its emergence in 1974, local broadcasting - as carrier of local information - has become a relevant factor in the Dutch media landscape (Bakker and Scholten 2007). Public policy focused on decentralisation and diversity of the broadcasting system, which has resulted in almost three hundred local radio stations. After Table 1: Analog Market Overview in the Netherlands, Great-Britain, the Flemish and French-speaking Community (own elaboration) 0 £ * i * (R G C (U the Netherlands Great-Britain French-speaking Community Flemish Community Geography Area (in kmj 41.526 244.820 17.006 13.522 Population (in mln) 16,4 60,8 4,5 6,2 Launch National public NPO 1930 BBC 1922 RTBF1930 VRT1930 National private 1992 1992 1991 2002 Regional public 1988 1967 - - Regional private 1992 - 1991 - Local public 1974 1967 - - Local private 1988 1973 1981 1982 Community - 2002 1987 - Amount National public 7 5 5 5 National private 15 3 5 3 Regional public 13 8 - - Regional private 12 - 5 - Local public 296 36 - - Local private 3 295 71 293 Community - + 160 15 - Market share (end of2008) National public 31,9% 46,4% 27,9% 66,6% National private 46,5% 10,6% 52,8% 23,9% Regional public 12,8% 5% - - Regional private 3,3% - 7% - Local public 1% 4,3% - - Local private <1% 31,6% 5% 7% Community - <1% <1% - Radio advertising (2008) Investment (in mln €) 277 601 186 191 Investment/capita(in €) 16,8 9,9 41,3 31 Advertising share 7% 3,5% 14,8% 10,1% several experiments, local radio was incorporated in the public system. Neither advertising was allowed, nor was structural funding provided by the national government. As a result, local radio depended on grants, contributions by members and in some cases subsidies from local governments. However, absence of structural public funding restricted the further development of local broadcasting in the Netherlands (Stappers et al. 1992). In the 1990s, media policy changed as commercial radio both at the national and local level was legally introduced. As local authorities were reluctant to subsidise local broadcasting, advertising was allowed in 1990. The introduction of advertising induced the commercialisation of local radio stations, which were eager to programme advertiser-friendly to maximise advertising income. This shift in media policy and the absence of structural public funding has caused a split between local radio stations, which had to choose between staying small-scale community-oriented with limited resources, or developing into an advertising-oriented music-format station. Quite remarkably, the former appeared to be more successful in smaller communities than in major cities (Hollander et al. 1995). After years of pressure by the community sector's lobby organisation OLON, policy makers moved towards a structural funding mechanism in 1997. Recently, new legislation has passed that should guarantee an assured income for all local radio stations during the whole licensing period of five years (de Wit 2007). Great-Britain Although Great-Britain is often hailed for its pioneering role in community broadcasting, policy only recently changed in favour of the establishment of the so-called "access radio." The BBC's national monopoly, which was strengthened with the establishment of local and regional divisions, was first challenged by pirate stations operating illegally from broadcasting ships in the mid-1960s (Carter 2003). Twenty years after the introduction of commercial television, the Sound Broadcasting Act of 1972 opened the way for independent local radio and defined the geographical and programming requirements for interested parties. Originally, these stations had to be complementary to the public broadcaster but their reliance on advertising revenues drove most stations towards commercial programming formats. Because of its very strict regulatory framework, many pirates continued their operations in illegality despite fulfilling a community role (Cammaerts 2009). Meanwhile, commercial local radio grew quickly and merged with regional press groups. Today, this commercial radio industry is highly profitable as well as highly concentrated. After a long existential struggle and lobby work from the Community Media Association (CMA), non-commercial radio finally gained a legal basis as the Communications Act (2003) and later the Community Radio Order (2004) were voted. Community radio became recognised as third tier media, complementary to public and commercial stations and would fulfil social gain objectives. Although advertising is allowed, community radio would remain not-for-profit and funding from any single source would not exceed fifty percent of total budget. In 2005, the Community Radio Fund was established to fund the station's core competencies and to support the further development of the sector. Despite its still fragile financial situation, the community radio sector now hosts an impressive number of stations (Lewis 2008). Belgium As d'Haenens et al. (2009) state, Belgium hosts two communities with diverging cultural politics and media landscapes. Being a federal state, media regulations (except for frequency regulations) were transferred to the Flemish and French-speaking Community while the nationwide public broadcaster BRT was split in 1977. Whereas the public radio monopoly was first challenged by pirate stations from ships in the North Sea in the late 1960s, terrestrial FM pirates hijacked the airwaves at the end of the seventies. Some of these stations were idealistic; most had commercial ambitions and provided popular music, which was in stark contrast to the programming strategies of the public channels those days. Both communities legalised local radio in 1981 and 1982 respectively, but they reacted quite differently to these evolutions and soon developed diverging policy frameworks. In order to preserve the position of the public broadcaster, Flemish policy makers tried to limit the impact of local radio by preventing national networks and by decentralising the public broadcaster. While policy makers aimed for guaranteeing the small-scale and non-commercial nature of local radio, many stations struggled with financial difficulties due to overcrowded airwaves, limited geographical coverage and lack of public funding. This protectionist policy is best illustrated by the relatively late opening of the national commercial radio market, which developed only by 2002. To date, only a few local stations in Flanders de facto operating as community radio have survived (Evens and Hauttekeete 2009). This approach sharply contrasts with that of the policy makers in the French-speaking Community, who allowed nationwide commercial radio already in 1991. Moreover, in 1987, local stations were allowed to build networks to some extent, which would ameliorate their financial status. In that same year, a specific statute for community radio was created within the regulatory framework. In this regard, the strong influence of the French model should not be underestimated as France implemented a similar regulatory shift a few years earlier. The establishment of the "Fonds d'Aide à la Création Radiophonique" (FACR), a public fund supporting the production of cultural radio projects, in 1994, also closely reflects the French media policy. According to a new decree (in 2008), community radio stations can now be funded structurally by the FACR when applying for grants. Contrary to the Flemish approach, which fails to consider the specific status of community radio and to provide it with a structural funding scheme, community radio is recognised and more actively supported in the southern part of Belgium. Policy Options and Recommendations Apart from the particular social, economic and cultural contexts wherein local radio develops, media policy plays a structuring role in the successful development y and sustainable growth of the sector. The current state of both commercial and non- Q commercial local radio in particular countries is thus largely but not exclusively £ shaped by the policy approach to the emerging phenomenon of small-scale radio. In this section, structural conditions and policy actions for the successful development of local radio are identified and discussed. All these conditions and actions were identified in the literature and almost all are met in the selected countries except for the Flemish case (summarised in Table 2). Hence, these conditions may contribute to a sustainable local radio market and may therefore be considered for a future policy framework. As policy makers have a wide array of choices in regard to issues such as recognition, funding, diversity etc., policy options are sketched and further recommendations are made for the Flemish case. I (R 0 Recognition and Legal Status c > The recognition of local radio as third tier media is considered important for the sector's development. Being registered as a separate entity in media regulations enables community radio stations to engage with regulators and funding organisations. A legal status is important, not only for taking tailored policy measures, but also for stimulating the social recognition of the sector in general (Peissl r\i Table 2: Policy Measures Overview of the Netherlands, Great-Britain and the French-speaking Community fv^ the Netherlands Great-Britain French-speaking Community Recognition and legal status Public broadcasting system Third tier sector Third tier sector Funding and financing National subsidies Community radio fund Community radio fund Concentration and diversity Cross-ownership regulation Programming clauses Cross-ownership regulation Programming clauses Cross-ownership regulation Regulation and control Integrated regulator Self-organisation of sector Representative organisation Representative organisation Digital switchover Planning Planning and Tremetzberger 2010). Such a status should define several criteria, including non-profit orientation, participatory character and accountability to local communities, which illustrate the sector's key roles and functions. Only by fulfilling these criteria, stations can be recognised as community radio and can apply for funding. Ideally, this recognition is accompanied by structural funding to fully support the sector's development. However, a legal status as separate entity not automatically involves the provision of public funding. The European Parliament recently called its Member States to change over to the recognition of community media (Resetarits 2008). The extent to which community radio is legally recognised varies across Europe. An overview of policy models suggests that community radio has experienced more support in Nordic countries than in South-European countries. In some Scandinavian countries, community radio was introduced by the government while the sector developed from bottom-up and struggled for recognition in Southern countries (Runge 2007). According to Cammaerts (2009), however, the recognition of community radio is closely related to the position of the public service broadcaster. In countries with a dominant public service tradition, community radio is only recently recognised whereas in more liberal countries, community radio has a longer history and legacy. Specific regulations define the borders between which community radio can operate. While some countries opt for flexibility and entrepreneurship, others prefer a more stable, institutionalised approach. In general, our country analysis has shown that there are several ways to recognise community radio. In the Netherlands, local radio is part of the public broadcasting system and its programming requirements are similar to those of the national and regional public channels. Community radio in the United Kingdom has been recognised as third tier, complementary to public and commercial radio. Thanks to a set of objectives (localness, social gain, not-for-profit, participation etc.) community radio operates quite separately from established radio stations. Until recently, community radio in the French-speaking Community was only partially recognised. The audiovisual decree mentioned the concepts of "associative radio" and "educational radio," but did not provide financial resources to these stations. Thanks to recent legislation, community radio is now fully recognised and funded as a third tier sector. In Flanders, local radio is by definition considered to be commercial, thereby disregarding its specific role in the media landscape. As the regulatory framework only distinguishes between public and commercial radio, the few non-commercial radio stations that have survived are not really recognised and are treated equally as commercial networks. As there is no regulatory basis for actively supporting these stations and for taking tailored measures, policy makers could consider the development of a regulatory framework that recognises the social and cultural value of non-commercial radio in Flanders. In addition, the experts preferred non-commercial local radio being considered as third tier rather than as part of the public broadcasting system. The latter scenario would only strengthen the market position of the public broadcaster while the commercial sector is not seeing local radio stations as real competitors and therefore not opposed to a third tier recognition. Funding and Financing The diversity of the European local radio scene is partly illustrated by its variety of financing models. The sector should be understood as a "mixed economy" in which radio stations rely on different financial resources. These resources may be long-term or project-based, and may be provided both by public and private organisations (Runge 2007). The financial circumstances greatly vary across Europe as in some countries local stations largely rely on advertising while other countries have established public funding mechanisms. Since such structural financing mechanisms are a logical result of the sector's recognition by law, they are more frequent in Nordic than Southern countries. Jauert and Prehn (2003) argue that structural financing mechanisms improve the diversity and quality of (local) programming and prevent stations from homogenising their audio output. For being y effective, such mechanisms should be transparent, accountable and accessible for all local stations. Moreover, the independence and stability of the sector is further strengthened by a diversity of funding options (Price-Davis and Tacchi 2001; Coyer 2006; Peissl and Tremetzberger 2010). Governments can choose between a range of public funding mechanisms. Splitting the public broadcasters' licence fee is the most common and sustainable mechanism as it assures predictable funding for local radio stations. In this case, a (fixed) share of the national broadcaster's budget is allocated for and distributed to the local level. Despite being part of it, local radio in the Netherlands is funded separately from the national public broadcaster. For each household they serve, local stations are granted €1.30 by the national government. The creation of a fund, mostly financed by a share or levy on advertising revenues of established broadcasters, is another popular practice for supporting small-scale radio stations. In the French-speaking Community, for example, the FACR is financed from a percentage of the revenues from public and private broadcasters' advertising. In 2009, thirteen associative radio stations were granted a total of €130,750. The philosophy behind such a "Robin Hood fund" is that it transfers money from the "wealthy" to the "poorer" stations. The Community Radio Fund in the UK (£459,992 in 2010), in 0 c > contrast, is part of total media budget and is not funded by taxes on commercial revenues. Furthermore, local radio is often supported by indirect public funding, LO which not primarily targets the radio sector. In the UK, for example, community radio receives grants from employment and training support schemes, social inclusion or regeneration programmes provided at the local, national and European level. In addition to public funding, two almost private resources are found important for local radio stations. First, many stations rely on financial support from listeners, members and even local institutions. Therefore, fundraising events to support the stations' activities are being organised. Second, advertising plays an important role in the funding of small-scale radio in Europe and elsewhere - albeit its impact on the sector varies by country. Local stations are allowed to earn advertising income in most European countries, but this income is often strictly regulated. In the UK, for example, a revenue cap of fifty percent has been installed to make sure that non-commercial but successful stations would not distort local advertising markets; community radio stations therefore cannot extract more than the half of their income out of advertising revenues. In some cases, advertising income is considered unethical as commercialism is not in line with the stations' social objectives (Runge 2007). In Flanders, local radio stations largely rely on advertising revenues as structural funding is not provided by the government. However, many of these local stations are found unattractive by advertisers owing to the limited audience reach and programming quality. As the local radio sector is thus undercapitalised, its viability and sustainability are endangered (Evens and Hauttekeete 2009). Therefore, experts plead for a more active role of the government that supports the sector by the establishment of a public funding mechanism. As the Flemish market for radio advertising is particularly strong, a tax on public and private broadcasters' advertising revenues is suggested to assure the future of local radio in Flanders. However, there are serious doubts about the political support for such a structural funding mechanism for non-commercial radio stations in Flanders. Regional policy makers escape their responsibility by arguing that local stations are free to apply for support at the local level (e.g. municipalities). Also public and commercial broadcasters strongly argue against such a public funding mechanism by fair competition concerns. Concentration and Diversity The sustainability of small-scale radio is increasingly endangered by the emergence of media corporations with interests in several media types (cross-ownership). These organisations no longer target specific media markets but aim for creating synergies between different content outlets in order to establish economies of scale and market power. Policy makers have wrestled with a variety of issues involving ownership of media and concerns over the impact of integrated media companies. Most of these concerns, however, are based on normative and almost unproven assumptions on the relationship between market concentration and company size on the one hand and performance and media diversity on the other hand (Harcourt and Picard 2009). As the general belief is that society is best served by a greater diversity of content, media diversity is defined as a key objective for media policy and regulation. In this context, media ownership has traditionally been strictly regulated by most European Member States. Generally, two different policy approaches to media diversity are distinguished. According to the market-based approach, economic regulation and competition law are understood to prevent market failure. Governments only intervene in case free and fair competition is distorted and market entrance is limited by a dominant firm. The interventionist or public model, in contrast, involves an active media policy and highlights the importance of various political views and cultural values (Karp-pinen 2006). This closely relates to Valcke (2009), whose model is not confined to ownership issues, but also assesses cultural, political and geographical pluralism in the media. In addition to competition law, sector-specific provisions regulate and restrict concentration and cross-ownership in media. The interventionist approach allows for a variety of measures aimed at protecting or promoting media diversity, including must-carry rules and quotas for specific output. Generally, small states tend to the interventionist model as the market-based approach fails due to economic realities of small media markets. This also explains why most small states have opted for a late introduction of commercial broadcasting (Puppis 2009). Frequency allotments linked to particular music or programming genres are a popular policy tool to maximise diversity in broadcasting markets. These clauses ensure a wide range of genres in the market and contribute to diversity both in local and national markets. Licenses that fail to meet the clauses required by their allotment are withdrawn and then granted to other candidates. Experiences from the Netherlands and Great-Britain show that especially in dense populated areas, granting multiple, overlapping licences with different profiles ensures media diversity (Peissl and Tremetzberger 2010). In sparsely populated areas, on the contrary, licence exclusivity (and less rivalry) may be an option, as ruinous competition for audiences and advertisers has induced homogenisation and mainstream content (van der Wurff et al. 2000). Both the North-European and pragmatic policy model have followed this rationale while creating a sustainable radio sector. In the Neth-y erlands, only one local radio per municipality is granted while the British legislator has introduced advertising revenue caps for community stations operating in the same area as commercial local radio. In the UK's low-density areas, no community radio licenses were granted due the presence of commercial local radio. In all selected countries, measures for limiting media concentration have also been taken. Great-Britain, the Netherlands and the French-speaking Community all have media-specific concentration rules in terms of audience and/or revenue shares while the former two also have established regulatory bodies permanently monitoring market structures. According to d'Haenens et al. (2009), the Flemish media legislation is one of the yj sole West-European frameworks without sector-specific concentration rules other than general competition regulations. In the past, the government even stimulated cross-ownership of press groups in commercial television and recently relaxed radio ownership restrictions in favour of the major radio group. As Flemish airwaves are overcrowded inducing irrational competition between several local stations in the same but small area, experts almost agree that a reduction of local stations and the implementation of programming clauses would improve the diversity and sustainability of local broadcasting in Flanders. Specifically for Flanders, a switch 0 c ¥ I m (R G C (U towards the interventionist model (including sector-specific media ownership thresholds) would enrich media diversity and enhance local radio's sustainability. Content regulation by means of programming clauses, however, seems difficult 1—1 as policy makers are likely to define these clauses on a market-based approach with mainstream genres to create the highest level of competition in the market. In addition, the main broadcasters believe programming decisions are up to the market and not to the government. Regulation and Control Next to passing specific laws that define the objectives and role of community radio, underlying regulations regarding small-scale radio stations could also be implemented. However, as the majority of European countries have failed to create any political awareness of the social and cultural potential of local radio, subsequent regulatory procedures and policies are missing. Runge (2007) argues that an up-to-date regulatory framework increases the understanding of policy makers regarding local radio and thus helps the sector to develop. Therefore, the existence of transparent processes and evaluation criteria for local radio is crucial for the sector's growth and sustainability. This approach requires media regulators with expert knowledge to proactively scan activities in the field and sanction infringements of the law. Moreover, national regulators should ideally consult the sector prior to proposing new legislation, licensing stations or making other decisions. This level and quality of cooperation between authorities and the sector are found crucial for the sector's success and sustainability. Therefore, a platform for the exchange of knowledge, ideas and information between all relevant stakeholders could be established. Great-Britain is a textbook case for how regulators contribute to the smooth introduction of new legislation and engage with the sector in a transparent and accountable fashion. In this case, the British Ofcom shows that interacting with the sector permanently results in a better understanding of and by the sector (Smith 2006). In addition, the radio broadcasting sector would profit from a stable (co-)regu-latory regime and from an integrated regulatory body. A single communication regulator could be considered an adequate answer to the increasing complexity of communication regulation fuelled by the convergence of the media and telecommunications industries. Ofcom, the prime example of a unitary regulatory body in Europe, regulates radio and television broadcasting, fixed line and mobile telecoms including licensing and spectrum issues in Great-Britain. In the Flemish and French-speaking Community, however, the fragmentation of competencies between media and telecommunication regulators results in conflicts about whether the national or regional level is authorised. This may hinder an efficient approach to the radio sector and hampers the development of the local radio scene. To make things worse, disputes and lawsuits between the communities regarding their frequency plans have made a stimulant radio policy even more difficult. The fragmentation of power in a federal state not necessarily involves regulatory conflicts and instability, as experiences from Germany learn. Unlike the Belgian case, the federal state remains responsible for the technical aspects of broadcasting (including frequency planning and coordination) while the regions regulate media contents (Kleinsteuber 2006). According to our experts, such distribution of competencies may contrast with the current developments towards converging communications, but creating integrated structures in federal states seems politically unviable as no level is likely to give up their competencies over one of these aspects. However, a better coordination between these competencies (media, telecom and competition) could be a goal for policy makers in federal states so that the vigorous regulation and control of the communications sector is ensured. Strengthening regulation implies that the existing rules are applied more vigorously and with more focus on the specific characteristics of media and telecommunications markets. Self-organisation of the Sector Umbrella organisations are considered important for representing the local radio sector towards regulation authorities. Such organisations fulfil coordination, information and support functions for the sector and act as representatives towards legal recognition and co-regulation. Associations with a more broadly defined identity, deploying a wide range of activities and representing several community media including radio, television and internet projects, more effectively defend the interests of the sector (Peissl and Tremetzberger 2010). Of all media sectors, Runge (2007) found that community radio is the most organised sub-sector, which is possibly due to the heavy regulation of broadcasting and its scarcity of frequencies. In addition, the research shows that especially in smaller states and in countries with little support for community media, the sector has difficulties in establishing interest groups. In the Netherlands and in Great-Britain respectively, OLON and CMA represent the interests of community-based radio, television and internet projects, and have played an important role in the establishment, recognition and funding of the community radio sector. They are widely regarded as the biggest representative organisations in community radio and are closely cooperating with governments, regulators and funding bodies. In Flanders, it was impossible to establish a representative organisation defending the interests of the local radio sector. Owing to the diverging interests of commercial networks and non-commercial stations, two organisations emerged but soon disappeared. According to our experts, this lack of self-organisation partly explains the lack of recognition and funding of the sector by the government. It remains a point of discussion whether the government or the sector itself has a responsibility in establishing (and funding) an independent umbrella organisation for community radio in Flanders. Ideally, a representative body would emerge from the radio sector itself and could be structurally supported by the government as can be learned from the OLON and CMA experiences. Digital Switchover 0 £ Local radio may face serious challenges and opportunities owing to the switchover from analogue to digital transmission systems. The switchover to digital platforms provides local radio stations with the opportunity for a wider reach and more diverse programming by using the radio spectrum more efficiently. To do so, local radio should gain fair and reasonable access to digital platforms and spectrum. As some fear that platform operators will deny access to community radio in favour of more popular radio stations, must-carry regulations could oblige multiplex operators to transmit at least one non-commercial radio station in each service area. c « 00 Community radio organisations are also concerned about the high transition costs for going digital, estimated at a tenfold of the current costs for setting up analogue C^ transmission infrastructure. This raises questions about the financial sustainability ^ of digital radio for small-scale and non-commercial broadcasters and the role of the government in providing financial support for completing this transition process (Runge 2007). There are also widespread concerns regarding the implementation of DAB, which is the dominant digital audio broadcasting standard. As DAB has been designed to cater for nationwide public radio broadcasters, more localised stations are less suited to the system. Meanwhile, the emergence of new digital standards such as DAB+ and DRM+, which are less costly and less complex to implement, may provide new perspectives for local stations (Lax et al. 2008). Recent policy options also leave opportunities for reallocating the freed FM spectrum to new community services. This would improve coverage of existing community radio stations, whose signals are currently weaker because of the high occupancy levels of the band. Thanks to this increased space, more radio projects with a wider audience reach can be allowed. Staying analogue, however, ultimately depends on the political and industrial strategies. First, policy makers should cancel their plans for phasing out FM, which is part of the larger digital dividend policy, while equipment suppliers should guarantee the FM availability on future radio receivers (Hallet and Hintz 2010). Contrary to the Flemish and French-speaking Community, policy makers in Great-Britain and the Netherlands are investigating which technologies are suited the best for the (digital) transmission of small-scale radio and are already preparing the implications of the digital switchover for radio. Great-Britain, for example, is preparing the digital switchover as part of its "Digital Britain" strategy. The report claims that community radio will occupy the vacated FM spectrum and stresses the importance of a balance between public and private interests in the digital domain. Therefore, policy makers in Flanders should be aware that a part of the spectrum could be set aside for civil society use. No matter how the strategy for (digital) radio looks like, experts stress the importance of a detailed implementation plan for the technological future of radio. Conclusion This article focused on local radio policies from three "good practices" and the lessons that can be learned from the more or less sustainable development of local radio in each of them. Thereby, the article aimed to explore policy options that support the establishment of a stable and diverse local radio landscape, and to make recommendations for a more proactive media policy regarding local radio in the Flemish Community (Belgium). In our cross-country analysis, scrutinising local radio policies in Great-Britain, the Netherlands and the French-speaking Community (Belgium), six structural conditions of such a proactive media policy were identified. These conditions may ensure a sustainable growth of the sector and may assure its future in the digital media industry. Ideally, future regulatory frameworks may consider recognising and funding non-commercial radio, creating media-specific concentration rules, safeguarding diversity and pluralism in media, establishing transparent and coordinated regulatory procedures, recognising representative bodies and facilitating the switchover towards digital broadcasting u s 5 o £ platforms. By taking measures on each of these issues, local radio's economic and social capital would be strengthened. Policy makers have a wide array of options regarding each of these aspects and can therefore make choices that keep into account the specific nature of each media landscape. Given the structural constraints of their media markets, small states are generally inclined to proactive media regulation approaches. In Belgium, in contrast, policy makers have chosen for a market-based approach to media regulation. Local radio developed after the free market model and was persecuted before being legalised. Apart from this common history, the Flemish and French-speaking Community each reacted differently and developed a diverging policy framework. The experience from the French-speaking Community, which recently evolved from a commercial model to a more interventionist approach, shows that a "regulatory revolution" is possible when a fresh wind is blowing through politics and regulators. We therefore hope that this cross-country study may inspire policy makers to develop a framework that supports small-scale radio in Flanders. If not, the sector is likely to blow over thanks to ruinous competition within and between media markets. Instead of disclaiming responsibility, Flemish policy makers could take tailored measures for ensuring the future of non-commercial radio in Flanders and consider each of the proposed policy options. Although recommendations for one particular case are not necessarily fruitful for other markets, this study shows relevance for similar local radio sectors that are also falling between commercial and government-based broadcasting systems. Therefore, the study could be of interest to policy makers and scholars not only in Flanders, but also in other countries where local radio is facing structural difficulties. Following recent examples (see Cammaerts 2009; Peissl and Tremetzberger 2010), this article pleads for more research to local radio from a European or even global perspective, rather than case studies of particular countries. As a result, policy models should be studied from a comparative perspective while recommendations for particular countries should be based upon experiences of policy strategies in similar states. Such a research approach would contribute to the comparability of international radio studies and enhance the quality of policy measures. References: Bakker, Piet and Otto Scholten. 2007. Communicatiekaart van Nederland. Overzicht van media en communicatie. Alphen aan den Rijn: Kluwer. Cammaerts, Bart. 2009. Community Radio in the West. A Legacy Struggle for Survival in a State and Capitalist Controlled Media Environment. International Communication Gazette 71, 8, 635-654. Carter, Meg. 2003. Independent Radio: The First 30 Years. The Radio Authority: London. Coyer, Kate. 2006. Community Radio Licensing and Policy. An Overview. Global Media and Communication 2, 1, 129-134. Crookes, Philip and Patrick Vittet-Philippe. 1986. Local Radio and Regional Development in Europe. Manchester: European Institute for the Media. De Bens, Els and Vibeke Petersen. 1992. Models of Local Media Development. In K. Siune and W. S ^ W. Truetzschler (eds.), Dynamics of Media Politics. Broadcast and Electronic Media in Western Europe, 154-178. London: Sage. de Wit, Pieter. 2007. The Dutch Community Media Scene: Building Further. Paper presented at O Finding and Funding Voices: The Inner City Experience. London Metropolitan University, 17 September 2007. D'Haenens, Leen, Frédéric Antoine and Frieda Saeys. 2009. Belgium: Two Communities with Diverging Views on How to Manage Media Diversity. International Communication Gazette 71, _| 1-2, 51-66. rN Drijvers, Jan. 1992. Community Broadcasting: A Manifesto for the Media Policy of Small European Countries. Media, Culture and Society 14, 2, 193-201. Dunaway, David. 2002. Community Radio at the Beginning of the 21st Century: Commercialism vs. Community Power. In N.W. Jankowski and O. Prehn (eds.), Community Media in the Information Age: Perspectives and Prospects, 63-82. Cresskill: Hampton Press. Evens, Tom, and Laurence Hauttekeete. 2009. From Hero to Zero: How Commercialism Ruined Community Radio in Flanders. The Radio Journal: International Studies in Broadcast and Audio Media 6, 2-3, 95-112. Glevarec, Hervé and Michel Pinet. 2008. From Liberalization to Fragmentation: A Sociology of French Radio Audiences since the 1990s and the Consequences for Cultural Industries Theory. Media, Culture and Society 30, 2, 215-238. Hallet, Lawrie and Arne Hintz. 2010. Digital Broadcasting - Challenges and Opportunities for European Community Radio Broadcasters. Telematics and Informatics 27, 2, 151-161. Hallin, Daniel and Paolo Mancini. 2004. Comparing Media Systems: Three Models of Media and Politics. Cambridge: Cambridge University Press. Harcourt, Alison and Robert Picard. 2009. Policy, Economic and Business Challenges of Media Ownership Regulation. Journal of Media Business Studies 6, 3, 1-17. Hollander, Ed, Coen Van der Linden and Maurice Vergeer. 1995. Access in the Age of Commercialisation of Information: The Case of Local Radio in the Netherlands. Javnost-The Public 2, 4, 75-85. Jankowski, Nicholas, Ole Prehn and Jo Stappers, eds. 1992. The People's Voice. Local Radio and Television in Europe. London: John Libbey. Jauert, Per. 1997. Local Radio in Western Europe. Conflicts between the Cultures of Center and Periphery. The Nordic Review 2, 1, 93-106. Jauert, Per and Ole Prehn. 2003. Danish Subsidy Scheme for Non-commercial Local Stations. Javnost-The Public 10, 1, 63-84. Jiménez, Nuria and Salvatore Scifo. 2010. Community Media in the Context of European Media Policies. Telematics and Informatics 27, 2, 131-140. Karppinen, Kari. 2006. Media Diversity and the Politics of Criteria: Diversity Assessment and Technocratisation of European Media Policy. The Nordic Review 27, 2, 53-68. Kleinsteuber, Hans. 2006. Radio Broadcasting in Germany. Kleinsteuber, Hans and Urte Sonnenberg. 1990. Beyond Public Service and Private Profit: International Experience with Non-commercial Local Radio. European Journal of Communication 5, 1, 87-106. Lax, Stephen, Marko Ala-Fossi, Per Jauert and Helen Shaw. 2008. DAB: The Future of Radio? The Development of Digital Radio in Four European Countries. Media, Culture and Society 30, 2, 151-166. Lewis, Peter. 2008. Finding and Funding Voices: The London Experience. Information, Society and Justice 2, 1, 5-20. Peissl, Helmut and Otto Tremetzberger. 2010. The Legal and Economic Framework of the Third Audiovisual Sector in UK, Netherlands, Switzerland, Niedersachsen (Germany) and Ireland. Telematics and Informatics 27, 2, 122-130. Price-Davies, Eryl and Jo Tacchi. 2001. Community Radio in a Global Context: An Overview of Community Radio in Australia, Canada, France, Holland, Ireland and South-Africa. Sheffield: Community Media Association. Puppis, Manuel. 2009. Media Regulation in Small States. International Communication Gazette 71, 1-2, 7-17. Resetarits, Karin. 2008. Draft Report on Measures to Support Alternative Media in Europe in Order to Guarantee a Pluralistic Media Environment and Cultural Diversity. European Parliament: Brussels. Runge, Jan. 2007. The State of Community Media in the European Union. European Parliament: Brussels. Saeys, Frieda and Tomas Coppens. 2007. Restricted Opportunities for Community Broadcasting in Belgium. In L.K. Fuller (ed.), Community Media. International Perspectives, 77-88. New York: Palgrave MacMillan. Skogerbo, Eli. 1997. Radio for the Few or the Many? Experiences from the Political History of Local Radio in Norway. The Nordic Review 2, 1, 107-122. Smith, Paul. 2006. The Politics of UK Television Policy: The Making of Ofcom. Media, Culture and Society 28, 6, 929-940. Stappers, Jo; Frank Olderaan and Pieter de Wit. 1992. The Netherlands: Emergence of a New Medium. In N. Jankowski, O. Prehn and J. Stappers (eds.), The People's Voice. Local Radio and Television in Europe, 45-61. London: John Libbey. Valcke, Peggy. 2009. From Ownership Regulation to Legal Indicators of Media Pluralism: Background, Typologies, and Methods. Journal of Media Business Studies 6, 3, 19-42. van Cuilenburg, Jan and Denis McQuail. 2003. Media Policy Paradigm Shift: Towards a New Communications Policy Paradigm. European Journal of Communication 18, 2, 181-207. van der Wurff, Richard, Jan van Cuilenburg and Genevion Keune. 2000. Competition, Media Innovation and Diversity in Broadcasting. In J. van Cuilenburg and R. van der Wurff (eds.) Media and Open Societies, 119-157. Het Spinhuis: Amsterdam. s I 0 £ * 1 * (R G C fN fN