The CBAA's submission to the CBF Review Consultation Paper 2

The CBAA submitted its positions on the CBF Structure and Governance Review Consultation paper 2, Embracing change – a stronger future for Community Broadcasting, to ensure that the reforms were in the interest of community broadcasters and listeners. 

This submission  submission.pdf builds upon the CBAA’s two earlier submissions to the CBF Structure and Governance Review and the positions outlined in those submissions remain consistent on many aspects of the Review.

Some key aspects of the submission include:

• The CBAA continues to understand from the CBF Structure and Governance Review Consultation Papers and discussions with the CBF that there is no intention to change its formal purpose to ‘seek, secure, administer and distribute funding to support the development, creativity and sustainability of community broadcasting in Australia’. The CBAA continues to support this as the appropriate purpose for the CBF. However, it is essential that the focus of the CBF must continue to be on funding and, while there are overlaps, the CBF role must not extend to initiating projects or project management, nor to commentary, analysis or recommendations about broader sector or industry strategy issues.

Allocations from Government

• Whilst some simplification of funding categories seems advisable, the CBAA remains considerably concerned about the proposal to simplify funding lines. The CBAA is particularly concerned about the role of political advocacy for specific funding purposes required in the sector, the capacity for flexibility within funding lines in terms of CBF mechanisms regarding priorities and distribution of funding (or scope to increase flexibility within funding deeds with DOC); and longer term implications and impacts of reducing funding lines in terms of the risks of ending up with broad funding categories that compromise the sector’s capacity to argue for maintaining funding or increased funding in specific areas (i.e. supporting a government position that allocates $xxx to a specific area and any and all development priorities then become the CBF/sector responsibility).

Grant Advisory Committees and Assessment

• The CBAA has concerns regarding the practicalities of the operations of assessment panels, however, it is understood that change brings with it uncertainty. The CBAA encourages the CBF to monitor the implementation and operations of the assessment of the grant advisory committees on an ongoing basis and adjust where necessary.

Grants

• It is essential that the CBF has a key focus on investing in the organisational capacity of the community broadcasters that they fund and, therefore, the CBAA supports the CBF in seeking to strengthen sector sustainability and resilience. There are a number of obstacles facing stations undertaking capacity-building, as outlined in our July 2015 submission. We encourage the CBF to revisit this. We also encourage the CBF to continue to consider the points that we made in our comments to the proposed planning assistance grant category.
• The CBAA strongly supports outcomes-based reporting. It is widely recognised as best practice for granting activities to have an outcome orientation so that grant recipients focus on outcomes and outputs for beneficiaries. 
• It is noted that neither the Nous Review report nor the Content Review report recommended a move away from the hourly rate to funding of specialist Ethnic programming based on actual content production and related service support costs. Whilst the CBAA supports transparency in funding allocations, the CBAA is yet to hear a solid argument for the proposed changes and believe that, in the absence of a separate, dedicated and extensive consultation process backed by sound reasoning, they should not go ahead at this time. 
• The purpose of community broadcasting funding distributed by the CBF is to support the community broadcasting sector and community broadcasting licensees. Only community broadcasters holding appropriate ACMA licences or Sector Representative Organisations should be eligible for CBF funding. Providing funds to a wider pool of NFP organisations will dilute the effectiveness of limited CBF funds and is totally unacceptable to the CBAA. Opening up funding eligibility also disempowers licensed community broadcasters. This is an especially critical issue during this time of disruption to traditional media. Whilst the CBAA is excited by the challenges presented by the evolving digital environment for radio, it is vital to ensure all Australians continue to have access to a diverse range of free‐to‐air services.

Board Structure

• The CBAA has some concerns with the proposed structure of the nomination advisory committee. A committee of the proposed size may be unwieldy. We also note that by making it representative it may bring a political element to the appointment process. However, the CBAA is not opposed to the proposed structure of this group. Such a group should be restricted to national Sector Representative Organisations that meet appropriate criteria.
• The CBAA believes it is essential that criteria be developed to formally recognise Sector Representative Organisations as such. These criteria would be used to determine which organisations are eligible to be represented on the CBF nomination advisory committee as well as eligibility for funding.

Draft Guidelines for Content Grants

• The CBAA thanks the CBF for the opportunity to comment on the draft guidelines for Content Grants. The CBAA views our response as an initial response to the draft criteria and believe that considerable work still needs to be undertaken in their development. We would be pleased to work closely with the CBF on this. The CBAA's comments are available in the full  submission.pdf

Draft Guidelines for Development Grants

• The CBAA thanks the CBF for the opportunity to comment on the draft guidelines for Development Grants. The CBAA views our response as an initial response to the draft criteria and believe that considerable work still needs to be undertaken in their development. We would be pleased to work closely with the CBF on this. The CBAA's comments are available in the full  submission.pdf

Further information on the CBAA's involvement in the CBF Review process is available here.