This is the open letter we sent to PRS and PPL

The letter has already been endorsed by over 100 independent operators, if you would like to sign it too you can do so at this link –


Dear PRS and PPL

Local Radio Support (LRS) and its undersigned associated stations would like to draw attention to the
points below.

We believe it is in the interests of PPL (and PRS) to review licencing for smaller independent
commercial operators. We suggest the relatively new joint licence for community radio is also
reviewed and simplified. Distinctions between small commercial operators and community stations
are becoming increasingly difficult to define. We believe a turnover based system for all smaller
operators regardless of licence type would be more appropriate as the sector evolves. Our logic is:

 The current commercial model was built for heritage commercial brands, this still works for
stations with much larger turnover than a typical ‘new breed’ independent operating on DAB

 There is much confusion across the industry especially amongst smaller operators.
Regardless of platform (AM, FM, DAB, SSDAB and Online) a turnover only based model
would mean a simple ‘size’ based system. Moreover ‘not for profit’ organisations would
potentially benefit the most in the true spirit of serving their audience. Music is a staple for
most stations but is of no more or no less value according to platform or licence type.

 Many ‘would be’ broadcasters abandon plans when they are made aware of the current
minimum licencing levels. We see this all too often through our connections to multiplex
operators. This is not good for all parties moving forward, PPL, PRS, DCMS, Ofcom and more.

 Despite the above there are literally hundreds of new stations on DAB, SSDAB and online
however many are struggling to cover costs. In many cases music royalties rank high or
highest on the list of costs, even at the current minimum levels. If they are forced to close
(and many have) the royalty revenue falls to zero whereas at a more sustainable level they
could continue to contribute. This is important for future growth and also many of such
stations provide exposure for artists that are NOT considered mainstream.

 The absence of a more sustainable tariff for smaller operators of all types has the potential
to severely restrict the success of digital growth in broadcasting and along with this in
plurality of listener choice. Especially important as many local operators (both community
and commercial) provide local information no longer carried by national brands in some

 As well as securing and retaining more licensees for PPL (and PRS) a new tariff would avoid
removal of services because of royalty costs, something we are sure PPL (and PRS) would not
wish to be responsible for. Alternatively given time to prosper new services can potentially
grow into larger royalty contributors.

A new and simple approach for smaller operators on any platform (DAB, SSDAB, FM, AM, Online)
based on a percentage of audited annual turnover and not minimum fees (with say a qualifying
turnover level of less than £50,000) is we suggest more likely to ensure long term contributions from
the fast evolving sector, avoid closures and lead to continued growth. and the undersigned:

The letter has already been endorsed by over 100 independent operators, if you would like to sign it too you can do so at this link –


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