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Stake Holders
Media Policy Briefing: Vol 3

The Secretariat/Coordinator
Nigeria Community Radio Coalition (NCRC)
c/o Institute for Media and Society
3, Emina Crescent,
Off Toyin Street,
P.O.Box 16181
Ikeja, Lagos,Nigeria.
Phone: +234 1- 8102261;
+234 803 307 9828;




In August last year, responding to your call for responses to the defects in the current National Mass Communication Policy, we, the Initiative on Building Community Radio Broadcasting in Nigeria, submitted a detailed memorandum to the Core Working Group on the review.

We would like to express gratitude that some of our proposals were incorporated in the draft document which is now out for comments and reactions.

In spirit of this new call for public validation of the draft we would like to observe and propose:

Changes in the language of some of your proposals to align them with current international standards.
The inclusion of new items which were omitted but which we believe will compromise the integrity of an otherwise brilliant document if they are not addressed.



We appreciate the word “public” as used in “public communication” in paragraph 1.2 (iv). The choice of the lexical item “public” which is intended to mean the entire constituency of the Nigerian communication environment is somewhat ambiguous and even problematic. In the context of a policy document where there is need to recognize and respect the segmentation and structural character of an affected constituency, the word will appear inadequate and requires synthesis into clearer lexical categories.


Under paragraph 1.2 (iv) we would propose that you extend the language to read: “ to preserve the national and cultural identity, promote the national patrimony, and enhance the development of cultural and artistic capabilities and institutions for public, private, and community communication”.



The implementation strategies of this chapter appear silent on some key issues of governance and media/communications, which straddle all aspects of national life in Nigeria. These include popular participation, pluralism and diversity, transparency and accountability.


Implementation Strategies:

Under paragraph 2.2, we propose that you consider inserting the following sub-sections:
“Regulation is guided by democratic principles that respect the participation of the public, and that these are implemented through independent mechanisms mindful of the need for pluralism and diversity in the media”.
“The national system is characterized by a deep sense of diversity in form and content across all the media platforms”.
“Media quality is guaranteed through the emergence of a credible audit bureau that promotes circulation accountability in the print media, and a ratings system that promotes greater reach and accountability in the broadcast media”.



The recognition given to community broadcasting does not provide equitable support for its emergence, sustainability, environment and health as a distinct tier of the sector.
It is inadequate to require the mere allocation of some percentage of airtime to local production (para4.4 (vi). There should be specific obligation to develop such content, while the word ‘local’ should be given a clear and realistic definition, that includes African (non Nigerian) content.

The welcome spirit of convergence proposed in para 4.4 (x) regarding a unified body known as National Broadcasting and Communications Authority (NBCA) requires some important provisions to give it effective meaning.

Whereas convergence is the progressive trajectory worldwide, antecedents in Nigeria give cause for worry over the capacity to effectively manage a huge agency like the NBCA such that certain sub-sectors are not marginalized in the regulatory process. Some mechanism should be in place to guard against this possibility.
The realities of the issues of globalization, foreign investment, improvement of standards, among others, combine to make a strong case that this policy document should address the issues of foreign participation in the sector.

Policy reformers are tackling big media conglomerates the world over on the question of cross-platform ownership (i.e. the simultaneous ownership and control of print and electronic media) The dominant voice (anti-cross ownership) which argues, that media concentration in the hands of a few destroys pluralism, freedom and ultimately, democracy, deserves a consideration for your august committee to pass a judgment upon.

This policy document needs to clarify the definitions or concepts of the different tiers of broadcasting to avoid confusion. For example, the federal/state government-owned stations in Nigeria today are not “public service stations”. If the intention is to have the latter (and that is the progressive path) as put in the draft report, then there must be provisions to support its actualization. Similarly, within the ambit of the definition of the African Charter on Broadcasting, as adopted at the African Union Summit in Maputo, Mozambique, in 2003, “community broadcasting” is different from “decentralized state broadcasting”, and we urge your committee to so reflect in this document.

Sustainability is a key issue for the media, as indeed for all other sectors. All tiers of broadcasting must be allowed sufficient space to source revenue/funding from appropriate channels, including commercial activities.


(Policy Objectives) :

4.3 (ix) should read: “encourage an environment conducive to community development, growth, profit and public service delivery”.
4.3 (ix) should read: “ promote the development of public, private as well as community-based broadcasting”
Implementation Strategies

There should be a provision, which makes a clear recognition of a three-tier structure of broadcasting in line with the provisions of the African Charter on Broadcasting. These are: Public Service, Private/Commercial and Community.

4.4 (iv) Should read: “the development of community broadcasting shall be promoted, as distinct from decentralized state broadcasting”.

4.4 (v) Should read: “A Production Fund shall be established to encourage local independent productions, while an independent Community Radio Trust Fund should also be established to cater for the community radio sector”.

4.4 (vi) Should read: “ Broadcasters should be required to promote and develop local content, which should be defined to include African content, including through the introduction of minimum quotas”.

The following should be added as sub-sections to complement 4.4 (x):
The NBCA shall be a truly independent body, which exercises all formal regulatory powers; its membership shall be equitably representative of stakeholder constituencies, while the appointment process shall be open, transparent and involve the participation of civil society.
The administrative structure of NBCA shall be such that makes for equitable attention to all the electronic media sub-sectors.

Decision-making on frequency spectrum allocation should be open and participatory, and ensure that broadcasting is allocated a fair proportion.

The frequencies allocated to broadcasting should be shared equitably among the three tiers of broadcasting.

The licensing process should be fair and transparent, and based on clear criteria, which include promoting media diversity in ownership and content.

The following should also be inserted as sub-sections (after 4.4 (xiv):

In order to improve quality and standards and to attract more investment into the environment, there should be upward review of foreign participation in the sector.

Cross ownership of the media (print and electronic) should not be accommodated. As a complement, local content quota of such media shall be upwardly reviewed.
Funding for Categories of Licences

4.5 (i) Should read: “ Public service stations shall be involved in commercial broadcasting.

They shall be funded from sources such as advertising, licence fees, grants and other industry charges. However, they shall not engage in the commercialization of news”.

The following provisions should be added:
Community Radio shall derive funding from specific commercial activities, from community contributors, including non-salaried labor, from donors and charities and from the independent Community Radio Trust Fund

Community Radio shall be granted concessions in the form of:
Lower licence fees relative to private commercial broadcaster
Tax breaks in security equipment
Tax breaks in operational cost
All incentives granted to the development of the print media industry in section 3.2 (ii and iii)



The policy objectives should strive to give voice to all segments of the population. The constitutional guarantee of “ press freedom” in para. 6.1 (i) is narrow and insufficient.
The recommendation of the national broadcasting commission (NBC) laws for amendation in para. 6.4 (B)(i), there is no reference to an envisaged NBCA which is already proposed in chapter four.

6.1 (i) Should read: “There shall be constitutional guarantees of press freedom and freedom of expression”
6.4 (i) National Broadcasting Commission Decree 38 and 55 should be amended to accommodate the emergence of an independent NBCA and encourage the establishment of community stations.



Why should media regulatory and training institutions develop research and training programmes even up to masters degree level to the exclusion of education sector regulatory bodies like the National Universities Commission (NUC) and National Board for Technical Education (NBTE)?
Why limit the mass communication policy training specialization to be developed to masters’ degree level?

9.2 Should read: “The National Universities Commission (NUC) and National Board for Technical Education (NBTE), in collaboration with the proposed National Broadcasting and Communication Authority, the Nigerian Press Council, and relevant media training institutions…”
9.2 (v) Should read: “ develop a mass communication specialization at master and doctorate degree levels in appropriate institutions”


We are glad to have had the opportunity to make a further contribution into the making of new mass communication policy for Nigeria.

We commend the progressive work done by the Core Working Group on the Review, and believe this modest input we have again made will help improve the report and enhance the emergency of a great policy document for the mass communication sector in Nigeria.

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