Three distinctive models of communications -- Commercial, Public (government-sponsored) and Community -- have evolved in American broadcasting, each characterized by different modes of financing, control, programming and access. Since 1930, U.S. broadcasting has been predominantly commercial, although coexisting with an embattled public sector (McChesney 1993). Community broadcasting established itself as an alternative model with the establishment of KPFA, Berkeley, in 1949.
This chapter examines institutional constraints on community radio in the United States and the ways in which these are reshaping community broadcasting. These constraints fall into three primary areas: the licensing and regulatory process, financing mechanisms, and access to programming. Each has been affected by changing government policy over the last 15 years as policy-makers and community broadcasters have sought to incorporate, to varying degrees, community radio into the public broadcasting system. I then turn to a brief discussion of efforts by community activists to operate outside the parameters of government-licensed operations by establishing low-power, community-based FM stations, and conclude by examining the implications of these developments for community access to, and control over, its own media institutions.
Grassroots Communications
Throughout the world, the public sector has proved to be neither accountable nor accessible to the public. Grassroots organizations have established their own means of communication where the necessary means could be procured. In broadcasting these efforts -- known as community, free or neighborhood radio -- have developed throughout Western Europe, in the United States and Canada, in Latin America, and elsewhere (Lewis 1984a; White 1983). Despite substantial differences in origin and structure, each developed as a reaction to existing broadcasting systems (whether commercial or public) by excluded groups seeking to meet their own needs and develop their own programs.
Community radio is characterized by access, public participation in production and decision-making and, predominantly, by listener-financing. The intention is that management of the station is in the hands of those who use and listen to it. Though the workings of such stations are never easy, the structure does offer the possibility of accountability to the audience/user in a way state and commercial stations do not. (Lewis 1984b, 141)
Community radio is thus part of a broader struggle for grassroots access to communication media, a struggle not only for freedom of communications but for freedom to communicate (Berrigan 1977; Barbrook 1987). Rather than leave power in the hands of a few experts, "the community station is the locus for a joining of disparate people with differing needs and interests to share in the construction and dissemination of information and entertainment" (Hochheimer 1988, 164). The idea of a right to communicate has recently gained support as the shortcomings of state and commercial services become increasingly evident. Such a right "includes the principles of access, participation and self-management in communications" (Lewis 1984a, 1) and a conception of media as "direct instruments for active groups or movements to produce their cultural identity" and create new social relations (Mattelart and Piemme 1980, 336).
Community radio ... is not some electronic Iskra, calling the masses to battle ... It is not even a facility for a closed circle of professional journalists, however "ideologically sound," to mediate between listeners and social events. Rather, what is subversive about community radio is the way it can challenge the division between broadcasters and consumers in our society. (Barbrook 1985, 71-72)
Breaking down this division entails more than simply allowing ordinary citizens access to the airwaves (important though this is); it entails participation in the production and management of communication systems and ownership and control of the means of communication.
In Europe, community radio began as an unlicensed (pirate) service, sometimes going on to gain legal recognition -- though often at the cost of government regulation, or of opening the door to commercial broadcasters as well. While pirate broadcasters are often closely integrated with social movements and explicitly activist in tone, this illegal status leaves them vulnerable to suppression and creates barriers to wider community involvement. In North America community radio developed as a licensed service, although growing numbers of community broadcasters are turning to unlicensed operations in order to circumvent the Federal Communications Commission's inhospitable regulatory framework and the shortage of available frequencies (Hallikainen 1991; Radio Free Detroit 1992; Radio Free Venice 1991; Rodriguez 1991; Drew 1993).
Licensing
The licensing and regulatory procedures adopted by the Federal Communications Commission serve as an insurmountable obstacle to many community broadcasting efforts, and tend to discourage true self-management and community control. KKFI, a community radio station in Kansas City, found that it took more than ten years from conception to going on-air (KKFI 1987). Lorenzo Milam (1986), who helped establish five community radio stations, provides harrowing detail on the difficulties of navigating the bureaucratic processes to obtain a broadcasting license. Dennis Gross, an organizer of Dallas station KCHU, found that it took four years to complete the necessary paperwork:
there's the application for construction permit form from the Federal Communications Commission, and the application for STL and SCA form from the same body; there's the Federal Aviation Authority (sic) form to construct a tower. The Internal Revenue Service has an army of them for tax-exempt status. ... If you took all the forms, and stacked them all together, and took Dennis Gross, and stacked him next to them, they'd both stand at about 4'9". (Milam 1986, 110)
Few community-based institutions have the bureaucratic savvy or staying power to see this process through years of delays, or to handle the barrage of paperwork. Milam was involved in founding several stations precisely because he had developed expertise in shepherding applications through the bureaucratic maze, and because he could get his hands on the necessary funds. Other stations developed their own experts or, after the founding of the National Federation of Community Broadcasters, relied on NFCB experts.
Once a station is on the air, the constraints imposed by the licensing and regulatory process continue. Community radio stations (like all broadcasters) are required to maintain programming and engineering logs; to comply with FCC regulations governing indecency, equal time, technical standards, etc.; and to periodically apply for license renewal. In addition, FCC regulations require that stations be operated only by licensed personnel. While obtaining a Restricted Radiotelephone Operator Permit is relatively simple, the majority of the population is thereby precluded from direct access to the airwaves and can broadcast only with the assistance and mediation of a licensed operator. The FCC did exempt broadcast personnel at noncommercial stations from a $35 application fee after months of protest from community broadcasters (FCC waives $35 fee 1991). Similarly, state and federal authorities require the filing of periodic financial reports and tax forms, and require that certain hierarchical forms (Boards of Directors, Chief Engineer, etc.) be observed.
And the FCC now requires that FM radio stations operate at least 100 watts, although it does allow unlicensed transmitters with a maximum coverage radius of 200 feet (Hindman 1990, 2-3; Federal Communications Commission 1991). By increasing its minimum power requirements from 10 watts in 1980, the FCC barred many localized and low-budget operations from broadcasting, even while permitting hundreds of licensed and unlicensed all-commercial operations difficult to reconcile with traditional public service doctrines (Harris 1990; Bagdikian 1992).
The need to meet FCC regulations for record-keeping, technical standards and uninterrupted service ensures that "there will be a nucleus of professional workers" and a division of labor between administration, engineers and programmers (Barbrook 1985, 73). Some stations have operated without any paid staff; a few even offering 24-hour service on an all-volunteer basis. But in practice even these stations depend upon a core of dedicated volunteers who have acquired the technical and bureaucratic skills to maintain compliance with state regulations and keep the station on the air, and who thus wield greater power and influence than can other participants. While most community broadcasters attempt to minimize the effects of this division of labor, FCC and other government policies inexorably pull in the opposite direction.
Government Financing
Until the 1960s federal funds were not available for public radio and most noncommercial stations were operated by educational institutions for in-house purposes (Carnegie Commission 1979). In 1967, public radio stations became eligible for Educational Broadcasting Facilities Program grants (now the Public Telecommunications Facilities Program [PTFP]) to purchase transmitting and studio equipment. Although no formal regulations barred community broadcasters from receiving these grants, they were not made available in practice until the late 1970s, following lobbying by the National Federation of Community Broadcasters (NFCB) which then assisted local stations in obtaining these funds.
PTFP funds now play a major role in financing new community radio stations, and in enabling existing broadcasters to upgrade facilities or replace worn-out equipment. For example, KKFI, Kansas City, MO, received $204,200 in PTFP matching funds to build its 100,000 watt station (KKFI 1987). Before the advent of PTFP funding, no community radio station could have hoped to raise these sorts of funds, or to broadcast at such high power levels. PTFP funds are not the only governmental monies available for community radio. Several community broadcasters have obtained grants for arts programming through state and federal arts agencies. These grants are often not tied to specific programming, but made available to meet general operating expenses. CETA funds enabled many stations to hire paid staff, some for the first time, before that program was abolished in 1981. And community broadcasters have actively pursued, with varying levels of success, Corporation for Public Broadcasting funds.
In addition to financing National Public Radio, television's Public Broadcasting System and individual program producers, the Corporation for Public Broadcasting offers Community Service Grants. To qualify, radio stations must have an annual budget of at least $195,000 in non-federal funds, at least five full-time employees, programming that does not duplicate that of other local public stations, and a broadcast schedule of at least eighteen hours daily (CPB raises fundraising hurdle 1991). In 1998, the CPB will add requirements that broadcasters either demonstrate average quarter-hour listenership of 15 percent (12 percent in large markets) or financial support from 18 to 20 percent of coverage area residents (Corporation for Public Broadcasting Board 1996).
These requirements are particularly difficult to meet for stations targeting minority and low-income communities or in small and medium-sized communities with a smaller potential base of support (Barlow 1989). Community broadcasters have been unsuccessful in efforts to count the value of volunteer staff time towards their non-federal support, and only a handful -- notably the Pacifica stations -- have met the requirements (Robertiello 1991; Hindman 1990, 6; NFCB 1987). In pursuing Community Service Grants, however, many stations have embarked upon ambitious expansion programs. WEFT (Champaign, IL), for example, expanded its paid staff and broadcast power in an unsuccessful effort to qualify for CPB funding which left insufficient funds for station operations and undermined the role and authority of volunteers (Stein 1988).
Since few community broadcasters can meet the program's staffing and budget requirements (let alone the new Arbitron standards), the Corporation introduced two programs to facilitate integration of community broadcasters into the public broadcasting orbit (Chadwick 1990). A Station Development Grant program permits broadcasters to qualify for CPB funds incrementally over a five-year period. Participating stations must have at least three full-time employees and spend more than $75,000 in non-federal funds annually. Qualifying stations are also integrated into the public radio satellite program service as CPB pays connection fees. Stations which cannot meet these initial requirements may seek one-time Program Acquisition Grants which cover access fees and provide funds for purchasing and promoting satellite-distributed programming.
Both programs offer very real incentives to community broadcasters to pursue the public radio model. WEFT, for example, applied for and received a Program Acquisition Grant in hopes of securing increased listenership and, hence, support. The decision was controversial; station volunteers protested the Board of Directors' decision to go further into debt to acquire the satellite dish necessary to participate in the program (Bekken 1990; Robertiello 1990).
These and other government programs encourage professionalization. Columbia's KOPN increased its paid staff from one full-time to 25 full and part-time positions between 1976 and 1980, after operating for its first two years without any paid staff at all. Only one-and-a-half staff positions were paid out of listener funds -- the others were funded through grants which provided more than half of KOPN's income. In 1981, KOPN received $30,000 in CPB funds but was in the process of losing its other remaining federal funds, and thus the staff positions required to retain CPB funding (Palmquist 1981a, 1981b). KOPN retained CPB funding only by soliciting underwriting and operating weekly bingo games (Poses 1983). In 1993 a collapse in bingo revenues led to renewed financial crisis. The station responded by developing a "more homogenous, predictable" sound based upon the Adult Album Alternative format and heavy use of the American Public Radio satellite feed. The National Federation of Community Broadcasters used KOPN as a pilot for its CPB-financed Healthy Station Project, aimed at increasing the station's budget by developing a more commercial sound (Teutenberg 1993; KOPN 1993; LaPage 1994; Board of Directors 1994). While the NFCB considers the Healthy Station Project a success, many participating stations objected to recommendations for homogenized programming that would appeal to a more upscale audience (Jacobson 1994).
As government support of community radio becomes increasingly important, concerns are being raised over the impact these funds will have on community broadcasters' independence and integrity. Pacifica Foundation vice president Peter Franck (1979, 181) noted that
Pacifica has ... presented voices and views, some unpopular, which otherwise would have been absent from the airwaves. ... Such programming has led on occasion to criticism by public officials, subpoenas from investigating bodies and court challenges. Listener sponsorship, the support of many subscribers, made Pacifica's independence and innovative programming possible.
"The vitality of the democratic processes in this country needs a strong listener-supported community radio movement," Franck argued (1979, 191), opposing proposals supported by the National Federation of Community Broadcasters (1979) to allow advertising. Nor did Franck favor government operating subsidies:
Funds should be made available in a way that does not increase dependence on a continued flow of funds ... Clearly the grant of funds for the construction of new facilities or for the improvement of existing facilities is a one-time kind of thing and does not generate dependence.
General, un-earmarked funds, as in the Corporation for Public Broadcasting's present Community Service Grant (CSG) program, encourages dependence on a continuing flow of such funds ... We fear that a station which was getting a large part of its operating budget from the United States government would have hesitated to attack J. Edgar Hoover in 1963, or would have hesitated to have a reporter in Hanoi in the early 60s. (Franck 1979, 192-93)
I quote Franck not because his views are representative of community broadcasters -- the National Federation of Community Broadcasters' pleas for easier access to public funding (NFCB 1979 and 1987; Thomas 1979, 1981a and 1981b; Robertiello 1991) seem more typical -- but because he raises issues that few community broadcasters have seriously grappled with. Most have eagerly pursued federal funding with little consideration to related institutional constraints (whether in the form of increased dependence, staff time needed to pursue and administer grants, or the structural changes needed to qualify for funding and the impact these might have on the station's character and mission). Even where such concerns are raised, they are generally given short shrift. At WEFT, for example, station volunteers voted against seeking further PTFP equipment grants because they consumed staff time needed for other purposes, entangled the station with the government contrary to the philosophy of the station's membership, and was not clearly a benefit to the station since it required matching grant funds with donated funds.
WEFT's board expressed "its appreciation of the Associates' concern," but voted unanimously (with one abstention) to seek the funds anyway (WEFT Board of Directors' Minutes 1988, 2).
When NFCB's president testified against proposed federal budget cuts, he noted
I myself started in public radio some 10 years ago at a station that received not a dollar of tax funds. ... Looking back, I know we did some great things, but we worked for poverty-level wages, and our ability to attract and keep competent, professional staff was severely limited.... Community radio has come a long way from those days ... [and] Federal assistance has played a crucial role. (Thomas 1981b, 200)
Thomas described stations built without Federal assistance as "crippled projects" without the technical or economic foundations essential for effective broadcasting.
Yet most community radio stations were built under such conditions, and were thereby forced to rely on the communities they served for expertise, funds and labor. Where community radio once depended entirely on volunteers not only for programming but also for administration and support services, state and federal sources of funding enable and require stations to develop a core paid staff for station operations -- ranging from administrative and technical functions to professional programmers. These professionals now argue for severing their station's remaining reliance on volunteers.
Mark Fuerst, station manager at Philadelphia's WXPN, views volunteer programming and the power volunteers exercise over programming decisions as anachronisms that must be overcome. A core of paid on-air personnel would in this view enable station management to require more "professional" programming from remaining volunteers and result in improved listenership and financial support. Fuerst admits that such a policy would meet with fierce resistance from existing volunteers and listeners, but argues that it is a logical extension of the earlier shift from volunteer to professional administrative staffs. Extending hierarchy and professionalization into the programming sphere is, in this view, the next logical step in the institutionalization of community radio (Fuerst 1988; see also Buchter 1990).
The process of professionalization, however, has led to intense conflicts between volunteers and listeners on the one hand, and station management on the other (Miami judge orders volunteer deejays reinstated 1991; Behrens 1991; Kurtenbach 1988). Volunteers and listeners have organized strikes, financial boycotts and alternative slates for elected board seats, and have demanded formal mechanisms for ensuring community control (Noton 1994; Kneedler 1993). These struggles have arisen even at Pacifica flagship KPFA, where subscribers contend that the station is increasingly undemocratic, driven by corporate and foundation funding, and indistinguishable from mainstream media outlets (Save KPFA 1993; Noton 1994). Pacifica managers responded to the controversy by prohibiting on-air discussion, illegally closing board meetings to the public, and hiring a union-busting consultant to aid in its efforts to eliminate unpaid staff's union protection (Blankfort 1996).
Satellite Programming
Professional broadcasting ideology and financial incentives thus combine to create a vision of "community radio" quite unrecognizable to those who have sought to break out of traditional, hierarchical models of media practice. These trends are further reinforced by reliance on satellite technology for program dissemination and, particularly, on the institutional forms and practices that have emerged to govern the satellite system. Until a few years ago, community broadcasters could obtain external program material only through expensive telephone feeds or on tape. While both Pacifica and the NFCB operated program exchanges, these were primarily a medium whereby volunteer programmers could disseminate locally-produced programs with wider appeal. The overwhelming majority of community radio programming was produced in-house.
With satellite program distribution, strong incentives towards reliance on non-local programming come into being. This programming -- often produced with (relatively) lavish financial backing from corporations, foundations or the government -- is generally of higher technical quality than can be expected from volunteer programmers and frees program directors from reliance on what volunteers are willing or able to produce. Instead they can schedule programs off the satellite to meet perceived audience desires and/or needs or to replace recalcitrant volunteers.
The satellite link makes possible greater -- and more contemporary -- coverage of national issues and news. But the economic and institutional arrangements governing satellite access and usage foster greater reliance on institutionally-sponsored, professionally-produced programming. Not only must a community radio station spend several thousand dollars for equipment to receive programs off the satellite, it must also pay annual access charges (Greene 1987; Satellite Distribution/Interconnection 1988). This entitles stations to free or nominally-priced usage of many programs on the satellite, although National Public Radio and American Public Radio charge substantial fees for their programs (few community broadcasters carry NPR programming, APR's programs are sold individually and are carried by some stations -- KOPN, for example, carries Monitor Radio, as does Seattle's KUCM). Yet producers must pay to place their material on the satellite and meet their program costs. Pacifica's live coverage of the Iran-Contra hearings included periodic fund appeals (with an 800 telephone number) in an effort to recover costs (Stum 1987). More commonly, however, producers resort to corporate or other underwriting.
The availability of satellite-distributed programming gives paid staff a stronger hand in setting programming, as they are no longer dependent upon volunteers or the community to meet their objectives. Albuquerque's KUNM replaced volunteer programmers with satellite-distributed classical and jazz music programs despite bitter opposition by volunteer programmers and listeners (Glick 1987a, 1987b). And many community stations now carry the Corporation for Public Broadcasting-financed "World Cafe," a daily world music feed described as "a texture, a profile of programming that gives your station a sound and a style in listeners' minds so they tune in over and over again" (Singer 1990, 10). However, this audio wallpaper has drawn heated criticism and been financially disastrous for some stations (Radio Resistor's Bulletin 1993a; Kneedle 1993).
Satellite distribution is initially attractive both to producers and to broadcasters who gain access to a wide variety of programs that can be used to fill gaps in available programs and serve unmet community needs. Unlike tape exchanges, satellite transmission makes possible rapid transmission of programming, particularly for the handful of stations with the facilities to put programs onto the satellite. With tape-based distribution each program is individually purchased or exchanged, encouraging reliance on local production. Flat-rate satellite access charges and federal funding transform the economic and organizational constraints on national programming. Once a station has committed resources to meeting the annual access fee it costs little more to carry additional externally-produced programs.
The economics of satellite distribution also work to bar most community productions from the air. To distribute programs on tape requires only modest investment, well within the resources of most volunteers. Access to the satellite, while subsidized, is comparatively expensive. Fairness & Accuracy in Reporting, for example, paid $6,000 a year to distribute its half-hour weekly program over the satellite in 1994. Funding agencies -- whether corporate, governmental or philanthropic -- are unlikely to support volunteer productions, or to finance programs inconsistent with their objectives and values. Thus satellite distribution increases dependence upon external funding, strengthens the hands of paid staff in setting programming policy (particularly as they seek to develop more consistent, professional "sounds"), and erodes community members' power over (and access to) their media institutions.
Unlicensed Broadcasters
Even as government policies work to incorporate community broadcasters into the public broadcasting model, however, a new wave of unlicensed broadcasters is challenging both this model and the very right of the government to determine who will be permitted to broadcast (Sakolsky 1992; Markoff 1993). Mbanna Kantako has operated Black Liberation Radio (now Human Rights Radio) in Springfield, Illinois since 1986. His unlicensed station broadcasts black music and literature, political and social commentary, and confrontations with the police -- often turning his microphone over to local residents (Shereikis 1990; Rodriguez 1991; Bishop 1991; Larsen 1991). Similar stations are broadcasting across North America, and their operators actively encourage others, offering technical information and a video showing how to set up a low-power transmitter (Sakolsky 1990; Kneitel 1991; How To Build Your Own Radio Transmitter 1992; Edmondson 1988). Kantako says FCC policies put radio broadcasting
out of the reach of the people that we're trying to reach -- people who live in public housing ... who have no hope at all ... of ever achieving any economic success in this country. ...
That regulation [requiring a minimum 100-watt transmitter] systematically excludes the disadvantaged. ... When you're facing the conditions that our community in particular is facing, you have a duty as a human being to do whatever you can to try to turn those conditions around. And we feel that communications is one of the things that we have to take control over. (Kantako 1990)
Similarly, Radio Free Detroit (1992) has argued that FCC policies are designed "to enforce and maintain corporate control of the media," and that freedom of speech necessarily entails the right to communicate free of both government and corporate control. Unlicensed broadcasters have argued that since the FCC as a matter of policy does not license stations operating at less than 100 watts, low-power broadcasting is unregulated unless it causes interference with existing broadcasters. In California, Radio Free Venice (1991) notified the Federal Communications Commission that it would commence unlicensed broadcasting, citing the Federal Communications Act and the First Amendment to argue that the act applies only to interstate communications. A Hawaii broadcaster seeking to serve a remote, sparsely populated district which received no FM signals went on the air after being denied permission to operate a 10-watt station (Hallikainen 1991). (See Phipps [1991] for an earlier, and unsuccessful, argument that government licensing of intrastate broadcasting was an unconstitutional infringement of free speech rights.) And the National Lawyers Guild's Committee on Democratic Communications is assisting unlicensed broadcasters in appeals before the FCC and the Ninth Circuit Court of Appeals (Democratic Communiquè 1993, Radio Resistor's Bulletin 1993b). While the FCC remains intransigent, its arguments have thus far fallen flat in court (Dunifer 1995, 1996).
Although unlicensed broadcasters have historically operated clandestinely, many low-power broadcasters now operate openly, encouraging community participation. Their stations are not merely alternative, they are oppositional, "giving community people a chance to have a vehicle for the direct expression of their ideas and needs ... breaking the silence that is a product of the media monopoly" (Sakolsky 1990, 4). As such, they represent a continuation of the community broadcasting model.
Conclusions
Community broadcasting in the United States has generally operated within the constraints imposed by the licensing and regulatory processes. Although these constraints impose very real barriers to full democratic control and grass-roots communications, particularly by fostering reliance on experts and bureaucracy, broadcasters' dependence upon their communities for financial support and volunteer labor served as an important countervailing force. Station management or the legally-empowered corporate boards could not act without regard for the wishes of their community of listeners and volunteers.
Recently, however, the institutional environment in which community radio operates has been transformed. Federal funds have made possible state-of-the-art broadcasting equipment and enabled many stations to hire relatively well-paid, professional staffs. Federal policies have encouraged community broadcasters to increase signal strength to a point where it is no longer possible for many listeners to hope to participate in running their "community" radio station. The development of (relatively) large paid staffs and budgets made possible by the increased availability of funds has left many stations dependent on continued infusions of outside funds, and has undermined the possibility of self-management and genuine community control. Similarly, corporate and governmental support for programming -- both in sponsorship of particular programs and, more generally, through the satellite network -- serves to devalue the efforts of volunteers while encouraging professionalization and centralization of programming.
Community broadcasters generally welcomed the infusion of federal funds. These funds have made possible more sophisticated and reliable broadcast facilities, paid staffs, professionally-produced programming, operating funds and access to satellite distribution services. To many community radio stations, accustomed to operating on bare-bones budgets, this has seemed a golden opportunity. Yet a heavy price has been paid for these funds. Writing twenty-five years ago, Theodore Roszak (1968) argued for the central importance of two factors in grassroots communication:
The first is independence. Pacifica is ultimately responsible to no one but its own listeners -- to no sponsor, to no institution, to no creature of the state. ... Secondly, Pacifica has always been characterized by an inveterate amateurishness, which, at last, is the station's finest quality. ... There would quite simply be no Pacifica if programme participants were not willing to contribute their words and works ... if members of the community were not willing to help out continually at everything from remodelling the studios to editing the news each day. (Roszak 1968, 327-28)
Whatever their purpose and short-term benefit, government policies have created strong institutional pressures towards professionalization and bureaucratization, undermining efforts at grassroots communications. While the emergence of unlicensed, low-power broadcasters offers an important alternative, they face government reprisals (including fines and seizure of equipment) as a result of their at-best questionable legal status.
Writing in the British context, Richard Barbrook (1987, 109, 125-26) argues:
The Left should be interested not just in advancing the democratic rights of certain communities to broadcast, but also in overcoming the separation of the working class as a whole from the means of electronic communications. ... These stations represent a space where more democratic and accountable methods of collective working in the mass media can be tried, albeit limited by the continued existence of market pressures in and around them.
Such spaces have, in many places, been opened. But countervailing pressures threaten to undermine these efforts at community control over its own media institutions, and to incorporate them into the public sector. The example of community radio points to the necessity of examining regulatory and funding mechanisms with an eye to their implications for grassroots communications -- for the right "to seek, receive and impart information and ideas through any media and regardless of frontiers" set forth in Article 19 of the Universal Declaration of Human Rights.
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