Maltese community leaders in Victoria and New South Wales presented a joint submission to SBS Radio in response to the draft Language Selection Criteria 2016/17, calling for an overhaul of the draft criteria. In their view, the criteria are “fundamentally flawed, grossly inequitable and unfairly disadvantageous to communities of medium to small size”. They believe that a complete makeover is necessary to ensure a fairer and more equitable distribution of radio broadcasting hours among the communities.

For several years, the Maltese Community Council of Victoria (MCCV) and the Maltese Community Council of New South Wales (MCCNSW) have been working together in the interests of the Maltese community in Australia to fight for a fairer method of distribution of radio broadcast hours on SBS Radio among ethnic communities. 

On 14 November 2016 SBS launched a public consultation on the criteria for the SBS Radio Review. The draft criteria are identical to those used in the SBS Radio review conducted in 2012, except for the increase from 20,000 to 25,000 in the threshold population figure that a community must have in order to qualify as a ‘large’ language.

The Maltese community organisations gave several grounds on which they based their call for an overhaul:

  • Currently the largest six languages in terms of population size speaking the language at home are allocated 14 hours per week or 2 hours per day air time, which is way too high. This overgenerous allocation to the larger ethnic groups has resulted in insufficient air time left over to be allocated to the remaining communities to meet their information needs. In the case of one of these six languages, SBS even set up a 24/7 radio station in March 2016 dedicated exclusively to programs in that language, while still retaining the allocation of 14 hours per week accorded to that language under the 2012 SBS Radio schedule review.
  • The draft criteria are based on the flawed assumption that the information needs of a community are commensurate with the size of its population. Such an assumption leads to the absurd result that the largest six communities were allocated 14 times more broadcasting hours than the smallest, with some communities even missing out completely.
  • Under the draft criteria, the high needs of communities, which exceed the arbitrarily set threshold of 25,000 to qualify as a ‘large’ community, are not taken into account at all. The draft ‘high needs criteria’ only apply to communities whose population is below that threshold. This is a major flaw in the draft criteria. All communities must be subjected to the ‘high needs’ test as part of the determination of the number of hours they are allocated.
  • To make an overgenerous allocation of program hours to ‘large’ communities simply on the basis of their size without applying the ‘high needs’ test to them is to discriminate against the remaining communities who are required to jump the ‘high needs’ hurdle before they can qualify for any program hours.
  • In the draft criteria there is too strong a bias in favour of size and not enough importance given to other determining factors listed in the criteria for ‘high needs’ communities, particularly, that of ageing. The right balance can only be achieved if all communities, regardless of size, are subjected to the ‘high needs’ test.
  • Basing criteria for eligibility to radio broadcasting hours so heavily on census data relating to the number of persons in a community, who stated in their census form that they speak their native language at home, is a flawed and unfair way to allocate radio time. Much more emphasis should be placed on the specific needs of a particular ethnic community.
  • The draft criteria do not take into account the fact that the larger ethnic groups have many other non-SBS sources of information in their own language, including direct ongoing broadcasts from their country of origin. An adjustment should be made to reduce the number of SBS radio hours allocated to a community which has the luxury of such services.
  • The draft criteria do not take into account the size of the ethnic community audience actually listening to their respective SBS Radio programs when allocating the number of hours to the various communities. The number of radio listeners from the largest communities, which have the luxury of other comprehensive non-SBS sources of information, is likely not to be as high as that from the smaller communities. This is because, for smaller communities like the Maltese, such a quality information service tailored to the specific needs of a community can only be obtained through SBS radio’s language program, as there is no other service of equivalent quality available to them broadcasting in their language.

The MCCV and MCCNSW also complained about the complete lack of transparency in relation to the exact methodology used to apply the criteria in allocating the number of radio broadcasting hours to communities. The criteria document should include clear information on the methodology.

The two community organisations proposed a set of basic principles that should underpin the overhaul of the criteria to make them more equitable and fairer:

  • The same set of criteria should be applied to all communities regardless of the size of their overseas-born and/or language speaking population in Australia.
  • An appropriate weighting and scoring methodology should be developed, agreed and applied to each criterion in order to rank the languages and their respective community needs.
  • A maximum number of broadcasting hours for any language should be set at not more than seven hours per week in order to free up sufficient air time to adequately meet the information needs of the several medium to small sized communities and be accommodated within the limited resources available.
  • A minimum number of broadcasting hours for any language should be set at not less than two hours per week to adequately service the information needs of the small communities.
  • Communities with a large proportion of elderly members over 65 years of age, who are not internet savvy and are unable to benefit from the use of the SBS digital platform services and social media, should be compensated with more radio air time.

In their joint submission the MCCV and MCCNSW proposed a set of criteria and weightings for the scoring of all communities without exception in the allocation of radio broadcasting hours.

In addition to population size in terms of language spoken at home (15% weighting); English language proficiency (15%); ageing (20%); recentness of arrival (10%); and household income (10%), they proposed two new criteria: availability of non-SBS sources of broadcast media in the language of a community (20%); and listenership levels for SBS Radio programs in the language of a community (10%).

The MCCV and MCCNSW also proposed a scoring scale to rate all communities without exception against the proposed criteria. The aggregated weighted score for each community would be used to rank communities and languages from highest to lowest. The allocation of radio broadcasting hours and digital services to the various community languages would then be based on the application of the aggregated weighted score for a community within the parameters of the proposed basic principles.

The MCCV and MCCNSW stressed that it is critical that SBS set an adequate budget for its radio program services in the ethnic community languages, which the organisation was primarily set up to serve.

In their joint submission, the two organisations severely criticised SBS for complaining about government funding cuts but then being able to find significant funds to: finance its highly expensive but totally inappropriate participation in the annual Eurovision Song Contest; set up a 24/7 Food Network TV station in 2015 dedicated to cooking and food shows which SBS sources from the USA; establish a 24/7 Arabic radio station in March 2016; and win an expensive auction against the Nine Network for commercial content to secure content owned by US cable channel Viceland in October 2016.

The funding of these expensive SBS initiatives contrasts sharply with the mean-spirited decision taken by SBS in July 2015, when it decided to discontinue the two hours of Maltese radio programs on the digital network that were added in April 2013 after persistent representations were made by the MCCV and MCCNSW. SBS had given its funding situation as the reason for these cuts and had explained that its funding no longer permitted the provision of these additional services.

The MCCV and MCCNSW questioned the latest commercial projects undertaken by SBS in the past couple of years, which would appear to be in violation of the SBS Charter, as provided in the Special Broadcasting Services Act 1991. They also complained about SBS abandoning a number of ethnic communities by directing its funds to purposes other than those it was intended to serve.