<<

Television Licence Fee A report prepared by Kevin Rafter for the Independent Broadcasters of Ireland.

September 2015

1 | Independent Broadcasters of Ireland Licence Fee 2 5 7 9 10 11 1. TV LICENCE FEE Contents 2. SOUND & VISION & 3. COLLECTION CHARGE 4. 5. FUTURE DIRECTION 6. CONCLUSION There are also also are There 2 3 obligations in relation to Irish language programmes, Irish language programmes, to obligations in relation and serving local content music and drama Irish culture, communities. these independent areas, In many of their franchise for of choice station the become have stations listeners. (JNLR) report Research The Joint National Listenership of independent profile strong the 2015 confirmed in July the overall 1 shows Table areas. in their local stations in 15 years adults over for share position on audience In many parts of the 7pm time slots. the peak 7am to adult population than 40% of the local more country 7am between independent station their local tunes in to in share the majority audience areas and 7pm; in several station. radio held by a local public service content including commitments for news news for including commitments content public service laid down Similar obligations are affairs. and current the BAI and between agreements contract in license and in legislation. independent stations, Act under Section 39 of the Broadcasting Specifically, that ensure to required are 2009 independent stations time is devoted than 20% of their broadcasting not less content. affairs and current news to The introduction of different categories of categories of different The introduction 1

Section 144 of the Broadcasting Act 2009 does provide Act 2009 does provide Section 144 of the Broadcasting different to in relation of regulations the introduction for and commercial residential for of licences classes premises. There is only one type of licence payable, and it covers and it covers payable, one type of licence is only There There in the same property. any number of for structure or fee system licensing is no separate operators. commercial

The requirement to have a TV licence has existed since the introduction of domestic of domestic the introduction since existed has a TV licence have to The requirement Act 9 of the Broadcasting in Part is outlined system The current in Ireland. television the penalties to and a licence have to out the requirement sets 2009. The legislation licence. not having a valid be imposed for 1. TV LICENCE FEE 1. TV LICENCE RTÉ and TG4 have detailed legislative obligations - set legislative detailed have RTÉ and TG4 provide - to in the 2009 legislation recently out most With the deregulation of the Irish broadcast market market of the Irish broadcast With the deregulation public service the sole RTÉ is no longer post-1988 and owned On both state in Ireland. broadcaster of programme a variety are there independent stations that indicate clearly types. Schedules content or as either public service, classified programmes any single to not exclusive are non-public service, broadcaster. Despite this process, the ultimate decision on revising decision on revising the ultimate this process, Despite and the with the Minister remains fee the licence of public is taken No account of the day. Government and on independent radio programming service stations. television Section 124 of the Broadcasting Act 2009 allows the Act 2009 allows Section 124 of the Broadcasting a recommend (BAI) to Authority of Ireland Broadcasting Communications, for the Minister to increase fee licence commence to In order Resources. and Natural Energy of the a review commission the BAI must this process, fulfilling their public are which RTÉ and TG4 to extent and the adequacy of available commitments service both media organisations enable public funding to as set out in their annual meet these commitments of performance. statements licences is one of the issues to be addressed in the be addressed to is one of the issues licences (see Charge Broadcasting new of a proposed context below).

2 | Independent Broadcasters of Ireland Television Licence Fee 3 | Independent Broadcasters of Ireland Television Licence Fee 6.1% 6.6% 7.4% 79.9% 5 % of total RTÉ & TG4 Sound & Vision An Post Total Total €000 13.4m 14.5m 16.2m 174.9m allocation, allocation, €160 €9.72 €10.52 €11.92 €127.84 of every of every Breakdown Breakdown An Post An Post Collection Agent Sound & Vision TG45 RTÉ Derived from RTÉ, Annual Report 2013, p17. from Derived Source: Where the licence fee goes fee the licence 3: Where Table 2013 Allocation, Fig. 1: TV Licence The most recent RTÉ annual report shows the station the station shows RTÉ annual report recent The most of €328m in 2014. This figure revenue had total activities commercial €149.6m (46%) from comprised income. fee licence and €178.6m (54%) from on data RTÉ has provided annual reports several Over its various across allocated monies are fee licence how this verified activities. Although not independently licence some insight into 4 offers in Table information public service the broadcaster’s spending against fee obligations. 7.1% 1.9% 7.9% 6.6% €000 226.2 222.4 217.8 215.0 216.4 213.3 21.9% 54.1% Weekdays, 7am-7pm Weekdays, 4 Today FM Today RTÉ 2FM RTÉ Lyric Newstalk stations & regional Local RTÉ Radio 1 2010 2011 2012 2013 2014 Year 2009 The licence fee is currently set at €160 per annum. Total Total set at €160 per annum. currently is fee The licence 2. in Table is shown revenue fee licence Source: JNLR, 2015 Source: TV Licence Fee 2: TV Licence Table Radio Audience, 2015 1: Radio Audience, Table aged 15+) all adults (Share, As shown in Table 3 the vast majority of licence fee fee majority of licence 3 the vast in Table As shown just receive they RTÉ and TG4; between is shared income €160 licence or €139.76 in every 87% of the total, over fee. Prior to 2003, RTE received all net licence fee fee all net licence 2003, RTE received Prior to net income Changes in 2003 meant 5% of the income. produced support independently to was allocated on public and independent broadcasters programming 7% to was increased Sound & Vision. This level through in 2009. Following the deduction of a payment fee to An Post An Post to the deduction of a payment fee Following is revenue fee agent, the net licence as the collection and the Broadcasting the RTÉ, TG4 between allocated by as Sound & Vision) administered known (better Fund the BAI. 6.2m 5.7m 5.9m 4.5m 7.1m 7.1m 0.3m € 000 55.6m 49.3m 18.4m 10.6m 11.7m RTÉ One TV TV RTÉ Two Radio 1 2FM RnG FM Lyric Orchestras Online Other channels HQ Support TG4 related DTT Source: RTÉ, Annual Report 2013, p96 Source: RTÉ Licence Fee Fee 5: RTÉ Licence Table spend, 2013 total allocation, 5.0% 3.5% 6.0% 3.2% 6.7% 3.3% 2.5% 31.5% 27.9% 10.4% % of total €6.51 €4.49 €7.70 €4.13 €8.54 €4.27 €3.26 €40.04 €35.62 €13.28 of €160 Breakdown Breakdown 6 RTÉ One TV RTÉ Two TV RTÉ Two Radio 1 2FM RnG Lyric FM Lyric Orchestras Online Other channels Other RTÉ’s Licence Fee Fee Licence 4: RTÉ’s Table each €160 is spent, revenue The total allocation of licence fee revenue within RTÉ is revenue fee of licence allocation The total 5. in Table shown The balance of the licence fee revenue - the station’s - the station’s revenue fee the licence of The balance between ‘is distributed notes, 2013 annual report potential revenue commercial significant with services - RTÉ of the public services’ the net cost to in proportion Radio One, 2fm and RTÉ Online. One, RTÉ Two, According to RTÉ licence fee revenue is in the first is in the first revenue fee RTÉ licence to According that have channels and services to allocated instance - revenue commercial generate to capacity limited of provision fm, statutory RnG, lyric RTÉ Orchestras, and DAB DTT supplementary TG4, to programming HQ and financing Corporate channels (‘other channels’), costs. Derived from RTÉ, Annual Report 2013, p17. from Derived Source:

4 | Independent Broadcasters of Ireland Television Licence Fee 5 | Independent Broadcasters of Ireland Television Licence Fee 4.6% 8.4% 31.2% 21.1% 34.6% % of total € 5.0m 8.2m 1.1m 7.4m 2.0m This exclusion means that the 20% news and means that the 20% news This exclusion 8 TG4 Independent TV Independent Radio & TV RTÉ The funding is allocated independent of audience levels levels independent of audience The funding is allocated majority of awardees The vast sectors. in the different although in some rounds independent producers are awardees. were as applicants themselves stations current affairs requirement on independent stations - on independent stations requirement affairs current fee no licence - receives content which is public service support. & Sound from allocations 6 show Table in The figures funding five the final Vision II in 2013 and 2014, namely for years recent most of the scheme in the two rounds is available. which information in licence of €23.7m was awarded In this period, a total programming for independent producers to income fee stations. and radio on public and independent television radio funding - 474 for received In all, 586 productions television. and 112 for Table 6: Sound & Vision Table II, 2013 and 2014 These objectives were derived from statutory provisions provisions statutory from derived were These objectives Irish Language, be summarised as: Quality, and can and Community Local Heritage, Diversity, Additionally, and/or or Media Literacy, Adult Literacy Broadcasting, Issues. Global specifically are programmes affairs and current News funding support under Sound receiving from excluded & Vision. 6 7

‘played a key role in making public revenue in making public revenue role a key ‘played are they whether all broadcasters, to available commercial. private/purely or are owned publicly making it this by Sound and Vision acknowledges exclusively is not content public service that clear broadcasters.’7 publicly-owned by produced ‘to increase public access at national, local and local national, at public access increase ‘to and high-quality television to level community in English and programmes sound broadcasting Irish culture, of the themes Irish which explore in contemporary or heritage and experience, contexts.’ historic

The second round of funding under the Broadcasting of funding under the Broadcasting round The second in - Sound and Vision II - commenced Scheme Funding The Scheme until the end of 2014. January 2010 and ran to: was intended In a 2013 review of Sound & Vision it was noted that the of Sound & Vision it was noted In a 2013 review scheme had: Essentially, Sound & Vision provides funding to to funding Sound & Vision provides Essentially, that are programmes make to independent producers channels. In on BAI-approved free-to-air broadcast and RTÉ, TG4 & Vision is open to Sound this regard, in the independent and community the broadcasters prior support have must programmes Proposed sectors. apply. to be eligible to in order of a broadcaster With the exception of an allocation to fund a broadcast fund a broadcast to of an allocation With the exception the costs, scheme and BAI administration archive spent are Fund majority of monies in the Broadcasting the Sound & Vision Scheme. through The Broadcasting Funding Scheme is designed to Scheme is designed to Funding The Broadcasting and based on Irish culture support programming funded It is currently other objectives. among heritage, fee licence of 7% of the net television by an allocation 5% 7% (from to was increased The funding level income. under the 2009 legislation. previously) Section 154 of the Broadcasting Act 2009 assigned responsibility for the for responsibility assigned Act 2009 the Broadcasting Section 154 of radio of high quality the transmission support to of a funding scheme administration sector. the independent production by produced programming and television 2. SOUND & VISION 2. SOUND content transmitted by a variety of stations irrespective irrespective of stations by a variety transmitted content type. of ownership RTÉ & TG4 Independent TV Independent Radio Community TV & Radio 87.3% of total licence fee allocation; fee licence 87.3% of total Sound & Vision allocation. 52% of total • are fee allocations that licence suggest The figures in market the changed broadcast not acknowledging and audience stations by licensed as represented Ireland the increased particularly, and, more preference with public service output in programme diversity • Taking the overall allocation of the licence fee in fee of the licence allocation the overall Taking shows with the Sound & Vision allocation conjunction RTÉ and TG4: majority of the monies go to that the vast The balance was shared among independent and shared was The balance received - independent television stations community just €1 allocated; every cent in (0.35) thirty-five almost broadcasters; community to went eight (0.08) cent over cent (0.05) five than less received and independent radio €1 awarded. in every In total, for every €1 in Sound & Vision funds distributed €1 in Sound & Vision funds distributed every for In total, to the public went cent (0.52) fifty-two over just broadcasters. Fig.2: Sound & Vision, 2013 & 2014 The allocations in 2013 and 2014 show that over half over that in 2013 and 2014 show The allocations Sound through funding allocated fee of the licence for independent producers to & Vision was awarded broadcasters, owned publicly on the two programming RTÉ and TG4. In this category, independent radio stations had 34 stations radio independent In this category, 12 funds (€213,914), RTÉ radio securing programmes one programme RTÉ television (€78,646), programmes programmes two television (€70,000) and independent (€703,000).

6 | Independent Broadcasters of Ireland Television Licence Fee 7 | Independent Broadcasters of Ireland Television Licence Fee 15 17 16 ‘evasion both reduces the level of funding available available funding of the level reduces ‘evasion both an and creates broadcasting public service for holders licence inequity between compliant it is desirable these reasons, and evaders. For evasion should be minimized or fee licence that eliminated.’ A high proportion of summons are returned unserved unserved returned are of summons A high proportion cases in 2004). Where 50% at approximately (estimated with fines rate is a high conviction there court to proceed Again, based on imposed and some prison sentences. evaders convicted few seem that very it would 2004 data hearing. a court following a licence purchase Evidence shows there is considerable scope to increase increase to scope is considerable there shows Evidence by bringing evasion in Ireland income fee licence total in other experienced type of levels the to down levels countries. Access Database and Energy The Department of Communications, legislation preparing is currently National Resources to access agent have collection the TV licence allow to service and cable held by subscription data such as Sky and UPC. companies the from advice legal The Department has taken of commercial issues around General Attorney committed It has privacy. and customer confidentiality to Commissioner Protection liaising with the Data to security requirements. meet data the proposals ensure has enactment of this legislation the for No timetable the names and addresses to been set. Having access would services television digital to of subscribers fee identifying licence easily in more assist undoubtedly evaders. higher to achieve in order however, Significantly, likely will most vigilant detection more from revenues As noted in a Comptroller and Auditor General Report in General and Auditor in a Comptroller As noted 2004: 14 11 In July 2014 the then In July 10 13 9 12

Where evaders are detected, and do not subsequently and do not subsequently detected, are evaders Where are proceedings prosecution a licence, purchase for number of summonses served The commenced. was 16,566 in 2014. non-payment of TV licences By way of contrast, the evasion rate in the United in the United rate the evasion By way of contrast, Kingdom is put at 5.5%. The lost revenue from this level of evasion is estimated is estimated of evasion this level from revenue The lost at €30m. The evasion rate has varyingly been estimated been estimated has varyingly rate The evasion and 15%. 12% at between The TV licence fee has always been subject to a degree a degree been subject to has always fee The TV licence high, and have are in Ireland levels Evasion of evasion. years twenty the last high for stubbornly remained period a prolonged over have These levels and longer. including the higher than in other countries remained Kingdom. United Evasion While An Post had previously indicated a preference a preference indicated had previously An Post While has the company in collection end its involvement to has undertaken as the agent. The company continued 1984, having previously in its formation since this work within role Office agent in its Post been the collection The amount and Telegraphs. the Department of Posts the volume to by reference is calculated An Post paid to payment on an incentivised based sales of licence the for with additional amounts payable structure targets. sales of defined achievement Collection on behalf of system the collection administers An Post and Natural Energy the Department of Communications, the for responsibility which has overall Resources, process. management of the collection 3. COLLECTION & EVASION 3. COLLECTION Communications Minister Pat Rabbitte described Rabbitte Pat Minister Communications when he suggested as ‘an ongoing scourge’ evasion be higher than 15%. could levels evasion require more successful efforts to change the behaviour to efforts successful more require the before summons or convicted with of those issued courts.

8 | Independent Broadcasters of Ireland Television Licence Fee 9 | Independent Broadcasters of Ireland Television Licence Fee 21 20 19 Earlier in 2015, the current Minister for for Minister Earlier in 2015, the current Alex Resources and Natural Energy Communications, the TV licence replace to that plans announced White proceed not would charge broadcasting with a new fee of the Fine Gael-Labour government, during the lifetime issue. was a post-2016 and that its introduction The Minister has spoken about the need to build about the need to spoken has The Minister the for and acceptance/support public understanding arrangement. funding broadcast of a new introduction While no commitment has been made on the level has been made on the level no commitment While - it was revenue overall of this change - or projected at would, arrangements that the proposed understood funding existing sustaining to a minimum, be capable levels. 18

‘We will examine the role, and collection of, the of, and collection the role, ‘We will examine and project existing of in light fee TV licence technologies, broadcasting of convergence a broadcast- into transform the TV licence all applied to Charge based regardless businesses, households and applicable and review content access use to they the device of including the collection, ways TV licence new of another through in instalments paying of possibility by collection or telecom), utility boll (electricity with An contract authorities, Revenue or new local Post.’

In summary, it was envisaged that this new charge charge was envisaged that this new it In summary, households and businesses all eligible to apply would or content access used to of the device irrespective services. The Programme for Government of the Fine Gael- Government for The Programme to a pledge 2011 contained in March Labour coalition Public with a new funding system the current replace The document noted: Charge. Broadcasting A household-based charge has the attraction of dealing has the attraction A household-based charge by habits - driven consumption with changing viewer as - as well in technologies and convergence advances levels. evasion in addressing assisting For example, the Culture, Media and Sport Committee Media and Sport Committee the Culture, example, For published in February in a report at Westminster future was no long-term that there 2015 concluded a new for fund the BBC and argued to fee in a licence of subscription. a degree or possibly levy, broadcasting The idea of moving away from a device-specific levy to levy a device-specific away from The idea of moving independent charge, a household-based broadcasting in many is under consideration device, of the viewing countries. Under existing statutory requirements those watching those watching requirements statutory Under existing or streaming devices on portable content’ ‘television a TV licence. own to online do not need programming The concept of a TV licence fee has been challenged - and undermined - by changing - and undermined - by challenged has been fee licence of a TV The concept devises. and platforms of viewing range by a new driven patterns consumption television. a on owning reliant is no longer content’ ‘television to Access 4. BROADCASTING CHARGE 4. BROADCASTING With the possible introduction of a new broadcasting broadcasting of a new introduction With the possible and clarity about debate be more to needs there charge in Ireland. broadcasting public service what constitutes market and television in the Irish radio In this regard, that the argument to sustain difficult it is very today public and broadcast produce stations owned state only programming. service output - public defined by mixed is now The Irish market - on content and non-public service content service and independent owned state of different a variety stations. independent funding for increasing for The case of their in respect be strongest seem to would stations programming. affairs and current news 20% mandatory in ensuring important is especially This argument and vibrant a strong to the Irish public has access and news, of broadcast source information alternative and that gathered beyond its transmission, for outlets by RTÉ and TG4. provided a functioning is good for sources of news A diversity enhancing the quality and In that regard, democracy. affairs and current ensuring the viability of news an should be on independent stations programming from winners The real public policy objective. important be the Irish public. would such a process 22 23 24

In the context of the financial difficulties and challenges difficulties and challenges of the financial In the context by both public and independent broadcasters faced but also by crisis economic by the post-2008 - driven - it market ongoing changes in the media advertising support to exists scope considerable seem that would stations on all licensed programming public service type of those stations. of the ownership irrespective The current Minister for Communications in May 2015 Communications for Minister The current debate’ ‘a considerable the need for acknowledged this issue. around In this context, arguments about a ‘zero sum game’ sum about a ‘zero arguments In this context, public for resources will be fewer - that there on independent content if public service broadcasters - do not apply. extent a greater is funded to broadcasters In the context of an overall increase in revenue scope scope in revenue increase of an overall In the context additional monies to distribute to be available would both the public and independent sectors. Yet, as we have seen, scope does exist to increase overall overall increase to does exist scope seen, have as we Yet, benefit both public and to fee the licence from revenue in the current (without an increase independent sector, with evasion reduced through First, annual €160 fee). Second, subscriber databases. service digital to access fee. licence a commercial by introducing Doubts have been raised at ministerial level about level at ministerial been raised Doubts have greater for allow to system modifying the allocation on broadcast content of the public service recognition of weakening fear in particular for independent stations, sector. the public broadcaster It is also possible to make a similar argument about a similar argument make to It is also possible affairs and current of news value the public service media. This broadcast owned output on independently for Horwath report in the Crowe was referenced issue or analysis the BAI in 2013 but without any significant discussion.

Successive ministers have argued the case for a continuation of a funding model - of a funding a continuation for the case argued have ministers Successive ensure to - so as charge broadcast household a new or fee, licence be it the existing meet to RTÉ and TG4 for is available source income and reliable that an independent and current of news in the case particularly objectives public service their legislative programming. affairs 5. FUTURE DIRECTION 5. FUTURE

10 | Independent Broadcasters of Ireland Television Licence Fee 11 | Independent Broadcasters of Ireland Television Licence Fee

Ireland now has a variety of stations producing and transmitting programming programming and transmitting producing of stations has a variety now Ireland content. public service as be classified that can RTÉ to allocated - 87% - are fee the TV licence majority of monies from The vast Sound & Vision the from the main recipients also are stations These two and TG4. in 2013 and 2014. 50% of funding awarded over Scheme - receiving access Obtaining high in Ireland. stubbornly remain levels evasion TV Licence in identifying will assist services and cable of satellite the subscriber details to be will also need to summons and convictions attitudes to but prevailing evaders tackled. model. fee undermine the licence to will continue habits Changing viewing until 2017 at fee the licence will not replace Charge Broadcasting The proposed change TV license/broadcast commercial of a new The introduction the earliest. increase. revenues should see overall - it should fee commercial and a new evasion less from monies - With increased and independent on both public content service public enhance to be possible in Ireland. benefit the audience to stations is strongest on independent stations content public service funding for The case programming. affairs and current of their news in respect broadcasting service about funding public a debate for call White’s Minister funding on new movement of immediate in the absence even should proceed models.

AUTHOR books and of several as the author/editor on media and politics in Ireland has published widely Rafter Kevin the Irish Film Board, for research journals. He has undertaken academic in international articles research experience He has substantial of Ireland. Authority and the Broadcasting of Ireland the National Newspapers as works and currently (2008-present), in journalism (1995-2008) and academia careers across acquired [email protected] Contact: at Dublin City University. Professor Associate

1. 2. 3. 4. 5. 6. 7. 8. 6. CONCLUSION design: www.cronindesigns.ie ref: 002972 IBI television Licence Fee report 200 no 16pp A4 330gsm mat lam card cover 150 gsm silk body full colour 02 date: September 25, 2015 6:39 PM See Minister Alex White, Dáil Debates, 19 May 2015. Dáil Debates, White, Alex See Minister The current distribution system for TV licence fee fee TV licence for system distribution The current See, for example, Minister Alex White, Dáil Debates, Dáil Debates, White, Alex Minister example, See, for Parliamentary Question [22939/15], 16 June 2015 [22939/15], 16 June Question Parliamentary Comptroller and Auditor General, p16. General, and Auditor Comptroller 16 June 2015. [22943/15], Question Parliamentary 2015. See House of Commons, 2015. 14 July [28234/15], Question Parliamentary 11 February Dáil Debates, White, Alex See Minister income was introduced following state aid clearance aid clearance state following was introduced income It has been noted Commission. the European from arrangements of the current that any modification Pat See Minister similar approval. might require 2013. 26 February Dáil Debates, Rabbitte, 19 May 2015. 2015. 24 23 22 21 16 17 18 19 20 Parliamentary Question, [1895/15], 15 January 2015. Question, Parliamentary p9. General, and Auditor Comptroller RTÉ Annual Report 2014, p9. Media and Sport House of Commons Culture ‘Cabinet approves measures for TV licence TV licence for measures ‘Cabinet approves The 12% evasion rate was referenced in the C&AG in the C&AG was referenced rate The 12% evasion See Comptroller and Auditor General, Television Television General, and Auditor See Comptroller The latest version of the Broadcasting Funding Funding of the Broadcasting version The latest Crowe Horwath, Final Report to BAI in respect of a BAI in respect Horwath, Final Report to Crowe Includes spending on governance and financing, BAI Includes spending on governance Includes licence fee allocation and RTÉ programme and RTÉ programme allocation fee Includes licence Data for 2009-2013, Parliamentary Question Question 2009-2013, Parliamentary for Data Joint National Listenership Report, Ipsos MRBI, July Report, Ipsos MRBI, July Joint National Listenership Parliamentary Question [28557/13], 13 June 2013. [28557/13], Question Parliamentary in 12 hours than more for is provided If the service Committee, Future of the BBC, 10 February 2015, p71. of the BBC, 10 February Future Committee, crackdown’, Irish Times 8 July 2014. Irish Times 8 July crackdown’, Report, again in media reports in December 2010 and, in December Report, again in media reports mentioned Rabbitte Pat when Minister recently, most January 2012. in the Dáil on 18 rate a 15% evasion Licence Fee Collection, January 2004(p9); RTÉ Annual Collection, Fee Licence Report 2013 (p13). Scheme - Sound & Vision III - commenced in February in February Scheme - Sound & Vision III - commenced of in the region allocate to 2015 with a commitment a over programming and radio television €24m to period. two-year Statutory Review of the Sound and Vision II Scheme, Review Statutory 10 June 2013, p71. levy and DTT related costs, RTÉ Annual Report, 2013. RTÉ Annual costs, related and DTT levy support. [29979/14] 9 July 2014; data for 2014, Parliamentary 2014, Parliamentary for 2014; data [29979/14] 9 July [1894/15] 15 January 2015. Question 2015. a single day, stations must ensure that two hours hours that two ensure must stations day, a single news to devoted are 07.00 and 19.00 hours between a The BAI may approve content. affairs and current if it is satisfied that these conditions from derogation of the service. benefit listeners such an opt-out would application. set out in a licence is generally A request 15 14 13 12 11 10 9 8 7 6 5 4 3 1 2 References

12 | Independent Broadcasters of Ireland Television Licence Fee 13 | Independent Broadcasters of Ireland Television Licence Fee IBI, Macken House, Mayor Street Upper, Dublin 1 E: [email protected] W: www.ibireland.ie