I agree that the wording is broad enough to include other societies to act as beneficiaries and collectors. I used to be in favour of the licensing solution, until I realised that what is being discussed really is to give licensing rights almost exclusively to collecting societies. I was in a conference recently on orphan works, collecting societies were practically tripping over each other shouting “choose me!”

I share your views that ideally we would want an exception – however the wording “authorising a licensing body or other person to do…” + propositions in (2) I think means that if anything, non collecting societies can apply directly to the Secretary of State for a non-exclusive licence, which I believe places these proposals in a very favourable position to academics/cultural heritage sector etc (as well as complying with Berne and renumeration to rights holders should they come forward). I’d be interested in your views.

Best

Naomi