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Public Notice
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Ottawa, 15 June 1992
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Public Notice CRTC 1992-42
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Assessment of the Impact of the Benefits Test Applied at the Time of Transfers of Ownership or Control of Broadcasting Undertakings
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BACKGROUND
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The Broadcasting Act of 1968 stated that the Canadian broadcasting system should be effectively owned and controlled by Canadians. Parliament, through this legislation, gave recognition to the fact that Canadian ownership is essential to the creation of a strong Canadian broadcasting system. Between 1968 and 1971, there developed within the Commission a process for dealing with transfer of ownership applications. Because the Canadian broadcasting system makes use of radio frequencies that are public property, the Commission, with the public interest in mind, established as a fundamental principle that its prior approval must be obtained for any transfer of effective control. In keeping with this principle, the Commission has consistently maintained that the approval of any transfer application should not result in a reduction in the existing level of service nor impose a financial burden that might impair the purchaser's ability to continue providing the service.
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In a 10 July 1969 policy statement entitled "On the Pricing of Broadcasting Undertakings", the Commission first made reference to the possibility of holding competitive hearings for transfer of ownership applications. It is however the policy of the Commission to scrutinize applications for transfer of assets of licences or for transfer of control of licensees in a manner comparable to its examination of applications for licences for new undertakings.
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Consistent with previous practice, such applications are subject to public hearings, at which objections may be raised and at which companies or persons other than the purchaser proposed by the current licensee may apply for the licence.
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The Commission, however, never adopted this practice and did not hear competing applications.
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This issue was later revisited by the Commission in 1978 in a working paper entitled "Proposed CRTC Procedures and Practices Relating to Broadcasting Matters", which stated:
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...the Commission has given serious consideration to the possibility of implementing a competitive transfer system whereby if control of a licensed undertaking were to be transferred, the situation would be treated as if the existing licence was being surrendered and a new one in its place being applied for, with interested parties entitled to submit competing applications. Such a procedure has been strongly advocated by a number of critics and intervenors. The Commission finds, however, that while there is much merit in theory in such a process, there are also such formidable obstacles to its implementation as to render it impracticable.
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A Public Announcement dated 25 July 1978 released this working paper and invited comments on various aspects of Commission procedures, including the handling of transfer applications. Only 3 of the 90 written submissions received specifically addressed the issue of competitive hearings. In view of the reasons outlined in the working paper, the Commission remained of the opinion that the holding of competitive hearings for licence renewal was not appropriate. In rejecting the competitive process, the Commission opted instead to continue with the development of a process to review benefits related to transfers of ownership.
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The Commission's first specific reference to benefits was in Decision CRTC 77-275 dated 15 April 1977, wherein it stated:
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The transfer of control of a licensed broadcasting undertaking frequently results in additional financial obligations being imposed, directly or indirectly on the undertaking involved. In such circumstances the Commission must be fully satisfied, before granting approval, that such a transfer will not affect the ability of the licensee to maintain existing broadcasting services; that it will benefit the subscribers and the communities concerned; and that it is in the public interest.
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A revised reference to benefits was later enunciated in Decision CRTC 77-456 dated 28 July 1977:
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The Commission considers that in cases of transfers of ownership and control, particularly one of such significance, the onus is on the applicants to demonstrate that approval of the transfers would be in the interest of the public, the communities served by the licensees, including listeners, viewers and cable television subscribers, and the Canadian broadcasting system. In transactions of this magnitude, there must be significant and unequivocal benefits demonstrated to advance the public interest. The current Broadcasting Act, like that of 1968, requires that the Canadian broadcasting system provide opportunity for the public to be exposed to the expression of differing views and a wide range of programming that reflects Canadian attitudes and opinions, ideas, values and artistic creativity. The Commission has therefore consistently weighed proposed benefits against the potential for concentration of ownership and concerns regarding any reduction in the diversity of expression available in a market.
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Such concerns have been addressed in several decisions, including CRTC Decision 86-367 dated 18 April 1986, which clearly stated the manner in which the Commission would deal with future applications for transfer of ownership or control:
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Concentration of ownership within the broadcasting system is not itself necessarily of concern to the Commission, provided that there continues to be an effective degree of diversity of ownership and of programming sources to ensure that the objectives of the Act are met. Today's highly competitive communications environment in every market as well as the high costs and risks involved dictate that the ownership structure must undoubtedly be composed of broadcasting holdings of various sizes, including larger entities with larger pools of resources, which are strong enough to compete with foreign competition and have the capacity to produce Canadian programming of competitive quality. The Commission will continue to deal with such issues on a case-by-case basis and will have to be satisfied that the purchaser demonstrates that the advantages of any such concentration clearly outweigh the disadvantages, and that the transaction is in the public interest. Decision 86-367 further states that:
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As the Commission does not solicit applications for transfers of ownership or control of broadcasting undertakings, it considers it to be the sole responsibility of the applicant requesting such transfer to demonstrate to the Commission that the application as filed is the best possible proposal under the circumstances, taking into account the Commission's general concerns with respect to transactions of this nature. In this regard, the Commission has developed general policy guidelines for disposing of applications for changes of ownership or effective control of all classes of broadcasting undertakings.
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The first test any applicant must meet is that the proposed transfer of ownership or control yield significant and unequivocal benefits to the communities served by the broadcasting undertakings, to the Canadian broadcasting system as a whole, and that it is in the public interest.
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The Commission codified its approach to benefits in Public Notice CRTC 1989-109 dated 28 September 1989 entitled "Elements Assessed by the Commission in Considering Applications for the Transfer of Ownership or Control of Broadcasting Undertakings". In that notice, the Commission reiterated the policy established in numerous decisions over a 15-year period, including the statement that it:
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must be satisfied that the proposed benefits package is commensurate with the size and nature of the transaction and takes into account the responsibilities to be assumed, the characteristics and viability of the broadcasting undertakings in question and the scale of programming, management, financial and technical resources available to the prospective purchaser. The notice specified how the Commission evaluates whether or not proposed benefits meet the key conditions of the test, and provided specific examples of the kinds of benefits that are likely to be accepted or rejected. The Commission emphasized that, while a key consideration in this assessment is that any expenditure proposed as a benefit must be incremental (that is, over and above normal operating expenses), there is no benchmark, formula or relationship between the dollar value of the benefits package and the size of a transaction and each application is assessed on its own merits. It further indicated that the public hearing process is not to be used to negotiate alterations or additions to the benefits package; rather the Commission would assess the acceptability of the total package of benefits and, when approving transfers, would require that the full monetary commitment be implemented.
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APPLICATION OF THE BENEFITS TEST
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The Commission has recently reviewed the application of the benefits test in all ownership transfer applications involving radio undertakings that have been approved since 1985, and those involving cable and television undertakings approved since 1986, in order to assess the impact of financial expenditures related to benefits on the overall financial viability of each sector of the industry and the value of the benefits proposed or implemented. The Commission undertook this review in order to determine whether the benefits test remains valid in light of current economic conditions prevailing in the radio and television industries, and whether the test should be retained or modified in any way.
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TYPES OF BENEFITS ACCEPTED
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In general, accepted benefits have tended to fall into three broad categories: operating expenditures, frequently in the areas of additional staff or programming improvements; capital expenditures for technical improvements; and grants or contributions to Canadian talent or program development funds. Certain sector-specific characteristics of accepted benefits that have emerged from radio transactions since 1985, and from cable and television transactions since 1986, are shown in Table 1 of Appendix I.
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In addition to these "tangible" benefits, the Commission also considers such intangible benefits as the experience and resources of the purchaser, local ownership, entry of new players and, occasionally, the promise to maintain or improve a struggling service, have been found to be equally significant and, in some cases, of primary importance in the approval of transactions. These types of intangible benefits have been put forward more often in the radio sector in view of the economic situation of that industry over the past five years.
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In the cable sector, a key factor is that the cost of any benefit must not be passed on to subscribers through rate increases. Approximately two-thirds of all benefits accepted in cable transactions involved capital expenditures to upgrade or consolidate the systems, and generally resulted in the provision of improved quality of service to subscribers, including increased channel choice. In the majority of cases in which cable transfer applications have been denied, the denial was based on the Commission's disqualification of claimed benefits and its finding that the level of remaining acceptable benefits was not commensurate with the size and nature of the transactions. The clarifications and examples provided in Public Notice 1989-109, however, seem to have reduced the number of benefits claimed by applicants, but deemed by the Commission to be unacceptable. In the radio sector, benefits were more or less evenly distributed between improved technical facilities, enhanced programming, and various types of Canadian talent development initiatives, all of which the Commission considered to be beneficial to the public or to the broadcasting system in general. Lack of adequate benefits (tangible and intangible) was cited as the main justification in the majority of denial cases.
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In the television sector, over 70% of benefits were programming-related, and fell mainly in the areas of Canadian news and drama. The Commission considers that enhanced Canadian television programming is of primary importance to the survival and growth of the industry, and that the injection of new programming expenditures through the benefits test has been of clear benefit, both to the system and to the Canadian viewers it serves. Inadequacy of benefits was quoted as being a factor in only one denial.
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Overall, the Commission is satisfied that the amount of approximately $317 million injected into the broadcasting system over the period reviewed as a result of application of the benefits test is a reasonable one when measured against the total purchase price of approximately $2,135,000,000.
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THE COST OF BENEFITS
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1.The Cable Television Sector
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Since 1986, the Commission has approved a total of 48 transactions affecting 278 cable systems of 2000 subscribers or more. The total cost of these transactions to purchasers was approximately $842,586,000 with total acceptable tangible benefits amounting to approximately $97,926,000, or 11.6% of the total cost. On a case-by-case basis, however, tangible benefits ranged from 2.4% to 37.1% of individual purchase prices. A summary of these findings is included in Table 2 of Appendix I attached. Based on the assumption that expenditures for all proposed benefits were made in accordance with the projections contained in the submitted applications, the benefit expenditures made in respect of approved transactions have had a relatively insignificant negative financial impact on Canadian cable operations as a whole.
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Benefit expenditures lowered the industry's 1991 operating margin from 39.01% to 38.62%, the PBIT (profit before interest expense and taxes) margin from 22.00% to 21.35% and the return on average net fixed assets measured against PBIT from 22.77% to 22.15%. A review of the 1991 operating results of systems that were subject to a change of control in the period under examination obviously reveals a more significant impact. Benefit expenditures lowered these systems' 1991 aggregate operating margin from 40.74% to 38.44%, the PBIT margin from 27.92% to 24.18% and the return on average net fixed assets measured against PBIT from 38.68% to 30.11%.
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2. The Radio Sector:
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A total of 79 transactions involving 191 radio undertakings and associated transmitters was approved by the Commission since 1985, involving a total cost of $409,823,413, with accepted tangible benefits valued at $58.3 million or 14% of the total cost. A look at individual transactions reveals benefits ranging from 0% to 23.3% of the individual purchase prices. A summary of these findings is included in Table 2 of Appendix I attached.
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Using the same assumptions set out previously for cable, the impact of benefit expenditures on Canadian radio operations was significant, essentially due to the very narrow margins existing at this time. Benefit expenditures lowered the radio industry's 1991 operating margin from 6.45% to 5.88% and the PBIT margin from 2.38% to 1.68%. For radio undertakings subject to a change of control in the period under review, benefit expenditures lowered their 1991 aggregate operating margin from 5.5% to 3.29% and their aggregate PBIT from 1.04% to a negative 1.69%.
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3. The Television Sector
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Fourteen transactions involving 125 television stations and rebroadcasting stations have been approved since 1986, representing a total cost of approximately $882,577,000, with accepted benefits of $162,412,000, or 18.4% of total transaction costs. The television sector had by far the highest ratio of benefits proposed, ranging from 7.3% to 49.90% of the transaction cost on an individual basis. A summary of the findings for these 14 transactions is included in Table 2 of Appendix I attached.
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Again, using the same assumptions set out previously for cable, the impact of benefit expenditures on Canadian television operations was significant due to both the large numbers of stations involved relative to the total number of stations and to the relatively narrow margins in television in recent years. Benefit expenditures lowered the industry's 1991 operating margin from 12.51% to 11.03% and the PBIT margin from 8.84% to 7.09%. For stations subject to a change of control in the period under review, benefit expenditures lowered their 1991 aggregate operating margin from 18.85% to 15.34% and their PBIT margin from 15.67% to 11.5%.
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GENERAL CONCLUSIONS
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Having reviewed the 141 transactions approved over the past six years, the Commission is satisfied that its treatment of applications within each of the broadcasting sectors has been as reasonably consistent as possible, notwithstanding the case-by-case approach generally applied, and taking into consideration the basic financial differences between the sectors. The Commission is also of the view that, because the Canadian broadcasting system makes use of frequencies that are public property, the Commission has a responsibility to ensure that the best possible use is made of those frequencies at the time of licensing, license renewal, and transfers of ownership or control.
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For the time being, the Commission considers that, in the absence of a competitive process, application of the benefits test remains the best method of ensuring that applications for transfer of control or ownership are the best possible proposals under the circumstances, and are beneficial to the public served by the undertakings and to the Canadian broadcasting system as a whole.
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As stated in Public Notice 1989-109, and as made abundantly clear by the data contained in the review of transactions referred to in this document, and in Table 2 of Appendix I attached, the Commission emphasizes that there is no benchmark or formula, and that each application should be assessed on its own merits.
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Nevertheless, taking into account the findings of its internal review referred to earlier, the Commission considers that some adjustments to the application of the benefits test may be appropriate. In addition, the differences between each of the broadcasting sectors, including the economic situation that has prevailed in the radio industry over the past six years (see Tables 3, 4 and 5 of Appendix I), and in particular the downturn of the past two years, may justify a tailoring of some of the considerations to the particular situation of each sector.
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Accordingly, without limiting the discussion, and bearing in mind the Commission's ongoing concerns with respect to concentration of ownership, the Commission invites comments from all interested parties on the following questions:
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1. Should the Commission forego the benefits test for undertakings in financial difficulties? If so, what should be the threshold?
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2. Should the Commission establish thresholds below which it would not apply a benefits test? Should these thresholds be based on market size, subscriber levels, revenues, level of profitability, or on a combination of these or other factors?
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3. Should certain types of intangible benefits take precedence over tangible benefits? If so, which ones?
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4. Should the Commission add categories of tangible benefits, or provide clearer definitions of acceptable benefits, in addition to those described in Public Notice 1989-109?
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5. Should the Commission place more importance on system-wide benefits than on local benefits?
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CALL FOR COMMENTS
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The Commission invites public comment with respect to the matters raised by the questions set out above or to any other questions that may be relevant. Submissions should be addressed to the Secretary General, CRTC, Ottawa, Ontario, K1A ON2 and received by the Commission on or before 14 August 1992.
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To facilitate comments on these and any other aspects of the benefits test, a number of financial documents have been placed on the public file. These documents are listed in Appendix II and are available upon request at the addresses provided below:
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Commission Headquarters
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Central Building
Les Terrasses de la Chaudière
1 Promenade du Portage, Room 201
Hull, Quebec K1A ON2
Tels: (819) 997-2429 - TDD 993-0423
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Atlantic Regional Office
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Suite 1007
Bank of Commerce Building
1809 Barrington Street
Halifax, Nova Scotia B3J 3K8
Tels: (902) 426-7997 - TDD 426-7268
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Quebec Regional Office
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Guy-Favreau Complex, East Tower
200 René-Lévesque Boulevard West
Suite 602
Montréal, Quebec H2Z 1X4
Tels: (514) 283-6607 - TDD 283-8316
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Prairie Regional Office
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Suite 1810
275 Portage Avenue
Winnipeg, Manitoba R3B 2B3
Tels: (204) 983-6306 - TDD 983-8274
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Pacific and Northern Regional Office
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Suite 1380, 800 Burrard Street
Vancouver, British Columbia
V6Z 2G7
Tels: (604) 666-2111 - TDD 666-0778
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Related Documents:
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Public Announcement dated 10 July 1969, "On the Pricing of Broadcasting Undertakings"; Public Announcement dated 25 July 1978, "Proposed CRTC Procedures and Practices Relating to Broadcasting Matters" and related working paper; Decision CRTC 77-275 dated 15 April 1977 concerning Western Cablevision Limited and M.S.A. Cablevision Ltd.; Decision CRTC 77-456 dated 28 July 1977, "Applications Involving the Transfer of Effective Control of Premier Cablevision Limited and Western Broadcasting Company Ltd."; Decision CRTC 86-367 dated 18 April 1986 "Applications for Authority to Transfer Effective Control of Télé-Métropole Inc. to Power Corporation of Canada"; and Public Notice CRTC 1989-109, "Elements Assessed by the Commission in considering Applications for the Transfer of Ownership and Control of Broadcasting Undertakings".
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Allan J. Darling
Secretary General
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APPENDIX I
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A. NATURE OF ACCEPTED BENEFITS - TABLE 1
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MEDIUMCAPITAL OPERATINGGRANTS AND
CONTRIBUTIONSCDN. TALENT
DEVELOPMENT OTHER RADIO 22% 23% 8% 29% 18% TV 26.45% 72.57% .02% N/A .96% CABLE 67.02% 18.55% 14.43% N/A N/A
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B. BENEFITS AS A % OF TRANSACTION COSTS - TABLE 2
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MEDIUMNO. OF
APPLICA-TIONS NO.
APPROVED UNDER- TAKINGS AFFECTEDTRANSACTION VALUE
VALUE
OF
BENEFITSBENEFITS
AS % OF
COST RADIO* 90 79 191$409,823,413$ 58,300,000 14% TV * 18 14 125$882,577,000$162,412,000 18.40% CABLE 48 48 278$842,586,060$ 97,925,867 11.6%
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*In the case of two transactions which involved both radio and television undertakings, and where the applicants did not breakdown the purchase price into its components, staff have arbitrarily assigned values to each of the components based on the amount of benefits earmarked to each component.
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C. FINANCIAL OVERVIEW
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TABLE 3: RADIO INDUSTRY
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YEAR PBIT ($M) INTEREST ($M) PBT ($M)* GFA ($M)1991 $12.6 $68.6 ($54.4) $476.01990 $40.1 $67.7 ($20.2) $456.51989 $58.9 $56.3 $22.2 $437.01988 $62.7 $37.4 $26.7 $411.31987 $55.4 $34.7 $24.2 $370.51986 $58.1 $31.2 $26.0 $344.41985 $45.1 $23.6 $16.9 $317.4* Includes Adjustments
(Source: Annual Returns)
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C. FINANCIAL OVERVIEW (Continued)
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TABLE 4: TELEVISION INDUSTRY
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YEAR PBIT ($M) INTEREST ($M) PBT ($M)* GFA ($M)1991 $97.5 $l09.5 ($69.2) $839.61990 $93.6 $91.2 $15.6 $814.31989 $130.4 $51.7 $84.7 $764.51988 $167.3 $40.0 $115.5 $690.91987 $159.9 $35.7 $130.4 $621.61986 $191.1 $30.6 $174.7 $569.61985 $200.5 $36.6 $180.0 $499.5* Includes Adjustments, one being $56.2M goodwill write-off in 1991
(Source: Annual Returns)
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TABLE 5: CABLE INDUSTRY
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YEAR PBIT ($M)* INTEREST ($M) PBT ($M)* NFA ($M) RETURN
ON ANFA
(%)1991 $297.0 $153.1 $148.1 $1,551.7 19.71990 $255.8 $122.7 $140.0 $1,460.6 19.3 1989 $279.9 $101.1 $190.3 $1,192.0 26.1 1988 $245.8 $86.7 $167.7 $951.4 28.0 1987 $209.4 $73.4 $148.8 $802.3 27.8 1986 $175.8 $68.7 $117.3 $703.0 26.71985 $147.2 $75.7 $77.7 $616.8 24.7 * Includes Adjustments
NFA is calculated using standardized depreciation
(Source: Annual Returns)
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LEGEND: PBIT: Profit Before Interest and Taxes
PBT: Profit Before Taxes
LT DEBT: Long Term Debt
NFA: Net Fixed Assets
GFA: Gross Fixed Assets
ANFA: Average Net Fixed Assets
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APPENDIX II
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DOCUMENTS AVAILABLE ON THE PUBLIC FILE
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.List of transactions treated in the Radio sector since 1985 and in the Cable and Television sectors since 1986
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.Aggregate financial summaries of each of the Cable, Television and Radio industries
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.Aggregate financial summaries of licences involved in transactions in radio since 1985, and cable and television since 1986
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.Aggregate financial summaries of licences involved in transactions in radio since 1985, and cable and television since 1986, with benefits extracted from the figures
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ANNEXE I
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A. GENRES D'AVANTAGES ACCEPTÉS - TABLEAU 1
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MÉDIUMIMMOBI-LISA-TIONSEXPLOI-TATIONBOURSES ET
CONTRIBUTIONSDÉVELOPPEMENT
DES TALENTS
CANADIENS
AUTRE RADIO 22% 23% 8% 29% 18% TÉLÉ 26.45% 72.57% .02% S/O .96% CÂBLE 67.02% 18.55% 14.43% S/O S/O
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B. AVANTAGES EXPRIMÉS EN POURCENTAGE DES COÛTS DES TRANSACTIONS - TABLEAU 2
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MÉDIUMNOMBRE
DE DEMAN-
DESNOMBRE DE
DEMANDES APPROU-VÉESENTRE-
PRISES VISÉESVALEUR DES
TRANSACTIONS
VALEUR
DES
AVANTAGESAVAN-TAGES
% DU COÛTRADIO* 90 79 191409,823,413 $ 58,300,000 $ 14% TÉLÉ* 18 14 125882,577,000 $162,412,000 $18.40% CÂBLE 48 48 278842,586,060 $ 97,925,867 $11.6%
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*Dans le cas de deux transactions qui touchaient à la fois des entreprises de radio et de télévision, et lors desquelles les requérantes n'ont pas effectué la ventilation du prix d'achat en ses diverses composantes, le personnel a, de son propre chef, attribué une valeur à chacune des composantes en fonction de la valeur des avantages attribuée à chaque composante.
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C. APERÇU FINANCIER
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TABLEAU 3 : INDUSTRIE DE LA RADIO
ANNÉE BAII
(EN MILLIONS
DE DOLLARS) INTÉRÊTS
(EN MILLIONS DE DOLLARS) BAI
(EN MILLIONS
DE DOLLARS)* IM. BRUTES
(EN MILLIONS
DE DOLLARS)1991 12.6 $ 68.6 $ (54.4)$ 476.0 $1990 40.1 $ 67.7 $ (20.2)$ 456.5 $1989 58.9 $ 56.3 $ 22.2 $ 437.0 $1988 62.7 $ 37.4 $ 26.7 $ 411.3 $1987 55.4 $ 34.7 $ 24.2 $ 370.5 $1986 58.1 $ 31.2 $ 26.0 $ 344.4 $1985 45.1 $ 23.6 $ 16.9 $ 317.4 $*Comprend les révisions
(Source : rapports annuels)
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C. APERÇU FINANCIER (Suite)
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TABLEAU 4 : INDUSTRIE DE LA TÉLÉVISION
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ANNÉE BAII
(EN MILLIONS
DE DOLLARS) INTÉRÊTS
(EN MILLIONS
DE DOLLARS) BAI
(EN MILLIONS
DE DOLLARS)* IM. BRUTES
(EN MILLIONS
DE DOLLARS)1991 97.5 $ l09.5 $ (69.2)$ 839.6 $1990 93.6 $ 91.2 $ 15.6 $ 814.3 $1989 130.4 $ 51.7 $ 84.7 $ 764.5 $1988 167.3 $ 40.0 $ 115.5 $ 690.9 $1987 159.9 $ 35.7 $ 130.4 $ 621.6 $1986 191.1 $ 30.6 $ 174.7 $ 569.6 $1985 200.5 $ 36.6 $ 180.0 $ 499.5 $* Comprend les révisions, l'une étant la radiation de 56,2 millions de dollars de l'achalandage en 1991
(Source : rapports annuels)
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TABLEAU 5 : INDUSTRIE DU CÂBLE
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ANNÉE BAII (EN
(MILLIONS DOLLARS)* INTÉRÊTS
(EN MILLIONS DE DOLLARS) BAI (EN MILLIONS DE DOLLARS) * IM. NETTES
(EN MIL- LIONS DE DOLLARS) RENDEMENT DES IMNM (%)1991 297.0 $ 153.1 $ 148.1 $ 1,551.7 $ 19.71990 255.8 $ 122.7 $ 140.0 $ 1,460.6 $ 19.3 1989 279.9 $ 101.1 $ 190.3 $ 1,192.0 $ 26.1 1988 245.8 $ 86.7 $ 167.7 $ 951.4 $ 28.0 1987 209.4 $ 73.4 $ 148.8 $ 802.3 $ 27.8 1986 175.8 $ 68.7 $ 117.3 $ 703.0 $ 26.71985 147.2 $ 75.7 $ 77.7 $ 616.8 $ 24.7 * Comprend les révisions.
Les immobilisations nettes sont calculées selon l'amortissement normalisé.
(Source : rapports annuels)
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LÉGENDE : BAII : Bénéfices avant intérêts et impôts
BAI : Bénéfices avant impôts
IM : Immobilisations
IMNM : Immobilisations nettes moyennes
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ANNEXE II
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DOCUMENTS VERSÉS AU DOSSIER PUBLIC
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.Liste des transactions traitées dans le secteur de la radio depuis 1985 et dans les secteurs de la télédistribution et de la télévision depuis 1986
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.Résumés financiers globaux des industries de la télédistribution, de la télévision et de la radio
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.Résumés financiers globaux des licences visées par des transactions dans le domaine de la radio depuis 1985 et dans le domaine de la télédistribution et de la télévision depuis 1986
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.Résumés financiers globaux des licences visées par des transactions dans le domaine de la radio depuis 1985 et dans le domaine de la télédistribution et de la télévision depuis 1986 à partir desquels les avantages ont été calculés.
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