ARCHIVED - Broadcasting Public Notice CRTC 2004-12

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Broadcasting Public Notice CRTC 2004-12

  Ottawa, 9 March 2004

Program log reporting requirements for conventional television stations - Call for comments

  The Commission seeks comment on actions it might take to streamline the program log reporting requirements for conventional television stations while ensuring that its regulatory objectives related to compliance and policy monitoring continue to be fulfilled and that no unreasonable burden results in the short term when weighed against improved effectiveness in the long term.



Section 10 of the Television Broadcasting Regulations, 1987 (the Regulations) requires licensees of television stations to keep, in a form acceptable to the Commission, a program log or a machine readable record of its programming.


Program logging is a key element in the regulation and supervision of the Canadian broadcasting system. This tool enables the Commission to verify the compliance of television licensees with regulations and conditions of licence, and to gather the information necessary for monitoring the impact of its policies on the broadcasting system.


Section 5(2)(g) of the Broadcasting Act stipulates that the Canadian broadcasting system should be regulated and supervised in a flexible manner that "is sensitive to the administrative burden that, as a consequence of such regulation and supervision, may be imposed on persons carrying on broadcasting undertakings." In recent years, the Commission has implemented this objective through various streamlining initiatives and it continues to do so. In addition to benefiting those persons carrying on broadcasting undertakings, these ongoing initiatives allow the Commission to improve its efficiency and effectiveness as a regulatory body.


The Commission has reviewed its regulatory requirements as well as its existing procedures and practices concerning the program logs of conventional television stations. This review focused on the needs of the licensees and the Commission, as well as on the demands on their respective resources. As a result of this review, the Commission has concluded that there are opportunities to reduce the administrative burden on many television licensees with respect to their logging requirements.



Approximately 150 conventional television stations and associated networks file program logs on a monthly basis. Program logs include information on all matters broadcast by the station. Each program break (e.g., commercials, promotions, and newsbreaks) requires an additional entry in the log. Since the early 1990s, this information has been filed electronically by the licensees and processed at the Commission by its software system. Each program entry in the log requires the verification of some 25 different fields. As a result, the data for a typical program log for one day, if reproduced on paper, would require approximately 20 pages of 8 ½ x 14 paper. To reproduce the information for one month of program logs for one station would, therefore, require some 600 pages of paper. The result remains the same for a television station originating 168 hours per week of programming locally (including programming acquired from non-network sources) and a station originating only five hours per week of programming because each station must file program logs covering its entire program schedule.
6. The Commission is of the view that the current program log reporting requirements are still valid, particularly for television networks, television stations serving as the principal originating point of television networks, groups of stations, and television stations not affiliated to a network.


On the other hand, the Commission considers that the requirement might not always be efficient or even necessary. For example, under the current regulatory framework, an individual affiliated television station is required to file a complete program log while its affiliated network or group also files a complete set of logs for the broadcast month. This requirement results in the duplication of program logs, which is not necessarily administratively efficient.


The Commission considers therefore that it may be possible to streamline the television program logging process. Section 10(1) of the Regulations allows the Commission to make exceptions to its general program log reporting requirements through conditions of licence. The Commission could, for example, consider applications from certain individual affiliated television stations for an exemption to the log reporting requirements. This exemption could be implemented through licensee-specific conditions of licence.


In light of the above, two alternative options could be available for those affiliated television stations that would qualify for the streamlined process: replace program logs with annual reports on locally originated programs broadcast or continue to file program logs but limit them to locally originated programs.


The Commission estimates that approximately 100 television stations currently affiliated to networks or groups file separate program logs that could qualify for this streamlined process. This reduction in the program log reporting requirements could be meaningful for both television licensees and the Commission.


The Commission notes that the current program log reporting requirements have resulted in licensees and the Commission investing considerable resources to establish and maintain software systems that meet the others' needs. Any amendment to filing requirements, such as requiring only information pertaining to locally originated programs, would likely translate into further investments to change the current systems or to create new ones.

Call for comments


The Commission seeks comment on actions it might take to streamline the program log reporting requirements for conventional television stations while ensuring that its regulatory objectives related to compliance and policy monitoring continue to be fulfilled and that no unreasonable burden results in the short term when weighed against improved effectiveness in the long term.


Specifically, the Commission seeks comment on the following questions:

(a) Within the existing regulatory framework, should certain licensees (e.g., individual television stations affiliated to a network, groups filing network logs, small stations originating only a limited number of hours of programming each week) be exempted, in whole or in part, from the current program log reporting requirements? If so, what criteria should be used to determine which licensees should be exempted? Proposals should be as detailed as possible, and should include how the system would be implemented and how reduced reporting requirements would be of overall benefit to the broadcasting system.


(b) If certain licensees are exempted, which reporting option should be selected and what mechanisms could be put in place to ensure that the Commission will continue to be able to (i) verify a licensee's compliance with its various regulatory requirements, and (ii) still collect the information necessary for input into its policy-making responsibilities? For example, could annual performance reports on locally originated programming be filed by the licensee? Are there other options?


(c) Where changes to existing software systems are needed, what would be a reasonable period of time to expect that the necessary changes would be implemented and what would be the costs incurred?


The Commission will accept comments that it receives on or before 10 May 2004.


Following the Commission's review of these comments, it may call for further submissions if it considers that additional information is necessary. The Commission will then determine if changes to its current regulations or policies on program log reporting are necessary.


The Commission will not formally acknowledge comments. It will, however, fully consider all comments and they will form part of the public record of the proceeding, provided that the procedures for filing set out below have been followed.

Procedures for filing comments

17. Interested parties can file their comments to the Secretary General of the Commission by using ONE of the following formats:
  • Intervention/Comments form
    available from the Commission's web site by indicating and selecting this public notice number under the Decisions, Notices and Orders section


  • by electronic mail to


  • by mail to
    CRTC, Ottawa, Ontario K1A 0N2


  • by fax at
    (819) 994-0218


Submissions longer than five pages should include a summary.


Please number each paragraph of your submission. In addition, please enter the line ***End of document*** following the last paragraph. This will help the Commission verify that the document has not been damaged during transmission.


The Commission will make comments filed in electronic form available on its web site at but only in the official language and format in which they are submitted. Such comments may be accessed in the Public Proceedings section of the CRTC web site. Copies of all comments, whether filed on paper or in electronic form, will also be placed on the public examination file.


The Commission encourages interested parties to monitor the public examination file and the Commission's web site for additional information that they may find useful when preparing their comments.

Examination of public comments and related documents at the following Commission offices during normal business hours

  Central Building
Les Terrasses de la Chaudière
1 Promenade du Portage, Room G-5
Gatineau, Quebec K1A 0N2
Tel: (819) 997-2429 - TDD: 994-0423
Fax: (819) 994-0218
  Metropolitan Place
99 Wyse Road
Suite 1410
Dartmouth, Nova Scotia B3A 4S5
Tel: (902) 426-7997 - TDD: 426-6997
Fax: (902) 426-2721
  405 de Maisonneuve Blvd. East
2nd Floor, Suite B2300
Montréal, Quebec H2L 4J5
Tel: (514) 283-6607
Fax: (514) 283-3689
  55 St. Clair Avenue East
Suite 624
Toronto, Ontario M4T 1M2
Tel: (416) 952-9096
Fax: (416) 954-6343
  Kensington Building
275 Portage Avenue
Suite 1810
Winnipeg, Manitoba R3B 2B3
Tel: (204) 983-6306 - TDD: 983-8274
Fax: (204) 983-6317
  Cornwall Professional Building
2125 - 11th Avenue
Room 103
Regina, Saskatchewan S4P 3X3
Tel: (306) 780-3422
Fax: (306) 780-3319
  10405 Jasper Avenue
Suite 520
Edmonton, Alberta T5J 3N4
Tel: (780) 495-3224
Fax: (780) 495-3214
  530-580 Hornby Street
Vancouver, British Columbia V6C 3B6
Tel: (604) 666-2111 - TDD: 666-0778
Fax: (604) 666-8322
  Secretary General
  This document is available in alternative format upon request and may also be examined at the following Internet site:

Date Modified: 2004-03-09

Date modified: