ARCHIVED - Broadcasting Procedural Letter addressed to Monica Auer, M.A., LL.M. (FRPC), John Lawford (Counsel to COSCO-PIAC) and Nathalie Blais (CUPE)

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Ottawa, 23 December 2015


Monica Auer, M.A., LL.M.
Executive director

John Lawford
Executive director and General Counsel to PIAC
Counsel to COSCO-PIAC

Nathalie Blais
Research Advisor

Re: Procedural requests regarding Broadcasting Notice of Consultation CRTC 2015-421 and 2015-421-2

The Commission is in receipt of three procedural requests relating to the review of Local and Community Programming, as outlined in Broadcasting Notice of Consultation CRTC 2015-421 (BNC 2015-421) and Broadcasting Notice of Consultation CRTC 2015-421-2 (BNC 2015-421-2). These requests were filed by the Forum for Research and Policy in Communications (FRPC) (on 21 December 2015), by the Canadian Union of Public Employees (CUPE) (on 22 December 2015), and by the Council of Senior Citizens’ Organizations of B.C. (COSCO) and the Public Interest Advocacy Centre (PIAC), together COSCO-PIAC (on 22 December 2015).

In its letter, FRPC notes that the Commission announced in BNC 2015-421-2 its intention to publish an additional document on 12 January 2016 that would set out areas for exploration in order to focus discussion and debate during the public hearing (the additional document). FRPC argues that these timelines would not provide interested parties with a reasonable opportunity to submit evidence in response to the additional document in time for the 25 January 2015 hearing. Therefore, FRPC requests the Commission to either issue the additional document on or before 4 January 2016 or to postpone the commencement of the hearing to 15 February 2016. FRPC notes that it prefers the first option.

In its letter, CUPE also requests that the Commission either issue the additional document on 4 January 2016 or postpone the commencement of the hearing to mid February 2016, for reasons similar to those raised by FRPC.

Finally, COSCO-PIAC states in its letter that it shares FRPC’s concerns regarding the time provided to interested parties to prepare and address the ideas and proposals raised in the additional document. However, COSCO-PIAC notes that the Commission had announced in BNC 2015-421 that parties may have an opportunity to file brief final written comments following the public hearing. COSCO-PIAC therefore requests that the Commission formally provide an opportunity for parties to file final written comments of a maximum of 15 pages following the hearing, with the deadline of 12 February 2016.

In response to COSCO-PIAC’s request, I can confirm that parties who have filed interventions in this proceeding will be given the opportunity to file final written submissions after the hearing. Specific details regarding final comments will be announced by the Commission at a later date.

Regarding the time between the publication of the additional document and the commencement of the hearing, it should be noted that the purpose of the additional document announced in BNC 2015-421-2 is to set out areas for exploration at the hearing. When it announced the date of publication for the additional document, the Commission had taken into consideration the period of time between the publication date and the commencement of the public hearing. As such, it does not expect interested parties to file new written submissions in response to the additional document, but rather that they would prepare to discuss specific issues identified by the Commission based on information that already forms part of the public record, at the hearing.

Furthermore, as mentioned above, parties will have an opportunity to file written submissions after the hearing, which will provide parties with ample time to prepare and submit final comments in response the discussions that will have taken place at the public hearing, including on issues raised in the additional document.


Peter Foster
Director General
Television Policy and Applications

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