Broadcasting Procedural Letter Addressed to Gretchen King (Community Media Advocacy Centre)
Ottawa, 4 August 2017
Ms. Gretchen King
Community Media Advocacy Centre
Re: Broadcasting Notice of Consultation CRTC 2017-160 – Various procedural requests
Dear Ms. King:
The Commission is in receipt of the letters filed by the Community Media Advocacy Centre (CMAC), dated 23 June and 27 June 2017, with respect to the renewal process of the broadcasting licences for terrestrial broadcasting distribution undertakings (BDUs) initiated by Broadcasting Notice of Consultation 2017-160.
Among other things, in its letters, CMAC:
- identified what it qualified as missing logs and audio-visual recordings of programming aired on some of the community channels operated by the BDUs in question;
- requested that all BDUs provide additional information regarding the programs broadcast on their community channels, the records and forms for local not-for-profit community television corporations, as well as the “Accountability and reporting” information set out in Appendix 2 to Broadcasting Regulatory Policy 2016-224;
- stated that there were inconsistencies between the programming categorizations in the logs; and
- requested an extension to the intervention deadline, which ended 27 June 2017, to 15 days after the public record would be corrected.
The Commission has also received replies from Cogeco Communications Inc., Quebecor Media Inc. on behalf of Vidéotron G.P. (Videotron), Rogers Communications Canada Inc., Saskatchewan Telecommunications, and Shaw Communications Inc. on behalf of Shaw Cablesystems Limited and Shaw Cablesystems (VCI) Limited, addressing CMAC’s requests. All argued that they should be denied, mainly on the basis that the record is already full and complete.
We do not consider the additional information requested by CMAC to be necessary to complete the record of the BDU renewal proceeding. Consistent with paragraph 210 of Broadcasting Regulatory Policy 2016-224, a sample of community channels was selected and BDUs submitted the logs and audio-visual recordings, as required by the Commission for the purpose of conducting its monitoring exercise to evaluate compliance.
Where logs may appear to be missing, we note that some of the information requested of BDUs varied by location. As reflected in Appendix 2 to Broadcasting Notice of Consultation 2017-160, some BDUs were asked to submit three weeks of logs, while others had to submit the same three weeks, as well as an additional fourth week of logs and related audio-visual recordings for that week only. For this reason, the BDUs that were only required to submit logs (but not recordings) have one less week of logs on the public record. We also note that the locations of the BDUs included in this exercise are clearly identified in Appendix 2, excluding Sorel-Tracy and Granby operated by Videotron, which you indicated were missing.
As regards the accountability and reporting set out in Appendix 2 to Broadcasting Regulatory Policy 2016-224, we note that when the information is filed as part of annual returns, it is done so in confidence and the data is only made public on an aggregated basis. In addition, the annual returns that must be filed as part of the Commission’s survey for 2017 will only reflect the information from the previous broadcast year and will not necessarily include all of information from the reporting requirements set out in the appendix. Therefore, if information were to be disclosed as part of this process, it would be incomplete and possibly misleading.
As regards the coding categories used in the logs, we understood that the harmonization of the ones included in the templates we provided to the BDUs with those used by their internal systems would minimize the manipulation of data. Given that the categories are clearly specified within each of the logs, we are of the view that the standardization of the categories is not warranted.
In light of all of the above, CMAC’s requests are denied.
A copy of this letter and all related correspondence will be added to the public record of the proceeding.
Original signed by
Television Policy and Applications
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