ARCHIVED - Broadcasting Commission Letter addressed to Kevin Goldstein (Bell Media Inc.)

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Ottawa, 4 June 2019


Mr. Kevin Goldstein
Vice-President, Regulatory Affairs, Content and Distribution
Bell Media Inc.
299 Queen Street West
Toronto, Ontario   M5V 2Z5

Re: Audit of Bell Media Inc. (Bell Media) tangible benefit requirements for the 2014-2015 broadcast year

Dear Mr. Goldstein:

As part of its annual audit of Bell Media’s radio tangible benefit contributions, the Commission recently reviewed the licensee’s contributions for the 2014-2015 broadcast year imposed on Bell Media as a result of Broadcasting Decisions CRTC 2011-163 and 2013-310.  During this audit, Commission staff identified issues with several expenditures claimed towards meeting Bell Media’s CCD tangible benefit requirements.  You were notified of this apparent non-compliance by Commission staff letter dated 9 January 2018 and responded by letter dated 15 February 2018.

This letter is to inform you that the Commission finds that a portion of certain expenditures made by Bell Media towards meeting its tangible benefit obligations in the 2014-2015 broadcast year were ineligible based on the Commercial Radio Policy, 2006. Footnote1

Bell Media received a number of the tickets to the Canada Music Week Fanfest and Breakthrough Canada Showcase Series live events which were sponsored with the CCD funds. The receipt of tickets in this case was more than a minor component of the main event and Bell Media could use these tickets for its own marketing and promotion. As a result, the use of tickets by Bell Media in this manner include a promotional aspect that is significant enough to consider that there is a sufficient aspect of the initiative that is not well above and beyond promotional activities.

In the circumstances, the Commission finds that a portion of the expenditures directed towards these initiatives are ineligible. Specifically, the amount of the contribution deemed ineligible is equal to the percentage of the total tickets received by Bell Media for the event.   For example, if 15% of the total tickets available for the event were received by the licensee, then 15% of the total CCD contribution for that same event is deemed ineligible.

Below is a breakdown of the ineligible expenditures by initiative:

Initiative Contribution Deemed ineligible ($)
Canada Music Week - Fanfest 76,923
Breakthrough Canada Showcase Series 111,848
Total 188,771

As a result of these findings, the Commission directs Bell Media to pay the total shortfall of $188,771 within 30 days of the date of the letter, as follows:

In addition, the Commission directs Bell Media to file proof of payment for the total tangible benefit shortfall ($188,771), with the Commission, within 60 days of the date of this letter.

Further information on CCD contributions and eligible initiatives can be found on the CRTC website:

Lastly, it should be noted that the determinations set out in this letter address only the 2014-2015 broadcast year and do not relate to any subsequent broadcast years. 

Yours sincerely,

Claude Doucet
Secretary General

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