Broadcasting Commission Letter addressed to Daniel Bernhard (Friends of Canadian Broadcasting)

Ottawa, 28 January 2020

Daniel Bernhard
Executive Director, Friends of Canadian Broadcasting
200/238-131 Bloor Street West,
Toronto, ON
M5S 1R8

Re: Broadcasting Notice of Consultation CRTC 2019-379 – CBC/SRC License Renewals – Procedural Request for Further Disclosure

Dear Mr. Bernhard:

This letter is in response to the procedural request sent to the Commission on November 29, 2019, regarding the CBC/SRC licence renewal process announced in Broadcasting Notice of Consultation CRTC 2019-379 (the Notice).  The Commission’s determinations with respect to each of the requests raised in your letter are detailed herein.

Incremental funding from the government

Friends of Canadian Broadcasting (FRIENDS) is requesting that the Commission require CBC/SRC to submit a detailed assessment of the consequences of the government choosing not to renew or extend the additional funding that was accorded to CBC/SRC from 2016 to 2021. The Commission finds that the appropriate means by which FRIENDS may raise its concerns is through an intervention. CBC/SRC will then have an opportunity to formulate a reply. Accordingly, the Commission denies this request.

Strategic plan

FRIENDS takes the position that the CBC/SRC’s strategic plan is a summary only and requests that the Commission should require CBC/SRC to provide a full strategic plan without delay.

Commission staff has sent questions to the CBC/SRC in relation to its strategic plan. In response, the CBC/SRC has provided significant additional information on the public record of this proceeding. This information can be relied upon by any intervener in formulating its submissions. The Commission notes that other CBC/SRC financial information and corporate documents are available in the public domain and may be referenced by interveners in their submissions. In light of this, the Commission denies FRIENDS’ request for the disclosure of a full and complete three-year strategic plan.

Financial information

In its request, FRIENDS seeks to have the following financial information placed on the public record: aggregate expenditures from the incremental funding (historical and projected) for the five-year period 2016-17 through 2020-21, for CBC and SRC, by platform (TV, radio, digital), and genre (local programming, news, programs of national interest), and for 2021/22 to 2022/23, should the funding be extended.

Much of the additional financial information requested related to the CBC/SRC’s historical news and regional expenditures, CPE, PNI, and other related information is provided on the Commission’s website. This information may be referenced in interventions in this proceeding. Additionally, questioning by Commission staff related to many of these areas has already been placed on the public record of these proceedings, as have the responses from the CBC/SRC. 

After reviewing this information, if FRIENDS or any other prospective intervener is of the view that additional details are required or that the CBC/SRC’s responses require further clarification, they may make those views known in the context of their respective interventions.  Accordingly, the Commission denies this request.

Financial information regarding online services

Presently, only the aggregate expenses for all CBC/SRC owned and operated digital services have been made public on the record of this proceeding. FRIENDS has requested that the Corporation provide aggregate digital advertising revenues for a seven-year period (2016-17 through 2022-23) “as between audio and audio-visual digital platforms”.

When evaluating the confidentiality of information provided by a licensee in the context of a renewal, the Commission generally evaluates such requests by considering whether the information would be likely to result in specific direct harm and whether that harm outweighs the public interest in disclosure.

While the release of undertaking’s specific information could result in specific direct harm to that undertaking, the Commission is of the view that releasing total aggregate revenues (subscriber and advertising) for all CBC/SRC owned and operated audio and audio-visual online services is in the public interest in that it will help interveners have a more complete financial portrait of expenses and revenues, while limiting the potential for direct harm to the CBC/SRC

The Commission has today sent a letter to CBC/SRC requesting that it submit, by no later than February 4, 2020, total aggregate revenues (subscriber and advertising) for all CBC/SRC owned and operated audio and audio-visual online services. This information will be placed on the public record of these proceedings.

FRIENDS is welcome to intervene and express its views and concerns on this information as a part of its intervention.  The CBC/SRC will then be afforded the opportunity to respond to that intervention as a part of the normal procedure for this hearing. The Commission may then decide to examine these and other issues further at the hearing. The deadlines for interventions and replies are indicated in 2019-379-1.


Claude Doucet
Secretary General

c. c: Bev Kirshenblatt, Executive Director, Corporate and Regulatory Affairs, CBC/Radio-Canada,

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