Broadcasting - Commission Letter addressed to Catherine Carr (Trafalgar Broadcasting Limited)

Ottawa, 14 October 2021

Ms. Catherine Carr
Financial Controller
Trafalgar Broadcasting Limited
284 Church Street, 2nd Floor
Oakville, Ontario    L6J 7N2

Re: Audit of Trafalgar Broadcasting Limited’s (Trafalgar) Canadian content development contributions

Dear Ms. Carr:

As part of its annual audit of Canadian content development (CCD) contributions, the Commission recently reviewed Trafalgar’s contributions for the 2015-2016 broadcast year (BY). During this audit, Commission staff identified two potential problems with expenditures claimed towards meeting Trafalgar’s basic CCD requirements. 

This letter is to inform you that the Commission finds that certain expenditures made by Trafalgar during the current licence term, from the 2014-2015 broadcast year to the 2017-2018 broadcast year, were in non-compliance with the Commercial Radio Policy, 2006.

The Commission does not necessarily dispute the eligibility of any of the initiatives or CCD recipients below; rather, the non-compliance stems from an insufficient contribution to the Community Radio Fund of Canada (CRFC) and a contribution to a school for a non-eligible activity, specifically the sponsorship of the musical theatre department.  The Commission has been clear that all contributions to schools and educational institutions must benefit only music or journalism students Footnote1.

Below is a breakdown of the ineligible expenditures by initiative/CCD recipient:

Ineligible expenditures by initiative/CCD recipient
Initiative/CCD Recipient Issue Amount
1. CRFC During the current licence term, from the 2014-2015 BY to the 2017-2018 BY, CJMR contributed $987 to the CRFC, compared to the requirement of $2,775, resulting in a shortfall of $1,788. $1,788
2. Sheridan College In order for CCD payments to be eligible contributions to post-secondary schools, they must support students in music or journalism. The Music Theatre performance program of Sheridan College does not meet these requirements as it supports the creation of musical theatre performances which differs from both music and journalism. $10,135
Total $11,923

As a result of these findings, the Commission directs Trafalgar to pay the total shortfall of $11,923 within 30 days of the date of the letter, as follows:

The shortfall payment breakdown was proposed by Trafalgar and accepted by the Commission. In addition, the Commission directs Trafalgar to file proof of payment for the total shortfall ($11,923) 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:

The Commission notes that failure to supply sufficient documentation to support the eligibility of Trafalgar’s contributions for future broadcast years may result in the Commission finding those contributions ineligible and may affect the party’s compliance with regulatory obligations. 

Lastly, the Commission notes that the determinations set out in this letter address only the 2014-2015, 2015-2016, 2016-2017 and 2017-2018 broadcast years and do not relate to any subsequent broadcast years.

Yours sincerely,

Original signed by Lilia Trombetti

Claude Doucet
Secretary General

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