Ms. Diane Rhéaume
Secretary General
CRTC
Ottawa, ON
K1A 0N2

Dear Ms. Rhéaume:

Re: Broadcasting Notice of Public Hearing CRTC 2006-1: Review of Commercial Radio Policy

1. Friends of Canadian Broadcasting thanks for Commission for the opportunity to comment in response to the above notice. Friends wishes to appear in order to offer the Commission a listeners' perspective on the issues raised in the Notice.

2. We endorse the objectives of this review, in particular the principle that a well-financed commercial radio sector should contribute according to its means to the fulfillment of the policy objectives of the Broadcasting Act, that it should make effective contributions to Canadian artists through airplay of Canadian music and Canadian talent development, and that it should provide listeners with greater diversity of musical genres and airplay for a greater variety of Canadian artists.

3. Our advice to the Commission is that it should not lose sight of repetitive evidence from the broadcast sector that regulation facilitates markets and is a necessary tool to ensure that the Act's objectives are attained. In this regard, the Canadian public, listeners and viewers, view your policies and procedures as a means to assure themselves of the quality and variety they expect from their public airwaves. Parliament has charged you with stewardship of the public interest in an environment where it is unreasonable to expect that commercial interests and the public interest will ever be completely aligned.

4. Friends believes that the Commission's current policies with respect to concentration of ownership in a given market, between formats therein, and in the overall Canadian marketplace are functional. You should beware of comments from vested interests seeking to persuade you to permit still further concentration.

5. According to Saint Luke, "those to whom much has been given, of them much is also expected".[1]  The profit data reflected in the Commission's recent annual reports suggest that you are dealing in the aggregate with a healthy industry, and one capable of making substantial contributions towards Parliament's goals on behalf of the listening audience as reflected in the Act.

6. With respect to Local Management and Sales Agreements, Friends' advice to the Commission is that such arrangements, which inherently reduce competition and diversity, should be employed only on an exceptional basis, and in those circumstances require substantive supervision to ensure that the parties respect their public obligations. We remind the Commission of our intervention in a northern Ontario market where our supporters detected abusive masquerading by two of the dominant industrial players in recent years.

7. The 1999 Policy's Canadian content regulations constitute a great success. Owing to turnover in your leadership, there may currently be no Commissioners who experienced directly the pressure from the CAB lobby when your Commission decided in 1999 to raise the bar for Canadian music. It was intense, repugnant and entirely without merit, as subsequent experience has demonstrated. We recommend mature skepticism to similar entreaties during the 2006 review process.

8. We also recommend that you raise the bar for category 2 popular music to 40% on a daily 6 am to 6 pm basis in the new policy, with at least one quarter of this minimum for new and emerging genres and artists.

9. Recent statistics on the aggregate health of the Canadian music industry suggest that this recommendation is desirable both from an industrial and a listener point of view.

10. Friends supports the logic of a 10% Canadian Talent Development benefit upon transfers (or changes) of ownership and control of radio licensees.

11. The commercial radio sector is a vital part of the communications infrastructure in communities across the land. The Commission should beware of any proposals to reduce the obligation of commercial radio stations to present substantial amounts of locally-produced news and information programming. This should apply to all stations, without exception.

12. If any changes are desirable, they should move in the direction of strengthening these obligations. Leaving this obligation to voluntary commitment is not warranted in view of the conflict of interest inherent where commercial radio undertakings seek to reduce local labour costs and import content from distant, often non-Canadian locations. This factor is of greatest concern in small and medium-sized markets, where fewer alternative sources of local news and information are available.

13. In the transition from analog to digital formats, the Commission should follow the principle that its prime duty is to ensure that the policy objectives of the Act prevail over technological considerations.

14. The Commission should articulate a policy on radio infomercials akin to those in its Television Policy. In considering representations from commercial radio interests, the Commission should bear in mind that only its Policy protects the listening public from abuse. If a licensee were to state that such regulation is neither necessary nor desirable, the question that must be answered is: "How could it ever be appropriate and in the listeners' interest for an infomercial to be broadcast without being clearly identified as paid commercial programming?"

15. The Commission's radio policy is a buttress for democratic participation and cultural sovereignty in a country with a relatively small population, sharing the North American continent with the United States of America. As Canada's economic relationship with the US draws closer, it becomes more important than ever to strengthen Canadian cultural sovereignty. This may be only an opinion, but it is one shared by 87% of Canadians.[2] Radio policy is an important component of this task. We wish the Commission well in addressing this challenge and look forward to contributing further to the process.

Yours sincerely,
 
Ian Morrison
Spokesperson
Friends of Canadian Broadcasting

Notes

1. Luke 12:48

2. In a survey of 1,100 Canadians conducted by Ipsos-Reid in May 2004 on Friends' behalf, 87% of Canadians agreed with the following statement: "As Canada's economic ties with the United States increase, it is becoming more important to strengthen Canadian culture and identity".