Mr. Robert Morin
Canadian Radio‐television and Telecommunications Commission
Dear Mr. Morin:
2011-203 the Commission denied an application by the Canadian Broadcasting
Corporation to amend the English language conventional television licence for
CBAT-TV to establish a post-transition digital transmitter to serve
Under the existing
licence, CBAT-TV and CBAT-2 serve Fredericton, Saint John and Moncton - all of
which are mandatory markets under
the Commission's digital conversion over-the-air policy. The CBC's digital
application was turned down because it proposed to move the transmitter from
the existing Mount Champlain site to a location closer to Fredericton in such a
fashion that the transmitter would no longer serve both Fredericton and Saint
John, but only Fredericton. Under the denied proposal, service to Moncton (through
a repeater transmitter) would cease, but your decision did not comment on that aspect
of CBC's proposal.
current application, CBC proposes an analog transmitter at a cost of $75,000 to
be located at the existing Mount Champlain site with a signal pattern that
would be directed towards Saint John. Once again, the CBC failed to propose
over-the-air service of CBAT-TV to residents of Moncton.
to your Commission's request, the CBC also filed detailing costing to provide
digital service to both Fredericton and Saint John totalling $3,082,217.
5. In its English language television licence
renewal application, the CBC included the following
chart listing the estimated digital conversion costs in mandatory markets where
the CBC currently operates a re-broadcast transmitter only. As noted, the cost
of a digital transmitter in Saint John alone is projected at $7.27M (we assume
this amount would include both English and French transmitters).
CBC also provided costing for the digital conversion of their proposed 27
transmitters (English and French) in the mandatory markets where it operates a
station. Included in this list is a cost of $ 2.8M for an English transmitter in
10. From this application it would appear that
the CBC could establish digital transmitters in both Fredericton and Saint John
at a cost of $ 3.1M or a digital transmitter in Fredericton and a modified
analog transmitter for Saint John at a total cost approximating $ 2.9M.
11. CBC's proposal raises a number of questions
which we invite the Commission to examine when considering this application.
12. We note that the digital option which would
comply with the Commission's digital conversion policy is only $207,000 greater
than the combined digital/analog model. We also note that the digital costing
provided to the Commission includes $225,000 for a replacement generator at the
site as well as a $300,000 contingency which might further reduce the gap between
the two options.
13. If the listed costs (from the CBC renewal
application) for the English digital transmitter for Fredericton ($2,800,000) are
accurate, plus half of the stated cost of the English and French transmitters
for Saint John ($7,270,000/2= $3,635,000) this totals $6,435,000 to provide
English digital transmission to Fredericton and Saint John, not the $3,082,217
total cost estimated in this application. We urge the Commission to examine
this substantial divergence.
14. While there is no question that analog
service is preferable to no service, approval of any analog service would, at
best, only postpone the termination of this service in the foreseeable future, as
opposed to providing viewers in Saint John with an assurance that their new
digital CBC service would be secure going forward.
15. FRIENDS submits that if the Commission were
inclined to approve the CBC's analog proposal for Saint John, this approval
should be contingent on a long-term commitment to the channel by CBC and a
clear understanding from Industry Canada regarding the likely duration of availability
of the analog spectrum.
16. FRIENDS also recommends that if CBC is allowed
to deviate from the Commission's digital policy through the provision of an
analog solution at a cost of only $75,000, that continuance of the CBAT 2
transmitter currently serving Moncton should be part of the bargain.
*** End of Document ***
 DM#1580418 - 2011-0276-4-CBC-SRC-General-EN
 DM#1580418 - 2011-0276-4-CBC-SRC-General-EN page 5
CBC/Radio-Canada response to FRIENDS' submission to the CRTC on Application 2011-0966-1