Mr. Robert Morin
Secretary General
Canadian Radio‐television and Telecommunications Commission
Ottawa, ON
K1A 0N2

Dear Mr. Morin:

1.     In CRTC 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 Fredericton.

2.     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.

3.     In the 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.

4.     In response 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[1], 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).  

6.    

7.     The 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 Fredericton. ^[2] 

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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.

Yours sincerely,

Ian Morrison
Spokesperson

cc:             Canadian Broadcasting Corporation 

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[1] DM#1580418 - 2011-0276-4-CBC-SRC-General-EN

[2] DM#1580418 - 2011-0276-4-CBC-SRC-General-EN page 5

Related Documents:

CBC/Radio-Canada response to FRIENDS' submission to the CRTC on Application 2011-0966-1