Call for comments on the public disclosure of aggregate financial data for owners of large broadcasting distribution undertakings, multi-system operators and conventional television and radio ownership groups

Mr. Robert A. Morin
Secretary General
Canadian Radio-television and
Telecommunications Commission
Ottawa, Ontario
K1A 0N2

Dear Mr. Morin:

Friends of Canadian Broadcasting is an independent watchdog for Canadian programming in the English-language audiovisual system, supported by 100,000 Canadians. FRIENDS thanks the Commission for the opportunity to comment on this important notice of consultation.

The ownership of Canadian broadcasting and broadcasting distribution entities has concentrated in recent years. Territorial monopolies or duopolies exist in cable and DTH while the ownership of Canada’s television and radio stations has become concentrated among a very small group of large companies. Given their market power combined with their shelter from competition afforded by the Broadcasting Act and your Commission’s regulatory framework, the public interest is best served by full and detailed public financial disclosure.

FRIENDS supports the Local Programming Improvement Fund (LPIF) and some form of fee-for-carriage for over-the-air television as a means of protecting and enhancing local and drama programming. Financial transparency is a necessary pre-cursor to public discussion and debate on such matters.

Therefore, FRIENDS fully supports the position articulated in paragraph 6 of the notice of consultation:

“The Commission’s policy objective with respect to the disclosure of financial information is to make available sufficient financial data from the large broadcast ownership groups so that the public can participate in the Commission’s public proceedings and decision-making processes in a better informed and more constructive manner. Submissions based on more complete disclosure will result in better and more informed Commission decisions and will ultimately benefit the Canadian broadcasting system.”

We note that the draft television financial disclosure form includes a breakdown for national, regional and local revenues, which on the public version are aggregated. FRIENDS recommends that revenues generated from Canadian programming also be disclosed so that the public can fully understand the funding gap which exists between the production costs of Canadian programming and the actual revenue generated.

While FRIENDS appreciates why the major broadcast and BDU groups might not wish to provide the financial information contained in the proposed public disclosure documents, we suggest that provided each group is treated equitably, then a material competitive advantage will not result.

The argument that a smaller competitor who would not be subject to disclosure would derive a benefit from the public disclosure of a larger competitor is a red herring which pales in comparison with the public benefit of disclosure.

Yours sincerely.

Ian Morrison
Spokesperson

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