- Friends of Canadian Broadcasting is a watchdog
for listeners and viewers supported by 100,000 Canadians. Friends does not seek
to appear at the public hearing.
- Friends does not oppose Shaw's application to
acquire CanWest's broadcasting assets but wishes to offer the following
comments intended to assist the Commission in its deliberations and decision.
- The proposed transaction is the outcome of a competitive
process supervised by the courts.
- The applicant's suggestion that keeping
CanWest's broadcasting assets in Canadian hands should be considered a public
benefit is without merit. By law, only Canadian owned and controlled entities
can hold broadcasting licences.
- The value of CanWest Global's broadcasting
assets exceeds $2 billion. The financial difficulties of CanWest under its
former controlling shareholder resulted from factors entirely divorced from the
viability of CanWest's broadcasting licences.
- In the nine months ending May 31, 2010 operating
profit from CanWest's "Canadian television segment", which includes CanWest's
"television networks in Canada as well as TVtropolis and five other Canadian
specialty television channels" was $99 million, of which $47 million was earned
in the three months ending May 31. Operating profit from CW Media in the same
nine-month period was $169 million, of which $54 million was earned in the
three months ending May 31. 
- The content and extent of the public benefits
package proposed by Shaw Communications Inc. is completely inconsistent with
the Commission's public benefits policy.
- The Commission should consider appropriate conditions
to deal with the increased market power that Shaw would enjoy if this
transaction were to be approved, as well as the potential to adopt
anti-competitive behaviour, especially in view of the following facts.
- In Broadcasting Decision CRTC 2008-234, the
Commission reduced the term of Shaw Cablesystems Limited's licence from seven
to two years in view of evidence of an extensive and continuing pattern of Shaw's
disregard for broadcasting policies and regulations.
controlling shareholder is also the controlling shareholder of Corus
Entertainment Inc., which controls a substantial portfolio of broadcasting
licences in specialty television and radio.
in view of the critical importance of local programming in the Canadian
television system, and CanWest's important role therein, prior to approval of
this application, the Commission should obtain substantive commitments from the
applicant to ensure that this important public service is protected for
Canadian viewers going forward.
evidence that this intervention has been faxed to the applicant.
enc: fax transmittal sheet
 CanWest Global Communications
Corp. Interim Management's Discussion and Analysis for the Three Months and
Nine Months May 31, 2010 and 2009, July 14, 2010, pages 26/31ff. (Sedar)