Re: CRTC Broadcast Notice of Consultation 2010-551: Application #2009-1674-4

Sep 7, 2010

Application by Corus Audio & Advertising Services Ltd., for a broadcasting licence to operate a regional, English-language Category 2 specialty television programming undertaking to be known as LOCAL1

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

Dear Mr. Morin:

  1. Friends of Canadian Broadcasting is a watchdog for listeners and viewers supported by 100,000 Canadians. Friends does not seek to appear at this public hearing.
  2. In principle, Friends supports applications which increase and promote local programming content. Friends, therefore does not oppose this application but asks the Commission to consider carefully the following points regarding ownership, concentration of ownership and citizen participation as part of its deliberation.
  3. Corus, a company that is already one of the largest holders of radio and specialty television services in the country is under common ownership with Shaw Communications, the same company whose cable division would carry the proposed Local1 Category 2 service.
  4. It would appear from the Corus Supplementary Brief that Local1 will draw upon many news resources, including its own radio stations. We assume that by extension, these same stations will also be selling the Local1 service and wonder how that might impact the competitive balance in markets where other stations are selling simply radio.
  5. Of greater concern, however, is Shaw’s proposed ownership of the Global Television Network and the Canwest specialty stations which, if approved, would give Shaw direct or indirect control over:
    a. the second largest English private over-the-air television network in the country,
    b. the second largest radio revenues of any of the major ownership groups,
    c. premium specialty services which cumulatively dominate several key advertising demographic categories including kids and women,
    d. the largest cable company in western Canada and the second largest in the country, and
    e. the second largest DTH operation in Canada.
  6. In many of its cable systems, Shaw operates Community channels which are funded by the 2% of revenues which would otherwise be directed to the Canadian Media Fund. These Community channels are very important in each of their respective markets and, should the Commission choose to approve the Local1 application, then we believe that appropriate Conditions of Licence should be put in place to ensure that the Shaw community channels and the Local1 service remain separate and distinct.
  7. We also invite the Commission to question the applicant closely on how the proposed service would ensure a two-way flow of civic information, balancing the outgoing messages from politicians and civic leaders with input from constituents and citizens.

Yours sincerely

Ian Morrison
Friends of Canadian Broadcasting

cc: Corus Entertainment