As part of its advocacy work, FRIENDS of Canadian Broadcasting frequently makes submissions and presentations to the CRTC, Parliamentary Committees, and other bodies.
FRIENDS submits final comments to the CRTC on several subjects: CBC Television - Balanced Schedule, Programs of National Interest, and Regional Production; CBC Radio 2 and Espace musique - Commercial Messages; and CBC Television - NHL Hockey.
FRIENDS presents information concerning the BBC Trust model and its potential to address accountability issues at the Canadian Broadcasting Corporation.
FRIENDS presents information on projected revenues should the CRTC approve the CBC's proposal to introduce commercials on Radio Two and Espace Musique.
In a presentation to the CRTC, FRIENDS recommends that the broadcast regulator help CBC learn how to earn and deserve renewed public support – and then mobilize that support to advocate for resources to do its job.
FRIENDS supports the renewal of CBC's various licences subject to a number of comments, recommendations and proposed conditions.
Re: Broadcasting Notice of Consultation CRTC 2012-370: Applications 2012-0516-2, 2012-0573-2, 2012-0710-9, 2012-0736-6 and 2012-0735-8 (BCE Acquisition of Astral Media)
FRIENDS recommends that the CRTC consider adopting dispute resolution mechanisms and meaningful penalties to ensure that an acquisition of Astral Media does not allow BCE to take undue advantage of behaviour that would subsequently be judged in contravention of telecom rules.
Applications by the CBC to renew broadcasting licences for radio, television, and specialty television as per Broadcasting Notice of Consultation CRTC 2011-379-2 and your letter to the CBC dated 18 May 2012
FRIENDS recommends that as part of the CBC licence renewal process, the CRTC carefully examine the importance of hockey rights to the overall CBC English Television commercial revenue model.
FRIENDS says the CRTC should defer a decision on a CBC proposal to cut off free over-the-air TV service to large numbers of Canadians until the Corporation's network licences are reviewed.
FRIENDS encourages the CRTC to reject a CBC proposal to place ads on Radio 2 & Espace Musique and instead proceed with the long-delayed review of the overall licensing of the Corporation's networks and services.
FRIENDS recommends that the CRTC bend over backwards to defend and protect the position of smaller ownership groups in view of the undue influence of the largest players in the broadcasting system.
Presentation to the Standing Committee on Access to Information, Privacy and Ethics House of Commons
FRIENDS tells a Parliamentary committee looking into CBC's access to information policies that the root cause of the public broadcaster's disclosure avoidance is patronage appointments of its Board and President.
FRIENDS asks the CRTC for clarification on the closing date for comments on the CBC application for a Saint John transmitter.
Submission to the CRTC on CBC's proposal for a digital transmitter to serve Saint John New Brunswick.
Considering that all large broadcasters in Canada - except the CBC - are now controlled by distributors, FRIENDS recommends that the CRTC protect the interests of small independent players.
Final submission to the CRTC on the group-based licence renewals for English-language television groups.
In a presentation to the CRTC, FRIENDS says that proposed changes to station group licences would result in a reduction of approximately $90 million annually in Canadian programming spending.
In a presentation to the House of Commons Standing Committee on Canadian Heritage, FRIENDS says that implementing the Committee's recommendation of increasing the CBC's parliamentary grant to at least $40 per capita would be a good first step in addressing the funding gap for Canada's public broadcaster.
In a submission to the CRTC, FRIENDS comments on proposed regulation changes for "false or misleading" news coverage.
Re: Broadcasting Notice of Consultation CRTC 2010-952: Group-based licence renewals for English-language television groups
In a submission to the CRTC, FRIENDS says that proposed changes to station group licences would result in a reduction of approximately $90 million annually in Canadian programming spending.
Re: BN CRTC 2010-926: Application 2010-1506-6 Change of Effective Control of CTVgm’s Broadcasting Entities to BCE
FRIENDS supports the proposed change of effective control of CTVglobemedia's broadcasting assets to BCE, subject that the CRTC require BCE to revise the content of its public benefits proposal.
In a submission to the CRTC, FRIENDS supports the application by Bluepoint Investments to acquire the assets and control of Saskatchewan Communications Network Corporation (SCN).
FRIENDS supports a proposal that would see 0.5% of cable gross revenues directed towards the creation of a Community Access Media Fund to which independent non-profit community-run access channels could apply for support.
Re: CRTC Broadcast Notice of Consultation 2010-649: Application 2010-1188-2 [TVA Group Inc. on behalf of a general partnership to be constituted or a corporation to be incorporated]
FRIENDS opposes a request that would see Québecor's Sun TV receive mandatory access in its first three years of operation and offers several observations and suggestions for consideration by the CRTC.
Re: Broadcasting Regulatory Policy 2010-629 -- Criteria for assessing applications for mandatory distribution on the digital basic service
In a letter to the CRTC, FRIENDS says a proposed two-year moratorium on the consideration of any Category 1 broadcast applications would be highly prejudicial to the smaller, independent members of the broadcasting system.
FRIENDS comments on an application by Corus for a broadcasting licence to operate a regional specialty television channel.
Re: Broadcasting Notice of Consultation CRTC 2010-498: Shaw Communications acquisition of CanWest Global's Broadcasting entities
As part of Shaw's application to take over CanWest's broadcasting assets, FRIENDS recommends the CRTC ensure commitment to local programming and adequate public benefit consistent with commission policies.
FRIENDS says The Standing Committee on Finance should adopt the 2008 recommendation of the Canadian Heritage Committee to increase the CBC's per‐capita grant to $40 per annum.
In a submission to Industry Canada, FRIENDS says that in an integrated communications environment, changing the foreign ownership requirement for one sector - telecom - can be expected to cause a domino effect in the other sectors - such as broadcasting.
FRIENDS recommends that the Canadian Media Fund, and other federally-sponsored funds, be augmented by tapping into the huge profits of the four big cable monopolies, whose profit before interest and taxes in 2009 exceeded 25%.
FRIENDS tells parliamentarians that tinkering with foreign ownership rules in one part of the media and communications industry will place other parts, such as broadcasting, at risk.