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Canadian Content Development

21 February 2012

 

John Traversy Acting Secretary General CRTC Ottawa, ON K1A 0N2

Dear Mr. Traversy,

Re: Call for comments on proposed administrative changes relating to the Canadian content development policy for commercial radio, Broadcasting Notice of Consultation CRTC 2011‐796 (Ottawa, 20 December 2011)

The National Indigenous Media Association of Canada, a newly formed coalition of Indigenous broadcasters and telecommunications and internet service providers, welcomes the opportunity to submit the attached comments on and recommendations regarding the CRTC’s proposed administrative changes relating to its Canadian content development policy in .

NIMAC’s submission also includes its request that the CRTC launch a public review of its current ‘Native Broadcasting Policy’ that, but for minor changes in 2001, has not been publicly reviewed since it was issued in 1990.

NIMAC respectfully submits that fundamental changes to the broadcasting and telecommunications landscape since 1990, serious reductions in Indigenous radio stations’ financial capacity and weak growth in the number of Indigenous broadcasting services establish the importance of reviewing and revising the Commission’s policy for Indigenous communications in Canada.

If you have any questions or comments, we would be pleased to hear from you.

Sincerely yours,

Lewis Cardinal
780‐288‐0314
Interim President
lewiscardinal@gmail.com
National Indigenous Media Association of Canada

 

 

 

Strengthening Our Voices

Call for comments on proposed administrative changes relating to the Canadian content development policy for commercial radio, Broadcasting Notice of Consultation CRTC 2011‐796 (Ottawa, 20 December 2011)

by The National Indigenous Media Association of Canada

21 February 2012

 

 

 

i.  Executive Summary

  1. Context of this submission
            A Parliament’s recognition of Indigenous broadcasting
            B Challenges confronting the 22‐year old “native” broadcasting policy
    1 The problem of stunted growth
    2 The looming financial crisis
            C New framework needed to strengthen Indigenous media sector
  2. The CCD policy
            A CCD policy’s development ignored Indigenous broadcasting
    1 1970s to 1980s
    2 1990s
    3 2000s
            B 2012: Problems with the current approach
    1 “Other” CCD eligible initiatives receive little support
    2 FACTOR / MUSICACTION: less than 1% of funding to Indigenous music
    3 CCD not transparent
    4 CCD is unpredictable
    5 Delayed accountability
  3. Conclusions and recommendations
             A Conclusions
             B Recommendations about the CCD
             C Recommendations for a review of Canada’s policy for Indigenous broadcasting

 

Executive Summary

ES1        The National Media Association of Canada (NIMAC) represents Indigenous broadcasters who give voice to the diverse, complex and unique Indigenous cultures that have been part of Canada for centuries before Confederation. NIMAC’s radio members include the Siksika Communications Society and Aboriginal Voices Radio.

ES2       NIMAC welcomes the opportunity to submit its views about the CRTC’s proposals concerning Canadian Content Development in radio. We support the use of CCD funding to achieve Parliament’s objectives for the broadcasting system.

ES3       While Indigenous peoples’ rights were granted constitutional proection in 1982, Parliament first explicitly recognized Indigenous peoples in its broadcasting policy in 1991. Subsection 3(1)(d)(iii) of the 1991 Broadcasting Act sets out Parliament’s objective that Canada’s broadcasting system should take into account the special place of Indigenous peoples in Canadian society.

ES4       The CRTC’s 1990 Native Broadcasting Policy has never been reviewed through a public hearing and has been amended only once (in 2001, to remove restrictions on advertising for Type B ‘native’ radio stations and to increase their Canadian content levels).

ES5       The Policy’s ability to achieve Parliament’s objectives for Indigenous broadcasting is seriously compromised by the fundamental changes in the communications landscape, the roles of Indigenous peoples over the last twenty years, very limited growth in Indigenous broadcasting sectors and the grave financial circumstances of Indigenous radio broadcasters.

ES6       Since 2003, 122 commercial radio and 22 community radio stations have reported their launch; only four Indigenous type B radio stations have launched. Between 2001 and 2010, the average revenues per Native Type B radio station have decreased 47%, while the Indigenous radio sector’s share of total revenues in the radio system decreased from 0.69% in 2001, to 0.65% in 2010.

ES7       The CRTC has a commendable practice of reviewing its policies to ensure the health of the sectors it regulates. The time has come to assess the 1990 Policy to determine whether its objectives for Indigenous broadcasting have been achieved, whether these objectives remain appropriate, and what Indigenous peoples believe should be the objectives for policies concerning Indigenous broadcasting going forward.

ES8       Insofar as Canadian Content Development is concerned, NIMAC supports revisions to the policy for several reasons.

ES9       First, “other” eligible initiatives – the category in which ‘native’ radio services are classified – receive very little CCD funding. We note that 59% of the $249 million allocated to CCD in the last ten years has been directed to FACTOR and other music industry associations. Barely 6 cents of every CCD dollar flows to “other eligible initiatives”, and a review of 253 licensing decisions between mid‐2008 and 2012 found only 6 in which licensees expressly committed to allocate CCD funding to support Indigenous broadcasting. Non‐Indigenous CCD commitments received just over 99% of the $170.7 million in CCD funding identified in those 253 decisions.

ES10      Second, CCD initiatives such as FACTOR, while worthy because they support Canadian recording artists, also offer relatively little support to Indigenous radio artists. Since 2007 less than 1% of the $71.5 million granted by FACTOR to applicants has been approved for applicants in the “Aboriginal” music genre; “World” music genre applicants received three times more funding than applicants in the ‘Aboriginal’ genre.

ES11      Third, CCD commitments are not transparent, and cannot be easily monitored by third parties.

ES12      Fourth, CCD funding is unpredictable. Not only do funding levels vary depending on which stations are being purchased or renewed, but broadcasters that make CCD commitments can too easily change their minds about where they place their CCD funding.

ES13      Fifth, accountability in ensuring that CCD commitments are met are delayed until licence renewals.

ES14      NIMAC supports changes to the CCD program to support Indigenous radio broadcasting, and to make it more accountable, more transparent and more predictable.

ES15     In particular, NIMAC supports the creation of a Fund operated by and on behalf of Indigenous radio broadcasters, to support the strengthening of our sector of the broadcasting system.

ES16     To conclude, NIMAC respectfully requests that the CRTC undertake a thorough and public review of its policy for Indigenous broadcasting, to take into account substantial changes in broadcasting technology, the regulatory landscape and the extremely serious financial crisis confronting the majority of Indigenous radio broadcasters today.

 

I. Context of this submission

1        The National Indigenous Media Association of Canada (NIMAC) represents Indigenous broadcasters who use the tools and methods of contemporary communications media to give voice to the diverse, complex and unique Indigenous cultures that have been part of Canada since time immemorial.

2       The National Media Association of Canada (NIMAC) has been formed to permit a coalition of Indigenous broadcasters to express their views about regulatory and legislative issues that affect their businesses. NIMAC’s radio members include the Siksika Communications Society and Aboriginal Voices Radio.

3        We welcome this opportunity to submit comments about the CRTC’s Canadian Content Development (CCD) policy, given its essential role in supporting the ability to give voice to culture.

4        In the pages that follow we provide the historical context for this submission. We then set out our perspective on the CRTC’s current CCD approach, and set out our recommendations. We support the idea that CCD commitments should be allocated to funds whose purpose is to achieve Parliament’s objectives for the broadcasting system.

5        Specifically, NIMAC supports initiatives that will ensure the policy objective set out in subsection 3(1)(d)(iii) of the Broadcasting Act:

the Canadian broadcasting system should

through its programming and the employment opportunities arising out of its operations, serve the needs and interests, and reflect the circumstances and aspirations, of Canadian men, women and children, including … the special place of aboriginal peoples within that society

6        NIMAC also supports initiatives that will enable “programming that reflects the aboriginal cultures of Canada” to be “provided within the Canadian broadcasting system”, as provided for by subsection 3(1)(o) of the Act.

 

Parliament’s recognition of Indigenous broadcasting

7         The Canadian government has supported the development of broadcasting for more than a century, including an $80,000 federal grant to Marconi in 1901 to build a transatlantic radio station in the U’nama’kik Mi’kmaw region at Patalutik (Cape Breton, at Table Head) to make the world’s first wireless transmissions of sound across the Atlantic.

8        Since 1905 Parliament has defined Canada’s approach to broadcasting through its laws and regulations. Of the six statutes that have set the parameters for using the airwaves in this country for radio and television, however, only the most recent raises the notion that Indigenous people are entitled to participate in the broadcasting services that use these airwaves.

9        The shift from ignoring to acknowledging Indigenous peoples’ access to modern media is based in a thirty‐year‐old change in Canadian constitutional law. As the Task Force on Broadcasting Policy noted in 1986, “Native people have special rights by virtue of their Aboriginal status” which are “now enshrined in the Canadian Constitution [and] are a part of the laws, customs and treaties of the land”.1 1

10      The 1986 Task Force recommended that Canada’s broadcasting legislation “should affirm the right of native peoples to broadcasting services in Aboriginal languages where numbers warrant and to the extent public funds permit”, and that “a general policy of native broadcasting for the whole country” should be established.

11       In particular, the Task Force accepted that it was important not to subject Indigenous broadcasting “to the vagaries of departmental priorities, budget allocations and bureaucratic bottlenecks.”3 The Task Force therefore recommended that

Native‐language broadcasting should be administered at arm’s length from the federal government and should be provided with sufficient funds to cover the cost of all essential related activities such as training. Furthermore, until there are new administrative arrangements, {we recommend} that no further cutbacks be made to the [Northern Native Broadcast Access Program] and funding for production training.

12       Parliament heeded the Task Force Report to some degree. In re‐writing the Broadcasting Act in 1991, it acknowledged for the first time that Canada’s broadcasting system should reflect the special place of Indigenous peoples in Canadian society.

13       Specifically, Parliament said that programming reflecting Indigenous cultures in Canada should be provided in the broadcasting system “as resources become available for that purpose” – or more broadly in French, “au fur et à mesure de la disponibilité des moyens” [‘in line with the availability of resources’].

Table 1: 1991 broadcasting legislation

 

14        NIMAC respectfully submits that over the past twenty years Parliament’s commitment to making space for Indigenous voices in Canada’s broadcasting system has not been met in a way that places Indigenous broadcasters on a footing that is equal to that of other broadcasters.

 

 

B Challenges confronting the 22-year old “native” broadcasting policy

15        At the heart of our concerns with the 1990 Native Broadcasting Policy is that the communications landscape and the roles of the Indigenous peoples of Canada have both changed fundamentally over the last twenty‐two years.

16        We would be remiss if we did not acknowledge that the Commission was quick to respond to the new status of Indigenous peoples set out in the 1982 Constitution. The CRTC moved quickly to address the concerns of Indigenous peoples in Northern Canada about the intrusive, non‐Indigenous broadcasting that began to be more readily available around the same time. In 1985 the CRTC established a policy framework designed to improve the quality and quantity of access by Northern native broadcasters to the Canadian broadcasting system.5

17        Five years later the CRTC again considered the challenges facing Indigenous people, when it published a Native Broadcasting Policy to address Indigenous peoples across Canada.

18        The 1990 policy attempted to encapsulate Indigenous broadcasting within the CRTC’s existing categories of community‐based programming. The result was an uneasy fit: while the CRTC on the one hand encouraged “the participation by aboriginal people in all aspects of the broadcasting system, including the commercial sector,”7 on the other it restricted ‘native undertakings’ to the non‐profit sector. The Commission wrote that

The revised definition of native undertaking is as follows:

Native undertaking: This undertaking is characterized by its ownership, programming and target audience. It is owned and controlled by a non‐profit organization whose structure provides for board membership by the native population of the region served. Its programming can be in any native Canadian language or in either or both of the two official languages, but should be specifically oriented to the native population and reflect the interests and needs specific to the native audience it is licensed to serve. It has a distinct role in fostering the development of aboriginal cultures and, where possible, the preservation of ancestral languages.

19        The CRTC explained its position as one that flowed from historical reality, rather than as one that would strengthen Indigenous broadcasting or place Indigenous broadcasters on a footing equal to that of other broadcasters in the Canadian broadcasting system:

The above definition reflects the current reality in which native broadcasting undertakings are confined, for the most part, to non‐ profit operations reflecting, to a large degree, the existence of government funding and the fact that most native broadcasters are situated in remote areas unable to sustain viable commercial undertakings. Where native Canadians wish to apply for licences to operate commercial undertakings, they will be required to meet the same obligations and expectations as other commercial broadcasters.

20       We also note that the CRTC decided not to restrict the programming offered by Indigenous broadcasters, but to rely on these broadcasters to govern themselves:

The Commission recognizes that, subject to broad CRTC objectives and to statutory requirements, it is the aboriginal broadcasters themselves who are best qualified to determine and meet the needs of their audiences.

21        Since issuing its 1990 policy on Indigenous broadcasting, however, a complete public review of its achievements has not been undertaken by the CRTC.

22        In NIMAC’s view, the time has come to assess the 1990 policy, to determine whether it has achieved its objectives, whether its objectives continue to be appropriate, and whether Indigenous peoples have different views about and proposals for the broadcasting services they enjoy, operate or want to operate.

1 The problem of stunted growth

23        Unfortunately, so little is know about the Indigenous radio sector that even the basic measures used to evaluate private broadcasters – such as the number and location of Indigenous broadcasting services in operation, their revenues, their expenses, or the number of people they employ – are not readily available from CRTC reports.

Table 2: Indigenous broadcasters by province, 2012

24       We estimate that approximately 57 Indigenous broadcasters in Canada operate 65 radio, television or distribution undertakings, but this figure includes several ‘type A’ Indigenous radio broadcasters that are not required to hold a broadcasting licence.

25       Given that this submission relates to the CCD policy for radio, we reviewed the available information about Indigenous radio services. Little is known about Indigenous radio broadcasters, however, in part because of shifting numbers in published information. For example, while the CRTC’s 2008 Communications Monitoring Report said there were 30 ‘native Type B’ radio stations in 2007, the CRTC’s 2011 Report says there were 28 in 2007. According to the Commission’s most recent data, 24 ‘native Type B’ radio stations were in operation in 2010.

26       Since 2003, 122 private commercial radio stations, and 22 community radio stations have launched. Over the same period, 4 Indigenous type B radio stations have launched.

27       NIMAC considers that the key reason why so few new Indigenous services are launching in larger urban centres is that they have little access to the financial resources needed to launch and operate professional broadcasting services.

28       As for existing Indigenous radio services, it is our submission that even with changes to the CCD policy introduced six years ago, our sector is facing a financial crisis.

2 The looming financial crisis

29       In 1990 the CRTC said that

… it is essential that aboriginal broadcasters receive sufficient funds to enable them to fulfill their responsibilities. Furthermore, native broadcasters should be mindful of the inherent pressures exerted on their programming and resources by the adoption of a commercial orientation.

30      The available evidence demonstrates that Indigenous radio stations lack the funds needed to fulfill our responsibilities, and that they are being forced inexorably to consider the very commercial orientation the CRTC directed Indigenous broadcasters to avoid.

31        For example, in its 872‐page review of Canada’s broadcasting system in 2003, the House of Commons Heritage Committee urged the CRTC to address the pressing needs of Indigenous radio. After quoting from numerous witnesses whose testimony described financial problems, the Committee wrote of its concern

… that the situation is much worse than witnesses indicated. For example, 11 of 96 community sites are now off the air and the actual cost of maintenance and equipment replacement is approximately $ 1 million more per year than available federal funds support. The Committee is gravely concerned by this information and believes that there is a pressing need to address this situation as soon as possible.

32      Reviewing the statistics published by the CRTC shows that since the 2003 report by the Heritage Committee, revenues in the Indigenous radio sector have continued to grow far more slowly than for other types of radio stations. From 2001 to 2010 commercial, community and campus radio stations’ revenues grew in real terms by 22%, 28% and 74%, respectively, while total revenues for all ‘native Type B’ radio stations rose by only 16% (see Figure 1).

Figure 1 : Radio stations’ change in revenues from 2001 to 2010 

33       Measured per station, revenues per station of ‘native Type B’ broadcasters decreased by 47% between 2001 and 2010, a substantially larger drop than for all other types of radio stations.

34       Where a commercial radio station operates with average revenues of just over $2 million, Indigenous radio stations must operate with $370 thousand (Table 3).

Table 3: Average revenues per station, 2001 to 2010

35       In fact, overall, Indigenous radio broadcasters’ share of total radio revenues (excluding the CBC) has been shrinking, not growing. As Table 4 and Figure 2 show, ‘native Type B’ radio stations’ share of the system’s radio revenues (excluding CBC) was tiny in 2001 (0.69%), tinier still by 2010 (to 0.65%).

36       By comparison Indigenous people made up almost 4% (3.8%) of Canada’s population in 2006.9

Table 4: Share of radio revenues, 2001 and 2010

Figure 2: Total revenues in Canadian radio, 2001‐2010

 

37       We do not believe the CRTC ever intended that Indigenous radio stations should slowly wither due to lack of funding. We believe the CRTC wants every sector in the broadcasting system to prosper on a sound financial footing so that audiences in Canada can enjoy high‐quality programming.

38       In revising its 1998 commercial radio policy in 2006, for example, the CRTC’s first objective was to create conditions for

A strong, well‐financed commercial radio sector in both official languages capable of contributing to the fulfillment of the policy objectives set out in the Broadcasting Act 10

39       We note that in the case of local over‐the‐air television, the Commission commented in 2008 that

In the Commission’s view, it is in the public interest for the Canadian broadcasting system to include healthy local stations that will enrich the diversity of information and editorial points of view.11

40       NIMAC respectfully submits that the health of Indigenous broadcasters is as important as the health of any other component of the broadcasting system. In fact, we submit that to some extent the health of Canada’s Indigenous broadcasters should be of even greater concern, given its absence from most discussions about Canadian broadcasting policy since the early 1900s. This absence effectively meant that all revenues derived in the radio system from the 1920s through to the mid‐1980s, accrued to non‐Indigenous broadcasters. From 1956 to 2010, for example, we estimate that private radio broadcasters earned just over $30 billion from Canada’s broadcasting system, compared to $135 million over the last fourteen years:

41      Respectfully, the current financial situation of Canada’s Indigenous radio broadcasters cannot be allowed to continue. Without a new approach to Indigenous broadcasting, Indigenous broadcasting cannot survive, let alone thrive.

42      Unless our broadcasting services are strengthened, the capacity of Canada’s Indigenous peoples to hear and have their voices heard, will slowly strangle. Based on current trends, Indigenous voices in contemporary broadcasting will gradually, but surely, be stilled.

43       NIMAC is therefore asking the CRTC to review and revise its approach to Indigenous media regulation in Canada, to ensure that ‘Native Type B’ radio stations are accorded commensurate financial resource and equal opportunities to grow as full members of Canada’s broadcasting system.

 

C New framework needed to strengthen Indigenous media sector

44       Parliament gave the CRTC the capacity to develop and implement policies and regulations to strengthen the broadcasting system in Canada. The CRTC regularly develops and modifies its policies and regulations in light of changes in the broadcasting environment.12

45       The CRTC has explained that it reviews its policies because “Strong Canadian radio and recording industries are essential if citizens are to have access to a variety of Canadian services providing high quality Canadian music and other programming that reflects both their communities and their country in this more competitive environment.”

46       Over the last forty years the CRTC has held at least 24 consultations and 6 public hearings to discuss regulatory issues involving commercial or non‐ commercial radio, and has issued at least 30 separate radio policies to address the challenges facing stations in those sectors.

47       By comparison the CRTC has introduced 4 policies to address Indigenous radio since 1968. The first, dealing with Indigenous broadcasting in the North, was issued in 1985. The second, in 1990, addressed Indigenous broadcasting in the South.14 In 1998 the third policy exempted some Indigenous radio stations from regulation,15 while in 2001 the fourth dropped advertising limits and raised Canadian content levels for non‐exempted Indigenous radio stations.

48       In the last 44 years the CRTC has not held a public hearing focussed squarely on Indigenous broadcasting policy for radio and/or television.

Table 5 CRTC’s approach to commercial, non‐commercial and Indigenous radio policies


 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

49       Compared to its treatment of commercial and non‐commercial broadcasting, Canada’s regulatory approach to Indigenous broadcasting in Canada could be described as a pattern of neglect. For example, the CRTC does not include Indigenous broadcasting in the annual Statistical and Financial Summaries it publishes separately for both radio and television. The old expression, ‘out of sight, out of mind’, seems à propos.

50       Our concern is that in devising or revising important policies with the potential to benefit different stakeholders in the broadcasting system, such as the radio policy for CCD, the current pattern of neglect enables fundamental challenges confronting Indigenous broadcasters to be ignored.

51        We are therefore calling on the CRTC in this submission to begin to take the steps needed to strengthen the capacity of Indigenous media stakeholders to participate in Canada’s broadcasting system.

52       In Part II we offer our views on the CRTC’s current approach to CCD. We demonstrate how and explain why the current CCD policy has not yielded the benefits expected for Indigenous broadcasting.

53       Part III sets out our conclusions about the current CCD policy and our recommendations for change, along with recommendations on how the CRTC could and should begin {to} address Indigenous broadcasting issues.

 

II The CCD policy

 

A CCD policy’s development ignored Indigenous broadcasting

54       The CRTC’s current approach to CCD emerged from its long‐standing goal of supporting local talent, but did not apply it to promote the growth of Indigenous radio for more than twenty years.

1 1970s to 1980s

55        In the 1970s and 1980s the Commission encouraged radio broadcasters’ decisions to hold local radio talent competitions and support the production of domestic recordings. Three private broadcasters and two recording industry associations created a private non‐profit body that could generate funding for such initiatives:

The Foundation Assisting Canadian Talent on Recordings, was founded in 1982 by CHUM Limited, Moffat Communications and Rogers Broadcasting Limited, in conjunction with the Canadian Independent Record Producers Association (CIRPA) and the Canadian Music Publishers Association (CMPA).17

56      FACTOR explains that it “was founded to develop musical works for radio play so all Canadians could hear them.”18 FACTOR was also created to assist the Canadian independent recording industry.

57      In approving FACTOR as a vehicle for promoting Canadian talent, it is not clear whether the CRTC specifically requested it to support the Indigenous media sector.

 

2 1990s

58      By 1990 the CRTC was reviewing its approach to developing talent in Canadian radio,19 and was considering the creation of a standard formula for supporting Canadian talent development initiatives.20

59      The CRTC’s 1990 review of Canadian Talent development offered examples of relevant direct and indirect initiatives, mentioning industry organizations founded by the private sector, such as MusicAction and FACTOR. The CRTC did not refer to Indigenous stakeholders in the broadcasting system or radio sector.

60      In early 1995 the CRTC held private consultations with parties that had written briefs to the Commission about its 1992 review of its radio policies and regulations,21 and then proposed a new, streamlined approach to developing Canadian talent. The Commission explained that it is in broadcasters’ “interest to take an active role in this process to ensure that there is a sufficiently large pool of Canadian recorded music as well as other types of Canadian creative material available for broadcast”.22 The CRTC also explained the importance of ensuring that transfers in ownership “yield significant and unequivocal benefits” to Canada’s broadcasting.

61       Late in 1995 the CRTC issued a new approach to fund Canadian talent development, with money directed annually to eligible third‐party initiatives related to Canadian talent development, and reported by broadcasters in their annual return forms. The eligible third parties again included industry‐ created organizations such as FACTOR and MusicAction, but now also included national and provincial music organizations, performing arts groups, schools and scholarship recipients.

62       The 1995 CTD policy did not address the support of Indigenous broadcasting, Indigenous radio or Indigenous content, however.

63       In 1998 the CRTC revised its approach to ownership transactions, to direct 6% of the value of transactions involving transfers of ownership and control to Canadian talent development initiatives. It also approved the creation of the Radio Starmaker Fund and Fonds RadioStar to support established artists’ marketing and promotion. but said that this 6% amount should be allocated as follows:

50% to Radio Starmaker/Fonds RadioStar (3% of the 6%)

33% to FACTOR or MusicAction (2% of the 6%); and

17% to other initiatives that could develop Canadian musical and other artistic talent (1% of the 6%)

64       The 1998 policy did not refer to Indigenous stakeholders in Canadian broadcasting.

 

3 2000s

65       It was not until 2006 that the CRTC included Indigenous broadcasters as potential beneficiaries of funding to support the development of Canadian talent. By this time the CRTC’s CTD approach had generated $2.83 million from commercial radio renewal applications.24

66       The CRTC noted the success of programs run by FACTOR and MusicAction that had “resulted in the emergence of many well‐known Canadian artists”, and set out five new groups it now viewed as eligible recipients for funding to support Canadian content:

National, provincial, and territorial music industry associations (MIAs).

Schools and educational institutions that are accredited by provincial authorities. Such contributions must specifically benefit students of music and journalism, including scholarships and the purchase of musical instruments.

Initiatives, including talent contests, for the production and promotion of local music and local musical artists, particularly emerging artists.

Independent parties dedicated to producing new spoken word content that would otherwise not be produced for broadcast.

Audio content initiatives that would further advance the fulfilment of specific objectives of the Canadian broadcasting system as outlined in the Act such as a community radio fund, Native radio and other specialized audio broadcasting services dedicated to serving the particular needs and interests of children, Aboriginal peoples, and persons with disabilities.

67       The CRTC divided commercial radio stations into three groups based on their annual revenues, and set out required CCD support levels expected from eachgroup.

68      The CRTC estimated that its new approach would yield 45% more funding than the old one: $2.83 million under the old, vs $4.1 million under the new, approach.

69      Emphasizing the necessity “to ensure continuity of assured funding” the CRTC mandated that 60% of the basic annual CCD funds be directed to FACTOR or MusicAction. It also said that distributing funds “in all of Canada’s regions is of critical importance”, and expected “FACTOR and MUSICACTION” will continue their efforts to develop talent in all regions of Canada, in all popular music genres.”

70       In addition to annual CCD funding, the CRTC explained that when parties apply for new radio licences, they often make additional commitments to CCD. In 2004‐05 fulfilling these new‐station commitments amounted to $5.8 million.29 Going forward the CRTC permitted new radio broadcasters to direct up to 80% of these commitments to eligible CCD initiatives of their choice, with the rest going to FACTOR / MusicAction.30

71        The CRTC said it was up to broadcasters to contact third parties “to establish payment schedules that are convenient to all parties”, and said that all CCD commitments had to be paid in full by the end of each broadcast year. 31

72        Finally, the CRTC retained its existing policy of requiring buyers of existing radio stations to allocate 6% of the stations’ value to CCD.

 

B 2012: Problems with the current approach

73        Broadcasting Notice of Consultation 2011‐796 invites comments about the CRTC’s approach to CCD because of problems it has with broadcasters who re offering ineligible initiatives as CCD recipients, and because broadcasters often submit incorrect information about the CCD projects they have funded.32

74        From our perspective, there are other problems with the CRTC’s approach to CCD.

 

1 “Other” CCD eligible initiatives receive little support

75        Perhaps the most important problem for Indigenous broadcasters is that very little CCD money has been designated towards Indigenous broadcasting.

76        Over the last decade radio‐related applications approved by the CRTC have yielded almost a quarter of a billion dollars ($249 million) to support Canadian content development.

77 But most of the money is being directed to commercial industry or industry‐ organized bodies. Over the last decade, 59% of total CCD funding has been directed to FACTOR, MUSICACTION, music industry associations and Star Marker Fund/Fonds Radio Star:

 

78        Barely 6 cents of every CCD dollar has been allocated to the “other eligible initiatives” category in which ‘contributions’ to Indigenous broadcasters are designated.

Table 6: CCD funding for “other eligible intiatives”, 2001‐2010

79         The CRTC has not published the amount of money actually being directed to support Indigenous broadcasting. When we reviewed 253 licensing decisions from mid‐2008 to 2012, we found only 6 (six) that explicitly targeted CCD support for Indigenous broadcasting, amounting to $1.05 million out of a total $170.7 million in CCD funding, or 0.62% of the total. In effect, it seems that non‐Indigenous CCD initiatives receive just over 99 cents of every CCD dollar.

80        Radio broadcasters’ lack of interest in targeting Indigenous broadcasters for CCD funding could stem in part from the CRTC’s own description of parties eligible for CCD support. The CRTC’s list literally places ‘native’ broadcasters at the very bottom: see Appendix 2.

81         But the low level of CCD funding directed to Indigenous broadcasters is also low because it is easier and entirely permissible for broadcasters very simply to direct all of their CCD funding to the largest CCD recipients. In 2009, for example, Northwoods directed 100% of its basic annual CCD contribution for CKTG‐FM and CJUK‐FM to FACTOR.33

82         NIMAC respectfully submits that achieving Parliament’s objectives for broadcasting cannot be achieved if the stakeholders such as Indigenous broadcasters receive the least amount of support to develop in the Canadian broadcasting system.

83         Achieving Parliament’s objective of making space {for} Indigenous broadcasting cannot happen if Indigenous broadcasters must constantly interrupt their business to visit their peers, hat in hand so to speak, to solicit money in the hopes of scraping by for another year.

84        Better alternatives exist. The CRTC has approved the creation of several types of funds to support radio and TV stations:

  •  The Local Programming Improvement Fund was established at the CRTC’s 2008 behest, is funded from 1.5% of BDU revenues, and now distributes more than $100 million annually to just over seventy private and public commercial television stations
  • The Small Market Local Programming Fund was established in 2003, is funded from 0.4% of DTH gross revenues, and now distributes more than $10 million annually to 17 independently owned small market private commercial television stations
  • The Community Radio Fund of Canada was established in 2008, is now funded by 15% of the CCD allocations made by commercial radio stations making more than $1.25 million/year, and offers support to roughly 80 community radio stations

85       NIMAC recommends that the CRTC use the approach it has employed for the LPIF, SMLF, and CRFC so that a new Fund can be created to strengthen Indigenous radio broadcasting in Canada.

 

2 FACTOR / MUSICACTION: less than 1% of funding to Indigenous music

86        A second problem is that existing private sector mechanisms offer erratic and insufficient support to Indigenous radio artists. “Aboriginal” applicants to FACTOR, for example, receive very little of the $15 million it has granted annually for the past several years.

87        As Table 7 shows, less than 1% of the $71.5 million granted by FACTOR since 2007 to help develop Canadian content has been approved for applicants in the ‘Aboriginal’ music genre. “World” music genre applicants have actually received roughly three times as much funding as applicants for the ‘Aboriginal’ music genre.

Table 7: FACTOR funding for indigenous applicants, 2007‐2011

88         Indigenous people’s representation on FACTOR’s juries is also low. Of 236 FACTOR juries comprised of 530 music and broadcasting professionals “across the country”, four (4) are “Aboriginal”.34

89         The past forty years have amply demonstrated that Indigenous and non‐ Indigenous peoples in Canada need all the financial support possible to ensure that the artists, story‐tellers and cultures in this country have access to and space on its airwaves. FACTOR and the other professional industries have played a role in providing financial support to Canadian artists.

90          In our view, however, the business model for professional recording industries in Canada has changed so that professional recording and publishing industries no longer require financial subsidies from the commercial radio stations that play their music. In the most recent year for which statistics are available, the profit margins of Canada’s sound and recording music businesses ranged from 10.3% to 23.1% (see Table 8).

Table 8: Operating revenues and profit margins of Canada’s sound recording and music publishing businesses, 2005 to 2009

91         As Canada’s recording industry is reasonably healthy, we think it is reasonable to question whether it is appropriate to divert more than half of the $250 million allocated to Canadian content development, to this industry (Figure 3).

Figure 3: CCD funding, 2001‐2010

92        NIMAC recommends that the CRTC direct CCD and other financial support to Indigenous broadcasting using the mechanism of a specialized, independent radio fund operated by, and on behalf of, Indigenous broadcasters in Canada.

93        A third important problem for Indigenous broadcasters is that the CRTC’s current CCD approach is not transparent. Lack of clarity in CRTC licensing decisions makes it difficult to support, challenge or monitor CCD support for Indigenous media.

94        For example, in 2008 the CRTC recognized Harvard Broadcasting’s plans to allocate $982 thousand over the next seven years to promote and develop Canadian content: the CRTC noted that 20% of this amount would be directed to FACTOR, but did not describe where the other three‐quarters of a million dollars would be directed.35

95       When we reviewed CRTC decisions related to CCD, we found that many offered insufficient or no detail at all about private broadcasters’ discretionary decisions to direct millions of dollars to support Canadian content. This makes it impossible to

  • predict the direction of Canadian content development in Canada
  • determine how broadcasters are allocating CCD funding
  • measure the impact of the CCD’s policy in supporting Canadian talent, or to
  • understand the financial crisis now affecting Indigenous radio.

96        At times, broadcasters that had not met their CCD commitments even filed their plans to become compliant, in confidence.

97        NIMAC recommends that the CRTC ensure that its decisions with respect to CCD funding offer precise details to permit the CRTC, broadcasters and CCD recipients to fully understand and monitor CCD funding in Canada.

98       Another problem of the CRTC’s current CCD approach is that it is entirely unpredictable.

99       Predictability matters in business, and the CRTC has often recognized the importance of certainty to broadcasters. In approving the Sirius‐CSR merger, for example, the Commission noted that it has

… stressed consistency in the way that it assesses elements relevant to control in fact, providing certainty to the industry and establishing clear precedents that can be helpful to licensees and other stakeholders. ….

100    In our experience, the stakeholders who rely on CCD funding have not benefitted from any similar commitment to certainty and predictability.

101     For example, in August 2008 the CRTC granted Astral Media a radio licence to serve the Ottawa/Gatineau area.37 Astral committed $5.87 million to Canadian talent development during the seven years of its new station’s operation, including just over half a million dollars to support Canada’s largest Indigenous radio broadcaster (Aboriginal Voices Radio).

102     After the Federal Cabinet ordered the CRTC to reconsider its 2008 decision, the CRTC held a second hearing beginning March 31, 2009, announced in Broadcasting Notice of Consultation 2009‐2:

103        None of the 48 documents posted regarding Astral’s 2009 application for the same radio station mentioned Canadian content development.

104        It was not until after the public hearing on June 26, 2009, that Astral advised the CRTC “that it wanted to amend its over‐and‐above CCD contributions. Specifically, Astral indicated in the letter that, if RCFO [Radio de la communauté francophone d’Ottawa] agreed to use frequency 94.5 MHz, it intends to reallocate to RCFO the CCD commitment of $504,460 over seven years that it had originally earmarked to support Aboriginal Voices Radio (AVR).”38

105       According to the CRTC, it accepted Astral’s CCD amendment because AVR had returned three of its licences due to inadequate financial capacity and the CRTC inferred that this reduced “AVR’s financial needs”. Since this change took place after the CRTC’s hearing, however, and AVR had no opportunity to challenge the CRTC’s conclusion, the evidence on which the CRTC relied to draw its inference is not known, and could not be questioned.39

106       Unexpected changes such as these eliminate the ability of those relying on CCD funding to plan the development of their businesses.

107       Worse, the experience of Canada’s Indigenous peoples is that all too often governments believe they are better placed to make critical decisions, than those who are most directly affected by those decisions. Adding insult to injury, having made arbitrary decisions without consultation that harm Indigenous peoples, governments subsequent lay blame for arbitrary decisions’ negative outcomes on the people who were left out of the decision‐ making process.

108       CRTC decisions often heighten uncertainty in CCD allocations, by noting commitments but not specifying them through conditions of licence. For example, in 2008 CKKW Kitchener applied to convert to the FM band. In its decision approving the transition, the CRTC noted

… that CTV made a commitment to exceed the minimum contribution to CCD. Specifically, CTV indicated that, in addition to the required basic annual contributions, it will, by condition of licence, make an additional annual contribution of $42,000 in each of the first seven years of operation. CTV proposed to direct $8,400 of this over and above amount to FACTOR, and the remainder, $33,600, to eligible initiatives as follows: $25,600 per year to the Waterloo Region District School Board and $8,000 per year to the Waterloo Catholic District School Board, for the purchase of new instruments and sheet music. 40

109 The CRTC did not, however, attach these conditions to CKKW’s licence, but referred vaguely to other “parties and initiatives fulfilling the definition of eligible initiatives”:

Conditions of licence …

4. In addition to the basic annual Canadian content development contribution, set out in section 15 of the Radio Regulations, 1986, as amended by Regulations Amending the Radio Regulations, 1986, SOR/2008‐177, 28 May 2008, announced in Amendments to the Radio Regulations, 1986 ‐ Implementation of the Commercial Radio Policy 2006 and the Digital Radio Policy ‐ Regulatory policy, Broadcasting Public Notice CRTC 2008‐67, 23 July 2008, the licensee shall, upon commencement of operations, contribute $42,000 annually to the promotion and development of Canadian content.

Of this amount, $8,400 shall be devoted to FACTOR or MUSICACTION. The remainder, $33,600, shall be allocated to parties and initiatives fulfilling the definition of eligible initiatives set out in Commercial Radio Policy 2006, Broadcasting Public Notice CRTC 2006‐158, 15 December 2006.

110     Again, if Indigenous stakeholders were counting on such CCD amounts for their operations, a broadcaster’s decision to alter its commitments because they were not set by condition of licence would eliminate the stakeholders’ ability to plan in a businesslike manner would be eliminated.

111      We therefore recommend that specific commitments to CCD be set as conditions of licence for broadcasters.

112      Including CCD commitments as conditions of licence would ensure that the public has an opportunity to become aware of and comment on subsequent proposals to change their CCD plans.

 

5 Delayed accountability

113       Even if the CRTC’s decisions clearly spelled out the details of CCD funding for Indigenous broadcasting, the only mechanism to address a broadcaster’s failure to make required payments in full and on time is currently the CRTC’s licence renewal process.

114      The licences of individual undertakings may last for up to seven years. It is unreasonable to require those who rely on CCD funding to wait for up to seven years to know whether they will receive the promised funds.

115      We note the example provided in 2009, in which the CRTC considered the performance of a station it had licensed in 2001 and which launched in 2003. It noted that required CTD payments totalling $785 thousand were not made on time in 2003 and 2005, including a $397 thousand commitment to an Indigenous broadcaster. 41

116     There are many other examples. In 2009, the CRTC noted the following concerns regarding CJLL‐FM’s CCD expenditures:

  • the contributions to Canadian Music Week were incomplete in 2004, 2006 and 2007
  • no contributions were made to FACTOR in 2004, 2005, 2006 and 2007
  • no contributions were made to the CHIN (Ottawa) Multicultural Music and Song Competition and the CHIN (Ottawa) Multilingual Music Initiative in 2004, 2005 and 2006
  • no contributions were made to scholarships for students at Carleton University and the University of Ottawa in 2004 and 2006;
  • no contributions were made to the CAEB catalogue of ethnic recordings in 2006
  • no contributions were made to assisting ethnic program development and the training of ethnic broadcasters at CKCU‐ FM and CHUO‐FM in 2004, 2005, 2006 and 2007, and
  • in several instances, shortfall payments from one year were deferred to the following broadcast year.

117      Stakeholders besides NIMAC have recommended more transparency. In 2010, for example, the CRTC noted ADISQ’s comment that

… that it was unfortunately unable to obtain all of the information required to ascertain whether the stations had met their obligations with respect to contributions to Canadian content development (CCD) during their previous licence term. According to ADISQ, the music industry must have access to not only the licensees’ CCD contributions statement, but also to the details of the contributions made to the various recipients to ensure that broadcasters fulfil their commitments and that MUSICACTION receives its fair share of contributions.

118     It is unreasonable to expect small, inadequately resourced Indigenous broadcasters and other stakeholders to monitor each and every one of the hundreds of CRTC licensing decisions that refer to CCD. We do not think that Parliament intended that Indigenous broadcasters should have to ask their peers for money, or that Indigenous broadcasters would have to enforce other broadcasters’ commitments to the CRTC.

119      We therefore recommend that the CRTC implement an online tracking system to enable parties designated as receiving CCD to monitor actual CCD expenditures, on a semi‐annual (November and June) basis. To the extent that broadcasters require confidentiality about the CCD amounts distributed by their individual radio stations, NIMAC recommends that such information be posted by broadcast group, not by individual stations.

120      The system we are proposing would reduce the CRTC’s workload in that it would enable CCD recipients to monitor funding being allocated to them more easily. It would also provide more transparency about the ways in which Canadian content development is being supported in Canada.

 

III Conclusions and recommendations

 

A Conclusions

121       NIMAC’s review of the CRTC’s approach to supporting the development of Canadian content leads us to conclude that the approach should be changed. While the Commission hoped in 2006 that CCD would provide more funding to Indigenous radio broadcasters, Indigenous radio broadcasting finances have not been strengthened by the change.

122       In addition, serious problems make it impossible to know what projects are being supported how much funding is being directed to specific projects and whether projects are achieving their goal, of developing new, original and exciting Canadian content.

123       Giving private broadcasters discretion about where to allocate much of their CCD funding has also had the unintended effect of creating a second regulatory‐like tier in the broadcasting system: now, in addition to applying to the broadcast regulator for permission to launch a broadcasting service, Indigenous applicants must presumably also solicit private broadcasters’ permission to proceed, through the CCD process. This is an ignominious position in which to be placed.

124       In brief, the CRTC should redesign its CCD policy to maximize accountability, transparency and predictability.

 

B Recommendations about the CCD

125       The recommendations we have made in the course of this submission are summarized below. NIMAC recommends that

  1.  the CRTC adapt the approach it has developed for community radio, to require that a specific amount of CCD funding be allocated to support Indigenous radio broadcasting
  2. the CRTC target support of Indigenous broadcasting through a specialized, independent radio fund operated by, and on behalf of, Indigenous broadcasters in Canada
  3.  the CRTC ensure that its decisions with respect to CCD funding offer precise details to permit the CRTC, broadcasters and CCD recipients to fully understand and monitor CCD funding in Canada
  4. the CRTC attach specific CCD commitments as conditions of licence
  5. the CRTC implement an online tracking system to enable parties eligible to receive CCD funding to monitor actual CCD expenditures by ownership group

 

C Recommendations for a review of Canada’s policy for Indigenous broadcasting

126      NIMAC respectfully calls on the CRTC to launch a major review of its regulatory framework for Indigenous broadcasting in Canada.

127       There are several reasons for undertaking a review of the CRTC’s Indigenous broadcasting policy at the present time.

128       First, the communications environment and regulatory landscape that existed when the CRTC crafted the 1990 Native Broadcasting Policy are fundamentally different from what exists now. The technologies we take for granted today – from the internet to mobile telephony – simply did not exist 22 years ago. What do today’s Indigenous peoples want and/or need from contemporary communications systems? A public policy review would enable Indigenous peoples to express their views, and would provide the Commission with a critical opportunity to consult with those most affected by Indigenous communications policies.

129        Second, Indigenous programming services do not show signs of significant growth. Between 2003 and 2010 the number of private commercial radio stations increased by 122, the number of community radio stations increased by 22 – while the number of Indigenous ‘type B’ radio stations grew by four (4). A policy review could explore the reasons for such low growth and consider approaches for increasing the availability of Indigenous programming services.

130        Third, Indigenous programming services have shown and continue to show signs of serious financial weakness. Over the last decade the revenues received in total, and per station, have been lowest for Indigenous radio broadcasters. Recent changes to federal legislation concerning non‐profit corporations may also affect the financial future of Indigenous broadcasters required to be non‐profit under the CRTC’s current policy. A policy review could consider proposals for strengthening the financial performance of Indigenous programming services so as to permit the quality of their programming to increase.

131         Fourth, almost two‐thirds of the licences of the Indigenous radio broadcasters we have identified will expire between 2013 and 2018. Undertaking a policy review in 2012 will permit the Commission to propose, publish and implement a new policy to strengthen Indigenous broadcasting before the majority of renewals must be considered.

132         Finally, NIMAC respectfully submits that as the CRTC has in the last decade completed major policy reviews of the commercial and community radio and television sectors, of its ownership policies and of its approach to diversity in general, the CRTC should also grant Indigenous broadcasters the opportunity to present their views and recommendations about their sector of Canada’s broadcasting system.

133         NIMAC looks forward to the CRTC’s determinations in this proceeding and to its consideration of our request that the Commission undertake a thorough review of the achievements of its Indigenous broadcasting policy, including a public hearing or hearings to afford Indigenous peoples across Canada the opportunity to participate in the direction of this important cultural sector.

 

 

Appendix 1: CRTC’s 1990 CTD categories

Public Notice 1990-111: APPENDIX I — CANADIAN TALENT DEVELOPMENT

Initiatives Generally Accepted by the Commission

The attached is a list of initiatives generally accepted by the Commission as contributions to the development of Canadian talent. This list indicates whether the Commission usually considers these expenses to be direct or indirect.

Initiatives Generally Not Accepted By the Commission

Initiatives that are not accepted usually include program hosts and programs that are more or less part of regular programming schedules, or that do not promote Canadian artists or Canadian arts, or that make minimal use and have minimal impact on Canadian creative and other resources. While the programs can be of excellent quality and supportive of community events, they do not further the knowledge or understanding of Canadian artistic or creative issues or events, nor do they provide exposure to Canadian artists; they also have a minimal direct benefit to Canadian creators.

Similarly the Commission recognizes the training and financial benefits provided to summer students when hired by a station but considers that the station benefits as much from this type of initiative as do the students. The Commission considers that Canadian initiatives should be over and above regular station programming, should be exclusively Canadian in nature and if possible have an impact on the Canadian creative and artistic community.

Other initiatives that are generally not accepted include Music Directors’ salaries, membership fees for music and other associations, staff travel costs to music and broadcasting seminars and events, and telephone lines or costs for open-line programming.

Initiatives Generally Accepted by the Commission

Type of Initiative

Generally Accepted – Direct

Generally Accepted – Indirect

Program

– Station-produced Concert, Drama, etc.

– Poetry, Drama

– Interviews -Artist features – Historical, other

Canadian Features – Canadian countdown – Album Sweeps

Promotion

– Artists, Concerts & New Recordings

Talent Contest

– Concert – Record production – Video production – Recording Time – Prizes

– Promotion – Interviews

Concerts

– Musician and staff pay – Hall rental – Recording for airplay

– Interviews – Promotion

Record or Video Production

– Studio time – Musicians’ fees – Production costs – Record pressing – Record distribution

– Use of Station Studio

Scholarships &

– Cash Donation

Page 2

Grants

Industry Talent Organizations*

– Cash Donation

* e.g. Musicaction, FACTOR, Videofact, Country Talent Development Foundation, Alberta Music Project, etc…

Grants to Local Arts Assoc.

– Cash Donation

– Promotion

Use of Studio Facilities

– Audio tape for artist

– Time in Studio

Seminars

– Hall rental – Guest Speakers

– Promotion

Page 1

Appendix 2: CRTC website describing eligible CCD parties and initiatives

Examples of eligible Canadian Content Development (CCD) parties and initiatives by category as described in CRTC Public Notice 2006-158, Commercial Radio Policy (the Policy)

1. National, provincial, and territorial music industry associations (MIAs):

Accessed 19 February 2012: < http://www.crtc.gc.ca/eng/general/ccdparties.htm >

The following are examples and guidance about the kinds of activities that have qualified in

past, including some specific examples of parties and initiatives that have that a portion of

their activities qualify for Canadian Content Development (CCD). These examples are

grouped into the categories listed in paragraph 108 of the Policy.

This list replaces any list published prior to this date. This is not an exhaustive list.

All CCD initiatives must involve direct expenditures and must be allocated to the support,

promotion, training and development of Canadian musical and spoken word talent, including

journalists. Contributions must be claimed for the broadcast year in which they are made,

regardless of the date the initiative occurs.

Not every activity associated with the listed parties or initiatives necessarily qualifies. It is the

responsibility of licensees, when filing their annual financial returns, or applicants when filing

applications for new licences or for transfers of ownership or control, to clearly link their

contributions or proposed initiatives with the CCD policy. Proof of payment may include a

cancelled cheque, a receipt and/or a letter from the third-party recipient to certify how the

contribution was used.

It is incumbent upon the broadcaster to supply sufficient documentation to support the

eligibility of their contribution(s). Failure to do so may result in the Commission finding a

contribution ineligible and may affect a station’s compliance with regulatory obligations.

As a result of discussions at the most recent policy review, the Commission determined that

allocations to Radio Starmaker Fund or Fonds RadioStar are only eligible in the context of

applications to transfer the ownership or control of radio undertakings as stated in paragraph

106 of the Policy.

The following are examples of initiatives grouped by the categories used in the definition.

Also includes specific initiatives of third-party music advocacy associations (i.e. Canadian

Independent Music Association (CIMA), ADISQ) to support emerging artists such as:

Showcases at music festivals and conferences

Professional development, seminars, training workshops on music related topics

including new media

Master classes with artists

The following have demonstrated in the past that a portion of their activities qualify

for CCD funding:

The Canadian Academy of Recording Arts and Sciences (CARAS)

Alberta Music Industry Association (AMIA)

Canadian Society for the Recording Arts (CSRA)

Page 2

Canadian Country Music Association (CCMA)

Gospel Music Association of Canada (GMA Canada)

Saskatchewan Recording Industry Association (SRIA)

Manitoba Audio Recording Industry Association (MARIA)

Music and Film in Motion (MFM)

Music BC

Music/Musique New Brunswick (MNB)

Music Nova Scotia (Music NS)

Music Newfoundland & Labrador (Music NL)

Music Yukon

Pacific Music Industry Association (Music BC)

Société professionnelle des auteurs et des compositeurs du Québec (SPACQ)

Types of initiatives/costs considered ineligible

General contributions to third party music advocacy associations such as CIMA and

ADISQ for general operating and administrative costs.

General costs associated with putting on a conference/music festival by a music

association

2. Schools and educational institutions that are (1) accredited by provincial authorities; (2) benefit students of music and journalism by way of (a) scholarships or (b) the purchase of musical instruments:

3. Initiatives, including talent contests, for the production and promotion of Canadian local music and local musical artists, particularly emerging artists.

Contributions in this category may include the support of specific music

training/educational classes, clinics, master classes, artists in residence for development

of musical and journalist skills.

The following have demonstrated in the past that a portion of their activities qualify

for CCD funding:

Cégep Beauce-Appalaches (QC)

Conservatoire de musique de Gatineau (QC)

Englehart Public School (ON)

Fanshawe College (ON)

Hartland High School (NB)

Henry Grube Education Centre (Kamloops, BC

Lethbridge Community College (AB)

St-Francis Xavier University (NS)

University of Manitoba (MB)

Types of initiatives/costs considered ineligible

Broadcasting courses including broadcast journalism courses

The general administrative and operating costs required to operate a music school

The following are examples of eligible activities specific to this category. In

instances where prize money or a contribution is awarded by the broadcaster

directly to an artist (and not through a third-party), documentation to demonstrate

the eligibility of the contribution must be submitted to the Commission. 1

Talent contest (singing, songwriter, “battle of the bands” type events)

Page 3

Promotional material to promote artists performing at a music festival/concert/event but

funding must go through a third party to manage/oversee advertising.

Prize money to be awarded to winners of music competitions

Initiatives using new media to promote emerging talent to listeners as well as radio

stations; online battle of the bands and online promotional/advertising material for

musicians.

The following have demonstrated in the past that a portion of their activities qualify

for CCD funding:

Canadian Chinese Song-Writers Quest (BC & AB) Cégeps en spectacle (QC)

Country Star Search (Global Country Rising Star program) (AB)

Francouvertes (QC)

Types of initiatives/costs considered ineligible

Entertainment reports broadcast on radio stations

Costs associated with the normal operations of a station (i.e. Program host salary,

overtime, street teams)

Station staff training, staff recruitment on behalf of a station

Local, regional and national musical initiatives

Production of music video and audio recordings of artists to be used to promote the

artists and their works on various communication platforms. Please note that the

production of the recording must be performed by a third-party and not the broadcaster’s

own studio or employees

Contributions to third-party organizations to produce websites, social media and

promotional materials for emerging artists (i.e. for the purposes of music competitions to

allow the public to vote for their favourite artist.)

Costs associated with providing training and/or promotional opportunities for emerging

artists

Orchestras & Symphonies

Support of local youth orchestras for vocal, instrumental training, purchase of musical

instruments.

Contributions to orchestras towards the costs of concert performances

The following have demonstrated in the past that a portion of their activities qualify

for CCD funding:

Kamloops Symphony Orchestra (BC)

National Youth Orchestra of Canada (NYOC) (ON)

Orchestre symphonique des jeunes de Montréal (QC)

Orchestre Symphoniques des Jeunes de Lévis (QC)

Orchestra London (ON)

Toronto Symphony Orchestra (ON)

Vancouver Island Symphony (BC)

Page 4

Choirs

Queens County Girls Choir (NS)

Amadeus Choir (Toronto, ON)

Moose Jaw Children’s Choir & Festival Choir (AB)

Chœur philharmonique du Nouveau Monde (ON)

Festivals and concert series

The following have demonstrated in the past that a portion of their activities qualify

for CCD funding:

Blueberry Bluegrass and Country Music Society Festival (AB)

Burlington Sound of Music Festival (ON)

Festival d’été de Québec (QC)

Festival International de Jazz de Montréal (QC)

Rendez-Vous country de Bathurst (NB)

Festival Nelson (BC)

Hillside Festival (ON)

Limestone City Blues Festival (ON)

Nanaimo Blues Festival Society (BC)

Oilsands Rotary Music Festival (AB)

Twin Rivers Music Festival (SK)

World Stage Festival (ON)

Types of initiatives/costs considered ineligible

Prizes and contributions to emerging artists that are not directly related to the

development of Canadian Content (i.e. car rental costs for a year)

Internship programs where the internship is to be hosted by a licensee

Awards shows & conferences

Sponsorship of televised award shows – performance fees for Canadian artists

performing at the show. Travel expenses for performing artists are also eligible.

Sponsorship of a musical act to attend national and international music performed at

competitions particularly for emerging artists.

The following have demonstrated in the past that a portion of their activities qualify

for CCD funding:

L’ADISQ (le Gala)

East Coast Music Association (East Coast Music Awards)

Indian Art-I-Crafts

JUNOs

Canadian Music Week (CMW)

Canadian Country Music Awards

North by Northeast (NXNE)

Foundations

Fondation Wilfrid-Pelletier (QC)

Other music initiatives

Artist fees to perform at a charity benefit that may or may not be related to music (i.e.

hospital foundation)

4. Independent parties dedicated to producing new spoken word content that would otherwise not be produced for broadcast

5. Audio content initiatives further advancing the fulfillment of specific objectives of the Canadian broadcasting system as outlined in the Act such as community radio fund, Native radio and other specialized audio broadcasting services dedicated to the particular needs and interests of children, Aboriginal peoples, and persons with disabilities

This category was developed subsequent to the 2006 policy to permit contributions for

the development of spoken word programming for which exclusive rights will not be

granted on the basis of CCD funding. Licensees must demonstrate that their

contributions to this category must be incremental to regular operational and

programming costs. One example could be the sponsorship of a comedy talent showcase

organized by a third-party featuring Canadian performers in a public venue with an

audience where the performances are recorded by the third party with the intention of

making the recording (in-whole or in-part) available for radio broadcast. The rights to air

the content must not be exclusive to a single broadcaster.

The following have demonstrated in the past that a portion of their activities qualify

for CCD funding:

Media BemBem’s Canadian Country Spotlight

Types of initiatives/costs considered ineligible

Expenses associated with regular, ongoing station programming and/or operations “

Production of a radio program by a third-party, not for the exclusive use of one

broadcaster and to be made available to any interested broadcaster.

Initiatives to fund the creation of community and/or native radio programming,

programming geared to children and to make radio content accessible to persons with

disabilities.

The following have demonstrated in the past that a portion of their activities qualify

for CCD funding:

Community Radio Fund of Canada (amount over and above the regulatory minimum)

Fondation Radio Enfant

VoicePrint – National Broadcasting Reading Services / Vues et Voix

Native radio initiatives

 

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