Ms. Laura M. Talbot-Allan
Secretary General
CRTC
1 Promenade du Portage
Terrasses de la Chaudière
Central Building,
Hull, Québec
K1A 0N2
November 3rd, 1997
Re: Public Notice 1997-104:
Review
of the Commissions Policies for Commercial Radio
Dear Ms. Talbot-Allan:
The National Campus and Community Association (NCRA) is pleased to provide a brief comment to the Commission concerning proposed changed to the commercial radio regulations.
The NCRA wishes to appear at the upcoming public hearings, scheduled to begin in December. We feel that, as one of the principle representatives of non-commercial radio, there is much we can contribute to the current discussion.
Sincerely,
Caroline Côte
Director
enc.
What is the future of radio in Canada? According the Canadian Association of Broadcasters (CAB), it is grim indeed. Without significantly restructuring of the sector, the CAB says, Canadian radio listeners could be doomed to fewer choices on their radio dial. The solution, according to the CAB, is broad-scale deregulation in areas ranging from Canadian content to ownership.
The National Campus and Community Radio Association (NCRA) believes that one of the principle causes of commercial radio’s current financial problems is a clear reluctance to innovate and a fear of creativity. Commercial radio has rightly lost listenership over the past several years, not because of the current regulatory environment, but because of its own unwillingness to face the challenges of the future.
The NCRA therefore objects to the general effort by the CAB to cloak an effort to deregulate under the guise of “saving” radio. Since it’s introduction in Canada in the 1920s, commercial radio has gone through significant changes, not the least of which is adapting to fundemental changes in audience behavior. The 1990s, with its plethora of media choices, presents opportunities which should be embraced, not feared.
It should also be clear that the real face of the CAB’s proposed deregualtion is not a healthier, more community- and listener-oriented approach to programming. Rather, the face of deregualtion is in fact that of Howard Stern, the American radio host whose morning show was recently purchased by radio stations in Montreal and Toronto. We urge the Commission to consider the CAB’s proposals with the unmost caution.
As should be obvious, the members of the NCRA are hesitant to comment overmuch on commercial radio regualtion. Afterall, those of us who work in and support the community radio sector do so in order to create a viable alternative to a commercial radio sector which we believe is oriented only to presenting audiences to groups of advertisers. However, we recognize the important of commercial radio to many Canadians and to the communities which individual stations serve.
First and formost, the members of the NCRA are people who love the length and bredth of what radio is and can be. More than 4000 Canadians, most of them voluteers, actively work in campus and community radio. We therefore feel justified in commenting on what the CAB has described as a “proposal for the future of radio.”
What follows are brief comments concerning the key CAB proposals.
The members of the NCRA look upon any movement by the Commission to change the current rules surrounding station ownership with great concern.
Community broadcasters are already troubled by a broadcasting system where so many stations, regardless of geographic location or music format, sound incredibly similar. The reason for this is well-known: station formats and programming are determined centrally, often by a small group of radio consultants. In order to cut costs, creativity and innovation are discouraged. Sameness - across formats and cities - is the rule, not the exception. Stations have a mandate to serve local communities, but formats and even individual playlists are determined in Toronto or Montréal.
It is hard to imagine a less-appealing prospect than this. But a further concentration of radio station ownership would only exaserbate this situation. Instead of two stations - one AM, one FM - shaing news, technical, and programming staff, we can imagine four stations doing so, with a resulting loss of variety and choice.
Admittedly, we read the CAB’s proposal for a change in Canadian content regualtions with confusion. To be frank, we do not understand how the CAB’s proposed system would benefit the Canadian music industry in any way. The proposal is a thinnly-veiled attempt to phase out Cancon over a five year period.
As we are sure the Commission is aware, the member stations of the NCRA have been pivitol in supporting emerging Canadian talent over the past two decades. We feel that it is important to point out a basic truth: that the current robust Canadian music indutry is the result of the CRTC’s strong committment to Canadian content on radio and (later) music television. Simply put, if the regulation isn’t broken, we see no reason to fix it.
The NCRA is encouraged by the CAB’s commitment to the new Canadian Radio Music Awards. NCRA would also encourage the Commission and the CAB to develop ways by which musical talent can be more directly supported. We would suggest that this support take the form of direct grants to both artists and to organisation which support them. Nothing can really take the place of direct support to artists.