Review of campus and community radio
Kathy, John and Ken presented at the CRTC community radio policy review (2009-418) by video conference in Vancouver on Tuesday January 19, 2010. The hearing  audio webcast from  Gatineau Quebec will be requested on disk.

The agenda for the week is here: http://www.crtc.gc.ca/Broadcast/eng/HEARINGS/2010/ag01_18.htm

CAB oral comments from that day are posted as  CAB oral comments.

Our testimony is copied below, for a complete transcript from the day go to http://crtc.gc.ca/eng/transcripts/2010/tb0119.html

CKGI comments

Hello from Vancouver. I’m Kathy R from Gabriola Radio Society, proposed CKGI.  Thank you for inviting us to comment.
Lovely day here in Vancouver although not nearly as nice as it would be if we were all on Gabriola island –

this is Ken Zakreski on my right, your left, John Hague on my left, your right

Ken is the president of the society (and our fearless leader)… in real life his background includes web publishing and printing, publicity and for profit print and was the developer of chly in Nanaimo

John is new to the society’s board and his real life experience is as chartered accountant retired from gov’t services and currently enrolled in Media Studies at Vancouver Island University

I am a founding director of the Society and 8 yrs later I am still here despite that we still don’t have a station … when I’m not meeting with the eclectic folk who make up radio societies I am an owner operator of a commercial art gallery.   I used be a big city daily reporter in what seems like another life-time ago

We would to like to invite anyone who’s listening, the appropriate assembled staff and CRTC commissioners to attend the National Radio Conference that our society is hosting on beautiful Gabriola Island, just off Nanaimo BC June 7-11th – details can be found on our new website ckgi.ca

Now ….

I would like the commission to sit in our chairs for a minute

The ground is shifting

-    new media has changed everything …. volunteer training is a huge drain on resources
-    the campus/community radio policy is AGAIN under review
-    the Rules of Procedure are changing
-    The Radio Fund is not fully funded
-    the tariff ruling for part 2 licensing fees decision is in …yet there is no funding for community/campus radio stations other than minority language stations
-    CCD (can content dev’t) funding for technical briefs for camp/comm. stations was requested and denied
-    Fed court of appeals ruling on internet regulation by the crtc is forthcoming
-    the commission struck section 22 of the bdu (broadcast distribribution undertaking) regulations thereby removing mandatory carriage for campus/ community radio.
-    climate change is making everyone nervous
-    local indie Canadian rock is getting harder to find

The CRTC could go a long way to shoring up the ground underneath community and campus radio by leveling the playing field with commercial radio.

I’m going to ask John to share the view from our chairs on CAB’s (Can Association of Broadcasters) written submission for this review.

transcript to follow

Thanks John and now Ken would like to highlight key points from our written presentation

In response to public notice 2008-11 and 2009-418 the following is a point form summation from Gabriola Radio Society  (CKGI):

2009-418 q. #9
restore analog cable carriage in the BDU regulations

2008-11 q. #18/2009-418 q. # 24
measures required are new media tariffs for internet access for campus and community stations

2008-11 q. #6-14 / 2009-418 q. #29-31
we support a preponderance of Canadian campus and community stations on the internet  (i.e. iTunes)
we support a reduction to the barriers to entry (i.e. internet access costs)

2009-418 q. # 24
we support CCD funding for technical briefs

2009-418 q. #8
evaluation criteria should include the following;
local content ongoing and during emergency events
isolation of the community to other local media outlets
unique attributes of the broadcasting community (cultural, language, ethnicity and geography)
new and original programming should take preference

2009-418 q. #3
we object to one policy for both campus and community radio stations as it would diminish the importance of the diversity of broadcasters in one market

The following is a copy of our comments that got us invited to present.

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

Subject:  New Media 2008-11 and Community Radio Carriage specific to
proposed Gabriola Radio CKGI application 2008-1533-4

Dear Secretary General,
The following comments reply to your question 18 in the Call for Comments 2008-
11 concerning the special role for community broadcasters in New Media.  This
is the  response from proposed CKGI, Gabriola Radio Society. We consulted
with several people involved in community radio at a regulatory, administrative
and technical level from November 17th to the submission date.

We argue the commission should regulate New Media at the telecom layer, spe-
cifically ISP’s, because they now carry audio and video content and are akin to
a broadcast distribution undertaking. Further, we argue the commission should
regulate new form content only if it is a problem (spyware) and  Canadian content
on the internet should be addressed by regulation.

The Diversity of Voices Decision, Broadcasting Public Notice CRTC 2008-4,
indicates the commission will follow up with a Community Radio Policy Review
dealing with modern issues like Universal Carriage. The National Campus and
Community Radio Association (NCRA) holds an annual national community radio
conference (NCRC), this is a excellent venue to seek opinion on issues for the
review. We recommend the commission, at the highest level, attend NCRC and
consult with the assembled campus, community and native (ccn) broadcasters.
In Broadcasting Public Notice CRTC 2008-100 the commission scheduled the
deletion of section 22 of the BDU Regulations. This action reduced the Diversity
of Voices in Canada by removing the requirement for community radio as a must
carry.  Community media, as it operates in Canada, is a public good widely sup-
ported by the public (enlightened self interest).  We ask you to restore carriage on
analog cable and require carriage on New Media , please. The quality of service
could based on NCRA best practice, of a high caliber and delivered in a variety
of speeds. Regardless of the method, upload bandwidth is the problem, the ISP
should deal with that. The role of a community broadcaster should be to focus on
Canadian Cultural Community Content and the FM OTA service. Beyond FM OTA
should be required by the Carriers.

Actions the commission could take
(Regarding proposed CKGI, Gabriola Radio Society)

1. Develop a policy of Universal Cultural Community Carriage. For carriage in
our community, list CBC, native, campus based community and community radio
stations as a must carry for BDUs. Require the audio service as analog FM.
Requiring analog FM service as a condition on a BDU ensures a audio quality
base line exists in the  ear of Canadians. Further, requirement of this  service for
at least another three licence terms, will contribute to diversity and maintain new
century preponderance. CKGI desires local Carriage to serve more residents.
Our situation reveals many residents living along the shorelines with intervening
topography degrading the broadcast. Some day, perhaps technology will provide
a method for more finely discriminating selective signals, but not today. We desire
the option to add repeaters for neighbourhoods in need of OTA service. Cable
service on analog  FM, provides a cheap, easy to access source of clear audio to
use for repeaters on a neighbourhood class FM service.

2. CKGI desires to carry our neighbours CFUV on occasion. CFUV has hosted
Gabriola programmers over their air service; we would like to have CFUV, deliv-
ered into our studios on cable analog FM for best quality broadcast. Access
to the occasional  network service, of a neighbouring station, adds diversity of
programming and  can provide local context for common issues. CKGI is a new
undertaking, experience dictates it will  take a couple of years to develop our full
broadcast schedule. In those early days it would be  nice to have  dependable FM
cable access to CiTR host’s broadcasts.   It is sad and true to point out that not
all residents of Gabriola Island can receive CFRO, 102.7 FM, Vancouver Co-op
Radio. Residents, by no fault of their own, cannot receive CFRO programming
like Red Eye. Gabriola Radio would like to supplement community access to the
airways, with  excellent Canadian programming, from neighbouring ccn stations,
as resources permit.

3. Currently no agreement exists with the CBC regarding CKGI rebroadcasts. We
don’t know what the future will bring. Gabriola Radio recognizes the challenge the
CBC has in serving Canada. The commission was made aware at the Vancouver
Hearing 2007-18 that the  CBC Victoria signal is not delivered to Nanaimo. Many
of our local performing artists often travel to  CBC Victoria for an interview. Those
important interviews are not heard in our area. CKGI desires an outcome where
by CBC Victoria arts and culture reports, specific to local  artists, can be broadcast
locally. Having a ready, high quality analog, FM cable CBC Victoria service, opens
the door for local broadcast of national events of local interest.

Telecom
1. New Media transmissions cross Canadian air space and its wires cross our
public roads. There is a role for the CRTC in regulating infrastructure (telecom).
You must regulate New Media lest it tacitly collude and act as a natural monopoly.
Market forces can cause collusion by the common interest of profit. Regulate at
the telecom layer. Regulate the ISPs and introduce a levy to pay for its admin-
istration. Charge at the retail event for content delivery devices.  Reinvest in the
communications system, educate, support cultural growth and the Canadian
experience.

2. BC is not flat.  Where Canada is a great plain her citizens are spread out far
and wide. Both require carriage. Universal Carriage for community media should
be guaranteed by the commission to ensure delivery of a public good. Universal
cultural community carriage should replace section 22 when it is deleted from
the BDU Regulations in 2011.  Our preference would be for a stable broadcast
environment with a mechanism to handle carriage as new technologies roll out.
Use the best practices demonstrated by member stations of the NCRA as your
model. Community Radio needs to “be responsive to the evolving demands of the
public.”

3. New Media needs  a market place, which exists in a new form with new scarci-
ties. IP OTA AV (internet protocol, over the air, broadcasting) requires platforms
and public platforms are one form of scarcity needed for a competitive market.
Additionally, local content and Canadian users are two other examples of scar-
city.

4. The  commission  has ruled to discontinue  FM analog carriage in  2011. This
will require community members, not serviced by our proposed OTA service due
to intervening topography, to utilize an alternate service, namely the internet. The
commission has an obligation to ensure Canadians can access a preponder-
ance of Canadian services.  The commission  should  require internet carriage of
Canadian community and cultural  services to ensure that preponderance.

Broadcasting, traditional content
1. Do not adopt regulations to limit content by restricting to a few providers. That
action will limit community and diversity. Content (broadcast) regulating should
only be undertaken to ensure our cultural producers have access to the resources
to compete in an emerging flat global climate. This is different from the current
model with CanCon, where you limit the supply of foreign (mainly US) content.
Slick news productions can have a negative impact on community broadcast news
which may have different training and production standards even for messages of
a high merit. Community media must over come this difference in quality percep-
tion, that is our challenge.

Broadcasting, content includes a new form, the new rabbit hole
1. Programs written by software engineers to “handle” traditional content are so
intertwined with the experience that software is the new form of content the CRTC
can regulate. The CRTC can improve the internet New Media experience for com-
munity media and the public. While connected to the internet, Spyware is a prob-
lem for some operating systems, like Windows, that are poorly implemented. The
commission should establish and promote voluntary industry standards for operat-
ing systems that broadcast or receive New Media on the internet. Net Neutrality is
a fine concept for those that are internet savvy, however, not all Canadians should
be thrown into the regulatory void because they want to see pictures of their
grandchildren.  If a software company wants to sell a non complying operating
system, let it be known; the public can decide what they want to purchase. Give
us the information we need to make an informed decision regarding the operating
system and control software when we want a truly Canadian experience. Let that
be part of the preponderance.

Request from CKGI
In Broadcasting Public Notice CRTC 2008-100 the commission scheduled the
deletion of section 22 of the BDU Regulations. We ask you to adopt a policy
of Universal cultural community carriage, restore carriage on analog cable and
require carriage on New Media, please.

Thank you,
peace
Gabriola Radio Society
proposed CKGI