Broadcasting Decision CRTC 2015-281

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Reference: 2015-84

Ottawa, 25 June 2015

Salt Spring Island Radio Corp.
Salt Spring Island, British Columbia

Applications 2014-0865-9 and 2014-0963-1, received 19 August 2014
Public hearing in the National Capital Region
13 May 2015

CFSI-FM Salt Spring Island and its transmitter CFSI-FM-1 Mount Bruce - Revocation of licence

The Commission revokes the broadcasting licence for CFSI-FM Salt Spring Island and its transmitter CFSI-FM-1 Mount Bruce, British Columbia. The revocation is effective 25 July 2015, and the licensee must cease broadcasting by no later than the end of the broadcast day on that date.

This revocation follows the Commission’s decision to impose six mandatory orders earlier in the licence term, which are set out in Broadcasting Decision 2014-330. In spite of these orders CFSI-FM continued to be in non-compliance with its regulatory obligations. As a result, the Commission has no confidence that the licensee will be able to operate in compliance with its existing or any new regulatory obligations for the remainder of the current licence term or for another licence term. Accordingly, the Commission considers that revocation of the licence is the only appropriate measure.

As a result of this revocation, Canadians living on Salt Spring Island will no longer have access to the radio service of CFSI-FM. However, given that the licensee operated with numerous recurring and serious instances of non-compliance during its licence term, the Commission is confident that a higher quality radio service could be provided to island residents.

In light of the revocation, the Commission finds that it is not necessary to rule on the application to amend Salt Spring’s ownership structure.

Applications

  1. Salt Spring Island Radio Corp. (Salt Spring) filed an application (2014-0865-9) to renew the broadcasting licence for the commercial specialty radio station CFSI-FM Salt Spring Island and its transmitter CFSI-FM-1 Mount Bruce, British Columbia, which expires 31 August 2015. Salt Spring proposed to operate CFSI-FM under the same terms and conditions as those in effect under the current licence.
  2. Salt Spring also filed an application (2014-0963-1) to modify its ownership through the transfer of all of its shares held by Satnam Media Group (Satnam), a corporation controlled by Mr. Sukhdev Singh Dhillon, in equal parts to Mr. Dhillon and Mr. Harman S. Gill.

Background

  1. In Broadcasting Decision 2007-387, the Commission approved an application by Salt Spring for a broadcasting licence to operate a specialty FM radio station to serve Salt Spring Island. The new station, CFSI-FM, went on the air on 15 September 2009. On 21 January 2013, the Commission approved a change in the ownership and effective control of Salt Spring from Gary Stephen Brooks to Satnam. The Commission announced the change in ownership and effective control in Broadcasting Information Bulletin 2013-274.
  2. During the present licence term, the Commission called Salt Spring to the 27 January 2014 public hearing in Surrey, British Columbia, to discuss its apparent non-compliance with various provisions of the Radio Regulations 1986 (the Regulations). At that hearing, Salt Spring was to show cause why the Commission should not impose mandatory orders requiring it to comply with the Regulations and why the Commission should not suspend or revoke CFSI-FM’s licence pursuant to sections 24 and 9 of the Broadcasting Act (the Act).
  3. The Commission set out its determinations in Broadcasting Decision 2014-330, which led to the imposition of six mandatory orders. These mandatory orders required Salt Spring to comply with:
    • sections 8(1) and 8(4) of the Regulations with respect to the maintenance, certification and filing of program logs (Broadcasting Mandatory Orders 2014-331 and 2014-332);
    • sections 8(5) and 8(6), of the Regulations with respect to the maintenance and filing of logger tapes (Broadcasting Mandatory Orders 2014-333 and 2014-334);
    • section 9(3) of the Regulations with respect to the submission of self-assessment reports and music lists (Broadcasting Mandatory Order 2014-335); and
    • section 9(4) of the Regulations with respect to responding to the Commission’s requests for information (Broadcasting Mandatory Order 2014-336).
  4. Broadcasting Decision 2014-330 also noted the following measures that the licensee committed to implement to ensure future compliance:
    • It had purchased a new computer and logging software as well as a remote back-up logging system.
    • It had established new phone facilities so that staff on Salt Spring Island can contact Mr. Dhillon, the owner, at any time.
    • It had hired a new station manager who, with the help of a part-time employee, will be responsible for maintaining and submitting program logs, logger tapes and music lists.
    • It had hired an experienced consultant.
    • Mr. Dhillon will spend more time on Salt Spring Island so he can be more involved in the day to day operations of the station.
    • It had implemented procedures for staff and volunteers to ensure that program logs, logger tapes, music lists and other information is maintained.
  5. The Commission further expected Salt Spring to file quarterly reports on the programming provided by CFSI-FM as well as on its community involvement. Concurrent with Broadcasting Decision 2014-330, the Commission issued Broadcasting Decision 2014-337, which administratively renewed CFSI-FM’s broadcasting licence until 31 August 2015. This renewal was to permit the Commission to examine Salt Spring’s overall compliance with the Regulations and its conditions of licence during the complete licence term, as well as with its mandatory orders in the context of a full licence renewal proceeding.
  6. In that decision, the Commission stressed the seriousness with which it views non-compliance and clearly stated that additional measures, including suspension, non-renewal or revocation of the licence under sections 9 and 14 of the Act, could attach to any further breach by Salt Spring of its regulatory requirements.
  7. In Broadcasting Notice of Consultation 2015-84, the Commission called Salt Spring to the 13 May 2015 public hearing in the National Capital Region to inquire into the following matters:
    • apparent non-compliance with Broadcasting Mandatory Orders 2014-331, 2014-332 and 2014-335 with respect to the maintenance and provision of complete program logs, attestation of the accuracy of those logs, and the submission of music lists for the broadcast week of 5 to 11 October 2014;
    • apparent non-compliance with section 9(2) of the Regulations concerning the filing of annual returns for the 2009-2010, 2010-2011 and 2011-2012 broadcast years;
    • apparent shortfalls in Canadian content development (CCD) contributions as required by previous Commission directions, by condition of licence 5 for CFSI-FM and by section 15(2)(a) of the Regulations;
    • apparent shortfalls in tangible benefits payments;
    • failure to provide quarterly reports in accordance with the Commission’s expectations; and
    • possible discrepancies between the ownership information submitted in CFSI-FM’s licence renewal application and in its ownership application.
  8. The Commission also stated that it expected the licensee to show cause at the hearing
    • why its licence should not be suspended or revoked pursuant to sections 9 and 24 of the Act; and
    • why, if the licence was renewed:
      • the renewal should not be for a short term;
      • the existing mandatory orders should not be reimposed; and
      • additional mandatory orders should not be issued under section 12 of the Act requiring Salt Spring to comply with the Regulations and its conditions of licence.
  9. Finally, the Commission stated that it intended to consider that licensee’s application for a change in ownership and that it may inquire into the ownership information provided by the licensee in both applications with a view to determine whether the licensee has at all times complied with section 11(4) of the Regulations, which sets out when ownership transactions require prior approval of the Commission.

Interventions

  1. The Commission received one supporting intervention in connection with the ownership application as well as several opposing interventions in connection with both applications from various individuals. The public record for these applications can be found on the Commission’s website at www.crtc.gc.ca or by using the application numbers provided above.
  2. The opposing interveners were of the view that the station could not be successful under an ownership structure involving Mr. Dhillon. Most of these interveners had been employees or volunteer program hosts at CFSI-FM. One opposing intervener, Ms. Radha Fournier, who was a former station manager at CFSI-FM, appeared at the public hearing. Ms. Fournier submitted that Mr. Dhillon was seldom present at the station, did not pay bills or employees on time, and did not maintain the station’s equipment to an acceptable standard. She submitted that CFSI-FM and CFSI-FM-1 had been off air several times during the licence term and all employees left the station in March 2015. Since then, CFSI-FM had run largely on automation. Ms. Fournier stated at the hearing that “the Commission should revoke the radio licence from Mr. Dhillon on the basis of non-compliance and failure to operate a licence with basic business practices that ensure the sustainability of the operation.”Footnote 1
  3. In Salt Spring’s reply at the hearing, Mr. Dhillon indicated that former employees and volunteers were upset when he assumed ownership of the station pursuant to a Commission process. Mr. Dhillon stated that “they are a disgruntled bunch”Footnote 2 who had been hostile to his ownership from the time that the station was sold to him. He stated that he would introduce a new operations team in June and that, as a result, CFSI-FM would operate in compliance with its regulatory obligations in the future and that the difference in the station would be evident “within a year.”Footnote 3

Non compliance

Maintenance, certification and submission of complete, certified and accurate program logs and music lists (Mandatory Orders 2014-331, 2014-332 and 2014-335)

  1. Salt Spring is required to maintain complete program logs or machine readable records as set out in section 8(1) of the Regulations and Mandatory Order 2014-331 and furnish them on request. Section 8(4) of the Regulations and Mandatory Order 2014-332 requires the licensee to furnish the logs or machine-readable records to the Commission on request, with a certificate by or on behalf of the licensee attesting to the accuracy of its content. Salt Spring is also required to maintain a list of musical selections in the order in which they are broadcast as set out in section 9(3) of the Regulations and Mandatory Order 2014-335 and to submit those lists on the Commission’s request.
  2. Following the 2014 Surrey hearing, but before issuing Broadcasting Decision 2014-330, the Commission requested the licensee to provide program logs, logger tapes and music lists for the 9 to 15 February 2014 broadcast week. The material filed in response was complete and did not reveal any non-compliance.
  3. On 20 October 2014, the Commission requested that Salt Spring submit program logs and music lists for the 5 to 11 October 2014 broadcast week. Commission staff’s review of the material provided by Salt Spring revealed apparent non-compliance with the Regulations and with Salt Spring’s mandatory orders.
  4. The information on the program logs that Salt Spring submitted did not include all the required information and did not accurately reflect the content of the logger tapes. For instance, the logs did not identify times for the beginning and end of programs and in some cases content categories were misidentified. Further, the logs did not indicate that the licensee had substituted a previously-broadcast program for a program indicated on the logs. As well, the licensee did not submit a certificate of accuracy with the program logs.
  5. There were also many inaccuracies in the music lists. For instance, some musical selections were not properly identified as Canadian selections, no hits were identified, and some musical selections were improperly categorized.
  6. In its written responses, Salt Spring stated that the replacement program was not noted by the volunteer announcer so the issue was not apparent to station management, and the music lists and program logs were not reconciled due to limited resources. With respect to certification of logs, the licensee stated that the logs were provided with preparation by the station manager indicated on each page. The licensee submitted that it had been facing financial hardships but had taken steps to ensure compliance going forward.
  7. At the hearing, Mr. Dhillon stated that some responsibility for the preparation and accuracy of the logs rested with the former station manager and with a broadcasting consultant he had hired for this purpose and who no longer represents Salt Spring. Mr. Dhillon stated that he now has a different employee who prepares the music lists and that he implemented a new logging system as of the first week of April 2015. According to Mr. Dhillon, the new system will ensure that logs and music lists are accurate and comply with the Commission’s requirements.
Commission’s analysis and decisions
  1. The submission of complete and accurate program logs, of a certificate attesting to their accuracy, and of music lists are basic and fundamental requirements of all radio stations regardless of the station’s location or type. The submission of these materials enables the Commission to conduct an analysis of a station’s programming to verify compliance with the Regulations and conditions of licence. The maintaining of accurate logs and music lists also enables the Commission to respond in the event that listeners submit complaints regarding a station’s programming.
  2. These important requirements are clearly set out in the Regulations. Moreover, the Commission issued mandatory orders in June 2014 against Salt Spring directing it to comply with these requirements and thereby further emphasizing the importance that the Commission places on these requirements.
  3. While the licensee pointed to the new logging system to argue that the logs and music lists will be complete and accurate in the future, it did not argue that the logs and music lists in question were complete, or that the required certificate had been filed. The implementation of a new logging system was one of the measures to which Mr. Dhillon committed at the previous hearing in order to prevent future non-compliance.
  4. In light of the above, the Commission finds the licensee in non-compliance with sections 8(1), 8(4) and 9(3) of the Regulations and with Broadcasting Mandatory Orders 2014-331, 2014-332 and 2014-335 for the broadcast week of 5 to 11 October 2014.

Timely filing of annual returns (section 9(2) of the Regulations)  

  1. Licensees are required to file, not later than 30 November of each year, their annual return for the broadcast year ending the previous 31 August.
  2. On 21 January 2013, the Commission approved the application to change the ownership and effective control of Salt Spring from Gary Stephen Brooks to Satnam, a corporation owned and controlled by Sukhdev Singh Dhillon, the current owner. In a letter of that date the Commission determined that the licensee was in non-compliance with section 9(2) of the Regulations concerning the submission of annual returns for the 2009-2010 and 2010-2011 broadcast years. Both annual returns were filed late, and the financial statement for 2010-2011 did not cover the correct reporting period. In the same letter, the Commission reminded Mr. Dhillon that Satnam would be responsible for the ongoing compliance of Salt Spring with all regulatory requirements.
  3. Subsequent analysis in connection with the licence renewal application indicated that Salt Spring was also in apparent non-compliance with the filing of annual returns for the 2011-2012 broadcast year. The annual return was filed on time but was missing the required financial statements.
  4. At the hearing, the licensee indicated that he had filed all annual returns in a timely fashion since acquiring the station and that he would refile the annual returns for the years in question.
Commission’s analysis and decisions
  1. The timely submission of accurate annual returns is important because it allows the Commission to monitor a station’s compliance with its regulatory obligations such as contributions to CCD.
  2. The annual returns in question were, at the time they were due, the responsibility of the previous owner of CFSI-FM. However, as Mr. Dhillon was informed upon Satnam’s purchase of the station, when a new company or group assumes control of a station, it also assumes all responsibilities and liabilities and must ensure that it is aware of and respects the station’s regulatory obligations at all times.
  3. Since it is the current licensee of the station that is regulated by the Commission, it is, therefore, the current licensee’s responsibility to correct the deficiencies in the previously filed annual returns.
  4. Although the licensee re-filed the annual returns after the hearing, the returns were the same as those filed previously, with the same financial information missing from the 2010-2011 and 2011-2012 annual returns.  
  5. In light of the above, in addition to the non-compliance for 2009-2010 and 2010-2011 broadcast years previously identified in its letter of 21 January 2013, the Commission finds the licensee in non-compliance with section 9(2) of the Regulations for the 2011-2012 broadcast year.

Canadian content development contributions (condition of licence 5 and section 15(2)(a) of the Regulations

  1. Salt Spring is subject to condition of licence 5 concerning CCD set out in the appendix to Broadcasting Decision 2007-387, which reads as follows:
    In addition to the basic annual contribution, the licensee shall, upon commencement of operations, contribute $2,500 annually to the promotion and development of Canadian content. This amount is over and above the licensee’s required basic annual CCD contribution. Of this amount, $500 per broadcast year shall be devoted to FACTOR. The remainder, $2,000, shall be allocated to parties and initiatives fulfilling the definition of eligible initiatives in Broadcasting Public Notice 2006-158.
  2. In the previously-referenced letter to the licensee dated 21 January 2013, the Commission found that the licensee was in non-compliance with condition of licence 5 for the 2009-2010 and 2010-2011 broadcast years. In the same letter, the Commission also found the licensee in non-compliance with the requirement under section 15(2)(a) of the Regulations related to basic CCD payments for the 2010-2011 broadcast year.
  3. These instances of non-compliance resulted in a total CCD shortfall of $5,500. The Commission further stated:
    Accordingly, the Commission requires that the licensee file with the Commission documentation supporting the fact that the CCD shortfall of $5,500 was paid to an eligible CCD initiative no later than 90 days following the Commission’s decision.
  4. According to Commission records, the supporting documentation filed indicates that only $5,000 was paid. It therefore appears that $500 is still outstanding in light of the Commission’s direction set out above.
  5. In addition, at the time of the hearing, the Commission had received no proof of contribution for any CCD payments pursuant to condition of licence 5 for the 2011-2012, 2012-2013 and 2013-2014 broadcast years. The total contribution under condition of licence 5 for those broadcast years was $7,500.
  6. CFSI-FM was also subject to annual basic CCD contributions of $500 pursuant to section 15(2)(a) of the Regulations for the 2011-2012 and 2012-2013 broadcast years. However, at the time of the hearing, the Commission had received no proof of basic CCD contributions for those broadcast years. The total outstanding basic CCD shortfall for the 2011-2012 and 2012-2013 broadcast years was $1,000.
  7. At the hearing, and in subsequent correspondence, the licensee did not dispute that a total shortfall of $9,000 was still outstanding. The licensee stated that it would pay the outstanding amount and within 30 days following the public hearing. Mr Dhillon also submitted that, going forward, he would arrange for an accountant to make the required CCD contributions on the station’s behalf.
  8. On 12 June 2015, the Commission received a copy of a cheque to FACTOR in the amount of $9,000.
Commission’s analysis and decisions
  1. The requirement for radio stations to make CCD contributions furthers the broadcasting policy objective set out in section 3(1)(e) of the Act, which provides that “each element of the Canadian broadcasting system shall contribute in an appropriate manner to the creation and presentation of Canadian programming.” The Commission considers that this objective, set out by Parliament, is of great importance and that CCD initiatives make a significant contribution to the Canadian broadcasting system.
  2. At the time of the public hearing, Salt Spring had a total shortfall in CCD contributions over the licence term of $9,000. The licensee did not make these CCD payments by the dates that they were originally due. The licensee had ample time to pay these outstanding amounts to eligible initiatives in the intervening period. While the licensee submitted a copy of a cheque in the amount of the shortfall on the thirtieth day after the start of the public hearing, this does not constitute proof that the required amount has been paid. As noted in Broadcasting Information Bulletin 2011-795, the Commission generally requires copies of cancelled cheques or receipts for CCD payments, which can demonstrate that the cheque has been cashed or the amount otherwise paid. The licensee submitted insufficient proof of payment within the promised time period.
  3. In addition to the non-compliance previously identified in its letter of 21 January 2013, the Commission therefore finds the licensee in non-compliance with the Commission’s direction in its letter dated 21 January 2013, with condition of licence 5 as set out in the appendix to Broadcasting Decision 2007-387 for the 2011-2012, 2012-2013 and 2013-2014 broadcast years and with section 15(2)(a) of the Regulations for the 2011-2012 and 2012-2013 broadcast years.

Tangible benefits

  1. In the letter of 21 January 2013 approving the change of ownership of Salt Spring, the Commission stated:
    In light of the above, the Commission requires the payment of tangible benefits corresponding to a minimum direct financial contribution of $20,112 (representing 6% of $335,200). The Commission requires that this contribution be spread equally over a seven-year period as follows:
    • 3% ($10,056) to the Radio Starmaker Fund;
    • 1.5% ($5,028) to FACTOR or MUSICACTION;
    • 1 % ($3,352) at its discretion, to any eligible Canadian Content Development initiative; and,
    • 0.5% ($1,676) to the Community Radio Fund of Canada.
  2. The licensee had not claimed any tangible benefits payments for the 2012-2013 and 2013-2014 broadcast years, resulting in an apparent shortfall of $5,746.
  3. At the hearing and in subsequent correspondence, Salt Spring indicated that the amount was outstanding and indicated that it would pay the shortfall within 30 days following the public hearing.
  4. On 12 June 2015, the Commission received copies of four cheques to the Radio Starmaker Fund in the amount of $2,873, to FACTOR in the amount of $1,436, to Music BC in the amount $957, and to the Community Radio Fund of Canada in the amount of $478.
Commission’s analysis and decisions
  1. Since the Commission does not solicit competitive applications for changes in effective control of broadcasting undertakings, the onus is on the applicant to demonstrate that approval is in the public interest. One way that this is accomplished is through the payment of tangible benefits that are commensurate with the size and nature of the transaction.
  2. The Commission approved Satnam’s acquisition of Salt Spring, at least in part, on the basis that tangible benefits as outlined above would be paid. At the time of the public hearing, Salt Spring had a total shortfall in tangible benefits payments since acquiring the station of $5,746. The licensee did not pay the amounts for the 2012-2013 and 2013-2014 broadcast years by the time they were due.
  3. While the licensee submitted copies of cheques in the amount of the shortfall on the thirtieth day following the start of the public hearing, the Commission considers that, in the absence of supporting documentation such as copies of cancelled cheques or receipts, the licensee has provided insufficient proof of payment for its outstanding tangible benefits.
  4. The Commission therefore finds the licensee in non-compliance with its obligations with respect to tangible benefits from the 2012-2013 and 2013-2014 broadcast years.

Ability of the licensee to operate in compliance

  1. The Commission has reviewed the various measures it may adopt to ensure that broadcasting licensees meet their obligations where it finds that they are in non-compliance, such as mandatory orders and short-term renewal, suspension, non-renewal or revocation of the licence, all of which were set out in Broadcasting Notice of Consultation 2015-84 and discussed with the licensee at the hearing.  
  2. The licensee was of the view that the Commission should renew the licence for a full seven-year term. Mr. Dhillon indicated that he did not oppose the imposition of mandatory orders. He submitted that the additional resources that would be available following the change to CFSI-FM’s ownership structure and the hiring of a new station manager would ensure that the station fulfilled its regulatory obligations.
  3. As noted above, the Commission took the extraordinary step of summoning Salt Spring to a show cause hearing in January 2014, part of the way through a licence term. As a result of that hearing, the Commission issued six mandatory orders requiring Salt Spring to comply with various provisions of the Regulations.
  4. These mandatory orders were issued in June 2014. Now, approximately one year later, the licensee has been found in non-compliance with three of these mandatory orders, as well as with a number of separate regulatory obligations, including the Regulations, its condition of licence with respect to CCD and its obligation to pay tangible benefits. Further, the licensee only submitted one of the four quarterly reports that the Commission expected in to submit in Broadcasting Decision 2014-330. When asked to comment on his failure to meet this expectation, Mr. Dhillon stated “... every time we were working on the quarterly reports there were some issues that came up with the staff and everything. I think it’s an oversight on my part.”Footnote 4
  5. The Regulations, conditions of licence and mandatory orders are some of the key tools that the Commission uses to fulfill its mandate to regulate and supervise the Canadian broadcasting system in the public interest, within the framework created by the Act. The Commission takes non-compliance with these regulatory obligations seriously and reacts to instances of non-compliance by licensees in the manner dictated by the circumstances.
  6. In light of the number of instances of non-compliance, their severity and their reoccurrence as detailed above, the Commission is gravely concerned that, going forward, the licensee will be unable to make the changes necessary to bring itself into compliance with the Regulations, its conditions of licence and the mandatory orders under which CFSI-FM operates.
  7. At the 2014 Surrey hearing, Salt Spring outlined a number of measures that it had implemented to ensure future compliance. The Commission considers that even where these measures have been implemented and maintained, they have failed to result in substantially improved compliance. A responsible licensee would have taken immediate action to come into compliance and remain in compliance with all of its regulatory obligations. The Commission has no faith that the measures proposed by Mr. Dhillon at the 13 May hearing would prove any more effective.
  8. The Commission is also concerned by Mr. Dhillon’s cavalier attitude to compliance, as demonstrated by his seeming reluctance to accept full responsibility for Salt Spring’s non-compliance. At the hearing, Mr. Dhillon admitted that, since the January 2014 public hearing, he was physically present at the station only once a month. In response to questions about why he was not there more often, Mr. Dhillon stated “because everything was going fine.”Footnote 5The record of this proceeding demonstrates that, while the licensee accepted a degree of responsibility for the station’s non-compliance he also, on multiple occasions, attempted to shift accountability onto staff, volunteers or consultants. At the hearing, Mr. Dhillon stated, “... I just took a backseat. Okay, they [the staff and the consultant] are handling it. I will let them handle it.” Footnote 6 With such a cavalier attitude, the Commission cannot be confident that Mr. Dhillon will make the changes necessary to ensure compliance.
  9. The Commission considers that the issues of non-compliance described above, when taken cumulatively, are extremely serious. The provision of complete annual returns, and complete and accurate program logs and music lists are fundamental to the Commission’s ability to monitor the station. These also become important indicators of whether the licensee has the stability and knowledge necessary to bring itself into compliance and keep itself there. CCD and tangible benefits obligations exist to serve the health of the Canadian broadcasting system. The Commission has no confidence that the licensee will operate in compliance going forward. The Commission considers that the licensee has neither the will nor the ability to institute the measures necessary to ensure compliance with the Regulations, its conditions of licence, and its mandatory orders during the remainder of the current licence term or in a subsequent licence term.

Conclusion

  1. In light of all of the above, the Commission revokes the broadcasting licence for the commercial specialty radio programming undertaking CFSI-FM Salt Spring Island and its transmitter CFSI-FM-1 Mount Bruce, British Columbia. The revocation is effective 25 July 2015, and the licensee must cease broadcasting by no later than the end of the broadcast day on that date.
  2. In light of the revocation, the Commission finds that it is not necessary to rule on the application to amend Salt Spring’s ownership structure.

Secretary General

Related documents

Footnotes

Footnote 1

Transcript, 13 May 2015 public hearing, volume 2, para. 2366.

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Footnote 2

Transcript, 13 May 2015 public hearing, volume 2, para. 2464

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Footnote 3

Transcript, 13 May 2015 public hearing, volume 2, para. 2502

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Footnote 4

Transcript, 13 May 2015 public hearing, volume 2, para. 1753

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Footnote 5

Transcript, 13 May 2015 public hearing, volume 2, para. 1537

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Footnote 6

Transcript, 13 May 2005 public hearing, volume 2, para. 2229

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