Broadcasting - Secretary General Letter addressed to Suzanne Lamarre (Lamarre, Conseils stratégiques)
Ottawa, 23 December 2024
Reference : 2024-288
Public Record: 1011-NOC2024-0288
BY EMAIL
Suzanne Lamarre
Strategy & Regulatory Affairs Advisor
Lamarre, Conseils stratégiques
suzanne@lamarrestrategies.com
Subject: Request regarding The Path Forward – Defining “Canadian program” and supporting the creation and distribution of Canadian programming in the audio-visual sector, Broadcasting Notice of Consultation CRTC 2024-288, 15 November 2024
Dear Suzanne Lamarre,
Thank you for your letter dated December 12, 2024, regarding The Path Forward – Defining “Canadian program” and supporting the creation and distribution of Canadian programming in the audio-visual sector, Broadcasting Notice of Consultation 2024-288 (NoC 2024-288).
You requested that the Commission's instruction in NoC 2024-288 limiting interventions to 20 pages be modified and increased to 24 pages for submissions written in French.
The Commission has considered the reasons you raised in your request. It acknowledges the summary and analysis exercises represented by drafting an intervention on such important subjects as those explored in NoC 2024-288, and that the 20-page limit may be more restrictive for interventions written in French.
Furthermore, the Commission is aware of its obligations under the Official Languages Act, including its duty as a federal institution to take positive measures in further promoting the equal status and use of French and English.
However, the Commission notes that no evidence was presented in the request to justify why certain interventions require more than 20 pages, or to specify the exact number of pages that would be necessary for these interventions.
Imposing the same space limits on interventions written in both English and French is consistent with the procedure followed by the Federal Courts. Nevertheless, parties wishing to submit interventions exceeding the maximum page limit established in NoC 2024-288 can submit a procedural request to the Commission along with evidence demonstrating that redress is necessary. While handling these procedural requests individually based on their own merits, the Commission will consider, to the extent that is reasonable, some flexibility within the limits of its discretion. These considerations will include, notably, the realities specific to French language.
If you have any questions, you may contact Scott Shortliffe, Vice-President of Broadcasting, at scott.shortliffe@crtc.gc.ca.
Yours sincerely,
Marc Morin
Secretary General
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