Broadcasting - Staff Letter addressed to Susan Wheeler (Rogers Communications Canada Inc.)

Gatineau, 21 July 2025

BY EMAIL

Susan Wheeler
Vice President, Regulatory, Broadcasting
Rogers Communications Canada Inc.
One Mount Pleasant Road, 4th Fl.
Toronto, Ontario M4Y 2Y5
cable.regulatory@rci.rogers.com

Subject: Part 1 Application for authority to operate linear community channels serving select licensed and exempt broadcasting distribution undertakings pursuant to four proposed zones – Application 2024-0219-7 – Request for information

Susan Wheeler,

This is in reference to the above-referenced Part 1 application by Rogers Communications Canada Inc. (Rogers) for authority to operate linear community channels serving licensed and exempt terrestrial broadcasting distribution undertakings (BDUs) in British Columbia, Saskatchewan and Manitoba pursuant to four proposed zones, as follows:

• Zone 1: Vancouver Island (Victoria, Nanaimo, Langford (Saanich/Sooke), Campbell River, Courtenay/Comox/Powell River, Duncan, Parksville, Port Alberni, Royal Oak, Salt Spring)
• Zone 2: Southern Interior British Columbia (Kelowna, Castlegar, Cranbrook, Penticton, Salmon Arm, Vernon, Winfield)
• Zone 3: Central Saskatchewan (Saskatoon, Moose Jaw, Prince Albert)
• Zone 4: Southern Manitoba (Winnipeg, where Rogers already operates two licensed BDUs, Lorette, Portage la Prairie)

To pursue the analysis of the above-noted application, please provide the following:

Community of Interest: Outreach to Indigenous communities

In its application, Rogers’ Community of Interest analysis outlines how the communities within the proposed zones share one or more of the identified attributes, including a common heritage, culture, or history of different Indigenous communities. While both the progress reports and the application of the Community of Interest test indicate efforts to serve Indigenous communities, it appears that the information provided does not sufficiently explain the potential impact of the proposed zone-based approach on these communities.

To allow for a more fulsome assessment, Commission staff requests the following additional information:

1. Outreach and Engagement: A detailed description of outreach and engagement activities undertaken with Indigenous communities in the proposed zones, including the nature, frequency, and outcomes of those interactions.
2. Impact on Content: How feedback from Indigenous communities will influence programming decisions and the representation of Indigenous perspectives on Rogers’ community channels.
3. Impact on Financials: How the zone-based approach might affect resource allocation, funding, or support dedicated to Indigenous content or initiatives.
4. Hiring of Indigenous Community Ambassadors: Provide an update since the publication of Rogers’ 2024 Cultural Diversity Report.

Distribution of independent community channels within proposed zones

Licensed independent community programming undertakings may operate in areas where a terrestrial BDU does not provide a community channel. In such instances, they must be distributed by licensed BDUs as part of the basic service pursuant to section 18(2)(a) of the Broadcasting Distribution Regulations. BDUs must also offer community-based low-power television undertakings and community-based digital services, where available within their service area. Community-based low-power television stations are considered local television stations in areas where they are available over-the-air and therefore must be distributed as part of the basic service in such areas, pursuant to paragraph 17(1)(c) of the Broadcasting Distribution Regulations and to Terms and conditions of the exemption order for terrestrial broadcasting distribution undertakings serving fewer than 20,000 subscribers, Broadcasting Order 2017-320, 31 August 2017. In the case of community-based digital services, a description of the geographic area to be served would form part of a condition of service on the nature of service.

You state that the authority to operate zone-based linear community channels is needed considering the decrease in the “financial resources available to each community channel,” among other things. However, should Rogers’ application be approved, it is unclear how Rogers would distribute an independent community station within its proposed zones.

Commission staff therefore requests the following additional information:

1. If an independent community station were to launch in one of the four proposed zones, would Rogers’ BDUs distribute the newly launched independent community-based low-power television undertakings across all service areas within those zones?

Financial impacts of the proposed zones

You state that this application is needed to mitigate the difficulties in providing and maintaining quality community programming in small licensed and exempt service areas where financial resources are limited. To better understand the direct financial impact of this proposal, Commission staff requests the following additional information:

1. Should this application be approved, provide three years of financial projections (revenues and expenses) for the four proposed zones. Alternatively, should this application be denied, provide three years of financial projections (revenues and expenses) for the separate undertakings. Use the table in the Appendix below to present both projections.
2. Should this application be approved, will programming investments be impacted? If so, elaborate.
3. Should this application be approved, what type of synergies could be leveraged between the affected undertakings What kind of resources would be shared (i.e. staff, facilities, etc.)?

Portions of the application filed in confidence

In its application, Rogers has designated certain portions of its application as confidential, citing Procedures for filing confidential information and requesting its disclosure in Commission proceedings, Broadcasting and Telecom Information Bulletin CRTC 2010-961, 23 December 2010, and sections, as well as articles 31 and 32 of the CRTC Rules of Practice and Procedure. Rogers submits that the information in the question constitutes commercial information that has been consistently treated as confidential. According to Rogers, the disclosure of this competitively sensitive information could prejudice its competitive position and provide competitors with detailed insights that could result in direct and specific material harm. Rogers also maintains that the public interest would not be negatively affected by treating this information as confidential.

Accordingly, provide a detailed explanation of how the disclosure of the following confidential information could reasonably result in direct and specific material harm to Rogers:

• Number of repeats in the 2023 Broadcasting Year
• Pre-zone – Average original hours of access and local programming across individual systems within proposed zones
• Post-zone – Estimate of original hours of access and local programming by zone-based channels
• The year’s total Broadcast Day hours

This information requested herein should be received by the Commission by no later than 11 August 2025.

A copy of this letter and your reply should be added to your application to be made available for public examination.

We also ask that your repeat each question in your reply.

Please note that, following receipt of your responses to the above, further clarification questions may be forthcoming.

The Commission requires that your response and/or other documents be submitted electronically by using the secured service “My CRTC Account” (Partner Log In or GCKey) and filling in the “Broadcasting Cover Page” or the “Broadcasting Online Form and Cover Page” located on this Web page. Also, on this Web page you will find information on the submission of applications to the Commission “Submitting applications and other documents to the CRTC using MY CRTC Account.”

Should you need further information concerning this application, please do not hesitate to contact me by email at mahtab.katz@crtc.gc.ca.

Best regards,

Mahtab Katz
Senior Analyst, Audiovisual Distribution, Broadcasting

c.c.: CACTUS (cathy@timescape.ca)

Appendix: Financial projections with and without approval of the application

Date modified:

2025-07-21