Research & Submissions > 1999 > April 12, 1999

A Submission to the Canadian Radio-television
and Telecommunications Commission with Respect to

Public Notice CRTC 1999-30

Call for Comments Concerning

A Proposed New Policy for Campus Radio

Prepared by:

Radio Board

April 12, 1999

CAB SUBMISSION  
A Proposed New Campus Radio Policy

Table of Contents

1. Campus Radio's Unique Contribution to Canadian Broadcasting

1.1 CAB Supports Role Of Campus Radio

1.2 Distinctive Programming

1.3 Canadian Talent Development And The Radio `Stars' Of Tomorrow

1.4 Supporting New Musical Genres

2. Strengthening Campus Radio's Position

2.1 Streamlining The Regulatory Approach

2.2 French-Language Stations

2.3 Structure Of The Board Of Directors

3. Advertising & Finance

3.1 Current Advertising/Sponsorship Approach Is Working

3.2 Maintaining Alternative Orientation

3.3 Impact On Commercial Radio

3.4 Cross-Sector Support

4. Programming

4.1 New Forms Of Expression

4.2 Musical Genres

4.3 New Music Incentives

4.4 Creation Of A Music Bank

4.5 Reassessing Musical Categories And Definitions

5. Developmental Stations

5.1 Support For Low-Power Stations

5.2 Caution In Granting Licences

6. Harmonizing the Policy Frameworks

7. Conclusion

Appendix A: Letter from FACTOR (available on request)

1. CAMPUS RADIO'S UNIQUE CONTRIBUTION TO CANADIAN BROADCASTING

1.1 CAB Supports Role Of Campus Radio

The Canadian Association of Broadcasters (CAB) represents the vast majority of private broadcasters - including radio and television stations and networks, and specialty television services. More specifically, CAB's members include the majority of private commercial radio licensees and, on their behalf, the Association wishes to underline their recognition of the important role played by the campus radio sector in enriching the Canadian broadcasting system.

The CAB appreciates this opportunity to present its views on the CRTC's proposed new campus radio policy. The Association also wishes to thank the Commission for organizing the meeting last September that brought together representatives from the National Campus Radio Association (NCRA), the CRTC, the CAB and the CBC. This discussion afforded the CAB a clearer understanding of campus radio's views on key issues that affect their operations, as well as areas in which private broadcasting may be able to provide assistance. The CAB recognizes the key role the thousands of volunteers and staff have played over the years in developing the sound and personality which sets campus radio apart from the mainstream broadcasters.

Underlying the CAB's comments on the proposed new policy is our support for the CRTC's overall objectives for campus radio that set goals for providing programming that differs from conventional radio and promoting alternative Canadian music not generally aired by other stations. The Association believes that a policy framework that reduces the regulatory burden and allows greater flexibility will encourage experimentation and creativity within campus radio. Further, the CAB believes that reinforcing campus radio's non-commercial nature is vital to maintaining this important role.

1.2 Distinctive Programming

Campus radio stations provide distinctive programming not available on either privately owned stations or, in many instances, on the CBC. The traditional regulatory framework for campus radio has enabled these stations to produce and air cutting-edge, non-commercial music and spoken word content that provides a unique forum for expression for specialized audiences.

1.3 Canadian Talent Development And The Radio `Stars' Of Tomorrow

Campus radio makes valuable contributions in the area of Canadian Talent Development and training for tomorrow's future private broadcasters. A key objective of the CAB's members is to develop Canadian broadcasting “stars”, not only in terms of the artists who create music, but also program producers, editors, copy writers, technicians, and on-air talent.

Campus radio is a particularly good vehicle to expose Canadians to non-commercial music. For example, many new Canadian artists are encouraged by campus radio to provide rough demos for airplay. While perhaps not suited for commercial airplay, these demos give our young artists much needed experience and exposure. Campus radio also provides Canadians with an outlet to hear new concepts in music and artists, thereby contributing early on in the process of building Canadian musical stars.

Campus radio is also an invaluable training ground for aspiring broadcasters. “Chicken Shwarma”, a popular on-air personality at The Edge 102.1 in Toronto (Shaw Radio Ltd), and Danielle Holke, an Internet and computer authority who provides on-air resource to Edge listeners, are just two of the campus radio grads who have gone on to a successful professional career in private radio. There are many, similar stories at CAB member stations across the country.

1.4 Supporting New Musical Genres

We agree with the CRTC's Public Notice on the proposed campus radio policy when it states that:

“Campus stations help to introduce new musical genres, which may later be adopted by commercial stations...the Commission considers that campus stations may have a special role to play in developing Canadian creative talent in new and emerging musical genres.”

Perhaps the most striking example of this was campus radio's championing of the alternative rock sound prior to its acceptance as a mass appeal format. We believe it was a significant contributor to enabling what was then only an emerging musical genre to build a loyal following that eventually led to its transition to commercial radio.

2. STRENGTHENING CAMPUS RADIO'S POSITION

2.1 Streamlining The Regulatory Approach

The CAB supports the CRTC's objective to simplify the rules and regulations to enable campus radio to devote more time to the production and broadcast of alternative programming. The Association believes this is appropriate given the nature of campus radio and its heavy reliance on volunteer staff that results in frequent turnover. The CAB agrees that greater regulatory flexibility and a reduction in administrative burden will assist campus stations, their staff and volunteers to meet this objective.

Streamlining Regulation

The CAB, therefore, supports the Commission's streamlining proposals in the following areas:

a) drop the level of hits from 15% to 10% for campus/community.

b) removal of requirement for 20% of Category 2 music to come from subcategories other than `Pop, Rock and Dance'.

c) simplification of the application process through the elimination of the Promise of Performance requirement in the application process.

d) elimination of the distribution requirement

e) removal of the repeat factor.

Support For Distinctive Campus Radio Programming

The Association also supports the following initiatives designed to reinforce the distinctive nature of campus radio:

a) maintaining the 25% spoken word requirement. We believe this is fundamental in ensuring that campus radio provides diversity and is distinctive from commercial broadcasting. In-depth spoken word programming is an important element in responding to community needs, while at the same time helping to develop copy and news writing skills that are highly valued in the commercial sector.

b) maintaining the requirement that 5% of music played on campus stations should come from category 3.

c) increasing the required weekly minimum level for Canadian content in category 3 music from 10% to 12%.

d) requiring a minimum of two thirds of programming to be produced locally by the station. This is another initiative we support because locally-produced programming is reflective of the community served by the station, adds diversity, and will provide excellent training for those involved.

CAB members are concerned that removal of several programming requirements (such as removal of the requirement for 20% of category 2 music to come from subcategories other than Pop, Rock and Dance) could lead to some campus stations being tempted to move away from their alternative role. The CAB looks to the Commission to monitor the development of campus radio on a case-by-case basis to ensure that it continues to play the essential role of providing programming that is distinctive from that of commercial radio.

Support For Canadian Music And Artists

The CAB recognizes campus radio's concerns about the availability of Canadian recordings in emerging genres, however, the CAB believes that campus stations can, and should be expected to, meet the same overall Canadian content requirement as other broadcasters. The Association, therefore, supports the proposal to increase the Canadian content level for campus radio to 35% in category 2 music.

2.2 French-Language Stations

The CRTC currently requires that French-language stations play a minimum 65% of French-Vocal Music selections from Category 2, and that these selections be scheduled in a reasonable manner throughout the day.

In terms of other provisions in the campus radio policy, the CAB believes that French-language campus stations should be governed by the same requirements as their English-language counterparts with respect to policies designed to ensure the distinctive nature of campus radio. The CAB further believes that French-language campus stations should also benefit from the streamlined regulatory proposals.

2.3 Structure Of The Board Of Directors

We agree with representatives of the campus radio community on the importance of having balanced representation on station boards, so that the interests of the community at large, the educational institution to which the station is affiliated, station staff and volunteers, as well as students are taken into account. The CAB is, therefore, supportive of any initiatives in the area of governance to promote balance and encourage longer terms for board members.

3. ADVERTISING AND FINANCE

The CAB believes removing limits on conventional advertising for campus stations could jeopardize the alternative nature of campus radio and, therefore, its key role within the Canadian broadcasting system. For the reasons outlined below, the Association recommends that the CRTC not proceed with proposals to eliminate the restricted advertising requirement.

3.1 Current Advertising/Sponsorship Approach Is Working

In reviewing the revenue picture for campus radio, the following facts speak in favour of the existing regulatory approach to advertising and sponsorship:

• Statistics Canada data indicates that revenues from local sales and other sources remained relatively stable in the period 1994 - 1997.
• During that period, other revenues, which include sponsorship, represented between 60% and 70% of total revenues.
• Grants to campus stations increased by 15%, during the same period.

During the September 1998 consultation process, the NCRA noted that:

“...there is no station in the campus community radio sector at all, that I have talked to or that who has written to me anything, that wants to do more advertising and that nobody gets their four minutes an hour.”

This is not to say that campus radio, like all sectors of the radio industry, does not face financial challenges. The CAB believes, however, that the above numbers reinforce its view that the current policy, including the limitation of conventional advertising by campus radio to 25% of total weekly advertising, is working.

3.2 Maintaining Alternative Orientation

The CAB is concerned that the removal of the restricted advertising component in CRTC policy could inevitably lead to an orientation away from `free radio' to an approach that is commercially driven. In our view, there is the real possibility that campus radio's alternative programming could be seriously compromised by pressure to move toward more mainstream programming in order to satisfy the needs of advertisers.

We believe the CRTC was correct in its Public Notice 1992-38 on Policies for Community and Campus Stations when it stated that:

“The Commissions' position has always been that campus stations should not rely heavily on advertising revenues lest this cause stations to adopt programming that is similar to that of commercial stations.”

The Commission went on to say that:

“...it considers that campus/community stations have a certain advantage over community stations in that they generally have a large membership of students to provide base funding while, for many community stations, sources of government funding are being reduced.”

The December 5, 1998 Toronto Star contained a report on the controversy surrounding the decision by the Board of Toronto University station CIUT to switch its sponsorship focus from local retailers to corporate sponsorship by large national companies such as HMV and Tower Records. According to the article, CIUT has developed a budget projecting 1998/99 revenues of $725,895, compared to last year's budget of $350,000. It appears that this target has led to a desire to maximize commercial revenues, and sparked not only resignations from the Board but substantial concern among station volunteers about a re-orientation away from `free radio' to an approach that is commercially driven.

In its proposed new campus radio policy, the Commission suggests that eliminating advertising restrictions is intended, in part, to streamline the administrative burden of campus stations. The CAB would suggest, however, that the opposite is likely to happen as stations add sales staff and undertake the administrative activities required to satisfy the demands of conventional advertisers. In CIUT's case, for instance, the Toronto Star article notes that staff size has doubled in recent years, with management salaries in the area of $30,000 on average per year. More aggressive advertising activity would undoubtedly exacerbate this situation.

3.3 Impact On Commercial Radio

Although campus stations do not currently generate sufficient reported audiences to negatively impact commercial stations, private broadcasters are concerned that removal of the advertising restrictions may lead to future competitive issues. Advertising rates for campus stations tend to be less that those of their private sector counterparts. Greater commercial availability, at rates often lower than commercial rates, will have an impact on commercial broadcasters, particularly in smaller markets. The first signs of such a development are already evident in smaller markets where our members have difficulty competing with local campus stations. Small market commercial stations do not have access to national advertising and rely almost solely on local advertising. Any expansion in campus radio's local advertising sales will impact directly on this limited commercial sector.

3.4 Cross-Sector Support

There are many instances across Canada of CAB members providing tangible and intangible assistance to campus stations. Examples of tangible support include the funding for scholarships and training workshops provided by The Edge 102.1 and Standard Broadcasting's contribution to the NCRA of upwards of $100,000 in recent years. We note that the CBC has a range of programs that can be accessed by campus radio staff and volunteers for training and on-air exposure.

CAB recognizes that there may be a need in the future for more diversified revenue sources for campus radio and believes it should be encouraged to develop a variety of revenue streams. With this in mind, during the campus radio consultations, the CAB indicated that some of its members would be more than willing to provide Canadian Talent Development funds (CTD) to campus radio. In CRTC Public Notice 1999-30, the CRTC has encouraged the NCRA to consider establishing its own third-party agency, enabling it to receive CTD contributions. The CAB encourages the NCRA to submit to the CRTC a proposal for the development of an independent, third-party funding organization to act as a mechanism for receiving contributions from private broadcasters through the Benefits and Canadian Talent Development programs.

There are also less-tangible ways in which CAB members support campus radio. For instance, at the September 1998 meeting with the CRTC, NCRA and the CBC, campus representatives noted that they receive information and CDs of new releases from FACTOR sporadically, if at all.

Subsequently, the CAB asked FACTOR to consider providing all campus stations with its releases. We are pleased to announce that, on March 29, 1999, FACTOR's Board of Directors adopted a policy whereby campus stations will now automatically receive copies of all new CD releases (see Appendix A). Private broadcasters are more than willing to use their expertise and contacts to assist campus stations in accessing product and information or to overcome other barriers they may face.

4. PROGRAMMING

4.1 New Forms Of Expression

In keeping with it's innovative nature, campus radio is working with new forms of expression such as the creative manipulation of existing musical selections in the forms of `turntablism' and `radio art', as defined in the Public Notice announcing the proposed new campus radio policy. While the CAB believes that live performances by turntablists or radio art producers in performance venues may be viewed as artistic creations by those attending, we do not believe they should qualify for the purposes of calculating compliance with Canadian content requirements.

As the Commission has noted in Public Notice CRTC 1998-41, the MAPL criteria and the minimum requirements for Canadian content have two essential objectives: 1) to ensure that Canadian artists and their works have access to Canadian airwaves; and, 2) to support a Canadian-based music and recording industry. In the same notice, the CRTC concluded that it was not convinced that allowing an `artist only' recording to automatically qualify as Canadian would assist in achieving the second objective.

Under the MAPL system used to qualify a Canadian musical selection, it is difficult to argue that `turntablism' and `radio art' meet the criteria for the music being performed principally by a Canadian, especially when the content may, in fact, be an international musical selection. Even if the definition could be stretched to accommodate this, it would be the only criteria met, therefore not meeting the general requirement to satisfy at least two criteria in order to be considered a Canadian selection.

We also think a parallel can be drawn between `turntablism' and `radio art' and the shortening of musical selections, an issue raised during the commercial radio policy review. In that instance, the Commission determined that selections must be played in their entirety in order to qualify for the purposes of calculating Canadian content.

There is also the additional issue of whether `turntablism' and `radio art' at the station level may be viewed as possible copyright infringement by artists. Royalty payments and the increased administrative burden on station staff are other factors campus stations should consider in the use of these genres. During the campus consultation, copyright issues were raised. It was noted that campus stations received selections, which were labeled `sample friendly'. None of the programmers the CAB consulted were familiar with the term `sample friendly', nor have they received any selections that were labeled in this manner.

4.2 Musical Genres

The development of new artists and genres of music is, the CAB believes, inextricably linked to Canadian radio's future success. As noted earlier, we see the role of campus radio in this process as a vital one.

Continuing to push the envelope for new alternative music, campus radio is now exploring the genres of `international', `urban' and `electronica' music. The campus radio community has suggested that reduced Canadian content levels should be applied to programming devoted to these genres, in light of the limited supply of Canadian product.

The CAB would make the following observations:

• while sympathetic to the challenges faced by campus stations with new emerging genres, they are the same as those encountered when campus radio introduced alternative music more than a decade ago.
• as with alternative music then, we are confident campus radio today can be successful in developing the `international', `urban' and `electronica' genres and meet the overall 35% Canadian content requirement, without genre-specific content levels. as the CAB demonstrated during the CRTC's commercial radio policy review, limited availability is also an issue for other genres. The Commission's music availability study conducted for the campus policy review confirms that genres such as classical, contemporary classical, music by first nations peoples, and some sub-categories of rock all face similar problems.
• the questions raised by the CRTC in relation to the appropriate level of Canadian content for periods in which programming is devoted to genres are important, but the CAB believes it is premature to attempt comprehensive answers and recommendations
• Heritage Canada is currently conducting a full review of the sound recording industry and the CAB suggests that it would be appropriate to wait for the conclusion of this process and the release of its recommendations before the Commission finalizes its approach.

In summary, CAB believes that should the CRTC introduce reductions for specific new genres at some point, they should apply to all radio licensees. Greater demand would be generated for these genres by encouraging their exposure to the widest possible audiences, thereby more fully meeting the objectives of the Broadcasting Act.

4.3 New Music Incentives

The CAB would recommend that the CRTC consider an alternative approach.

During the Fall of 1998, the CAB proposed to the Commission a series of initiatives entitled Building New Canadian Talent for the Future and Mise en valeur des artistes-interprètes, des auteurs, des compositeurs et des producteurs. The CAB believes this proposal also could be of significant benefit to campus radio.

The CAB draws attention, in particular, to its recommendation that a 150% time credit be applied to qualifying new Canadian musical selections broadcast Sunday to Saturday, between 6 a.m. and midnight. Recognizing the more limited inventory of new Canadian French vocal musical selection, the CAB recommends that a 200% time credit be applied to the first two French-language musical selections, with a 150% time credit applying to subsequent selections.

Since music availability and accessibility is often more challenging in Québec, the CAB recommends that francophone campus stations also be permitted to qualify for the new music incentive as it applies to French Vocal Music.

Private broadcasters believe these changes in policy would allow campus stations the flexibility they need to develop new genres of music, while living up to the same overall Canadian content requirements as private radio. In addition, this avoids the introduction of genre-specific Canadian content levels that would be unfair to other genres and licensees, as well as making the administrative process and the MAPL system unnecessarily more complicated.

4.4 Creation Of A Music Bank

Recognizing the difficulties campus stations face in obtaining music selections and the communications problems which exist between campus stations, the CRTC should consider recommending that campus stations create an Internet music bank. Such a bank would list various music sources, new releases, and other relevant information.

The CAB made a similar proposal in its submission to the Commission's Ethnic Policy Review and believes it is an initiative that would work equally well for the campus sector.

4.5 Reassessing Musical Categories And Definitions

The CRTC Public Notice 1999-30 raised the issue of availability of music in `international', `urban', `electronica' and other genres. How these genres should be defined is not confined to campus radio, but are of relevance to the entire radio industry. In fact, the majority of the CAB's members would agree that the categories are too complicated and out of date, given the evolving nature of music.

The CAB suggests that the time is appropriate to reassess musical categories and definitions and suggests that the CRTC may find a separate public review process beneficial in bringing these important tools up-to-date.

5. DEVELOPMENTAL STATIONS

5.1 Support For Low-Power Stations

The CAB supports the proposed licensing of low-power FM campus stations. This approach is attractive in giving those interested in campus radio an opportunity to experiment and learn during a developmental period before deciding whether or not to apply for a full-fledged campus radio licence.

The regulatory framework proposed by the Commission for developmental stations is, in our view, reasonable and does not impose an undue regulatory burden. At the same time, we welcome the assurance contained in Public Notice CRTC 1999-30 that: “Licensed developmental stations will be subject to fundamental requirements such as those concerning Canadian ownership, technical certification by the Department of Industry, and adherence to standard industry self-regulatory codes.”

5.2 Caution In Granting Licences

Though the CAB supports licensing low-power FM campus stations, we would ask the CRTC to proceed with caution in granting licences.

While new campus stations are starting up, notably the three now ready to go on-air in Winnipeg, many well-established campus stations have been facing financial difficulties. The CAB's concern is the potentially negative impact on campus stations should they be put into a highly competitive situation because of the launch of multiple campus operations. We would regret seeing a repetition here of the American experience, where many campus stations have essentially become mainstream stations.

The CAB also recommends that since developmental stations are `experimental' and use a five-watt transmitter, they should not be permitted to solicit carriage on their local cable system until they have applied for full campus status.

6. HARMONIZING POLICY FRAMEWORKS

The CAB's members strongly urge the Commission to maintain separate policies for campus and community radio. The Association believes that campus stations as compared to community radio have fundamentally different roles to play within the Canadian broadcasting system, and, as such, deserve policy frameworks and review processes tailored to their particular issues and situations.

In general terms, campus stations make a unique contribution to Canadian broadcasting through their airplay of cutting-edge music in new and emerging, or seldom heard, genres as well as their spoken-word programming. Community stations, on the other hand, generally provide programming that appeals to a more mainstream audience. There are community stations that are now operating virtually as if they were commercial broadcasters. Statistics Canada data indicates that, since the CRTC removed advertising restrictions for community radio, the sector's dependence and focus on advertising has increased substantially. In fact, Statistics Canada now classifies some community stations as commercial broadcasters because advertising revenues represent more than 50% of their total revenues.

In its last review of campus radio, the CRTC stated that it wanted to ensure campus stations provide a service that is complementary, not only to that of commercial broadcasters, but also to community stations. The Commission, therefore, adopted an approach to applications for new licences and licence renewal that requires campus stations to demonstrate how their service will be different from other stations, including community stations. The CAB supports the objective of maintaining campus radio as unique and different from community radio as much as from private broadcasting and the CBC.

A primary danger we see in harmonizing policy frameworks is the potentially negative impact it could have on maintaining the distinctiveness between campus and community stations. Campus radio stations, in particular, may well find themselves under increasing pressure to become de facto community stations, with less risk taking on new music and more emphasis on serving a mainstream audience.

The CAB also sees significant challenges in determining which policies are retained in a harmonized framework and how they would apply to the two very distinct types of radio undertakings. For instance, would all of the regulatory requirements now applied to community radio be added on to campus stations? Or would the streamlining now proposed for campus radio such as the removal of the promise of performance be extended to community stations? Given community radio's growing dependence on advertising and the trend toward providing a service quite similar to commercial radio, we do not believe it warrants the same degree of flexibility and streamlining as campus radio.

7. CONCLUSIONS

In summary, the regulatory framework for campus radio has generally worked well in ensuring campus stations remain a source of alternative programming, while allowing enough flexibility in advertising and sponsorship to provide relatively stable funding levels.

In order to strengthen campus radio's position further, the CAB supports initiatives in the proposed new policy designed to encourage diversity and to streamline the regulatory regime for campus stations.

Regulatory Streamlining

In particular, the CAB supports the following proposals for streamlining the regulatory process:

• decrease in the level of hits to 10% for campus/community stations
• removal of the requirement for 20% of category 2 music to be from subcategories other than Pop, Rock and Dance
• removal of the repeat factor rule
• elimination of the distribution requirement
• simplified application process, including the elimination of the Promise of Performance
• streamline the licensing approach for low power development campus stations
• apply the same streamlining rules for Francophone stations as those proposed for English-language stations

Mechanisms To Ensure Diversity

The Association also supports the proposals designed to strengthen campus radio's alternative nature, which contributes diversity to Canadian broadcasting. They are:

• maintenance of the 25% spoken word requirement
• maintenance of the requirement for 5% of music to be from category 3
• an increase from 10% to 12% Canadian content in category 3 music
• implementation of a requirement for two-thirds of programming to be locally produced

• the harmonizing of the CRTC's campus and community radio policy frameworks

Support For Canadian Music And Artists

Providing exposure for new Canadian music and artists is central to Canada's broadcasting objectives for radio, including campus radio. The CAB supports:

• an increase in overall Canadian content level to 35%
• maintenance of the requirement for French-language stations to have 65% of category 2 vocal musical selections be French-language selections
• the CAB also recommends that the CRTC should undertake a separate public process to reassess musical categories and definitions

In addition, the CAB recommends that the CRTC adopt the initiatives contained in the CAB's proposal - Building New Canadian Talent for the Future - and in the - Mise en valeur des artistes-interprètes, des auteurs, des compositeurs et des producteurs - as a means to encourage campus and other stations to air new Canadian music.

The CAB also urges the Commission to encourage campus radio to establish an Internet Music Bank that would enhance campus radio's ability to access new and existing selections, particularly in genres where inventory of Canadian product may be considered low.

The Association does not, however, support the following changes respecting genres:

• the inclusion of `turntablism' or `radio art' as Canadian musical selections for the purposes of calculating compliance with Canadian content requirements
• reduction in Canadian content levels for periods of programming devoted to musical genres where availability of Canadian music may be considered low

Advertising And Alternative Funding

The CAB does not believe the interests of those who look to campus radio as an alternative voice or of the broadcasting system as a whole would be well-served by a change in policy that risks campus stations evolving into commercial broadcasters.

Therefore, we do not support the following elements in the proposed new campus policy:

•  changes in the advertising rules to eliminate all requirements concerning restricted advertising.

To assist campus radio in generating additional funding through multiple revenue streams, the CAB encourages the NCRA to submit to the CRTC a proposal for the development of an independent, third-party funding organization to act as a mechanism for receiving contributions from private broadcasters through the Benefits and Canadian Talent Development programs.

In closing, the CAB appreciates the opportunity to provide the foregoing comments on the CRTC's proposed new policy framework for campus radio. CAB members will rely on the Commission to review the development of campus stations, on a case-by-case basis during the licensing and renewal process, to ensure they continue to fulfill their mandate as an alternative to commercial and CBC radio services.

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