A brief regarding Bill C-11, theOnline StreamingAct Local news information, stories, and music are at the core of a strong democracy. Communitybroadcasters are the last line of defense and require appropriate recognition. April 2022 1

Introduction Between the Alliance des radios communautaires du Canada (ARCC), the Association des radioscommunautaires du Québec ARCQ, and National Community and Campus Radio Association(NCRA/ANREC), we represent more than 180 community radio stations across the country. We havestations in almost every province and territory and these stations broadcast in more than 65 languages. Across the country there are more than 700 staff members and a network of more than 10 000volunteers.

All of our stations are not-for-profit and governed by a volunteer board of directors electedby and responsible to the communities they serve. As a result, ALL investments in community radio goesright back into the community they serve. More than 1.5 million Canadians listen to community broadcasters on a regular basis, and the criticalimportance of community radio truly came into focus during the pandemic when we saw a 16% increasein listeners as Canadians sought out reliable local information.

With Facebook and Google increasingly becoming the only source of information for many Canadians,finding that reliable local information has never been more difficult. It is widely known that there areapproximately a dozen social media profiles responsible for more than 90 per-cent of the COVIDdisinformation online. As the Facebook whistleblower proved, algorithms are prioritizing controversyover facts and promoting dangerous messaging in order to attract the almightyclick.

We are seeing a trend of commercial, for profit, stations abandoning local communities including thegutting of major newsrooms, and an increased use of centralized national programming devoid of localcontent. In the ongoing CRTC review of commercial radio, commercial broadcasters are asking to reducethe requirements for Canadian content, French language programming (for Francophone stations) and areduction of the number of new and emerging Canadian artists they have to play as per licensingrequirements. Meanwhile, CBC/Radio-Canada has moved to a “regional hub” model of broadcasting over the lastdecade.

As a result, community radio has become the only home of Canadian music, and local contentand information. Unfortunately, in the currentBroadcasting Act, communitybroadcasters are only acknowledged once insection 3 (1)(b) “the Canadian broadcasting system, operating primarily in the English and Frenchlanguages and comprising public, private andcommunityelements … ” We appreciate that in the previous iteration of the proposed amendments (C-10), an enhanceddefinition was included with the following modifications: Clause 1, be amended by adding after line 15 on page 2 the following: 2

“community element means the participation of members of the community in the contentproduction of community media in the language of their choice, as well as in the day-to-dayoperations and administration of community media; (élément communautaire)” Clause 2, be amended by adding after line 27 on page 3 the following: (iii.4) support communitybroadcastingthat reflects boththediversityof thecommunitiesbeingserved and the high engagement and involvement in community broadcasting by members ofthosecommunities, includingwithrespect tothelanguagesinusewithinthosecommunitiesandto the ethnocultural and Indigenous composition of the communities, Clause 2, be amended by replacing lines 41 and 42 on page 3 with the following: “

(5) Subparagraphs 3(1)(i)(

i) and (ii) of the Act are replaced by the following: (ii) bedrawnfromlocal, regional, national andinternational sources,including,atthelocallevel,from community broadcasters who, through collaboration with local organizations andcommunitymembers, areintheuniquepositionof beingabletoprovidevariedprogrammingtomeet the needs of specific audiences These modifications are a good start, but we can and must do better. Important objectives.The stated objective of C-11 is to support the production of Canadian music and stories because they arecurrently at risk.

The intention is to do so by supporting creators and producers which would thengenerate social and economic benefits for Canadians. It aims to promote diversity within the Canadianbroadcasting system to better reflect Indigenous peoples and languages, persons with disabilities, andCanada’s diversity, so that the system serves the needs and interests of all Canadians. This will be done by ensuring greater investment for the benefit of linguistic and cultural minorities. Community broadcasters are in a better position to help the government accomplish those goals thanany other segment of the broadcasting system.

Community based broadcasters produce content in more than 65 languages which includes 11Indigenous languages spoken by Canadians from coast to coast to coast. More than 35 stations serveOfficial Language Minority communities. Within these stations is the largest number of diversebroadcasters and programming in the country. The challenge is that, while C-10 made improvements, theBroadcasting Actdoes notyetreflect the keyrole these stations play in accomplishing the objectives as set out by the current government. Necessary amendments: The following are the modifications we propose. We have identified the

section where the proposals fitbest : 1) Define Community Media 3

The single most important modification of theBroadcasting Actthat is needed to support a robustcommunity “element” is to adequately define “community element”.

We propose the following additions (inbold), to theamended definition as proposed: Clause 1, be amended by adding after line 15 on page 2 the following: “community element means theparticipationofmembersofthecommunitythroughvolunteers,andacommunityboardelectedbymembers, inthecontentproductionofcommunitymediainthe language of their choice, as well as in the day-to-day operations and administration ofcommunitymedia,whicharenot-for-profitentitiesrespondingtotheneedsofthecommunitiesthey serve;(élément communautaire)” 2) Describe the Role of Community Media (as expressed in the definition of CRTC approvedcommunity licenses).

In

section 3(1)(

d) there is a definition of the role of the public broadcaster. In

section 3(1)(

s) there is asimilar definition of the role of private broadcasters, yet there is no

section defining the third element ofthe broadcasting system, community broadcasting. There is, however, a robust definition of “alternativetelevision broadcasting.” We propose clause 3(1)(

r) be amended to: 3(1)(

r) the programming provided by the community element; i. Be produced by and for local Canadiancommunities; ii. Strengthens the democratic processand combats disinformation; iii. Supports the development of new andemerging Canadian creative talent and providesprogramming in a range of underserved genres including local news and information,culture, politics, history, and the arts; iv. Supports stations who stimulate thelocal economy; v. Reflects Canada’s cultural diversityby providing exposure to underserved groups,ethnocultural minorities, Indigenous peoples and persons with disabilities; vi.

Provides third-language programmingto the ethnocultural and immigrant communitiesresident within their service areas; vii. Is an essential information servicefor public safety and health; *** Should a definition of “alternative television” still be required, the above could be included as anaddition rather than a replacement. 4

Conclusion Community radio is a critical part of the Canadian broadcasting environment. As we see all otherbroadcasters abandoning local news, information, stories, music and arts, community radio will alwaysfocus on supporting local voices. TheBroadcasting Actmust reflect all elements ofthe broadcasting system with equal measure. Theamendments proposed above will see community broadcasters recognized for their role in a healthydemocracy. Community broadcasters will benefit dramatically if the legislation does in fact ensure financialcontributions to support Canadian music, stories, creators and producers.

However, that support willonly reach the smaller broadcasters in the community broadcasting sector if their role in thebroadcasting system is acknowledged in the Act. 5