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  • Randy Kitt

Broadcasting Notice of Consultation CRTC 2021-281: Application by Rogers Communications Inc.

September 10, 2021 Filed Electronically

Mr. Claude Doucet

Secretary General

Canadian Radio-television and

Telecommunications Commission

Ottawa, Ontario

K1A 0N2

Dear Mr. Doucet:

Re: Broadcasting Notice of Consultation CRTC 2021-281: Application by Rogers Communications Inc. to effect a change of ownership and effective control of Shaw Communications Inc. (and its subsidiaries) Application No. 2021-0228-4

1. Unifor is Canada’s largest private sector union and has more than 310,000 members across Canada, working in 20 economic sectors. Unifor represents more than 26,000 workers in the telecommunication sector and 12,500 media workers, including 5,000 members in the broadcast and film industries.

2. We support a healthy and diverse telecommunications and media landscape. Acquisitions and mergers of this scope can create inequities in employment markets and in this case local programming and local news coverage. Unifor would like to caution the commission on these issues and ensure that should the commission approve this transaction, that it will consider the impact on employment as well as local programming, specifically local news; that needs to receive sustaining support in an equitable manner.

3. “Based on its 2020 annual aggregate returns, Rogers directed $7.2 Million of the allowable local expression contribution of $7.25 Million to fund the production of local news on Citytv, while Shaw directed $12.937 Million of the allowable contribution of $13 Million to fund the production of local news on the Corus-owned Global station.”[1]

4. When asked, “How this transaction would impact the current use of this funding flexibility,”[2] and whether they would continue to fund their current OTA stations and increase funding for OMNI, Rogers was vague and replied only that they had not yet finalized their plans, “However, Rogers expects to continue to use the flexibility granted in the Broadcasting Distribution Regulations (the Regulations) and related policies, and to reallocate funds to help support local English-language news programming and community programming, as we do today for Citytv and our community channels (Rogers TV/TV Rogers). We do not intend to continue to allocate funds to unaffiliated Corus-owned Global television stations.”[3]

5. Unifor would like to ensure that contributions will not diminish in the ‘flexible’ funding formula with this transaction. The loss of thirteen ($13) million dollars in funding for Corus television stations could be disastrous. At best, local news levels would stay the same, but would be redistributed from West to East in this country; at worst flexible funding formulas that aren’t adjusted could cause a devastating loss of local news and community content, that won’t be able to be recovered if we don’t act accordingly.

6. Therefore, Unifor submits that this merger should trigger a tangible benefit package that provides a lifeline to local news equitably across the country. Unifor further submits that beyond the tangible benefit package from this merger, ongoing, annual contributions should be made to support local news as Corus television stations will be affected by loss of a stable funding mechanism that was heavily relied upon.

7. Unifor also relies on the commission to ensure that the cost of this transaction is not undervalued, so that contributions to tangible benefits and funding to local news is calculated appropriately.

8. Consolidation and a concentration of larger companies do not necessarily lead to better jobs and working conditions. The labour market in the telecommunications sector is controlled by a few companies, leading skilled workers with less options for competitive employment. After the de-regulation of the sector, we saw that the large companies began to outsource or contract out work in order to reduce their labour costs. Typically, these contractors employed lower-wage workers compared to those being employed by the large companies directly. Over time, wages and working conditions have deteriorated due to outsourcing and the continued push from these companies to drive down the costs of labour. In the case of Unifor members,those who work as contractors for Rogers, for example, are some of the lowest paid workers in the sector.

9. We have seen the evolution of the sector after de-regulation – where the large companies are larger and more profitable than ever before (with more customers), at the expense of workers whose wages and working conditions have been eroded through outsourcing. Because there are less competitors (especially large competitors), workers potentially looking to leave one company have less options to work for a company that may provide better working conditions.

10.Unifor appreciates the commission reviewing this application with an employment lens as well as an opportunity, should this merger be approved, to protect and enhance the diversity of voices that tell Canadian stories in our communities.

11.Unifor would like the opportunity to respond in writing and in person to interventions, we would like to address, in person the questions and concerns outlined in this brief and it is for these reasons that I request to appear at the public hearing.

Respectfully submitted,

Randy Kitt

Director, Unifor Media Sector

Cell 416-806-2331

****End of Document****

Unifor comments on an application by Rogers Communications Inc., on behalf of Shaw Communications Inc.

Re: BNOC CRTC 2021-281, Public record: 1011-NOC2021-0281

Unifor Assistant to the National President, Katha Fortier & Unifor Media Sector Director, Randy Kitt

Thursday, November 25, 2021

1. Thank you for the opportunity to speak and to provide comment today. Unifor is Canada’s largest private sector union, with more than 310,000 members across Canada working in 20 economic sectors. Our union represents more than 26,000 workers in the telecommunication sector and 10,000 media workers, including 5,000 members in the broadcast and film industries.

2. Unifor supports a healthy and diverse telecommunications and media landscape. Acquisitions and mergers of this scope can create inequities in labour markets, local programming and local news coverage. Unifor would like to respectfully caution the Commission on these issues and ask that, should the Commission approve this transaction, it will consider impacts on employment and local programming, and especially -- local news.

Diversity of Voices and Local News

3. We are very concerned that the proposed takeover will lead to the loss of funding for local news in a number of locations including in Western Canada. The September 23rd response from Rogers does little to allay our fears. As we argued in our submission, the loss of $13 million in funding for local news provided by Corus television stations could be disastrous.

4. Rogers responded to this concern, which was also raised by a number of other interveners, by saying, “contributions that Rogers will be authorized to divert from community programming to local news will not be lost to the system as a result of this transaction.”

5. Rogers went on to say the diverted money will be used to enhance and bolster the locally reflective and relevant news that is offered on its OTA stations in its existing outlets in Edmonton, Calgary, Winnipeg and Vancouver.

6. Rogers argued that, “this additional funding will be instrumental in helping to build CityNews’ presence and coverage in these markets.” And in a passage that seems troubling to us, the company claimed this move to divert funding away from a number of smaller markets would actually “enhance diversity” by ensuring that CityNews had the financial resources to compete with Corus and Bell in these markets, where Rogers is currently in third place.

7. The purpose of the local news funding provisions is not to ensure that spending is concentrated in an-ever smaller number of markets, or to funnel more money to larger markets, or to make sure that a given broadcaster can build its competitive advantage. The purpose of these provisions is to provide financial support for more markets, and especially smaller markets, so the viewing public in places like Kelowna, Nanaimo, Lethbridge, Saskatoon, Peterborough, Kingston and St. John and Halifax (To name a few) have access to a diverse array of local voices in their news coverage. In fact, Rogers makes no commitments to even maintain, let alone increase the levels of original local news, even on its own stations. Of note, Red Deer, with a population approaching 100,000, is one of the largest standalone urban centres in Canada (i.e. one that is not part of a larger metropolitan area) without a local TV station.,_Alberta

8. From our perspective it is hard for Rogers to argue it is meeting the expectations laid out in the Diversity of Voices policy without being much clearer about what steps the company will take to mitigate the impacts of the loss of funding for the above-mentioned smaller markets. It’s not just about how much money is in the broadcast system overall, but how and where the money is spent, and on what.

Concerns regarding employment

9. This brings us to our next area of concern regarding the proposed Rogers/Shaw takeover, and that is the issue of employment. We at Unifor have first-hand knowledge that the broadcast sector in Canada is facing an employment crisis. The worrying trend of chronic job loss has been worsening year after year, and we are concerned that the proposed Rogers/Shaw takeover will only make things worse.

10. According to our own numbers, from 2014 to 2020, our membership in the broadcast sector decreased by 23%. And in that same time period, “In-house operations” – which includes studio crews, video editors, technicians, and others – saw job numbers decrease by 34%, and a loss of 20% for ‘boots on the street’ in field production.

11. We also, don’t need statistics to remind us of colleague after colleague losing their job to the many destabilizing factors facing the broadcasting industry today. Concentration, centralization, lack of regulation & funding and foreign competition. I watch them go one by one, with a heavy heart.

12. As we noted in our written submission, we are grateful the Commission is viewing the proposed Rogers/Shaw takeover through an employment lens. We would like to note that the increasing consolidation and centralization of news production occur at both a corporate and geographical level.

13. Corporate mergers and takeovers lead to a consolidation of voices into an ever-smaller circle of ever-larger media conglomerates. And, at the same time, financial resources and staffing are moved away from smaller local markets, and centralized in a smaller number of large urban centres. Again, we are deeply concerned about the future of the markets including those previously mentioned.

14. From a broader perspective, like a number of other interveners, we are concerned about Rogers’ long-terms intentions and commitments regarding employment levels overall. As you well know, if the takeover is approved, Rogers will be paying somewhere around $26 billion for Shaw. The company has said that the new merged entity will create “3000 net new jobs” arising from its investments in broadband and wireless technologies.

15. However, once again Rogers has come up short in terms of its plans and commitments for the broadcast segment of the company. What are the company’s plans to invest in -- and grow its broadcast activities? What commitments will the company make in terms of levels of employment in the broadcast sector? The company has said it will “will fulfil [its] regulatory obligations.” But we would argue that simply meeting minimum statutory obligations is not enough.

Local Expression, Tangible Benefits, and the Independent Local News Fund (ILNF)

16. Given the scale of the proposed takeover, the amount of money in play and the nature of the quasi monopoly that could be handed to Rogers, we ask the question, will this transaction strengthen the Canadian Broadcasting System? 13 million dollars may be leaving the Corus network of television stations. Those same stations will now be looking to the Independent Local News Fund (ILNF) for support, at the expense of many other small communities. And even with ILNF funding the shortfall cannot be made up with that alone. All the while Rogers makes no firm commitments to maintain or increase original local news programming or staffing levels. 13 million dollars at an average of $80,000 per job would equal 162 jobs. Simple math, but frightening consequences, if that funding disappears.

17. There is also the issue of tangible benefits and the value of the transaction. Unifor urges the commission to look at the fair value of the transaction. And, as the Forum for Research and Policy Communications has pointed out in their written submissions, this transaction may be undervalued to the tune of over 45 million dollars, depriving us of up to 17 million dollars in tangible benefits. (Para ES 9 FRPC Submission)

18. Unifor, therefore asks that should the commission approve this sale, Rogers is mandated to continue funding for the Corus stations, until such time as a hearing can be concluded to ensure that ILNF or other such equal funds can be in place to support the need of these Canadian communities.

19. Unifor asks that the fair value of the transaction is considered and the maximum tangible benefit package, suitable for a transaction of this unprecedented scale, is guaranteed. These tangible benefits should be used to strengthen original local news programing across Canada and in smaller communities.

20. In questioning on day one of these hearings Rogers states that they will put more “boots on the street”, meaning they will hire more journalists, but focusing on quality over quantity and not necessarily creating more hours of programming. Arguing that more hours is not necessarily better and quality journalism is more important. Then when questioned if Rogers would support a condition of license to increase its local news and local programming commitments they said they would not.

21. I ask you, if Rogers had its way and could divert all of this money to its own stations, how is it possible for them to spend 13 million dollars and not commit to an extra hour of programing? How is this possible? Quality and quantity must both be factors and clearly they must be mandated with clear programing conditions of license.

22. We respectfully urge the Commission to ensure that at the very least, the combined new entity should be required to maintain the same employment levels in the broadcast segment as the sum of the two pre-takeover companies. In other words, the proposed takeover should not lead to a net decrease in employment within the broadcast segment. In fact, we believe that, given the amount of money Rogers will make if the deal goes through, we should expect to see a significant increase in employment in its broadcast segment.


23. The Covid crisis, a snap election and more recently, the floods in BC’s lower mainland, have hit home for us --- showing us how much Canadians depend on high quality local news. Perhaps paradoxically, while our world becomes more globalized, and our problems – like the pandemic and climate change – seem to get bigger in scale, the need for local news has never been greater. Local news is an essential service and must start being treated as such, as it is essential to a functioning democracy. To support it means ‘feet on the street’, that means local people to tell local stories. We need to talk about ‘how many hours’ we program, but we also need to talk about ‘how many people’ are telling our stories. And, we can’t say we’re supporting it, unless we are funding it. If the commission is going to approve this merger the answer to the question, “Will this transaction strengthen the Canadian Broadcasting System?” has to be, with no hesitation, absolutely!

******************End of Document***********************


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