Tag Archives: Canadian Radio-television and Telecommunications Commission

The CRTC Wants You To Talk About TV

Today the CRTC released its public consultation on the state of the Canadian broadcasting system.  I assume that most of my readers are involved in the Canadian broadcasting industry and are not members of the general public (I’m not sure about you readers from Russia or the former SSR of Georgia).  So you may be asking yourself “should I get involved in this stage or wait for the industry consultation next spring?”*  You might want to get involved now.  If you are part of a member-based organization then I definitely think that you should get your members involved now.  We’re all part of the public, right?

The CRTC has set up a lot of different ways to get involved.  Find the official invitation here.  You can call, email or fax your thoughts.  There is a discussion forum, similar to past public consultations such as the ones on the wireless code or the CBC.  And new for CRTC public consultations is the encouragement to hold “Flash!” Conferences.  I don’t know the logic behind “Flash!” – flash mob?  It has nothing to do with the software.  The CRTC wants Canadians to gather, talk about the issues, and send the CRTC a report.  Interesting.  There’s a toolkit to facilitate the “Flash!” Conferences and the CRTC has limited funds to subsidize the cost of running them for smaller organizations (apply by November 13, 2014).  There doesn’t seem to be a push to get Canadians to use social media other than the request to use the hashtag #TalkTV (Note:  I may cave but at the moment I’m not using #TalkTV because it is already an active hashtag for people to talk about Canadian and US talk shows.  I’ll stick to #CRTC and #CdnTV for now.)  Update:  The FAQ suggests that there will be Twitter chats and a Reddit AMA.  Should be interesting.

What are the topics?  In most of the material there are only three general topics mentioned.

Programming:  What do you think about what’s on television?

Technology:  What do you think about how you receive television programming?

Viewer toolkit:  Do you have enough information to make informed choices and seek solutions if you’re not satisfied?

Those are pretty vague and general topics but if you dig into the Notice of Invitation you’ll find more detail on the questions and context for them.  I’ve put them all together in one place for ease of use (for you and for me).


1. What television programs are most important to you (children’s programming, comedy, documentaries, drama, feature films, news, sports, reality TV, variety, other)? Why?

2. Do you know which of the television programs you watch are Canadian? If so, how do you know which programs are Canadian? Would it be important for you to know which programs are Canadian? Why?

3. What programs do you consider to be local television programming—programs about your city, your province, other? How important is local news to you? Why? How important is community access programming and “community TV” to you? Why?

4. Do you think the programming on television is fully reflective of Canada’s cultural, ethnic, linguistic, geographic and demographic diversity? If not, what’s missing? How important is reflection to you? Why?

5. What do you think programming will look like in the next 5 to 10 years? Why? Would you be satisfied with that situation? Why?


1. How do you prefer to watch television—on a traditional television set, online, on a smart phone, etc.? Why? How do you usually watch television programs—live, on-demand, recorded on a PVR, other? Why?

2. If you subscribe to cable TV or satellite TV, how satisfied are you with the way your channels are packaged?

3. What type of television service do you subscribe to—cable TV, satellite TV, Internet Protocol TV (IPTV) or other?  Do you intend to stay with your type of television subscription in the next few years or switch to something else? What would make you stay? What would make you switch?

4. How do you think we will receive and watch television in Canada in the next 5 to 10 years? Why? Would you be satisfied with that situation? Why?

Viewer Toolkit

1. How satisfied are you that your television service provider supplies the information you need to understand your service options, including packaging and pricing?

2. Are you experiencing barriers that prevent you from changing your television packages or switching to another television distributor? If so, what are those barriers?

3. How satisfied are you that your television service provider supplies the information you need to make informed choices about programming that you may consider inappropriate for you or your family?

4. Do you have a visual or hearing impairment? If so, how satisfied are you with the tools available to enable you to share in our television culture?

5. Do you know where you can voice your concerns over television content, your television services and bills?

6. How do you think we will make informed content choices as program viewers and consumers in Canada in the next 5 to 10 years? Why? Would you be satisfied with that situation? Why?

I think these are really great questions.  All of us would like to know what the general public thinks of these questions.  For too long at public hearings all sides of the industry have tried to speak for the general public and what they want from our broadcasting system.  I just wonder how the CRTC is going to get people motivated to get involved.  There isn’t any hot button issue like there is whenever you deal with the CBC or want Canadians to talk about their cell phone bills.  This is big picture thinking that most Canadians, I think, would rather someone else do for them.  I suspect that organizations with agendas will be the easiest to motivate.  We know how important this is so perhaps we should start with our own people.  Gather and have a “Flash!” Conference in the next two months so that a report on the conference can be filed by January 10, 2014.  [Shameless Self-promotion – you can hire me to help you do that.]  I assume that anything gathered will be useful as well in the industry consultation.   Spread the word about the consultation.  The more ‘general public’ who hear about this and get involved the better for the industry.

*As part of this invitation to the public, the CRTC released its updated schedule on the industry consultation on the state of the Canadian broadcasting system.  There will be a call for submissions Spring 2014 and a public hearing September 2014.  Expect that one to be a doozy!

A Hodge Podge of CRTC Decisions (Independent Licence Renewals)

Or is it a mish mash?  I’m not sure of the technical term here but last Friday afternoon when most of the world was either sitting on a patio or packing up the car for the last summer long weekend, the CRTC released a whole pile of renewal decisions.  Several of them are of interest.

As you will remember, when the s.9(1)(h) hearing was posted, the call for comments included a number of non-appearing licence renewal applications for independent (i.e. not part of the large groups like Bell, Shaw, Rogers and Corus) broadcasters.  They were to some extent lost in the hubbub over the mandatory carriage applications but a few stalwart stakeholders weighed in.  I outlined a few issues that interested me in an earlier post.

I won’t go through all of the decisions but I do want to mention a few themes that came to mind as I read them.  The first is that almost all of the broadcasters asked for reduced CanCon expenditure and/or exhibition requirements.  This is partly because they can no longer include the CMF top up as part of their expenditure requirement.  As the top up was part of broadcasters’ calculations when they proposed their CPEs in their licence applications, the Commission has decided that it is fair to allow them to make new proposals at a lower level.  Most of them had reductions approved but not necessarily the full extent that they asked for.  ‘Why’ is interesting.

There seems to be a real attempt by the Commission to rationalize the various Cat A (and a few Cat B) licences so that there is some consistency of conditions of licence.  Services were licensed at different times, with different competitive environments and natures of service so to some extent they should have differing terms but the conditions of licence have morphed into a crazy quilt where the rationale is not always evident.  Where it doesn’t make sense to have different terms, the Commission has gone for consistency.  So, while OUTtv asked for a reduction in their CPE from 49% to 35%, they were granted 40%.  ONE asked for a reduction from 41% to 30% and they were granted 40%.  Blue Ant’s Cat A’s were granted 40% CPEs as well.  Most Cat A’s have a CPE of 40% so there’s the reason for the pattern.

Superchannel also asked for a reduction in CPE from 32% to 27% and they were granted 30% because Superchannel is a pay service and the more established TMN and Movie Central have 31% CPE and Family Channel (equally established but for some reason lower) has a CPE of 30%.  The Commission made that decision on the basis of consistency and did not accept Superchannel’s arguments that it has been having a hard time getting started and needs the break.  Here’s the interesting part.  Superchannel has had a hard time getting started and did have to complain to the Commission because they couldn’t get carriage or even if they did have an agreement, the BDUs weren’t letting their consumers know that Superchannel existed.  But the Commission based its decision on a) Superchannel made commitments to win their licence in a competitive bid so shouldn’t be allowed to make less of a commitment now that they  have the licence and b) they were in serious and regular non-compliance at the time that they asked for the break.  Superchannel also asked for a break in their regional outreach and script development commitments ($1 million annually for regional and $2 million annually for script development) and the Commission gave it to them but on the condition that they also pay the unspent commitment of $6 million, which averages out to a total of $2.5 million per year instead of the $3 million they were supposed to spend.   [Note – if you’re a screenwriter you might want to go knock on Superchannel’s door as they have to spend $1.5 million in script development annually.]

But that leads me to another theme.  When you are asking the Commission for a break, it helps if you have been following the rules over the last licence term.  Blue Ant asked for a number of concessions including being treated as a modified group under the group-based policy so they can allocate their CPE across the group.  They do not technically qualify because they have no conventional services but the Commission decided to agree because a) it is important to diversity in the system to have strong independent broadcasters and b) Blue Ant had demonstrated its commitment to Canadian programming through its historical CPE.

Now Blue Ant didn’t get everything that they asked for so there is a limit on what you can get just by being a good broadcaster.  I think that it was a little cheeky of them to ask that their inhouse production be treated as independent in order to qualify under independent production requirements, particularly using the argument that the independent production sector is small now due to consolidation.  Blue Ant’s services are lifestyle, reality and documentary services for the most part and there is no shortage of small producers working in those genres.  The Commission correctly denied the request in order to help those small producers continue to find sources for their programming.

Another item of interest across a number of decisions is the refusal to require that the independent broadcasters adhere to Terms of Trade.  The rationale is that Terms of Trade are necessary to balance the uneven bargaining positions between large broadcasters and small producers but with these independent broadcasters there is no such imbalance and the producers do not need help in their negotiations.  I wonder if the really small producers who work with these independent services feel the same way.

There was a lot more there of course so if you’re interested in the individual independent services, then check out the specific decisions.

CRTC S.9(1)(h) Hearing (Mandatory Carriage) Decision

For background, last March I wrote a post that explained what mandatory carriage means and talked about the applications that I was most interested in.  The hearing took place the week of April 23, 2013 and the decision was released today.  13 of the 22 applications for mandatory carriage were denied as the CRTC reiterated that mandatory carriage was reserved for services that ‘make exceptional contributions to meeting the objectives of the (Broadcasting) Act’.  See Fagstein’s blog for a good chart form summary.

Most of the mainstream media and social media focus has been on the Sun TV application for mandatory carriage (which was denied) – see Simon Houpt and Steve Ladurantaye of the Globe and Mail for excellent coverage of the topic) but I have always been much more interested in the other applications which had the potential to impact the Canadian content part of the broadcasting sector – APTN, VisionTV, Starlight.  There were also several licence renewal applications of interest, particularly Superchannel and Blue Ant, but those have not been released.  There was however, one aspect of the Sun TV decision that I think is worth noting (in addition to the upcoming policy hearing on Canadian news services which will address the bigger picture of whether all Canadian news services need regulatory assistance).  The Commission noted that not only did Sun TV not demonstrate how its service would make an ‘exceptional’ contribution to the objectives of the Act – it never referenced the Act in its application.  #duh (sorry – couldn’t resist).  Further, the service didn’t make ‘exceptional’ expenditure and exhibition commitments to Canadian programming beyond what other Canadian news services, which do not have mandatory carriage, make.

But enough about Sun TV.  APTN received a renewal of their mandatory distribution order on the basis that its service was consistent with the objectives of the Act, it was important that the service be widely available across the country and that APTN is ‘exceptional in its contribution to Canadian expression and reflects attitudes, opinions, ideas, values and artistic creativity that would not otherwise be seen on television’.  As well, should the BDUs only carry the service where concentrations of aboriginal populations warranted it, then many who were spread out around the country would not have access.  This is a good description of the bar required for a service to be entitled to mandatory distribution – exceptional contribution to the objectives of the Act, and anticipation that the market would not provide the service consistently across the country.

However, APTN also asked for an increase in their subscriber rate from $0.25 per sub to $0.40.  It requested the increase to keep up with inflation, improve programming and make more programming available on multiple platforms.  The Commission accepted that an increase was warranted but given that an increase in the subscriber rate will mean an increase in the cost of the basic package, decided that a $0.06 increase would be a good balance between APTN’s need and the consumer’s reluctance to pay more for basic cable.

The Commission used the same balance language when it agreed to an increase for CPAC.  The $0.01 increase ‘represents a good balance between the impact on the price of the basic service for Canadian consumers and the ability of CPAC to improve its programming’.  This is the consumer filter that we have been told will be applied to all decisions clearly at work.

There were two proposed youth-focused services that applied for mandatory distribution – Fusion and Dolobox.  It was interesting that both had significant user-generated content and online components and both were denied at least in part on the basis that there were enough existing alternatives in the online world that the Commission did not see a need to issue mandatory distribution and broadcasting licences.  I heard both presentations and I could not understand why they were at the CRTC as it seemed like a backwards looking business model for forward-looking services.

Speaking of which, then there’s Starlight.  While I strongly support the idea of finding a way to make it easier for Canadians to find and watch Canadian feature films, I was part of the camp who thought that Starlight for all of its good intentions, was not the solution because of its reliance on mandatory carriage in its business model (See also Denis McGrath’s Facebook post on the subject –- sometimes a former blogger has a relapse).  As you can see from those services that received or maintained mandatory carriage, the Commission looked very closely at whether a service was exceptional enough to warrant increasing the cost of basic.

The Commission did not feel that the proposed service was exceptional enough because Canadian VOD and pay services are required to licence all Canadian services that are available so Canadian films are not unavailable.  [Now, as Mario Mota pointed out in a tweet, pay is about $20/month on top of basic, which is not very accessible to Canadians so there is a flaw in that argument.]  Starlight would to some extent duplicate the offering on pay and VOD so would not provide additional diversity to the system.  I would agree except to the extent that Starlight was planning to reach into the back catalogue to films not currently or rarely available (some rightly so of course).

Part of Starlight’s strategy was to show general support for the service and it conducted a survey to demonstrate a high level of interest.  Unfortunately that strategy seems to have backfired as the Commission felt that the high level of interest demonstrated that Starlight could be successful as a discretionary service.   However, Starlight applied for mandatory distribution because it not only wanted to be sure that it was available in every home but also it needed the revenue to fund its original feature film financing plan.  This plan could not be financed without a mandatory distribution order.  The Commission felt that Starlight had not demonstrated that the existing funding for feature films was insufficient.  I think that another way of putting that is ‘don’t force consumers to solve the problem of insufficient feature film financing’.

Over the years Vision has applied for mandatory carriage several times on the basis that its multifaith programming and its focus on its 55+ audience offers needed diversity in the broadcasting system.  Vision expressed concern that as an independent service it runs the risk of vertically integrated companies moving it from a basic package to a discretionary package in order to make room for their own services.  A move like that would draw fewer subscribers and therefore reduce Vision’s revenue.  The Commission accepted the arguments of BDUs that the BDUs would not want to risk the wrath of Vision’s audience if they moved Vision out of basic (and warned the BDUs that the Commission would need to see good reasons if they ever did so).  Vision also has recourse to the Commission should the BDUs treat Vision unfairly.  The Commission also pointed out that Vision is no longer the only other faith programming service so there is no extraordinary need for Vision’s particular service.  Or in other words – it’s all good so there’s no need to regulate.

One of the few new mandatory orders granted is worth mentioning.  It went to The Legislative Assemblies of Nunavut and the Northwest Territories for a geographically limited broadcast of recorded and live coverage of proceedings in their Assemblies in aboriginal languages, English and French.  The service clearly supports the objectives of the Act, there was a demonstrated demand and a demonstrated market failure.  Bell ExpressVu stated no plans to carry the service and Shaw agreed to but without any time commitment.  And possibly most importantly, the service did not ask for a subscriber fee.

The general feeling about this hearing was that the Commission would not grant many or possibly any new mandatory orders but would maintain the existing ones in order to keep a lid on the cost of basic cable and this is pretty much what they have done.  The decisions were clear so if any service seeks to apply for a mandatory order in the future they will definitely know what issues to address in their application.  There will be an increase to the basic cable rate but it should not be significant (Fagstein came up with wholesale increases of $0.31 per subscriber per month in English and $0.63 in French, which Mario suggests may be used by the BDUs to justify $1 increases in your bill).

In many ways those of us who watched the hearing felt that it was a throw back to an earlier era when broadcast television was the only way that you could reach an audience.  That is so not the case any more.  Now the question is whether the rejected applicants, and those contemplating new services in the future, turn to digital platforms to reach audiences and whether the CRTC needs to be there to ensure that the objectives of the Broadcasting Act aren’t being undercut by these new platforms.  Yeah, I went there.

Does Canadian TV need an overhaul? Maybe. Probably.

Yesterday, Scott Stinson questioned whether we needed the CRTC in his column in the National Post.  I dismissed it as the usual ‘free market’ knee jerk ‘I hate the CRTC, I want my Superbowl ads’ kind of article.  So I was surprised that people within the creative industries were positively circulating it.  That set me off on a twitter rant.  I am calmer now so will aggregate my thoughts into a post.

Stinson’s article seems to have been prompted by two things.  The first, jokes from the WGC Screenwriting Awards, I won’t address as I was, not surprisingly, not there.  The second catalyst was the current mandatory carriage hearings, which Stinson suggested was a ‘lot like deciding who would get access to the horse and buggy even as Henry Ford was unveiling the Model T’.   He’s not wrong there but his thesis I have a problem with:  ‘why do we have the CRTC, exactly?  And just what do we get out of this wacky regulated system?’.  That’s where my rant started.

What do we get?  A Canadian broadcasting system.  That means Canadian-owned broadcasters who have a regulated commitment to fund and air Canadian programming.  Stinson says that because of the subsidies, we have a system ‘where anyone who wants to make a series in Canada has to ensure first that it will qualify for subsidies’.  Well, if we didn’t have the subsidies how exactly would Canadian television producers make a series?  We are a small market dominated by the U.S. media industry, which dominates most of the world.  We do not have a large enough population or economy for the private sector to finance television.  Without the CRTC protecting Canadian ownership of the broadcasters we would only have U.S.-owned broadcasters.  Why would they license Canadian television rather than amortize their costs and broadcast the same schedule that they air in the U.S. ?  They wouldn’t.

Stinson makes reference to recently cancelled “Less Than Kind” and “Bomb Girls” as examples of failure.  “Less Than Kind” only exists because of CRTC-mandated benefits.  It ran for 39 episodes despite the death of its lead actor.  A pay broadcaster picked it up after the primary broadcaster, Rogers, decided to no longer support it.  To me, this is a success story.  “Bomb Girls” did so exceptionally well in 6 episodes that Shaw decided to license a second season for 18 episodes.  CRTC-mandated benefits made it possible.  After substantial audiences in the first season, for some reason Shaw decided to broadcast the second season at the same time as “Murdoch Mysteries” on CBC.  I believe that was the major reason why “Bomb Girls” didn’t enjoy the same level of audience in the second season – competition from another, similarly themed, Canadian drama series that was already several episodes into its season.  Not a US drama series but a Canadian drama series.  “Murdoch Mysteries” was also dropped by Rogers (which frankly is trying to find itself as a Canadian broadcaster), picked up by the CBC and has been enjoying over 1.2 million viewers each week.  Another success story (and don’t even get me started about “Flashpoint”, “Orphan Black”, “Motive” and quite a few other success stories).

Television production spiked in 2012 from $2.12 billion in 2011 to $2.57 billion in 2012 according to the CMPA 2012 Profile Report.  We do not yet know whether the spike was completely due to the large amount of benefits that are now flowing into the system or in some way also due to the Group Licence Policy and CPE and PNI CPE (see the Acronym Decoder).  Next week, Mario Mota of Boon Dog will release his annual “Canadian Television Benefits Monitor” but in a tweet he teased that “2011-2012 TV benefits spending about the same as previous 4 yrs combined”.  There is more money in the system and more Canadian television is being produced, because of regulation (i.e. the CRTC), than in years.

Yes, the hearing for s. 9(1)(h) mandatory carriage licences does seem anachronistic (as Michael Macmillan of Blue Ant said today).    Which is probably why the CRTC is being so tough on applicants and their requests for mandatory carriage and, for incumbents, rate increases. CPAC was questioned on its need for maintained mandatory carriage since it is recognized as essential to Canadians and owned by the 6 biggest BDUs.  APTN was asked when it would be able to stand on its own feet without mandatory carriage and strongly urged to figure out how to do just that.  Every new applicant was challenged to justify how it was ‘exceptional’ enough to qualify for mandatory carriage.  Canadians do not want their cable bills to increase and I believe that Blue Ant was right today when it said that increased cable bills could lead to increase cord cutting or cord shaving which would be detrimental to the existing broadcasting system.   (Yes, cable bills have been going up for years without subscriber loss but there are reasonable alternatives now.)  But does that mean that the CRTC should not have this hearing and that somehow having the hearing justifies its dismantling?   No.

Does the Canadian broadcasting system need improvement?  I think we can all agree to that, including the CRTC.  Without the CRTC how do we do that?  Do we advocate scrapping the Broadcasting Act and the CRTC with it and let the free market dictate what gets made and who airs it?  I seriously do not think that any of us want the broadcasting system that we’d end up with then, it as it would likely be nothing but retransmission of US signals.  Or perhaps we should work within the CRTC framework to improve the system.  Canadian broadcasters are holding on tightly to the old models that have worked so well for them but their days are numbered unless they adapt.  The unregulated system is growing and we risk being lost in that world.  The current lack of Canadian programming on Netflix is a harbinger of what is to come.   The current high level of Canadian television production risks being a lost golden age unless we spend the time now to figure out how to ensure that regardless of platform we still have high quality Canadian television production and Canadians know that it’s out there.

That’s what we have to do.  End of rant.

CRTC S.9(1)(h) etc. Hearing

That’s what I’m calling this hearing for now. It’s a grab bag of renewals of mandatory carriage, applications for existing services to get mandatory carriage, new services to get mandatory carriage and a few independent specialty services to get renewal.  The full hearing notice is here.  All 13,018 interventions are here (though most have to do with wanting or not wanting Sun News Network).  Warning – this post is pretty wonky!

First – what exactly is mandatory carriage?  Under s. 9(1)(h) of the Broadcasting Act, the CRTC can require a satellite or cable company to carry a service, rather than leave it to the service to negotiate carriage.  If a service has mandatory carriage then its revenue stream and its audience is certain.  A service has to make an exceptional contribution to Canadian expression, contribute in an exception manner to the overall objectives of the Broadcasting Act and make exceptional commitments to original, first-run Canadian programming.  As mandatory carriage adds to the basic cable or satellite package and therefore increases the cost of those packages to consumers, there has traditionally been a very close review of that ‘exceptionality’ and few services have passed the test.  Examples of existing s.9(1)(h) services in English are CPAC, The Weather Network, APTN and CBC News Network.

The industry intervenors on this public hearing (submission deadline was February 27, 2013) are lining up on two sides of the mandatory carriage issue.  The cable and satellite companies do not want to add any new services to the basic package.  They are arguing against increased costs to consumers.  Generally cable and satellite companies argue from a place of great self-interest but in this I suspect that they are also reflecting the general mood of the marketplace.  Telus filed a public opinion study by Strategic Counsel that demonstrates a distinct lack of interest in increasing the basic package.  Our cable bills are high.  Consumers have a great reluctance to increase them at all for anything.

Generally, the English content creators (i.e. producers, talent unions) are only weighing in on the services which broadcast or might broadcast independently produced drama and documentaries:  Vision TV, APTN and the proposed new service Starlight.  There are a few concerns which some of the stakeholders would like to see addressed at the hearing but in general the content creators would like to see Vision TV given mandatory carriage, APTN get its increased rate and the new service Starlight launch with mandatory carriage.   All three services will support the independent production community in Canada and this is important.  Starlight is proposing a new solution to the problem of underfinanced and underbroadcast Canadian feature film.

The issue that the CRTC will have to grapple with is whether the support that each of these services provide to the independent production community, and the programming that they offer to Canadians, is exceptional enough to require Canadians to pay more to their cable company.  While the media is going to be most interested in the kerfuffle that is Sun News Media’s request for mandatory carriage, the Canadian independent production community will be more interested in the Starlight application.  As a new service aimed at solving a problem that the CRTC has itself identified – Canadians do not have enough access to Canadian feature films – has Starlight met the test necessary to require Canadians to pay for it?  I anticipate an interesting discussion.

But let’s not forget the independent specialty service renewals.  The CMPA has pointed out that a number of these services have asked for relief from their Canadian programming obligations (CPE) on the basis that the 2010 Group Licence Policy granted a reduction in CPE for the large corporate groups but contrary to that policy’s explicit statement that the policy would not apply to independent specialty services.   That policy balanced greater flexibility to broadcast group with specific obligations to Canadian programming and PNI.  It is very difficult to apply it to an individual service.

It also appears to be sliding under most people’s radar that Blue Ant (Travel + Escape, Bold, Bite, Aux and more) is asking to be treated as a group for the purposes of its CPE obligations and to be able to count in-house production for the purposes of calculating its obligations to independent production.  That last bit is pretty nervy and I’m confident that the CMPA is all over it.  So let’s go back to the concept of a ‘group’ under the 2010 Group Licence Policy.  The concept of Broadcast Groups was created to allow groups to air programs across their various services and count them towards a pooled obligation.  Bell could decide to air a program on CTV, CTV2 and/or Space in any order.  This regulatory framework was consistent with how the large corporate groups were licensing programming.  But does it make sense for a much smaller group of services, some of which are quite different from each other?   That will be the discussion.

The Public Hearing on these applications will start April 23, 2013. I’m experimenting with the hashtag #91hetc.  What do you think?