In spring 2019 the CRTC invited CBC to apply to renew its radio and television licences and to discuss the possible regulation of CBC’s online programming services that currently operate without CRTC oversight due to an exemption order. CBC submitted its licence renewal application at the end of the summer, and in fall 2019 answered questions from the CRTC about the application. (You can find the CBC’s application here, by scrolling down to the 2019-379 notice.)
When the CRTC asked how CBC has met the objectives set by Parliament in Canada’s broadcasting policy, CBC relied on a document entitled Your Stories, Taken to Heart. It said on 9 October 2019 that
“Your Stories, Taken to Heart outlines CBC/Radio-Canada’s new three-year strategy. It builds on the success of our existing services and, in particular, of our digital transformation, but now aims to deepen audience engagement across all platforms.”[1]
Clicking on the link provided by CBC’s response led to this URL: https://cbc.radio-canada.ca/en/vision/strategy/your-stories-taken-to-heart. A news release issued by CBC on 22 May 2019 described the document presented at that link as “[t]he full plan”.[2]
The CRTC published CBC’s renewal application on 25 November 2019, and invited comments from the public. The deadline for these comments to be filed with the CRTC was 20 February 2020.[3]
Altogether the CBC’s licence-renewal application refers to its ‘strategic plan’ or its ‘strategy plan’ at least sixteen times, suggesting that this plan has a role to play in what CBC does in the next several years:
| 30 September 2019, Supplementary Brief | DM#3720734 | 1 time |
| 9 October 2019, Application form – answers | DM#3733727 | 11 times |
| 30 October 2019, Answers to request for additional information | DM#3754953 | 4 times |
The link provided in CBC’s application to Your Stories, Taken to Heart led to a online document entitled Your Stories, Taken to Heart[4] that listed five priorities and amounted to five printed pages. The website page included a clickable invitation to “Read our strategy (PDF)”, which in turn led to a two-page PDF again entitled “Your Stories, Taken to Heart”. The URL of this PDF – https://site-cbc.radio-canada.ca/documents/vision/strategy/2019-strategic-plan-en.pdf – suggests that Your Stories, Taken to Heart is CBC’s 2019 strategic plan. Its subtitle describes it as “Our new three-year strategy May 2019”. A pulldown menu at the top of the page says, “strategy-one-pager-en-fushia”, hinting that a plan longer than one page may exist:
In the remainder of this document we refer to the 2-page PDF as CBC’s Strategic Plan Summary.
On 29 November 2019 Friends of Canadian Broadcasting (FCB) asked that the CRTC require CBC to disclose its complete strategic plan, on the basis that it constitutes a “roadmap” for CBC management.[5]
On 28 January 2020 the CRTC denied FCB’s request, on the grounds that CBC had provided a significant amount of additional information, including financial information:
“Commission staff has sent questions to the CBC/SRC in relation to its strategic plan. In response, the CBC/SRC has provided significant additional information on the public record of this proceeding. This information can be relied upon by any intervener in formulating its submissions. The Commission notes that other CBC/SRC financial information and corporate documents are available in the public domain and may be referenced by interveners in their submissions. In light of this, the Commission denies FRIENDS’ request for the disclosure of a full and complete three-year strategic plan.”[6]
On 4 February 2020 the Forum wrote to CBC under the Access to Information Act to request a copy of the strategic plan that, according to its 2018-2019 Annual Report, had been approved by CBC’s Board of Directors in March 2019.
CBC received the Forum’s request on 7 February 2020, and emailed a redacted copy of the plan to the Forum on 9 March 2020.
CBC’s March 2019 Strategic plan
The materials received by the Forum consisted of a 106-page PDF document and cover letter. The 106-page PDF consists of 53 pages in English and 53 pages in French. The entire document appears to be a copy of a Powerpoint presentation presented to CBC’s Board of Directors on 20 March 2020.
The title on its first page is again “Your stories, taken to heart Our strategic plan” suggesting that, if nothing else, it is a longer version of the 5-page Your Stories, Taken to Heart document and the 2-page Strategic Plan Summary referenced in CBC’s application and posted on CBC’s website.
The English-language 53-page Strategic plan includes 11 title pages and a list of its contents, leaving 41 pages of content. Half – 20 of the 41 slides with content – of the slides have been redacted: Slide 25 is entirely redacted, 14 slides are almost totally redacted and 5 slides are partially redacted.
Redactions are permitted by Canada’s Access to Information Act; in this document CBC is relying on sections 18(a), 18(b) and 21(1)(b) as grounds for its redactions:
“18 The head of a government institution may refuse to disclose any record requested under this Part that contains
(a) trade secrets or financial, commercial, scientific or technical information that belongs to the Government of Canada or a government institution and has substantial value or is reasonably likely to have substantial value;
(b) information the disclosure of which could reasonably be expected to prejudice the competitive position of a government institution or to interfere with contractual or other negotiations of a government institution;
21 (1) The head of a government institution may refuse to disclose any record requested under this Part that contains
(b) an account of consultations or deliberations in which directors, officers or employees of a government institution, a minister of the Crown or the staff of a minister participate ….”
The following table lists the slides that the Forum received, describes them and shows the level of redacted information.
| Page | Description of contents | Level of redaction |
| 1 | Title page | None |
| 2 | “Our strategic plan” – list of contents – 9 conditions for success, Financials, Measurement, Strategy governance and Communications strategy | None |
| 3 | Executive summary | Partial |
| 4 | Description of “Canada’s Unique Situation” | None |
| 5 | “The new challenges we face” | None |
| 6 | Section title page: “Mission, Vision, Values” | None |
| 7 | Mission | None |
| 8 | Vision | None |
| 9 | Values | None |
| 10 | Section title page: “Strategic Priorities and Initiatives” | None |
| 11 | Strategic imperatives | None |
| 12 | Five strategic priorities | None |
| 13 | 1. Personalized digital services (lists 3 bullets of text) | None |
| 14 | 2. Engaging with young audiences (lists 3 bullets of text) | None |
| 15 | 3. Prioritizing our local connections (lists 3 bullets of text) | None |
| 16 | 4. Reflecting contemporary Canada (lists 2 bullets of text) | None |
| 17 | 5. Taking Canada to the world (lists 2 bullets of text) | None |
| 18 | Section title page: Conditions for success | None |
| 19 | “Strategy is about choices” | Partial |
| 20 | “Conditions for success” – leveraging “the contribution of core enablers: people, commercial revenue; and technology” (Note, “commercial revenue” does not appear in CBC’s application) – adopting “specific incentives and business practices that drive our people, culture, and processes to deliver programming and content that puts [sic] audiences first” | None |
| 21 | Page listing 9 “Conditions for success” | None |
| 22 | CBC’s business approach | Almost total |
| 23 | Commitment to innovation, or “Continuous innovation” | Partial |
| 24 | “3.1 People strategy” – subtitle page | None |
| 25 | Entirely redacted | Total |
| 26 | “3.2 Revenue strategy” – subtitle page | None |
| 27 | “Revenue strategy” – 3 bullets and 10 sub-bullets | Almost total |
| 28 | “Revenue strategy” – 3 bullets and 10 sub-bullets | Almost total |
| 29 | “3.3 Technology strategy” – subtitle page | None |
| 30 | “Enable business strategy” | Almost total |
| 31 | “Technology strategy” – 5 priorities and 14 activities | Almost total |
| 32 | “3.4 Additional Strategic Considerations” – subtitle page | None |
| 33 | “Infrastructure approach (real estate)” | None |
| 34 | “Environmental approach” | None |
| 35 | “4. Financials” – subtitle page | None |
| 36 | “Funding of strategic initiatives” | Almost total |
| 37 | “Funding of strategic investments Total budget – including incremental and redirects” | Almost total |
| 38 | “5. Measurement” – subtitle page | None |
| 39 | “Measuring our return on investment” 1. impact on Canadians’ perceptions of their public broadcaster 2. impact on audiences 3. impact on revenues | None |
| 40 | “Measurement framework” | None |
| 41 | “Measurement framework” | Partial |
| 42 | “Impact of our strategy” | Almost total |
| 43 | “6. Strategy Governance” – subtitle page | None |
| 44 | “Strategy governance” | None |
| 45 | “Strategy governance” | Partial |
| 46 | “For decision” | None |
| 47 | “7. Appendix” – subtitle page | None |
| 48 | “Radio-Canada – Strategic initiatives” | Almost total |
| 49 | “Radio-Canada – Strategic initiatives” | Almost total |
| 50 | “Radio-Canada – Strategic initiatives” | Almost total |
| 51 | “CBC – Strategic initiatives” | Almost total |
| 52 | “CBC – Strategic initiatives” | Almost total |
| 53 | “CBC – Strategic initiatives” | Almost total |
Comparison of the Strategic Plan Summary and the 53-page Strategic plan approved by CBC’s Board of Directors in March 2019:
The Forum undertook a quick comparison of the Strategic Plan Summary and the 53-page Strategic plan approved by CBC’s Board of Directors.
Apart from the fact that half the material in the 53-page Strategic plan is redacted while none of the Strategic Plan Summary is redacted, we noticed that the 53-page Strategic plan’s Appendix, which seems to include figures for the total “incremental investments by CBC against strategic priorities”, provides these figures for three years: the current year (2019-2020), and two future years (2020-2021 and 2021-2022). CBC’s renewal application agreed to the CRTC’s suggestion of a five-year licence term (presumably from 2020/21 to 2024/25) even though its revised and abridged financials for its English-language audio-visual services only describe a prior year (2018-2019), the current year (2019-2020) and three years going forward: 2020-2021, 2021-2022 and 2022-2023. In other words, CBC has apparently not yet provided the CRTC with forecasts of the resources it will require for the last two years of the five-year licence term that the CRTC and CBC have discussed.
The Forum also noticed five differences between the summary and the longer plan.
First, the ‘business priority’ identified in the Strategic Plan Summary is presented in the 53-page Strategic plan as a two-page “Revenue strategy” with 20 components. CBC’s renewal application does not mention or discuss either CBC’s “business priority” or its “Revenue strategy”.
Second, the Strategic Plan Summary identifies the same five priorities for its English-language and French-language services. The 53-page Strategic plan then sets out 13 text descriptions of how these priorities will be achieved and describes these all as “CBC and Radio-Canada’s Initiatives”. When the 53-page Strategic plan sets out the “total additional investments” that will be required to achieve these priorities in 2019/20, 2020/21 and 2021/22, however, it sets out 18 separate bullet points for CBC, and 28 separate bullet points for Radio-Canada – suggesting unknown differences between the two services in some areas. Due to the level of redaction by CBC it is also unclear how much additional investment CBC’s Board believes that CBC will obtain, the source of its additional investment, and whether the different bullet point items for the English-language and French-language services of the Corporation will receive different levels of additional investment.
Third, while the Strategic Plan Summary lists five “key metrics”, the 53-page Strategic plan lists three, one of which – “production” – is not listed in the Strategic Plan Summary.
Fourth, the Strategic Plan Summary says that it will put communities first and ‘prioritize its local connections’. The 53-page Strategic plan then states that CBC “will strengthen our connection to Canada’s regions by re-imagining our local/regional offerings across multiple platforms” [bold font and italics added]. It is unclear how CBC intends to ‘re-imagine’ its local services, its local/regional radio and television stations and/or its local/regional programming.
Fifth, and finally, the 53-page Strategic plan mentions “redirects” in the context of CBC’s total budget, a word that is not used in either the Strategic Plan Summary or CBC’s English-language renewal application. It is unclear whether the Board has approved a redirection of CBC’s current or approved budgets, and if it has, what parts of CBC’s current or proposed services will gain or lose funding.
Details of this comparison are set out below.
1. CBC’s ‘business priority’
The 2-page Strategic Plan Summary lists and describes five “priorities to better serve Canadians”.
1. Customized digital services
2. Engaging with young audiences
3. Prioritizing our local connections
4. Reflecting contemporary Canada
and
5. Taking Canada to the world.
It then shows another, unnumbered priority beneath this list: “Business priority”, which refers to earned revenue and new revenue opportunities:
“We will increase the revenue we earn and find new revenue opportunities to fund the things that are important to Canadians and ensure our financial health. This won’t change who we are or what we offer, but it means thinking in new ways, and that’s what this strategy is all about.“
[italics in original text[
The 53-page Strategic plan lists the same five priorities as the Strategic Plan Summary, but does not include the “Business priority”. While two slides discussing “Revenue strategy” are almost entirely redacted, they include six bullets with 20 ‘sub-bullets’.
CBC’s English-language renewal application does not use the phrases, “revenue strategy”, “strategy for revenue”, “strategy for revenues”. While acknowledging that advertising revenues are declining in general,[7] It does suggest, however, that it intends to increase its commercial revenues:
“CBC/Radio-Canada has been providing programming to Canadians over both traditional and digital platforms for more than two decades. This hybrid approach has not required any regulatory action by the Commission. However, the expansion of platforms has placed considerable pressure on the Corporation’s resources. CBC/Radio-Canada is pursuing all available opportunities to increase its commercial revenues and will continue to do so over the next licence term. The Corporation will also continue to put audiences first while operating in a financially responsible manner when fulfilling its statutory mandate so that it may keep serving Canadians using the most appropriate and efficient means possible.“[8]
[bold font added]
2. 53-page Strategic plan suggests different activities for meeting CBC’s 5 priorities
The English-language and French-language Strategic Plan Summaries list the same 5 priorities
1. Customized digital services
2. Engaging with young audiences
3. Prioritizing our local connections
4. Reflecting contemporary Canada
and
5. Taking Canada to the world.
The 53-page Strategic plan lists different numbers of activities for CBC and for Radio-Canada for implementing the priorities, however. For example, while ‘customization of digital services’ is described by 3 bullets in the 53-page Strategic plan, the Appendix to the 53-page Strategic plan setting out strategic initiatives and financing by year lists 11 bullets for Radio-Canada and 6 bullets for CBC:
| Strategic Plan Summary | 53-page Strategic plan, pages 13-17: description | 53-page Strategic plan, Appendix – CBC | Strategic Plan Summary | 53-page Strategic plan, Appendix – Radio-Canada |
| 1. Customized digital services | 3 bullets with text | 6 bullets | 1. Personnaliser nos services numériques | 10 bullets |
| 2. Engaging with young audiences | 3 bullets with text | 3 bullets | 2. Captiver les jeunes auditoires | 5 bullets |
| 3. Prioritizing our local connections | 3 bullets with text | 3 bullets | 3. Prioriser nos liens avec les regions | 6 bullets |
| 4. Reflecting contemporary Canada | 2 bullets with text | 4 bullets | 4. Incarner le Canada d’aujourd’hui | 6 bullets |
| 5. Taking Canada to the world | 2 bullets with text | 2 bullets | 5. Faire rayonner le Canada dans le monde | 1 bullet |
| Total: 5 strategies | 13 activities | 18 bullets | 28 bullets |
3. Different metrics in the 53-page Strategic plan
The Strategic Plan Summary lists 5 “key metrics”: digital reach, engagement, brand value, diversity and revenue.
The 53-page Strategic plan refers to measurement, but mentions only one of the five metrics listed by the Strategic Plan Summary – “revenue”. Slide 3 says that “Performance will be measured with a streamlined KPI framework that includes audience engagement, production and revenue metrics”.
Where ‘audience engagement’ may encompass digital reach, engagement, brand value and diversity, it is unclear what ‘production’ addresses or includes.
4. 53-page Strategic plan suggests that CBC regional or local programming will be ‘re-imagined’
The Strategic Plan Summary says that it ‘puts audiences, individuals and communities’ first (“Putting audiences, individuals and communities first”. Its third priority is to ‘prioritize its local connections’:
“This is the heart of our connection with Canadians. We will strengthen this connection with significant local and regional content that is relevant to people in their communities, and bring those communities to the rest of the country.”
The 53-page Strategic plan refines this description, by suggesting that CBC will be ‘re-imagining local/regional’ programming across ‘multiple platforms’. Slide 12 says that
“[i]n 2022, CBC/Radio-Canada will strengthen our connection to Canada’s regions by re-imagining our local/regional offerings across multiple platforms, to better meet each communities’ needs.”
The unredacted text in the 53-page Strategic plan does not explain what CBC means by “re-imagining its local/regional offerings across multiple platforms”.
CBC’s English-language application, meanwhile, states that CBC does “not anticipate making changes to the nature of our regional/local television and radio programming” (DM#3733727, at p. 40, answer to question 20). Several pages later, though, CBC implies that it will increase local content:
“Looking forward, CBC/Radio-Canada intends to develop a greater local presence and greater community connection across the country using digital platforms. This will enhance the service to the regions and enrich the overall national offering since this local/regional programming will be accessible digitally across Canada and will also feed into national programming on both traditional and digital platforms. The enhanced reliance on digital media will also enable the Corporation to increase its engagement with Canadians by means of a variety of interactive features.”
(Source: DM#3733727, p. 43)
5. 53-page Strategic plan suggests CBC is planning to re-direct funding
The 53-page Strategic plan mentions “New strategic investments” at slide 36, and “redirects” at slide 37. Its unredacted text does not define these terms.
Neither the Strategic Plan Summary nor CBC’s English-language renewal application mentions “new strategic investments” or “redirects”.
The Forum has today submitted a procedural request to the CRTC asking that the 53-page long strategic plan approved by CBC’s Board of Directors in March 2019 be added to the public file of CBC’s licence renewal applications, due to the plan’s relevance to the proceeding.
[1] DM#3733727 – Response – 9 October 2019 – 2019-0282-5_CBC_Application_Form_TV_and_Radio_EN-Final.doc, at p. 16, Answer (to Question 1(b)).
[2] https://cbc.radio-canada.ca/en/media-centre/strategy-2019.
[3] The deadline was originally 13 February 2020, but was extended by one week to 20 February 2020 through Notice of Hearing, Broadcasting Notice of Consultation 2019-379-1 (Ottawa, 28 January 2020), https://crtc.gc.ca/eng/archive/2019/2019-379-1.htm, at para. 3.
[4] https://cbc.radio-canada.ca/en/vision/strategy/your-stories-taken-to-heart.
[5] DM#3761220 – Procedural Request – Friends of Canadian Broadcasting – FCB Procedural Request re CBC Renewal.pdf, (Toronto, 29 November 2019), at 1 – 2. See “Procedural Requests”, https://services.crtc.gc.ca/pub/instances-proceedings/Default-Defaut.aspx?S=C&PA=B&PT=NC&PST=A.
[6] CRTC, Broadcasting Commission Letter addressed to Daniel Bernhard (Friends of Canadian Broadcasting), (Ottawa, 28 January 2020), https://crtc.gc.ca/eng/archive/2020/lb200128.htm?_ga=2.249503431.1932118928.1583772757-1211976415.1582553073.
[7] DM#3733727, at p. 82, answer to question 34(g).
[8] DM#3733727, p. 14, answer to question 7(a) and (b), bold font added.