CRTC - Broadcast _________________________________________________________________ Ottawa, 29 May 1992 Public Notice CRTC 1992-38 POLICIES FOR COMMUNITY AND CAMPUS RADIO _________________________________________________________________ Table of Contents Pages Table des matieres A COMMUNITY RADIO 2 1. Definition 2 2. Types of Stations 3 3. Role and Mandate 7 4. Commercial Activity 7 5. Promise of Performance 10 a) Spoken Word 10 b) Musical Diversity 12 c) Program Formats 13 d) Music Usage Indicators 14 e) Canadian Content and French-language Vocal Music 15 6. Networks and Acquired Programming 17 a) Networks 17 b) Acquired Programming 18 7. Hours of Broadcasting 19 8. Local Talent Development 20 9. Volunteer Participation 20 10. Implementation 22 B CAMPUS RADIO 22 1. Defining Campus Radio 22 2. Structure of the Board of Directors 25 3. Complementarity 25 4. The Role Of Campus Radio 26 5. Financing and Advertising 29 6. Canadian Talent Development 32 7. News 33 8. Spoken Word 34 9. Categories of Music 35 10. Music Use Indicators 37 a) Hits 37 b) Repeats 38 c) French-Language Vocal Music 38 11. Levels of Canadian Music 39 12. Block Programming and Educational Programming 41 13. Licensing More than One Campus Station in an Official Language in a Community 42 14. Campus Carrier Current Stations 42 15. Low-Power Stations 43 16. High School Stations 43 17. Content Categories and Subcategories 44 18. Other Matters 45 a) Application Forms 45 b) Hours of Broadcast 45 c) Implementation 46 d) Applications by Campus Stations to Become Community Stations 46 C ACKNOWLEDGEMENTS 47 POLICIES FOR COMMUNITY AND CAMPUS RADIO In Public Notice CRTC 1991-118 the Commission requested comments on new policy proposals for campus and community radio. The proposed policy followed consultations between representatives of the Commission and various parties interested in that sector of the broadcasting system. This document includes a discussion of the points made in the 35 submissions received, and sets out the policies that the Commission has now adopted. Although the Commission proposed separate policies for community radio and campus radio, there are many similarities between the two. As noted in some of the submissions, community and campus radio are important components of the private non-profit sector of Canadian broadcasting. These stations, along with other non-profit stations operated by native broadcasters, provincial educational station CKUA-FM in Alberta, and CJRT-FM Toronto, make up a third sector of Canadian radio broadcasting that provides to Canadians a style of radio that is an alternative to that available from the CBC or private commercial stations. A major goal of the Commission in developing these policies, which will apply to community and campus stations operating on both the AM and FM bands, has been to ensure that community and campus stations have the necessary flexibility to respond to the needs of listeners in their communities while ensuring that these stations offer a programming alternative. ACOMMUNITY RADIO 1.Definition In its draft policy on community radio, the Commission proposed to retain the same definition it has used since the emergence of this type of broadcasting undertaking in the early 1970s. That definition is based on the principles of collective ownership, member access, and commitment to the community. Comments received during the consultations and in the briefs indicated some differences of opinion on this definition. The Commission notes the views of certain parties that broadcasters should be allowed to determine how they will operate and what services they can offer to their particular audience. Others stated that the Commission should place more emphasis on the community aspect of community radio programming. The Commission acknowledges the evolutionary process that community radio has undergone in recent years. It also recognizes that the present economic climate, and the decreasing availability of funding from all levels of government, have led to many changes in this sector of the broadcasting system. The Commission is therefore prepared to be flexible in allowing these stations to develop in an orderly fashion. Nonetheless, it considers it important to reaffirm that community involvement in all aspects of community radio, particularly programming, is essential to the development, and thus, to the preservation of the distinct character of community radio within the Canadian broadcasting system. Accordingly, the Commission has decided to retain the following definition of community radio: A community radio station is characterized by its ownership and programming and the market it is authorized to serve. It is owned and controlled by a not-for-profit organization whose structure provides for membership, management, operation and programming primarily by members of the community at large. Its programming should be based on community access and should reflect the special interests and needs of the listeners it is licensed to serve. 2.Types of Stations The existing policy recognizes two types of community radio stations: Type A stations, which provide first service in one of the two official languages in a particular market; and Type B stations, which operate in competitive markets. In Public Notice CRTC 1991-118, the Commission proposed to maintain the existing definition of "market", that being the geographical area: (a)within the 5 millivolt-per- metre daytime official contour of an AM station; or (b)within the 500 microvolt-per-metre official contour of an FM station. During the consultations, some groups argued that this definition could give rise to problems related to the determination of whether a Type A or Type B licence should be issued, particularly in the case of provincial border stations. In Public Notice CRTC 1991-118, the Commission indicated that it was willing to consider this issue and requested further comments and proposals. All of those who filed comments with the Commission were, for varying reasons, opposed to the above proposal. Some objected to a definition of market that would be based solely on geographic criteria, while others proposed the elimination of the language of broadcast in determining the type of licence to be issued community stations. Certain briefs argued that the Commission should protect existing community stations because of their "acquired rights". Under this proposal, Type A stations would no longer lose their status upon licence renewal if a new station has been licensed to operate in the same language and in the same market. These parties also recommended that the Commission incorporate some additional elements in the definition of market for the purpose of determining the type of licence to be issued to a community broadcaster, or, at a minimum, that the Commission assess all new community radio licence applications on an individual basis, particularly in the case of provincial border stations. On the other hand, although the briefs filed by commercial radio interests supported the definition of market, some recommended that the Commission make some additions and amendments which, they argue, would prevent excessive encroachment by community radio into commercial radio territory. They suggested that a new category be created for community stations in markets where at least one station is already operating in the other language. These community stations would be required to adhere to certain restrictions regarding advertising and programming. The Commission has considered very carefully the proposals and comments regarding the definitions of market and of the licence types. Opinions were very strongly divided, all the more so because of the current state of the economy. Having reviewed this matter, the Commission has concluded that some measures are required to ensure greater fairness and balance in the broadcasting system. Regarding the definition of market, although the Commission received some valid arguments in favour of expanding the definition, it remains convinced that the proposed criteria are adequate for the purposes of a general policy. Accordingly, the Commission has retained the existing definition of market. Although the Commission will not generally be prepared to make exceptions in this area, it is aware that exceptions may be warranted in particular circumstances. Regarding licence types, the Commission does not share the view that the language of broadcast should be disregarded in determining what type of community radio licence should be issued. The Commission does not intend to create a new licence category for community stations operating in a market that is served by one or more stations operating in the other language. Nonetheless, the Commission is aware of the problems that can arise in a market where this situation exists. Such cases will be considered on an individual basis. The Commission also recognizes that first service (Type A) community stations have been pioneers in serving markets that were once considered unprofitable. Moreover, these stations continue to provide an essential service as agents of cultural and social development within the communities they serve. The Commission considers that the establishment of a new station in a market hitherto served exclusively by a community station should not automatically cause the community station to forfeit its Type A status. Accordingly, the Commission has amended, as follows, the definitions of the types of licence to allow Type A stations to retain their Type A status when one or more new stations are established in the same market: Type A A community radio station is a Type A station if, when the licence is issued, no other AM or FM radio station is licensed to operate in the same language in all or any part of the same market. If one or more stations are licensed to operate in the same language in all or any part of the same market at the time of the licence renewal, the station will retain its Type A status. In all other cases, including applications to increase power, the Commission will assess the application on its merits. Type B A community station is a Type B station if, when the licence is issued, at least one other AM or FM station is licensed to operate in the same language in all or any part of the same market. For the purpose of determining whether a licence should be a Type A or Type B licence, the Commission proposed that existing campus radio stations would be counted as stations operating in a market, while CBC originating stations would not. The Commission received only one brief opposing this proposal. The brief recommended that the presence of a campus radio station in a market not be considered in the determination as to which type of community licence should be issued. Despite this opposing view, the Commission is satisfied that this measure is appropriate and will further enhance diversity in the Canadian broadcasting system. Accordingly, the Commission has decided that the existence of campus radio stations in the same market will be considered in the determination as to whether to issue a Type A or Type B licence in the same market. CBC originating stations, however, will not be included in such determinations. 3.Role and Mandate The Commission proposed to retain the six characteristics of community radio as set out in the existing policy. The briefs received generally support this proposal. However, some of those commenting argued that, in the current economic context, the Commission should remove the requirement that community stations diversify their sources of funding. The Commission considers that, in view of the nature of community radio and its role in the Canadian broadcasting system, it is essential that it continue to derive its revenues from a variety of sources. The Commission views revenue diversification as being much more than a laudable objective; it is essential to the existence and preservation of the distinctive character of community radio. Accordingly, the Commission has retained the definition of the role and mandate of community radio based on the following six essential elements: -the type of corporation and ownership; -participation of volunteer workers in management (board of directors) and programming; -membership; -local information, including news, community services, and air time available to organizations; -diversity of programming; and -diversity of funding. 4.Commercial Activity While reaffirming the requirement for diversity in the sources of funding for community radio, the Commission also proposed to abolish the limit of 1500 minutes of advertising per broadcast week for Type A stations. It also proposed to maintain the requirement that Type B stations adhere to an average, measured on a weekly basis, of 4 minutes of advertising per broadcast hour, with a maximum of 6 minutes in any single hour, for an overall maximum of 504 minutes of advertising per week. The Commission examined the issue of advertising by stations broadcasting ethnic programming. Based on requests received from some broadcasters, it proposed in Public Notice CRTC 1991-118 to consider on an individual basis applications by licensees that broadcast ethnic programming to increase the maximum level of advertising to 8 minutes per hour during ethnic programs. The comments received in response to these proposals indicated that no consensus exists on the overall issue of commercial activity. As for advertising by Type A stations, the vast majority of the briefs expressed support for the Commission's proposal; the support expressed in one of these was conditional on the Commission setting a maximum of 1500 minutes of advertising per week for Type A stations in the same market as a commercial station operating in the other language. As for the proposal regarding advertising by Type B stations, opinions were clearly divided between commercial radio interests, who supported the limit, and others who recommended greater latitude for community stations. Community radio supporters suggested several amendments to the restrictions proposed by the Commission, including an increase in the average advertising limits. A private broadcaster stated that the restrictions on community radio stations are inadequate, and recommended that advertising revenues be limited to 50% of total annual revenue. The Commission is fully aware that the present economic situation and the trend toward less financial participation by governments has influenced the opinions and recommendations of various parties concerning commercial activity by community stations. Indeed, it recognizes that the radio industry, including community radio, is going through a period of financial difficulty. Nonetheless, the Commission considers that an increase in advertising revenues is not the only nor the best solution to the financial problems of community radio. Rather, other solutions may very well lie in greater diversification of revenue sources and sound financial management. At the same time, it sees no need to limit the percentage of revenues derived from advertising. Accordingly, the Commission has adopted its proposals concerning commercial activity by community radio stations. The new policy will be as follows: Type A stations: There will be no limit on advertising by Type A stations. Type B stations: Type B stations will be permitted to broadcast a weekly average of 4 minutes of advertising for every hour of broadcast, up to an overall total of 504 minutes of advertising per week. The Commission will maintain the maximum of 6 minutes of advertising in any single hour by community stations. The Commission will not take into account any material broadcast between midnight and 6 a.m. With regard to advertising by broadcasters of ethnic programming, those who commented on the issue supported the Commission's proposal. One group, however, recommended that this enhanced flexibility be allowed only in markets where there are no commercial stations broadcasting the same kind of programming to the same ethnic community, and only where the licensee, despite this greater flexibility, observes the maximum advertising limit per broadcast week (504 minutes per week). The authorization to increase the hourly maximum for advertising in ethnic programs must not be interpreted as an encouragement to exceed the total advertising time limit applicable to these stations. At the same time the Commmission considers that it is inappropriate to apply this measure only to stations operating in markets where there are no commercial stations broadcasting ethnic programming to the same cultural community. Accordingly, the Commission has adopted the following policy for advertising during ethnic programs: The Commission is prepared to consider on an individual basis applications by licensees broadcasting ethnic programming to increase their maximum advertising time to 8 minutes per hour during ethnic programs provided that the licensee observe the overall maximum of 504 minutes of on-air advertising per broadcast week. 5.Promise of Performance a)Spoken Word The Commission proposed to maintain the current requirements for spoken word content on Type A stations; these requirements are limited to the 15% minimum per broadcast week prescribed in the Radio Regulations, 1986 (the regulations). It also proposed to lower the requirement for Type B stations from 35% to 25%. There was no consensus among the submissions regarding this proposal. Representatives of commercial radio considered that the spoken word requirement should be increased to anywhere between 30% and 35% for Type B community radio stations, and between 20% and 30% for Type A stations. The most common justification for reinstating this level was the desire to maintain a clear distinction between commercial broadcasters and community broadcasters. On the other hand, some interveners argued that the Commission should maintain the status quo for Type A stations, and set two levels for Type B stations depending on the time of day (25% during daytime hours, 15% during the evening), and depending on the day of the week (25% for weekdays, 15% for weekends). The basis for this recommendation is the fact that it is very difficult for volunteer producers to achieve a high level of spoken word content in their programming. The Commission has always sought to foster diversity within the Canadian broadcasting system by maintaining a clear distinction between community radio and commercial radio. It is also aware of the difficulty of maintaining a high level of spoken word content because of the limited human resources available to most community radio undertakings. Based on its analysis of the programming broadcast by community radio stations, the Commission considers the proposed level to be a reasonable one that will both preserve the diversity in radio services and provide enough flexibility to enable these stations to produce quality community-oriented programming. Accordingly, the Commission has decided to adopt the following measure: For Type A stations, the Commission will not set a specific minimum spoken word requirement. However, community stations will be expected to adhere to the minimum level of 15% spoken word per broadcast week required of all FM stations under the regulations. The Commission expects Type A stations to continue to produce community-oriented programming and, thus, to offer a level of spoken word sufficient to provide adequate service to their audience. Promises of Performance filed by Type A applicants and licensees will be assessed on an individual basis. As for Type B stations, the Commission will impose a minimum weekly requirement of 25% spoken word programming, with an emphasis on community-oriented programming. (b)Musical Diversity In the draft policy, the Commission proposed that at least 20% of the music on community radio be drawn from sub-categories other than 21 (Pop, Rock and Dance), and from Category 3. It also proposed not to impose a minimum level for Category 3 music. The Commission received several briefs in response to these proposals, some stating that they did not go far enough, while one party argued that they were reasonable. Among the parties opposed to the Commission's proposals there was no clear consensus as to the minimum level of music from sub-categories other than 21 that would be most effective in promoting musical diversity in each community station. Some suggested that 25% or 30% would be more appropriate, and one party went so far as to propose a requirement that selections from each of the sub-categories other than 21 should be evenly distributed throughout the broadcast week by all community stations. The vast majority of commercial stations play mainly sub-category 21 selections. As stated in the current policy, community stations should offer highly diversified musical fare in order to serve the musical tastes of all segments of the community. The Commission considers, however, that in promoting musical diversity, one cannot ignore the realities of community radio and the availability of material and financial resources. Accordingly, the Commission has decided to adopt the following measure: At least 20% of the music broadcast by community stations must be drawn from sub-categories other than 21 (Pop, Rock and Dance), and from Category 3. There will be no minimum level for Category 3 music, but the Commission will assess commitments regarding this category on an individual basis. Adherence to such commitments will be a condition of licence upon the issuance or renewal of a licence. (c)Program Formats Rather than restrict community stations to specific musical groups, the Commission proposed to classify them as Community Format stations without reference to musical groups. Of the comments received, all supported this proposal except for one, who proposed a new format for alternative music programming. Because the Commission encourages community radio stations to diversify their music programming by drawing on as many sub-categories as possible, it considers that they should be assigned a format that allows maximum programming latitude. The Commission also views its proposal as providing the flexibility required. Accordingly, the Commission will consider community stations as Community Format stations without reference to musical groups. (d)Music Usage Indicators The Commission proposed to maintain the maximum repeat factor of 10 for Type B stations only, and to disregard the list of distinct musical selections. In view of the inadequacy of the available French-language hit charts as a measuring tool, it proposed to continue to place no limit on the use of hits by French-language stations. The Commission further proposed to require English-language stations to make specific commitments in this regard, but not to impose a maximum level. Those who submitted comments were not unanimous in their response to this proposal. Some stated that the maximum repeat factor of 10 should be dropped, arguing either that it does not promote musical diversity on community radio or that it would unduly limit the options available to some community radio operators who have difficulty finding enough musical selections, especially French-language vocal music. One party supported the Commission's proposal, but stated that it should also apply to Type A stations in markets with at least one other station operating in the other language. Regarding the other music usage indicators, the comments received supported the Commission's proposal. Although there are differences of opinion regarding the proposed repeat factor of 10, the Commission considers that this measure will promote musical diversity in the programming of each Type B station. It is confident that this measure need not be applied to Type A broadcasters in competitive market situations. Accordingly, the Commission has adopted the following measure: The Commission will maintain as an important element of musical diversity, the maximum repeat factor of 10 only for Type B stations. The number of distinct musical selections will no longer be taken into account. The Commission will continue to place no limit on the use of hits by French-language stations; English-language stations, however, will be expected to make specific commitments in this regard. Although no universal maximum level will be imposed, the Commission reserves the right to set limits by condition of licence. (e)Canadian Content and French-language Vocal Music As of 1 September 1991, community stations, unless otherwise authorized by condition of licence, have been required to broadcast a weekly level of at least 30% Canadian content which is the same minimum level required of commercial stations. In addition, French-language stations are generally required to play 65% French-language vocal music over the broadcast week. The draft policy proposed to maintain these requirements. Most of the comments expressed support for this proposal, while two parties had reservations. One music industry representative stated that the Commission should require community stations to play 50% Canadian music, which is the level required of the CBC. One community station pointed out that, because of the kind of music it plays, defined by the Commission as falling in sub-category 21, it is concerned that it may have difficulty conforming to the 30% Canadian content requirement. Having considered these arguments, the Commission is confident that it is appropriate and reasonable to continue to require 30% Canadian music content and, in the case of French-language stations, 65% French-language vocal music. It does not consider it appropriate to require community stations to comply with the same Canadian content requirement as the CBC. Unlike community stations, which play a great deal of popular music, a very high proportion of CBC programming consists of spoken word and special interest music. Thus, a 50% Canadian content requirement for all popular music on community radio could jeopardize the musical diversity that these stations provide. Accordingly, the Commission has adopted the following measure: As required by the regulations, all community stations will be expected to ensure that at least 30% of general popular music selections (category 2) and at least 10% of traditional and special interest music selections (category 3) broadcast each week are Canadian. At least 7% of music in ethnic programming periods must be Canadian, as set out in the regulations. The guidelines on reasonable distribution of Canadian music set out in the policy for commercial FM stations (Public Notice CRTC 1990-111) also apply to community stations. These guidelines are as follows: -at least 25% of popular music selections broadcat between 6 a.m. and 7 p.m. Monday through Friday should be Canadian, -Canadian selections should receive reasonably even distribution throughout these dayparts and throughout the broadcast week, -there should be a significant presence of Canadian music in high audience periods, these traditionally being the morning and afternoon drive periods, and -French-language stations must continue to ensure that at least 65% of the vocal music broadcast each week is in the French-language. 6.Networks and Acquired Programming (a)Networks The Commission proposed to maintain the existing policy for Type A stations and amend the policy for Type B undertakings with a view to facilitating network affiliation. As no views were submitted opposing the Commission's proposal, the policy has been adopted as proposed, that is: The Commission will continue to permit Type A stations to affiliate with networks or acquire programming from other radio stations to avoid having to sign off at the end of their local programming. Type B station applicants and licensees will be required to file an appendix to their Promises of Performance demonstrating that the network programs or acquired programs they wish to broadcast will complement, but not replace, their local programs. Such filings will not form part of the Promise of Performance, and adherence to the commitments made in the filings will not be part of any condition of licence. Stations originating programming for network broadcast will also be required to file network applications in accordance with the Radio Networks and Syndication Policy (Public Notices CRTC 1989-3 and 1989-4). (b)Acquired Programming In response to a recommendation made during the consultation process, the Commission proposed to allow community stations to exclude up to 30 minutes per week of the commercials contained in Canadian syndicated programs when calculating the weekly total of advertising material broadcast. Different viewpoints were expressed by those who commented on this issue. Some were in favour of the Commission's proposal, while others were opposed, claiming that the exemption is not generous enough to encourage community stations to increase the exchange of acquired programming. They recommended raising the exemption to 60 minutes, which is the exemption accorded to commercial undertakings. On the other hand, one group recommended a 30-minute exemption for Type B stations, provided that the programs concerned are produced by another community broadcaster. The Commission is of the view that the formation of networks and the ability to exchange programs produced by other community broadcasters would contribute significantly to the development of community radio. Based on the comments received on this issue, the Commission considers that it is appropriate to allow community stations more flexibility in calculating their exemptions for acquired programming. It believes, however, that these programs must have a high spoken word content and be produced by not-for-profit organizations, producers or broadcasters. Accordingly, the Commission has adopted the following policy on acquired programming: The Commission will allow community stations to exclude up to 60 minutes per week of advertising material contained in Canadian syndicated programs when calculating their advertising broadcast time, provided that these programs are produced exclusively by a community or student organization (or broadcaster or producer), that the programs have a high spoken word content or are of concerts broadcast live or on a tape delay (first play) basis, and that they be of specific interest to the community served. 7.Hours of Broadcasting The Commission proposed to continue permitting community radio stations to increase or decrease their weekly broadcast time by 20% without application to the Commission. The few comments that were received on this matter supported the Commission's policy proposal. Accordingly, the Commission has adopted the proposal without amendment. 8.Local Talent Development In response to suggestions received during consultations conducted prior to the announcement of its policy proposals for community radio, the Commission proposed to no longer require community stations to make monetary contributions to the development of Canadian talent. Community broadcasters were to continue promoting the development of local artists through their programming. In general, the comments received concerning this question expressed satisfaction with the Commission's proposal. The Commission wishes to acknowledge the important role of community radio stations in providing on-air exposure for young talent. In its view, this contribution amply justifies relieving such stations of any requirement that they make financial commitments to the development of Canadian talent. Accordingly, the Commission has adopted the following measure: Community stations will no longer be asked to make monetary contributions to the development of Canadian talent. Instead, they will be expected to outline plans to promote and feature music by new Canadian artists, local artists and artists whose music is seldom heard on other stations. 9.Volunteer Participation Although the Commission made no specific proposals regarding public access to community radio programming, it remains a major Commission preoccupation. The issue was also raised in the filings received by the Commission. The licensee of a commercial station expressed the view that the Commission should require community stations to make specific commitments to maintain a strong element of volunteer participation. It proposed that such participation should be present in a minimum of 33% of all radio programming and that this percentage of the programming should be distributed uniformly throughout the broadcast day. The Commission notes that most community radio stations allocate a substantial proportion of their schedules to programming produced by individuals or organizations on a volunteer basis. The Commission considers that it is important that community stations encourage as much as possible community access to their programming. As the Commission has stated several times, community access to the airwaves was one of the principles underlying the establishment of this type of broadcasting undertaking. Accordingly, the Commission's concern is to ensure that this principle is reflected in the definition, role and mandate of community radio. Nevertheless, the Commission is aware of the limitations of volunteer participation, especially in sparsely populated areas. Accordingly, the Commission will not require community broadcasters to maintain any specific minimum level of volunteer involvement. At the same time, all community radio licensees will be expected to facilitate community access to their programming by clearly informing the public of the opportunities for community participation. The Commission further expects community radio applicants and licensees to describe in their licence applications or renewal applications the measures to be taken to promote volunteer training and the mechanisms put in place to train and supervise volunteer workers. 10.Implementation All community stations will be considered to be operating in compliance with their Promises of Performance until their next licence renewal provided they meet the guidelines set out in the policy, with the exception of any commitments that are subject to specific conditions of licence. Any changes to specific conditions of licence will require Commission approval before implementation. Stations that currently have commitments in their Promises of Performance that are outside the limits specified in the policy may continue with their current commitments and conditions of licence until the end of their current licence term. B CAMPUS RADIO 1.Defining Campus Radio In its draft policy, the Commission proposed to define two types of campus stations. Instructional stations would have formal associations with broadcasting courses and broadcast training as a primary objective. Campus/community stations would be stations not formally associated with broadcasting courses and would provide programming produced primarily by volunteers who are either students or members of the community at large. A number of briefs discussed the distinction that would exist between community stations and campus/community stations under the proposal. Four parties suggested that the Commission move toward a single policy for campus/community and community stations on the grounds that a unified policy, perhaps with specialized requirements for particular types of non-profit operations where required, would provide for easier interpretation and a clearer role for such stations. It was also observed that a single policy for both campus/community and community stations might make it easier for campus-based stations to obtain various grants available to community stations. On the other hand, three submissions from Quebec argued that there should be a clear distinction between campus stations and community stations, especially in Quebec where there are a large number of community stations. They expressed the concern that, under the Commission's proposal, campus stations could begin to compete with community stations and that campus radio would begin to lose its distinctiveness. These two points of view reflect the different environments in which Canadian campus and community stations operate: one essentially reflects the situation in Quebec, where community radio is well developed, and the other represents a perspective arising from circumstances elsewhere in Canada where there are few community stations, and campus/community stations have moved in to play the role that community stations were expected to assume. The Commission views as a positive development the evolution of campus/community stations toward greater involvement with and by the community at large, especially in areas without community stations, since such stations provide the means for all members of a community to have access to alternative programming that is of interest to them. However, it is also possible for a campus-based station to provide a diverse service to the community without assuming the role of a community station. In fact, in areas already served by a community station, this might be desirable to maximize program diversity. The policy should leave room for stations that maintain a strong campus orientation and also provide a mechanism for helping to ensure that a campus and a community station operating in the same area provide services that are different from each other. The Commission will therefore amend its proposal in several aspects as it relates to the distinction between campus/community stations and community stations. First, it will generally expect representatives of the student body, faculty, alumni or administration representatives of the university or college with which the station is associated, considered together, to form the majority of the board of directors of a campus station. The Commission considers that this will help ensure a distinction in orientation between campus and community stations. It will also require that, at the time of application for a new licence or for licence renewal, a campus station indicate how it will provide a service that is different from that of other campus or community stations serving the same market. The Commission will retain the option of making these commitments conditions of licence. Three briefs requested that the definitions of campus/community and instructional stations be clarified by specifying in what category a station devoting only a portion of its broadcasting time to students doing programming for class credit would fall. The Commission's definition of instructional stations was intended to include only those stations whose primary purpose is to train professional broadcasters. During consultations conducted prior to the release of the proposed policy, it was agreed that these stations are, indeed, different in purpose and philosophy from stations that fall into the campus/community category. Continued... 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