From fenner@synapse.net Mon Jun 21 09:17:23 1999 Date: Sun, 11 Apr 1999 13:45:08 -0400 From: Victoria Fenner To: ncra-info@chebucto.ns.ca Subject: CRTC Submission: Board Structure Here is my submission to the CRTC, filed today. Victoria April 11, 1999 Secretary General, CRTC, Ottawa, K1A 0N2 Central Building Les Terrasses de la Chaudière 1 Promenade du Portage Hull, Quebec K1A ON2 Submission by: Victoria Fenner 1140 Fisher Avenue # 504 Ottawa, Ontario K1Z 8M5 613-725-9799 RE: Call for Comments on a Proposed New Policy for Campus Radio Public Notice CRTC 1999-30 1. I would like to commend the Commission for the excellent job which has been done on the proposed campus/community radio regulations. 2. While there are many things to which I could comment, I will restrict my comments to the suggested revisions to the structures of the Boards of Directors for campus/community radio stations. Of all the proposed revisions, this is perhaps the most important. Obviously the writers of the proposed policy understand this quite well. I would like to add my voice to reinforce their perspective and emphasize the importance of this issue. I would also like to elaborate on my reasons for believing that this is a move in the right direction. 3. In general I would like to support the submission on this topic by the National Campus and Community Radio Association, but would also add the following comments. 4. I am writing this submission as a private citizen rather than as a representative of any particular organization. I have worked in campus/community radio for more than twenty years, beginning as a volunteer at CJAM (University of Windsor) in its carrier current days. I worked as both a volunteer and special project staff member at Vancouver Co-op Radio in the early 1980's, and most recently was station manager at CFMU (McMaster University) for more than five years. I now work on a variety of independent radio related projects in Ottawa. I am still involved in campus/community radio because I believe it is a unique and important voice which needs and deserves to be strengthened. People and groups from across the country call me for advice on starting and running community-based stations and I am frequently asked to speak on the subject or conduct workshops. 5. While at CFMU, I experienced firsthand the weaknesses of the current policy in the area of governance. Often I have been asked by emerging stations for copies of CFMU's administrative structure and bylaws. Half-jokingly, I usually told them I would give it to them on the condition that they use it as an example of how NOT to set up a Board of Directors. 6. On paper, CFMU was its own corporation. This would seem to be several steps ahead of those stations which are entirely owned and governed by a student union. But despite the separate incorporation, CFMU was still entirely a part of the McMaster Students Union, treated no differently from the pubs, convenience stores, and the daycare centre. CFMU's Board of Directors were the same three people who sat on the Board of the McMaster Students Union. They automatically inherited the CFMU board positions along with their student union positions (unless one of the student union Board members happened to be non-Canadian, in which case an alternate would be appointed). Quite often the Board of CFMU Radio was composed of people who had no knowledge of campus/community radio, or the regulations that govern it. 7. I should also point out that this Board of Directors did not operate in the manner of most non-profit boards. Many of their decisions were subject to ratification by the entire Student Representative Assembly, begging the question: were the Board of Directors of CFMU really directors or is the entire student assembly really the station's directors? It was all very muddy, but it was also very clear that the McMaster Students Union regarded the separate incorporation as a mere procedural matter. 8. I would not bring up the CFMU situation if it were unique. I have talked to people at other stations with similar issues and know that the problem is not isolated to CFMU. For the development and survival of our stations, it is critical to diversify and strengthen the composition of our Boards of Directors, and to encourage Boards of Directors who have a real interest in furthering the goals of our stations. I am pleased that the Commission has taken this issue seriously and is prepared to bring in regulations which will help ensure a broad base of decision-making. 9. Specifically, the Commission's proposed changes will mean: 10. a) A broader base of experience on the Board of Directors. Decisions will be made which are in the interest of the station alone, rather than the students' union as a whole. When the board is entirely controlled by the students' union, the people making decisions about the station are not always knowledgeable about the station. There have even been cases in the past, with other stations as well as CFMU, where the directors do not even support the existence of the station. The moderating influence of people on the board who are committed to and knowledgeable about the station will improve matters considerably. 11. b) Community representation at the board level will hopefully convince key funders and supporters that the commitment to the community is real. (When preparing foundation grant applications at CFMU, I was frequently asked for evidence of community involvement. It weakened our case considerably when funders were told that there is no community representation on the Board). 12. c) Greater continuity ^Ö community representatives are more likely to stay on the board beyond one year, helping create continuity and a pool of knowledge which is so badly needed. Also, community volunteers can be recruited for their connections in the community and their business knowledge and experience. This will undoubtedly help the station develop resources which are badly needed. A board made up entirely of young undergraduates is not in a position to forge these valuable community links. 13. d) A diversified Board of Directors is a powerful symbol that power and decision-making is shared. This symbol, I believe, is important to create a sense of volunteer empowerment, especially if volunteers are represented on the board. When the station is wholly owned and controlled by the students' union, volunteers have little incentive to improve the station. For example, why would a volunteer actively participate in fundraising without a voice in how the money would be spent? Or if there is a chance the money might be diverted to other student union services? Organizations can only move ahead when the people involved feel a sense of responsibility and belonging. When a station is wholly owned and controlled by a student union, the volunteers feel more like invited guests who are at the station only with the consent of the governing masters. There is often a fear that this consent will be revoked (I have noticed that this is especially true of multicultural programmers). A diversified board increases the likelihood that decisions made will be balanced, rather than based on an agenda of one group alone. 14. e) It is positive that the Commission's recommendations recognize that students and the university also have an important role to play, and are entitled to seats at the boardroom table. The relationship between student board members and community volunteers is often uneasy. Sometimes animosity is generated by community volunteers and representatives who do not acknowledge that students are supporting the station in a major way. It is foolhardy to antagonize a radio station's primary source of funding. To not acknowledge the contribution of the university and the students is to run the risk that funding will be reduced or eliminated entirely. 15. Consistently, stations whose Board of Directors consists of ALL major stakeholders work better than those stations which are operated as a subsidiary of a larger organization. 16. I wholeheartedly support the proposed regulations and also urge that you take them a few steps further. 17. a) Re: the clause "Licensees that do not conform to the policy would be asked to explain either why the new policy should not apply to them (for example, because their programming is targeted exclusively to the campus population)" ^Ö I suggest that the Commission only grant a license to a campus-only group if there are additional frequencies available for a community group which may want to start a station at a later date. Under no circumstances should a campus-only broadcaster be given a protected frequency in areas where shortages of frequencies exist. I also suggest that this apply when campus broadcasters apply for power and frequency upgrades. It should be an ongoing principle of the CRTC that the prime frequencies are allocated to radio groups serving the ENTIRE community, not just one special interest group. 18. b) The Commission should be vigilant in assessing compliance with the new regulation. Some hard questions will be needed at license renewal time. Some of the things the Commission can do to ensure compliance are to ask for a restructuring plan with firm timelines, and to grant short term licenses until the Commission is satisfied that satisfactory changes have been made. 19. c) The Commission could fund Board of Directors training workshops for stations. Some stations may have difficulty complying with the new regulations because they do not understand the role of the Board. Some current boards may have a hard time understanding that the Board of Directors has specific legal powers and responsibilities, and is not merely an advisory board which submits recommendations to the student council for final approval. They will need some coaching. 20. d) The Commission should require that the Board of Directors wholly separate the finances of the radio station from the finances of the student union. Separate treasurers, separate bank accounts, separate auditors. 21. e) The Commission should mandate a seat on the Board of Directors for a station volunteer. Our stations would not exist without the efforts of the volunteers. Their significant contribution should be recognized with an official voice at the highest leadership level. 22. Though there are other things I could comment on, I have chosen to limit my comments to the issue of governance. I could make other points about radio art, turntabling, or music categories but I'm sure my colleagues will cover those areas adequately. 23. Campus/community radio is still very fragile. We need strong leadership to ensure our survival into the next century. Of all the regulatory changes which have been proposed, this is by far the most important. Thank you for acknowledging this. Sincerely, Victoria Fenner