Service standards need revisiting: CAB’s Charman to CRTC

On March 2, Canadian Association of Broadcasters VP of television and specialty and pay services Wayne Charman offered his comments on the CRTC’s new proposed service standards. In his letter, excerpted below, he urged the commission to broaden the measures it proposes in Public Notice 2006-16.. …The CAB urges the commission to consider other initiatives that will serve to increase the efficiency and effectiveness of its various processes. For example...the CAB submits that the commission should develop a streamlined Category 2 licence renewal application process to minimize the regulatory burden placed on licensees. …The proposed service standard that 80% of applications processed via public notice should be processed within six months, where no interventions are received, and where no policy issues are raised, should, in the CAB’s view, be re-visited. First, the CAB wishes to clarify that where the commission refers to "no interventions," the intent is to refer to no negative interventions having been received, as supporting interventions should not slow down the processing of an application. Second, the CAB is of the view that the service standard should be applicable even where negative interventions are received, provided that such interventions do not raise policy issues. In these circumstances, the CAB believes the service standard should be four months, rather than six. Applications processed via public notice (excluding renewals), that do not raise policy issues, are generally straightforward in nature, and are similar in complexity to applications processed administratively. For this reason, the CAB is of the view that an appropriate service standard for these applications is one that is consistent with the standard for applications processed administratively... Accordingly, the CAB submits that the commission should consider a service standard of four months, rather than six months, to process 80% of all such applications. For applications, other than licence renewals, processed via public notice and for which negative interventions that raise policy issues are received, the CAB acknowledges that a longer processing time may be required....The CAB believes that processing 80% of these applications within six months is a reasonable standard in light of the inherent uncertainties with respect to the number of applications and their complexity. …The suggestion has been made that licence renewal processes that attract no substantive public comments, and/or which raise no significant policy issues, should be processed within 2 months of the deadline for public comments. The CAB recognizes that such a standard would represent a savings in administrative overhead for both the Commission and the licensee... ...The CAB urges the Commission to take the necessary measures to minimize the use of short-term renewals for administrative reasons, to avoid the uncertainty inherent with such renewals and the resultant impact on a licensee’s ongoing operations. …Finally, the CAB suggests that the Commission consider implementing an additional measure for any application that...cannot be processed within the time frame specified in the applicable standard...In such situations, the commission should advise the applicant as soon as it becomes aware that the standard won’t be met and...indicate to the applicant when it expects a decision to be issued.

Service standards need revisiting: CAB’s Charman to CRTC

Broadcast | March 13, 2006

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