Unifor Final Submission on The Path Forward – Working towards a modernized regulatory framework regarding contributions to support Canadian and Indigenous content


Unifor is Canada’s largest private sector union, with more than 315,000 members across Canada, working in 20 economic sectors. Unifor is Canada's largest union in the media sector, representing more than 10,000 media workers, including 5,000 members in the broadcast and film industries.

Our members work for radio and television stations serving local communities as well as national discretionary pay and specialty services, as well as distribution services that include cable, satellite and wireless telephony.


Unifor would like to take the opportunity in our final submission to emphasize the need for urgency.

Local news is in crisis, and news businesses and news creators urgently need financial support in order to survive and thrive. Broadcast television news stations are laying off employees, consolidating and regionalizing services, and downsizing operations just to stay on the air.

In our BNOC CRTC 2023-138-1 submission, we outlined in detail the decline in broadcasting over the last 15 years, but every week brings more bad news and more evidence that local news is in crisis. Unifor lost 136 members in broadcast television last year and 112 so far this year. That is the equivalent of five to seven TV or radio stations in a medium-sized market.

We know from our experience that for every union job lost, many more non-union jobs were also lost. The new funds raised through the Online Streaming Act are urgently needed, and any delay in the distribution of those funds will exacerbate the crisis and make it more difficult to repair and restore local news in Canada.

The loss of LPIF and Foreign Broadcasters allowed in Canada

This crisis isn’t simply a function of a change in viewer habits, but more a function of a distribution method of television that changed and made it difficult for regulators to keep the system Canadian.

In 2009, the Commission created the Local Programming Improvement Fund (LPIF), a program designed to provide additional funding for conventional TV stations in non-metropolitan markets. The LPIF was created to,

increase the quantity, quality and diversity of local programming produced by conventional TV stations in non-metropolitan markets. It was created in response to a decade-long decline of the financial model for local TV production in small markets, while cable and satellite companies that distribute the programming continued to generate record profits.[1]

Despite the ongoing decline of the broadcast TV segment in Canada, in 2012 the Commission announced it was phasing out the LPIF by August 31, 2014, citing, “the recovery in the advertising sector and the successful transition to digital television.”[2]

Foreign Broadcasters

Some of the foreign broadcasters have balked at their inclusion in the Canadian broadcast system. Some are arguing that they shouldn’t have to contribute to any new funds, or even going as far as suggesting that they shouldn’t have to contribute to local news. Allowing foreign broadcasters into the Canadian market while failing to have them contribute to the Canadian system has had a devastating effect on the broadcasting industry.

We cannot allow foreign digital streaming giants to continue to enjoy a regulatory and financial advantage over Canadian broadcasters, especially when those same digital streaming giants have contributed to the collapse of the financial model for broadcast TV.

Unifor believes it is not only important to ensure that the foreign digital streaming giants pay their fair share, but all broadcasting revenue by foreign broadcasters be included in the formulas. This should include unique transactions, as we’ve written in our reply submission to BNOC 138-1. Arguments that these revenues shouldn’t be counted because the analogy is wrong or the business is diminishing ring hollow. For Canadian consumers, there is no meaningful difference between renting a movie on a digital platform or subscribing to a streaming service to watch a movie. A transaction is a transaction, and all of these revenues should be included.

A New Local News Fund

The CAB, major Canadian broadcasters, independent broadcasters and other organizations, including Friends of Canadian Media, have all indicated their support for local news.

Regulations associated with the Online Streaming Act should acknowledge the need for sustainable and ongoing funding for the creation of local news in Canada. Unifor supports the creation of a fair and flexible funding arrangement that requires online broadcasters and traditional BDUs to support local news.

Unifor has made numerous recommendations regarding the news fund that should be created, the need for urgency in distributing funds, the administration and governance of the fund, and other important considerations. We stand by those submissions, and respectfully provide a summary below.

Summary of Unifor Recommendations

  1. Unifor respectfully recommends that the Commission prioritize establishing a local news media fund attached to the Online Streaming Act, similar to the LPIF. Like BDUs, qualifying foreign streaming companies would be required to contribute a portion of their revenue generated in Canada to a fund that would, in turn, be distributed to qualifying news organizations in Canada.]
  2. Unifor believes that the fund should be administered by an independent, arm’s length board of directors, comprised of media sector stakeholders including broadcasters, employee representatives, journalist associations, journalism schools, and members of the public, and no group should have a majority of seats. The board would be independent of the federal government and the Commission.
  3. Given the qualifying news organizations’ urgent need for financial relief, Unifor respectfully suggests a two-stage implementation model for the new news fund. We support the creation of an interim board, whose sole purpose is to distribute an initial round of funding. The creation of an interim board, tasked with distributing the initial round of funding that will flow from agreements associated with the Online Streaming Act, would give the federal government, the Commission, and media stakeholders additional time to create a permanent board and more detailed and permanent guidelines, policies and procedures. The interim board should be given a clear and simplified mandate, based on fundamental principles of accountability, transparency and inclusion. 
  4. Under the current system, cable, satellite and fibre-based TV distributors must contribute at least 5% of their broadcast revenues to Canadian content creation and production. This 5% contribution is divided up between the CMF/Certified Independent Production Funds (CIPF), the ILNF and Local Expression/Locally Reflective News. 
  5. Rather than change the distribution of these funds within the 5% total contribution, the Commission should make the whole pie bigger. In other words, Unifor respectfully recommends that the Commission should increase the Canadian content creation and production contribution from 5% to 7%. 
  6. The additional contribution of 2% should go directly to the proposed local news media fund. 
  7. Unifor also respectfully recommends that the Commission should integrate the ILNF with the new local news fund by adding the current % of funds already allocated to the ILNF to the new local news fund. Under this new proposal, no current ILNF recipient should receive less funding than they receive under the current program. While Unifor supports the principles and intentions behind the decision to establish the ILNF, the fund was always a partial solution to a much bigger structural problem. Canadian broadcasters and the viewing public deserve a solution that delivers stable, ongoing and fair funding for the creation of local news.
  8. In addition, Unifor respectfully recommends that the Commission should maintain current Canadian programming expenditure (CPE) requirements, and extend this obligation to online undertakings. Further, the Commission should consider requiring that a portion of this CPE money should be earmarked for the production of local news and programming, or the equivalent amount should be directed towards the local news media fund discussed above if the online undertaking doesn’t produce any news programming.
  9. The new funds should be earmarked for news creation; therefore, Unifor respectfully recommends that designated news outlets that employ journalists should be eligible for funding. The CRTC is currently determining broadcasters’ eligibility for the Online News Act based on the Qualified Canadian Journalism Organization (QCJO) criteria, and Unifor submits that this standard serves as a good foundation for determining eligibility for the proposed news fund. It is critical that eligibility criteria emphasizes the creation of original, first-run news content, and excludes organizations and outlets whose primary product is opinion-based content.
  10. Eligible news outlets should adhere to an accepted journalist code of ethics, such as the Radio Television Digital News Association (RTDNA) Code of Journalistic Ethics, and should be in good standing with the Canadian Broadcast Standards Council. In addition, eligible news outlets must be in compliance with the Conditions of licence set out by the Commission.
  11. To achieve transparency, we believe participants should be required to disclose basic information about their own operations, and the distribution amounts should be publicly reported so that “everyone knows what everyone is getting.” Finally, the funding eligibility requirements should be inclusive, ensuring that smaller, local and independent outlets also have access to desperately-needed support.
  12. Eligible broadcasters should meet a minimum standard of employment, and other measurable criteria (including, but not limited to, the number of hours of first run original news, the number of first run original news stories or items, and the geographic distribution of coverage). 
  13. The proposed fund could use a points-based approach or a weighting system based on the criteria above. This question, how to create a fair system to distribute funds in the long-term, should be a task for the Commission and the permanent board, with consultation from media sector stakeholders. 
  14. The success of this program can only be determined if the appropriate metrics are in place. The participating news businesses must be required to submit data including, but not limited to, employment levels (by job classification/title, workplace and location), number of hours of first run original news, the number of first run original news stories or items, and the geographic distribution of coverage (i.e. the number of stories by region or locale).
  15. Without this data, it will be difficult to measure the success of the program, and the board will not be able to make informed decisions regarding the allocation of funds. Unifor would like to reiterate that the funding that flows from the proposed news fund should be tied to the creation of local news, based on the number of news creators employed, and a number of related criteria. Without relevant data from fund participants, the funding program will not be transparent, accountable and inclusive, and the goals of the Online Streaming Act will not be achieved.
  16. Finally, Unifor recommends that the Commission reject all applications by broadcasters to relive them of their regulatory obligations to produce and fund Canadian content, including local news and programming. Recently, as the Online Streaming Act has approached completion, broadcasters including Bell Media, Corus and Quebecor Media Inc./ TVA Group Inc. have separately submitted applications seeking relief from various obligations related to local news and programming. 
  17. Granting the kind of relief sought by the traditional broadcasters would cause irreparable harm to the broadcast system. Unifor believes that “levelling the playing field” with online undertakings should not involve watering down existing standards and conditions.


Local news is essential to our democracy. In an age of disinformation, Canadians will depend on trusted news sources more than ever. The decline of local television news is not simply a function of a change in television viewing habits; it is a result of the systematic failure to regulate and properly fund and support. The Commission has the opportunity to create a new regulatory regime to address these concerns.

Unifor believes our recommendations will level the playing field by treating all broadcasters fairly. The Commission must ensure that “leveling the playing field” means increasing the contributions to Canadian programing, by prioritizing news and especially local news. Adequate and sustainable funding for local news will inform Canadians, protect our democracy and build our communities.

Thank you again for the opportunity to comment on this important matter.


Randy Kitt
Media Director, Unifor

[1] “CBC/Radio-Canada astonished by the CRTC’s decision to eliminate the Local Programming Improvement Fund.” Media Release. CBC/Radio Canada. (July 18, 20212). (https://cbc.radio-canada.ca/en/media-centre/cbc-rc-astonished-crtc-deci…).