Today the NCRA submitted a memo to the Government of Canada's public consultation on copyright. Industry Canada and Canadian Heritage launched this consultation together, asking for input into copyright act reform. The process has received thousands of submissions from industry stakeholders and individual Canadians, and our submission aims to put the needs of community-based radio stations forward as part of the copyright reform agenda.

The NCRA works with the Copyright Board of Canada, with copyright collectives directly, and with the federal government, to try to get a fairer deal for our member stations on copyright issues. This includes trying to make copyright tariffs predictable and affordable, and trying to make reporting requirements reasonable. Our goal is to make sure that our stations can continue to do all that they do to support emerging and Canadian artists.

Our comments emphasize the role of campus and community radio on the risk-taking forefront of supporting Canadian culture and emerging artists. Since our stations do this without making a profit from the music we play, we believe it would be reasonable to expand the tariff exemptions provided in the act to include community-based radio. We also think that new copyright legislation should not allow copyright collectives to charge retroactive tariff fees for playing music before a tariff is certified, since these unforeseen retroactive costs can be significant, and dangerous for struggling non-profit radio stations.

As well, we strongly believe that the copyright system should take into account the impact that a tariff is likely to have on users, and whether the tariff would produce an unreasonable financial hardship on users, which could make it counterproductive. And we argue that Canada needs a copyright system that encourages our broadcasters to embrace emerging distribution technologies, rather than discouraging it by imposing unpredictable and uncertain costs n new technology activities.

Please see the attached document for our full submission.