Unifor 830M Response to Roger’s Final Reply 2016-225

The following letter was declined by the CRTC and is not part of the public record for BNOC 2016-225.  Roger’s statements are misleading and do not represent the facts.

Monday, January 9, 2017

Danielle May-Cuconat

Secretary General


Ottawa, ON K1A 0N2

Dear Ms May-Cuconato;

I have reviewed Rogers final reply to BNOC 2016-225 and I am writing to address the fact that Rogers’ comments in paragraph 47  of its reply to interveners mischaracterize the evidence that I have presented during this important license application process, and to correct the errors it has made.

Rogers January 6th final submission states:

Correcting an Inaccurate Statement of an Intervener

47.One final issue that we feel compelled to address is the inaccurate statements made at the hearing by Steve Hawkins who appeared on behalf of Unifor Local 830. At the hearing, Mr. Hawkins said that our City station in Vancouver operates with “one journalist”, which is misleading.41 The reality is that our news team for City Vancouver consists of the equivalent of 28 full-time staff, which includes on-air hosts, news reporters, writers/researchers, news shooters/editors and studio crew.

The CITY newsroom employees are detailed in our evidence which also gives revealing details of the positions cut on May 2015 with an attached membership list that has strike-outs for the positions that were cut.

830M’s August Intervention, 2016-0009-9, stated:

24. In May of 2015, following a major staff restructuring, Rogers has only 6 full time news camera operators/editors, and 1 full time news editor. There are 6 members working in editorial news operations at CITY and 9 employees working on OMNI’s three current affairs programs.  There are 5 members working in station operations and another 11 members working in either promotions, traffic or sales for CITY and OMNI. (Membership List Mar2015)

25. Where does this leave CITY programming in 2016?  How does the local Canadian programming that airs on CITY Vancouver differ from other Vancouver broadcasters? How does it differ from what Rogers offers its Ontario viewers?

How does this compare to other Vancouver Broadcasters?

26. Shaw’s local news programming employs 13 full time anchors; 13 full time and 12 part-time/temporary reporters; 2 full time videographers; 2 full time assignment editors, 1 full camera assignment/ digital media producer; 24 full time & 2 part-time producers; 2 full time & 1 part-time associate producers; 4 full time  4 part-time/temporary writers; 6 full time online journalists; 1 online video producer; 17 full time & 8 part-time/temporary news camera operators; 14 full time & 12 part-time/temporary news editors; 6 full time LiveEye operators; 7 full time & 5 part-time/temporary feed co-ordinators. That’s a total of 112 full time, 44 part-time/temporary local news employees.

27. CTV’s local programming in Vancouver employs 12 full time & 7 part-time/freelance reporters; 19 full time & 5 part-time news camera operators; 2 Live Truck operators, 10 full time & 6 part-time news editors; 15 full time & 4 part-time writers and producers; and 4 full time employees involved in assignment. That’s a total of 62 full time, 22 part-time local news employees.

How does this compare to CITY in Toronto? 

28. Rogers CITY TV operations in Toronto have far more employees involved in local news programming.  There are over 124 full time and 41 part-time/casual operations employees; 37 full time and 6 casual in-house editorial employees; 24 full time and 14 part-time/casual news field operations; and 32 casual field news editorial employees.

Budget vs Quality 

29. I can tell the Commission there is a substantive difference between the programming provided by Rogers in Vancouver than in Toronto.  How could there not be when you objectively look at the number of hours of programming and the number of people involved in that programming, especially the lack of field journalists in Vancouver?

30. Rogers operations in Vancouver does not have a single person that works exclusively as a news reporter.  The morning news reporter spends the first few hours of their shift writing sports for Breakfast Television, then if the work flow allows it, they will go on location to report live segments into the news show, often only appearing live for a few hours of the show.  Once the show is off the air, that reporter day answers phones for Sportsnet, OMNI or CITY; or some other newsroom duty

Rogers’ misrepresentation of material facts in its reply to interveners

Rogers now states that the facts in my written intervention are incorrect, based on the evidence that it has now chosen to provide:  “our news team for City Vancouver consists of the equivalent of 28 full-time staff, which includes on-air hosts, news reporters, writers/researchers, news shooters/editors and studio crew”.

This statement misrepresents the facts I presented, by leaving the misleading impression that these were incorrect, and ignores my specific comments at paragraph 30, addressing the actual duties of their one field reporter.

Without seeking to re-explain the evidence in my written submission, or to introduce more evidence, permit me to note that Rogers has simply muddied the water even further:  it does not state whether these positions are devoted solely to City Vancouver, or to OMNI Vancouver or to both stations, or – and most importantly – the percentage of time that each position provides journalistic services.

Respectfully, Rogers has mischaracterized my evidence as inaccurate, without providing the evidence needed by the CRTC to determine the accuracy of Rogers’ own evidence.

Rogers’ reply is out of process

I have participated in a number of CRTC proceedings, and am aware that the CRTC does not normally permit interveners to respond to applicants’ response to interveners’ final replies.

In this case, however, it seems to me that Rogers is not responding to my final reply, but has instead decided to respond to the evidence presented in my written intervention.

My understanding of the CRTC’s procedural rules, however, is that Rogers should have presented this new information in its final reply either in its initial reply to interventions, in its opening remarks, during questioning from the CRTC, or in its final remarks at the hearing.

Rogers had many chances to prove that it was right, and that the people like me who work every day at the station are not. Perhaps its unusual decision to respond to me now – in its very last reply in this proceeding – shows that it now recognizes its error in failing to prove the level of journalistic resources it makes available to each station, in a proceeding focussed on its past performance and future commitments.

Regardless, allowing Rogers’ statements to stand unchallenged would be, quite simply, unfair.

I realize Rogers is supposed to have the last word in these matters, however when they use this opportunity to make statements like in paragraph 47, I feel the Commission should investigate these statements in context to all the evidence that has been presented.  At the very least, the CRTC should permit this response to Rogers’ mischaracterization of my evidence to be placed on the record of this proceeding, and I respectfully request that this be done.

Should you require any clarification of my written intervention’s factual evidence, please let me know.

I have provided a copy of this letter to Rogers.


Stephen Hawkins

Local President, Unifor 830M

cc, Susan Wheeler, VP Regulatory, Rogers Media Inc