APPENDIX 1

SUPPLEMENTARY BRIEF

CHQR (AM) LICENCE AMENDMENT

INTRODUCTION

This is an application by CKIK-FM Limited, a wholly owned subsidiary of Corus Entertainment Inc., to amend the licence of CHQR (AM) Calgary, by adding an FM transmitter in Calgary at 106.9 MHz (channel 295A) with an effective radiated power (ERP) of 1,000 Watts.

The purpose of the FM transmitter is to rebroadcast the programming of CHQR in order to correct coverage deficiencies in downtown Calgary associated with CHQR’s AM signal. Extensive surveying has shown that significant numbers of residents, workers and commuters in the downtown core have difficulty receiving a clear and uninterrupted AM signal from CHQR. This is due to the continuous growth in the number of both commercial and residential high rise towers and the increasing presence of man-made interference in downtown Calgary.

The proposed FM transmitter will operate as a full-time rebroadcaster of the AM signal within CHQR’s existing licenced area. This will allow CHQR to provide a reliable high-quality signal on the FM band to listeners in downtown Calgary who are no longer able to obtain satisfactory reception of the AM signal, whether in their homes, cars, on public transit or at their place of employment. This will enable CHQR to properly fulfill its mandate to deliver a vital and comprehensive (and sometimes essential) news and information service to all areas of the Calgary market for which it is licensed.

The proposed coverage contours of the FM rebroadcast transmitter are completely enclosed within the existing equivalent AM coverage contours of CHQR. Appendix B provides comparative maps showing the proposed 3mV/m and 0.5 mV/m contours of the FM rebroadcast transmitter in relation to the existing 15 mV/m and 5 mV/m contours of CHQR (AM), for both its day-time and night-time operation.

Accordingly, as a “nested” rebroadcaster, the new FM transmitter will not extend in any way the geographic reach of CHQR’s AM signal and the area it is currently licensed to serve. The presence of an FM signal delivering CHQR’s programming will simply allow us to properly serve a segment of the audience that CHQR has in fact been licensed to serve for the past 47 years, but which for technical reasons it can no longer consistently reach on the AM band.

In this Supplementary Brief supporting the proposed amendment to CHQR’s licence, we address the following matters:

• an overview of the Calgary radio market; • CHQR’s importance to Calgary and service to the community; • CHQR’s signal quality issues in Calgary; 2

• technical alternatives to correct reception issues; • the use of 106.9 MHz (channel 295A) for the proposed FM rebroadcast transmitter; and • compliance with the common ownership policy

OVERVIEW OF THE CALGARY RADIO MARKET

When it launched 47 years ago in 1964, CHQR became the 6 th station in the Calgary market. By 2001 the number of radio stations had grown somewhat, but there were still only 10 commercial English-language stations in the market, as well as an ethnic service and the stations operated by the CBC.

Since 2001, however, the Calgary radio market has expanded rapidly. Today, there are 26 radio stations licensed to serve the Calgary market, of which 18 are commercial English-language stations (5 AM and 13 FM). These numbers do not include three stations licensed to Golden West Broadcasting in High River/Okotoks to the south of Calgary which serve the southern part of the Calgary CMA.

Add to this mix of conventional radio stations new content delivery platforms such as satellite radio, a virtually unlimited range of internet-delivered audio services, and a host of personal electronic devices that enable listeners to access audio content anywhere from multiple sources, and it becomes obvious that CHQR must continuously adapt to new competitive realities to maintain the loyalty of Calgary radio listeners.

In the introductory statement to its 2006 decisions approving applications for four new FM stations to serve Calgary and one new FM station to serve Airdrie 1, the Commission reached the following conclusion respecting the ability of the Calgary market to support new radio services at that time:

The Calgary commercial radio stations enjoyed a combined profit before interest and tax (PBIT) of just under $24.5 million in 2005. This represented an increase of just over $5 million, or 26%, compared with the results for 2004. In 2005, the average PBIT margin of all Calgary radio stations was 31.8%, well in excess of the average PBIT margin of all English-language Canadian radio stations, which was 22.9%. ... On the basis of the strength of the Calgary market and the current profitability of Calgary commercial radio stations, the Commission is of the view that the Calgary radio market can support the introduction of four new commercial radio stations to serve Calgary as well as a new radio station to provide local service to Airdrie without an undue negative impact on existing stations.

Now, five years later and after the stations licensed in 2006 have had a chance to become established, the economic performance of the Calgary radio market is considerably less robust than it was at that time.

1 Broadcasting Public Notice CRTC 2006-97, Licensing of new radio stations to serve Calgary and Airdrie, Alberta – Introduction to Broadcasting Decisions CRTC 2006-321 to 2006-326 . 3

According to the financial information released by the Commission with the recent call for applications for radio stations to serve Calgary 2, the combined PBIT of the Calgary radio market increased slightly to $27.2 million in 2006, held relatively steady in 2007 ($26.5 million) and 2008 ($25.1 million), and then declined sharply in the following two years as a result of the global economic recession of 2008. In 2010, the PBIT of the Calgary radio market was only $17.5 million, almost 30% lower than the 2005 PBIT level cited by the Commission in 2006 when it decided to licence five new stations in the market. Meanwhile, more stations were dividing this total.

The decline in profitability is attributable to the weak revenue performance of the market since 2008. From a high of $102.2 million in 2008, radio revenues in the Calgary market have declined to $87.9 million in 2010, a drop of some 14%.

The July 2011 Trans-Canada Radio Advertising by Market (TRAM) Report shows only modest improvement in Calgary radio revenues this year, with an increase of 3.7% in total revenues on a year-to-date basis but only a 1.7% increase in local revenues on a year-to-date-basis. Clearly the Calgary market continues to struggle and its performance in 2011 remains far below the levels achieved in 2006 to 2008.

Given the depressed economic performance of the Calgary radio market over the past three years, Corus believes that the market cannot support the licensing of new radio services at this time. Nevertheless, given that three months ago the Commission issued a call for applications for new commercial radio services in Calgary, the fact is that the door has been opened to further upheaval in the market, potentially adding to the already daunting competitive challenges outlined above.

In this context, Corus must act now to address the serious technical reception issues that have increasingly plagued CHQR over the past several years. Our reception problems in downtown Calgary, in high-rises, and along the LRT tracks have resulted in the loss of listeners and hampered our ability to fulfil our programming mandate to the best of our ability. These technical issues and the solution we have proposed are described in more detail later in this Supplementary Brief.

With the potential of further changes to the Calgary market, CHQR cannot afford to be left behind with an AM frequency that, while providing extensive rural coverage both day and night outside of Calgary, is incapable of properly serving a significant segment of its listening audience in Calgary’s core areas. We must apply now for a technical amendment to CHQR’s licence to address these reception issues, so that we can compete on a relatively equal footing going forward with existing players in the market and with any new players that might be licensed as a result of the current proceeding.

Unlike potential new entrants, approval of our proposed rebroadcast transmitter will have negligible impact on the Calgary radio market. We do not project any revenue increases over the next three years as a result of this amendment; we simply wish to provide a reliable high-

2 Broadcasting Notice of Consultation CRTC 2011-398, Call for applications – Radio stations to serve Calgary, Alberta . 4

quality signal in Calgary to fulfill the coverage mandate of our existing licence. It will provide our listeners with improved access to CHQR’s signal in their cars when they commute downtown, in their high-rise condominiums and apartment buildings and at their offices in downtown commercial towers.

At the same time, we do acknowledge that over the longer term, the availability of CHQR’s signal on AM may enable us to attract new listeners, particularly in the younger demographic, who tend to listen only to FM. A news/talk format can work in FM, and we will address this point in more detail below. Approval of this rebroadcast transmitter will better position CHQR to reach these FM-only listeners in the longer term.

CHQR’S IMPORTANCE TO CALGARY AND SERVICE TO THE COMMUNITY

Since CHQR (“QR77”) first went on the air in 1964 it has been one of Calgary’s leading stations. The QR branding (“quality radio for quality people”) has been a hallmark of the station’s format and mandate which continues to this day.

QR77 moved to a news/talk format in 1991. The format has proven to be highly popular, with QR77 carving out a solid niche for itself even as the number of stations on both the AM and FM bands have increased over the years.

Today, QR77 is Calgary’s first choice for informative talk, news, sports, business, traffic and weather information. QR77 is the station to turn to for breaking news, providing listeners with up-to-the-minute information on stories of interest.

QR77 takes particular pride in its local news coverage. While it is possible to get international and national news in many places through social media and the internet, it is harder for people to get current in-depth coverage of local stories. This is why we cover city council extensively, including not only council meetings, but the behind the scenes stories that otherwise might not be told.

We have excellent relationships with the police, fire department and Emergency Medical Services allowing us to get breaking news on the air quickly. This is an especially important aspect when people’s safety and lives might be at stake, as in a school hostage taking which we covered in 2010. Our reporters are out in the community and have a good sense of what people are talking about, which allows us to localize our news even further to reflect the community’s concerns. During emergencies, such as weather warnings, amber alerts, power failures and implementation of the provincial emergency warning system, QR77 performs a valuable public service that is not available through other media platforms.

In a typical week, approximately 50% of our news coverage is local, with national stories comprising 30% to 40% and international stories comprising 10% to 20% of our coverage.

Our news anchors have embraced social media platforms as yet another vehicle to keep people informed using Twitter , Breaking News Alerts, Facebook and of course www.qr77.com

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QR77's community involvement, however, goes far beyond its regular programming and daily community events reports. From its inception, CHQR has positioned itself as a part of the Calgary community. In 1974 it bought the Allied Arts Centre, long thought of as the cultural heart of the city. Renamed the QR Centre, it became the second home of the radio station in March, 1975. The building continued to be the home of institutions like Theatre Calgary and allowed CHQR to continue to expand its commitment to the arts community.

When the Flames Hockey Club moved from Atlanta to Calgary in 1980, CHQR became the inaugural home for the team’s broadcasts. That commitment to coverage of sports activities in this community has not wavered over the years.

For the past twenty years, QR77 has been the proud home for Stampeder football. In partnership with the team QR77 has worked hard to provide an informed perspective on the organization, the players, and the season. That coverage is amplified by CHQR Sportstalk which airs week nights and provides a forum for informed comment and audience participation on a wide range of sports topics.

For more than three decades QR77 has been a leader in the community devoting countless hours to the stations marquee charity and fund raising effort – the Calgary Children’s Foundation. The raison d'être of the Calgary Children's Foundation is working with a wide range of local children’s charities that focus their efforts in a number of areas that help the physically, mentally and/or financially disadvantaged. The Calgary Children's Foundation funds mostly small, grass-roots groups who have limited dollars for fundraisers and external communications.

Each year, on the first Friday in December, the station sets up shop at the Westin Hotel and conducts a day-long fund-raising radiothon. Pledge Day, together with a number of other activities throughout the year, has allowed CHQR to raise nearly $2 million over the years, which in turn, has been dispersed through the Foundation to various worthy causes that work with children.

A list of this year’s recipients, along with a link to our web page dedicated to the QR77 Calgary Children’s Foundation, can be found in Attachment 1.

Our philanthropic efforts are diverse with partnerships with groups like Little Warriors (working with victims of child sexual abuse), the Calgary Philharmonic Orchestra, Kids Up Front (providing tickets to disadvantaged children to attend Calgary sporting and other events), and The Alberta Adolescent Recovery Centre.

We are proud of our role in the Calgary market. We provide a vital service in terms of our on- air news/talk programming, and we are active contributors to the day-to-day life of the community. The technical amendment we are proposing in this application is intended to allow us to properly fulfill our role by addressing the technical issues that have limited the ability of our listeners to receive a consistent, reliable signal in downtown areas of Calgary. This, we submit, is in the public interest.

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CHQR’S SIGNAL QUALITY ISSUES IN CALGARY

CHQR broadcasts on 770 kHz at 50,000 watts around the clock, enabling us to achieve extensive rural coverage outside of Calgary both day and night. While such expansive rural coverage is a key advantage of this AM frequency, the flip side is that the quality and reliability of our signal within the city of Calgary has become seriously affected by the explosion of construction in downtown Calgary that has occurred over the past 30 years.

Today, downtown Calgary is populated by numerous office and condominium high-rises, and more than a dozen new towers are presently under construction in the downtown. The cement and steel components of those towers are the major cause of signal deficiencies, deficiencies that have an adverse effect on the station’s ability to meet its mandate to more than 160,000 people that live/work in the downtown core every weekday.

Photographs of the Calgary skyline taken over the years since CHQR first went on the air provide graphic evidence of the extent to which high-rise construction in the downtown core has changed the physical environment in which we operate.

In 1969, five years after the launch of CHQR, the Calgary Tower dominates the skyline. There are only a handful of medium-rise buildings.

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Another view of Calgary in 1969.

Eight years later, in 1977, new high- rise construction is evident in downtown Calgary. The Calgary Tower is still the most prominent structure.

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In 1984, the new Petro-Canada Tower dwarfs the Calgary Tower.

Downtown Calgary in 2011. The skyline is now dominated by numerous high- rise towers, many much taller than the Calgary

Tower.

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Another view of downtown Calgary in 2011.

Listeners most commonly report reception difficulties inside large buildings or apartment blocks, or driving in or around the downtown core. In various parts of the city where there are concentrations of large apartment blocks or a mix of commercial and residential towers the same problem exists. LRT right-of-way and transmission power lines on the south and west side of the city also lead to an inconsistent signal.

A growing residential population is reporting its frustration at receiving an intermittent signal. For a station that prides itself on being a reliable source of information to its listeners, this is a problem. The 2011 Civic census reports more than 37,000 people live in the inner city and downtown core. That number will grow with large-scale developments underway including the Bridges on the north side of the Bow River, the East Village in the area between City Hall and Inglewood, and the Beltline where there are over 37 major residential towers and another 10 towers in some stage of development in the community.

In recent years, CHQR has conducted regular audience surveys to solicit listener feedback on our programming, plans and issues that need to be addressed. These surveys have shown just how serious our downtown reception problems are.

In January 2007, Solutions Research Group conducted a telephone survey of 416 Calgary radio listeners aged 18+, each of whom listened to radio at least 30 minutes during a typical weekday. Among other things, this survey showed that:

• Three-in-ten CHQR listeners indicated they have experienced difficulties receiving the station. Among all listeners who recalled tuning to CHQR, 30% reported they “frequently” or “sometimes” had reception problems in at least one of the situations 10

probed in the survey. Inside large buildings and apartment blocks (52%) and driving in downtown Calgary (44%) were identified as particular problem areas.

• 48% of FM listeners agreed that one of the reasons they don’t tune AM is that “it’s hard to get a consistently clear signal.”

In December 2009, Vision Critical undertook a research study for CHQR involving a total of 813 online interviews. Qualified respondents were 25-54 year-olds living in the Calgary CMA for 6+ months who listened to radio at least 30 minutes per typical weekday.

The 2009 study confirmed the general AM reception problems that had been identified in the previous survey. It found that 51% of radio listeners did not tune AM stations at all in the week prior to completing the survey. Of these FM-only listeners, 58% agreed that one of the reasons they don’t listen to AM is because it is hard to get a consistently clear signal on the AM dial.

With regard to those listeners who reported having difficulty in picking up stations, CHQR topped the list of stations identified as having particular problems due to the presence of large buildings and in the downtown core.

Most recently, Corus commissioned a study by Vision Critical in September 2011. This study consisted of an online survey of 602 residents of the Calgary CMA, aged 18+. With regard to signal problems experienced by CHQR listeners, it found the following:

• A majority of Calgary adults who have listened to CHQR have experienced difficulties receiving the station. Only 39% report “never” having trouble receiving CHQR. Particular problem areas are driving in the downtown core and locations within large buildings such as apartment blocks and office towers. LRT tracks also interfere with the signal.

• More than one-third of those who have ever listened to CHQR say they would listen “much” or “a little” more often if the station were on FM. This rises to 60% among those who have experienced problems receiving CHQR’s signal.

The 2011 survey also sought feedback to determine more general patterns respecting AM and FM tuning. Consistent with previous findings, the survey found that more than half of Calgary adults do not listen to an AM station regularly, and that tuning to AM is particularly low in the under 50 demographic. Of particular relevance to this application, the survey also found that CBC Radio One listeners, especially those under the age of 50, are more likely to listen to Radio One on its nested FM frequency rather than use its AM signal.

The findings concerning Radio One listening confirm an important point – contrary to the views of some parties who argue that news/talk formats are best-suited for AM and FM should be reserved for music formats, the fact is that a news/talk format on FM does work. The audience success of CBC’s Radio One service using nested FMs in western Canada and FM-only transmissions in several markets in eastern Canada, including Ottawa, Montreal and Toronto, is a testament to that fact.

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Moreover, Corus has had direct experience with a successful news/talk format on FM. Prior to its sale last year, Corus operated CHMP-FM Montreal on 98.5 MHz. We converted the station from an alternative-rock music format to a news/talk format and were able to make its morning show number one in the market.

The success of the CBC in placing its Radio One service on the FM dial, the Corus experience in Montreal with a news/talk format on FM, and the results of the recent Vision Critical survey all point to the fact that news/talk formats work on FM. Moreover, they provide much-needed diversity for those listeners who choose to listen only to the FM band.

In addition to the study conducted by Vision Critical, CHQR also conducted its own listener survey to obtain more detailed information as to the extent and nature of reception problems. Over the course of 10 days we invited our core listeners to take part in an on-line survey pertaining to reception difficulties. We also advised listeners that they could telephone our reception desk as well to provide their input. We received over 700 responses to the on-line survey, plus another 50 telephone calls to reception. The results of this survey, both on an individual and aggregate basis, have been included with this application in Appendix D (“Documentation supporting technical issues”).

Our online survey revealed the following information:

• 64% of the respondent over the past 90 days had difficulties with the reception of QR77. • 62% of respondents experienced a poor signal in their cars. • 59% of respondents experienced a poor signal at home. • 50% of respondents experienced a poor signal at their place of employment.

We have also included in Appendix D a sample of the qualitative comments provided by respondents to the survey. These comments provide 40 specific locations in Calgary where respondents have experienced reception problems, including residential and commercial addresses in the downtown core, numerous locations where in-car reception is deficient and in other areas such as along or near the LRT tracks. This appendix also includes a map that pinpoints precise locations where listeners reported reception problems. Clearly, much of the downtown core is affected.

Taken together, Corus submits that the evidence we have submitted, which includes the results of three studies of Calgary radio listeners conducted in 2007, 2009 and 2011, plus our own survey of CHQR listeners conducted in September 2011, shows a real and significant problem with the technical quality of CHQR’s AM signal in downtown Calgary, in commercial and residential high-rise buildings and along the LRT tracks. The reception problems stem from the increasing densification of the city of Calgary over the past three decades demonstrated by the pictures provided earlier, making it impossible for our AM signal to provide consistent and reliable service to an important segment of our listening public.

As the Calgary radio market becomes increasingly fragmented, as new audio platforms and unregulated services provide ever more listening options to the public, and now that the Commission is embarking on another licensing round for new commercial radio stations, it 12

becomes imperative that CHQR take the necessary steps now to address our significant coverage deficiencies. The proposal in this application would solve these problems.

TECHNICAL ALTERNATIVES TO CORRECT RECEPTION ISSUES

Corus has considered several technical alternatives to resolving CHQR’s reception issues. Each alternative is addressed below.

Power increase, antenna redesign or antenna relocation on 770 kHz

CHQR already operates at the maximum permitted power level of 50 kWatts on 770 kHz; a further increase is not possible under Industry Canada rules. Our daytime signal is optimized in all directions as we broadcast with an omnidirectional pattern. At night, we are required to broadcast with a directional pattern to protect other stations sharing this frequency in the United States; nevertheless, given our transmitter location to the south of Calgary we are still able to direct maximum power levels towards the city of Calgary.

Furthermore, there is no other transmitter location using 770 kHz that would offer any better signal in Calgary than our current transmitter site in Dewinton. No matter what location we use, it cannot resolve the fundamental interference issues that affect the reception of CHQR in downtown Calgary.

In short, our current site and broadcast parameters are optimized to provide the maximum possible coverage and the best possible signal in Calgary. There are no technical solutions that would allow us to provide a stronger, more reliable or more consistent signal on 770 kHz in Calgary.

Move CHQR to another frequency on the AM band

Notwithstanding its technical drawbacks discussed above, no other available AM frequency can provide better coverage than 770 kHz. CHQR’s existing frequency can be exploited at a full 50 kWatt power level day and night and it provides extensive rural coverage throughout southern Alberta. No other AM frequency can provide better rural coverage, and no other AM frequency can address the problems we experience in the downtown core due to the presence of high-rises and man-made interference. In this context, the problem is not 770 kHz per se , but the fact that any AM frequency will be subject to interference and reception problems in a high-density urban environment.

There are no advantages in terms of improving service in Calgary, but there are potential drawbacks in terms of our rural coverage, if we were to move CHQR to another AM frequency. This is simply not a realistic option.

New drop-in AM rebroadcaster

A drop-in repeater on AM might be able to provide a stronger signal in downtown Calgary, provided that there was (i) an appropriate frequency available that (ii) could be operated at a sufficient power level, and that (iii) would not be subject to incoming interference from other 13

stations, and that (iv) could be located at an appropriate transmitter site nearer the downtown core and that (v) would be able to somehow overcome the interference problems that plague any AM station in an urban environment.

The simple fact is, there is no such magic bullet in terms of a new drop-in AM frequency. If CHQR, a 47-year old legacy station operating on an otherwise solid AM frequency at maximum power cannot overcome the interference problems in downtown Calgary, there is no drop-in AM frequency that can solve the problem. Any new frequency in today’s environment would inevitably be subject to protection requirements and likely to receive interference from other stations, particularly at night. On top of that, the likelihood of finding a new transmitter site, capable of accommodating a multi-tower array and situated much closer to the city centre than the present site, is virtually nil. Expansion of the urban built-up area since 1964 almost certainly guarantees that any new AM transmitter site would have to be developed further away from downtown Calgary than our present site.

For any number of reasons, therefore, a new drop-in AM repeater to rebroadcast CHQR is not a realistic option.

New drop-in FM rebroadcast transmitter

By the process of elimination, Corus submits that the only realistic and feasible option to correct CHQR’s coverage deficiencies is to find an appropriate drop-in FM frequency to rebroadcast CHQR’s AM signal in downtown Calgary.

To that end, our technical consultants D.E.M. Allen & Associates Ltd. conducted a thorough frequency search to determine the optimum FM frequency available for this purpose. After considering several possible FM frequency alternatives, Corus has concluded 106.9 MHz (channel 295A) is the most suitable for our needs while having essentially no impact on existing radio services. It has the added benefit of having zero impact on the potential availability of suitable frequencies for other respondents to the recent call for applications.

THE USE OF 106.9 MHZ (CHANNEL 295A)

As Corus is not seeking to provide rural coverage on the FM band outside of Calgary, due to the fact that our AM signal already provides extensive coverage throughout southern Alberta, we focussed the search on potential Class A frequencies that would be less attractive to new commercial services but that would be ideal for our purposes. Channel 295 (106.9 MHz) fits those criteria perfectly.

This is a Class A frequency that is limited in terms of the power levels at which it can broadcast. At our proposed ERP of 1,000 watts, its coverage potential outside of the city of Calgary is limited to the immediately surrounding area. It is, however, ideal to address our need to provide a reliable high-quality signal within the city of Calgary.

A key feature of this frequency is that it is 2 nd adjacent to the Corus station CFGQ-FM Calgary, which operates on 107.3 MHz. While Corus has traditionally opposed the use of 2 nd adjacent FM frequencies on a short-spacing basis, we do have first-hand experience with the use of 2nd 14

adjacencies and on that basis we believe that there are limited circumstances where such situations can be appropriate.

First, the two stations in question should be operated by the same company. That allows the broadcaster to control the technical parameters of the new station, to weigh the relative advantages and disadvantages with respect to potential interference and to make an informed decision. This is the situation with our proposed rebroadcaster at 106.9 MHz and CFGQ-FM at 107.3 MHz. Corus would own both and therefore we would have full control over the technical parameters and the resolution of any potential interference issues.

The second critical factor is a technical one – to avoid undue interference between 2 nd adjacent stations, they should transmit from the same antenna location. With appropriate antenna design and choice of technical parameters, this allows the broadcaster to minimize the extreme ratios of “undesired to desired” signal that can lead to interference.

To this end, Corus will co-locate the transmitter of the new FM rebroadcast station at the existing antenna location of CFGQ-FM, which is also the CBC transmitting site for Calgary. CFGQ-FM uses the CBC tower at this site pursuant to a site sharing arrangement with the CBC. The CBC has confirmed that it is prepared to negotiate a similar site sharing arrangement for the new rebroadcast transmitter. A copy of the CBC’s letter to this effect is provided in Appendix C.

With the co-location of the new transmitter at the existing CFGQ-FM site and the technical parameters we have chosen (i.e. 1,000 watts omnidirectional ERP), we are confident that both stations can be operated successfully with no undue interference issues. A strong precedent for this conclusion is CKFG-FM (Caribbean and African Radio Network) in Toronto and CBLA-FM. In this case the two stations are co-sited, CARN has a max ERP of 1,000 watts and CBLA-FM has a maximum ERP of 98 kW. The reception of the CARN signal is very good throughout its service area.

While we believe that 106.9 Mhz is the ideal solution to resolve CHQR’s coverage deficiencies, the fact that it is 2 nd adjacent to another Corus station means that it is not available for use by any other user in Calgary without our permission. For the reasons we have cited above, Corus would not be prepared to provide such permission to another broadcaster.

Accordingly, the use of this frequency by Corus does not in any way curtail the ability of applicants responding to the call to find a suitable frequency, nor does it limit the options available to the Commission in terms of potential new licensing.

In short, the use of 106.9 Mhz makes efficient use of spectrum and does not preclude other stations from being licensed in the future.

COMPLIANCE WITH THE COMMON OWNERSHIP POLICY

As a final matter, Corus wishes to address the Commission’s Common Ownership Policy (COP) and any questions that might be raised in terms of our compliance with that policy if this application is approved. 15

Corus currently operates three stations in the Calgary market – CHQR (AM), CFGQ-FM and CKRY-FM. The COP provides that, in markets with more than eight commercial stations operating in a given language, such as Calgary, a person may be permitted to own or control as many as four stations operating in that language, with a maximum of two stations in any one frequency band. Thus, Corus currently complies with the COP.

This application is for a technical amendment to the licence of its AM station, CHQR. While the application proposes the addition of an FM transmitter, it is in the context of the existing AM licence and does not represent a new service. The new transmitter would simply rebroadcast the programming of CHQR within its existing contours and would be governed by the conditions applicable to the CHQR licence and regulations applicable to AM stations generally. No new sales inventory would be available to Corus and hence it would not impact upon the revenue market.

In these circumstances, Corus submits that it would continue to operate three stations in the Calgary market, CHQR (AM) and the two FM stations mentioned above. The new rebroadcast transmitter would be part of the CHQR operation, clearly not a 3 rd FM service.

Corus submits therefore that this application is fully compliant with the COP.

If, notwithstanding this argument, the Commission were to consider that the proposed circumstances nevertheless constituted technical non-compliance with the COP, presumably because the new rebroadcast transmitter would represent a 3 rd FM transmitter in Calgary (albeit not a 3 rd FM service ), then Corus requests that the Commission grant an exception to the COP in light of the unique circumstances associated with this application as explained above.

We further note that, since the new transmitter would use a frequency not available for use by any other party, approval of such an exception would not jeopardize diversity of voices in Calgary. Indeed, given the high percentage of Calgary listeners who choose to listen to FM only in Calgary, the availability of an AM news/talk service on the FM band would arguably increase the diversity of voices available to those listeners.

We therefore submit that approval of this minor exception to the COP, if the Commission deems that an exception is required, is justified by the facts and in the public interest.

CONCLUSION

CHQR’s technical ability to deliver a high-quality, uninterrupted signal to the Calgary and area marketplace has been greatly compromised over the past three decades as the City of Calgary has grown upward and outward. The population of both the urban area and the surrounding countryside has increased substantially since CHQR signed on the air in 1964.

The downtown audience is growing in size, both in terms of permanent residents and in terms of those who commute into the core, especially during the work week. The ability of that audience to listen to CHQR and to get the information programming they need and want, is 16

being steadily eroded by the technical challenges of delivering a clear and uninterrupted AM signal in an urban environment characterized by high-rises and man-made interference.

CHQR’s coverage shortcoming can best be rectified through a “nested” FM rebroadcast transmitter to improve CHQR’s reception within the City of Calgary. It is a cost-effective solution; it allows CHQR’s signal to penetrate the urban core and provide a clear, uninterrupted signal; and it would allow an audience that is interested in CHQR programming to listen on a more regular basis.

Approval of this amendment to CHQR’s licence will have negligible impact on the Calgary market but is vital to our ability to continue serving our listeners in today’s increasingly competitive market and at a time when the Commission is considering the licensing of new entrants into the market. Furthermore, the proposed FM transmitter will not impact any applicant for a new FM licence in Calgary, as the frequency we have chosen is usable only by Corus.

For all of these reasons, Corus respectfully requests the Commission to approve this licence amendment application for CHQR.

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Attachment 1

2011 Calgary Children's Foundation Recipients http://www.qr77.com/Community/CalgaryChildrensFoundation.aspx

Boys and Girls Clubs of Calgary (Fans) Brown Bagging It For Calgary Kids Meals on Wheels (Hot Soup) Between Friends Club(Camp Bonaventure) G.R.I.T. Calgary Society Calgary Cerebral Palsy Ass. (Adaptive bikes) Safe Haven Foundation (Haven’s Way) Learning Disabilities Ass of AB –Calgary (Camp Amicus) Connections Counseling and Consulting (Sibshops) Janus Academy Hull Child and Family Svcs (PATHS) CASP Albert Park/Radisson Heights Community After School Program Kids World Outreach Society Kidsport Kings Kids Foundation Boys and Girls Clubs of Calgary (Ready Set Go Preschool Program) Pace Kids Providence Child Development Society CUPS One World Child Development Project Hope AARC Kids Up Front Student Health Partnership – Alberta Health Svcs

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