Via Access Key

March 30 th , 2011

Mr. Robert A. Morin Secretary General Canadian Radio-television and Telecommunications Commission Ottawa, Ontario K1A 0N2

Dear Mr. Morin:

Re: Application 2011-0503-1 to amend the authorized contours of CFMI-FM , – Response to deficiency letter dated March 25 th , 2011

Corus Entertainment Inc. (Corus), on behalf of Corus Premium Television Ltd., hereby provides its response to the Commission’s deficiency letter dated March 25 th , 2011.

The Commission’s question is reproduced below with the Applicant’s response provided in bold .

Commission question:

The proposed technical amendment implies a decrease in the coverage area and in population (a decrease of population of about 2% in the 3 mV/m service contours and about 9% in the 0.5 mV/m service contours).

In your supplementary brief, you state that over the years you have experienced a number of antenna problems at the Rogers site. In Spring 2010, for example, a fire in the antenna feeder lines required CFMI-FM and CFOX-FM to temporarily broadcast from your nearby emergency transmitting facility on Mt. Seymour. More recently, as of March 13th, 2011 you have again been forced to broadcast from our emergency transmitting facility due to more problems with the antenna at the Rogers site.

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Please explain what further technical solutions to achieve your technical and economic objectives, and which could maintain the current coverage, you have explored.

Corus response:

To begin, Corus would like to address the significance of the population changes within the theoretical 3 mV/m and 0.5 mV/m contours, as alluded to in the Commission’s letter.

CFMI-FM’s principal marketing activities are directed towards the cities of New Westminster and , plus surrounding communities within the 3 mV/m contour. As indicated in the application, the existing 3 mV/m contour of CFMI-FM covers 2,311,315 persons, while the proposed 3 mV/m contour covers 2,264,605 persons, according to 2006 census data. This represents a decrease of just 2% in the population covered by these theoretical contours.

The population within the existing and proposed 0.5 mV/m contours will decrease from 2,938,949 to 2,675,678. As shown on the comparative coverage map provided with the application, this decrease is almost entirely due to the fact that the 0.5 mV/m contour will no longer encompass the city of Victoria. Victoria is not currently part of the principal marketing area of CFMI-FM and, although it is located just inside our existing 0.5 mV/m contour, CFMI-FM’s signal in that market is inadequate for reliable reception. Therefore, in practice, our proposed site relocation has no material impact on reception in Victoria.

The decision to request the move of CFMI-FM and CFOX-FM from the Rogers site to our own site was made only after careful consideration of all technical and economic factors including actual listening tests and field measurements.

In order to fully appreciate the logic behind our proposal, it is important to note that CFMI-FM operated at the proposed Corus site up until approximately 1986. It was relocated to the Rogers site at that time on the assumption that the higher height of the Rogers site would improve the coverage of the station. Anecdotal evidence from that time, however, was that the change in site did not improve coverage as was anticipated; in fact, it resulted in weaker coverage in areas east of Vancouver in the lower Mainland.

After the Spring 2010 failure of the Rogers antenna, Corus temporarily moved CFMI-FM to the Corus site in order to reduce the number of stations feeding into the Rogers antenna, while CFOX-FM continued to operate from the Rogers site. This provided an opportunity to directly compare the coverage obtained from the Rogers site with that obtained from the Corus site.

This comparison revealed the following:

• Listening tests with CFMI-FM broadcasting from the Corus site and CFOX- FM broadcasting from the Rogers site showed no noticeable difference in 3

the quality of the reception in the primary coverage area and no material loss of coverage.

• Measurements of the CFMI-FM and CFOX-FM signal levels verified that signal levels in the core coverage areas are very similar between the two sites.

• Listening tests indicated that we will get better reception in Abbotsford, which is within our primary market area and where the population is growing.

Because our lease is due to expire at the Rogers site as of August 31 st , 2011, Corus is in a position to explore other transmitter site locations. When Corus began looking for an alternate site due to the technical problems being encountered at the Rogers site, we had to look no further than our own site because there is no material loss in coverage by moving from the Rogers site to the Corus site and, furthermore, there are several technical and operational advantages. The advantages of the Corus site include the following:

• The Corus site is an existing developed site with a long term lease. A new site does not need to be developed.

• Access to the Corus site is easier during certain times in the winter than the Rogers site due to its location at a lower elevation on Mount Seymour.

• A new FM antenna has been installed at the Corus site to serve as a standby antenna. This new antenna at our own site will be far more reliable than the existing antenna at the Rogers site.

• The existing Corus site is an intermediate link for the CKNW AM studio- transmitter link. Hence, by moving CFMI-FM and CFOX-FM to the existing Corus site, Corus is consolidating its facilities on Mount Seymour at a common location.

• By using our own site, Corus has greater control of the operation of the facility compared to us being a tenant at the Rogers site.

• By moving to our own site, there will be better backup facilities for CFOX- FM.

Corus is also prepared to consider making our site available to other FM stations as an emergency backup transmitting facility.

Finally, it should be noted that CFMI-FM is presently operating at the Corus site. This was requested by Rogers in order to reduce the power in to their existing antenna system in the hopes of averting another antenna failure.

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For all of these reasons, we urge the Commission to approve this site relocation application at the earliest opportunity.

We remain available to respond to any further information requests if required.

Sincerely,

Sylvie Courtemanche Vice President, Government Relations Inc.

c.c. Éric Paulhus, CRTC ([email protected] )

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