Always Read the Appendix

August 17, 2026 · CBA Team

Nobody reads appendices. Appendices are counting on it. This is the story of a 1,010-row list, the one row that is not like the others, and why the most useful consumer skill in Canadian broadcasting is scrolling to the bottom of the document.

The One Meeting You're Always Invited To

A broadcasting licence comes with an expiry date. When it runs out, the company has to come back to the CRTC — in public, on the record — and ask to keep it. That renewal is the one meeting the public is always invited to, and the only one where the broadcaster has to explain itself whether or not anyone shows up. Anyone can file. The onus is on the company.

A proceeding that closed this July, BNoC 2026-115, proposes to cancel those meetings for 1,010 licences at once, by renewing them for indefinite terms. No expiry date, no scheduled review. The CRTC keeps its other powers — it can change a licence's conditions any time it likes. What disappears is the calendar entry. After conversion, if anyone wants a public review of one of these services, someone has to start a proceeding.

And that someone, dear reader, is you.

For 1,008 of Them: Honestly, Fine

Here is the part a fair account has to concede. For a local AM or FM station, the scheduled review was never the real accountability. A station that stops serving its market loses listeners the same week, and the advertisers leave with them. Renewal paperwork was paperwork. The Commission even excluded the CBC and developmental stations from the conversion, so the list was not assembled carelessly.

If the appendix were 1,010 radio stations, this would be a sensible policy and a boring blog post.

Then You Scroll to the Bottom

The appendix lists 1,010 services. On review, 1,008 are over-the-air radio stations. The other two are national subscription services, and they are not alike:

  • A satellite radio service. You subscribe to it directly. If it disappoints you, you cancel it. Accountability survives conversion.
  • The only licensed pay audio service in Canada — the music channels that arrive inside cable and satellite TV packages. Licence expires 31 August 2027.

Run the accountability test on that second one. Nobody can tune away from it: it has no over-the-air audience. Nobody can cancel it: its subscribers never signed up with it in the first place — it reaches them through whatever package their TV provider assembled. Its revenue comes from carriage arrangements, not from listeners choosing it. It is, structurally, a membership you do not remember joining, billed through a front desk that does not handle cancellations.

For this one service, the scheduled review was not paperwork on top of accountability. It was most of the accountability there is. And its next one — 2027 — is on the list to be cancelled.

How Things Slide Through

No villain is required for this. Watch the sequence:

  1. The consultation behind the policy, BNoC 2024-290, was addressed to radio station operators. It never mentioned pay audio.
  2. The policy it produced, BRP 2025-265, decided radio licences would become indefinite. It never mentioned pay audio either.
  3. The implementation list, BNoC 2026-115, has a row for the pay audio service.

A framework consulted on for one kind of undertaking, decided for that kind of undertaking, arrives at a different kind entirely. Not by conspiracy. By list. On a list of 1,010 entries, nobody has to argue anything.

It gets better. The actual rulebook for this category of service is being rewritten right now: the CRTC's audio policy proceeding (BNoC 2025-52) expressly asked how pay audio should fit the system. Its record closed in December 2025 and it is still undecided. Convert the term first, and an open question gets answered by administrative default — permanently, before the framework meant to govern it exists.

Homework You Can Do in Two Minutes

When this licence was last renewed, in 2020, exactly one individual objected — arguing that mandated specialty audio is a charge for something people do not use. The Commission's answer, on the record, was that as a discretionary service it is “only made available to those who elect to subscribe to it.” The renewal rests on that finding.

Unlike most regulatory findings, this one is checkable from your couch. Get your TV bill. Look for a package of music channels. Did you elect to subscribe? Were you asked? Can you see what it costs? Can you remove it?

Congratulations — you are now doing regulatory oversight. And note what that 2020 exchange proves: one person filed, and the answer they extracted is the load-bearing premise of the current licence. Individuals leave marks on these records. That is not a pep talk; it is how the file reads.

What Showing Up Looked Like This Time

In this proceeding, one subscriber — this site's author, filing personally — read the appendix, found the row, and filed on it, taking no position on the 1,008 radio stations. The ask was deliberately small: decide the audio framework first, then decide this term; failing that, keep a fixed term for this one service; failing that, at least say conversion does not prejudice a later review. The Commission already excepted the CBC and developmental stations, so excepting one more row is not exotic — and it preserves the streamlining for the other 1,009.

Others showed up too, and went further. The Consumers Council of Canada opposed the conversions outright, citing research by the Forum for Research and Policy in Communications that reviewed every radio licensing decision from 1968 through 2026 and found 61% of 1,022 originating non-CBC stations in breach of a licence condition at least once — more than 20% of them twice or more. The broadcasters' own association conceded the administrative benefit of conversion is modest.

The record closed 21 July 2026. A decision is pending.

Sneaky Is a Condition of Empty Rooms

None of this required bad faith. It required inattention — a system that runs on lists, defaults, and the safe assumption that nobody is watching. The fix is not outrage. The fix is attendance.

And attendance is cheap: filing an intervention is free, the form is online, no lawyer is involved, and your submission becomes part of a public record the Commission is required to weigh. An evening of your time buys a permanent entry in the file. Very few civic acts have that exchange rate.

Two rooms are open right now:

  • Device, SIM and setup fees (TNoC 2026-155) — Bell, TELUS and Rogers must show cause why their new fees do not violate the switching-fee ban. Reopened for comment until 31 August 2026.
  • The complaints-commission awareness proceeding (BTNoC 2025-274) — TV customers are the only class with no code right to be told the complaints body exists. Written process, no hearing, anyone may file, until 7 October 2026. Our explainer covers what to say.

Both are on the consultation tracker, and the plain-language guide to intervening walks you through the form. The one to watch for is the audio conditions-of-service consultation expected this fall — the proceeding that would stand in for the cancelled 2027 review. Join the email list and we will tell you the day it opens.

Further Reading

Canadians for Broadcast Accountability tracks CRTC proceedings and helps Canadians take part in them. Learn more about what we do or join our email list for updates when comment periods open.