CCNA responds to PAP discussion paper

CCNA has responded to a discussion paper from the Department of Canadian Heritage on the Publications Assistance Program (PAP), calling for a variety of changes to the objectives and criteria of the program. The discussion paper is a review of the PAP program, preparatory to Canadian Heritage entering into negotiations with Canada Post for the Memorandum of Agreement dealing with the PAP. The old Memorandum of Agreement expires on Mar. 31, 2002, and the new one would begin at that time and continue on for another three years. The program is not in jeopardy and will continue. CCNA's PAP Committee (chaired by Bruce Penton, Moosomin (SK) World-Spectator) reviewed and discussed the discussion paper in a series of teleconferences in early August. The committee wrote a response to Director General Allan Clarke, focusing on the following categories: program objectives, basic eligibility requirements, relative value of subsidy/alternative distribution methods/use of funds, distribution of funding, fixed reference tariffs, advertising content, and targeting. The following information has been taken from the response letter. The entire discussion paper and response letter can be downloaded in PDF format from CCNA's web site at Because the issues involved with PAP are complex and warrant further debate, CCNA has requested a meeting with Clarke and Canadian Heritage officials to discuss CCNA's concerns in detail. Program Objectives Only one of the four current objectives of the PAP discussion paper applies to community newspapers: To recognize the important role played by small community weekly newspapers in rural communities by ensuring that they continue to be accessible to their readers. CCNA is concerned that the terms 'small' and 'rural' are not appropriately quantified in the current program. There are many communities in Canada that are neither small nor rural, but are served by local community newspapers. Basic Eligibility Requirements The PAP requirements for community newspapers should be addressed in a separate set of criteria. CCNA suggested that a definition of community newspapers should reflect their proximity to the markets they serve. This would exclude publications in newspaper format that serve readerships across several provinces. CCNA also suggested a recognition that community newspapers are increasingly appearing more than once each week, a recognition that "small" community newspapers increasingly serve readerships greater than 10,000 in communities with populations greater than 10,000 in size, a recognition that the advertising needed to support community newspapers increasingly comes in the form of pre-printed flyers rather than advertising within the pages of the publication, and a recognition that changing consumer expectations have accelerated the trend to controlled, or unpaid circulation even in Canada's rural communities. Relative Value of Subsidy Because of their proximity to their local market, and the subsequent lower postage rates charged, community newspapers receive far less than the 80 per cent of publications' mailing costs quoted in the discussion paper. While community newspapers in Canada's larger cities have access to alternative distribution methods, for most community newspapers there is no viable alternative to Canada Post. In addition, Canada Post, by virtue of its monopoly status, has sole and exclusive access to apartment mailboxes and community mailboxes. Fully 40 per cent of CCNA member titles are published in communities with rural postal codes, signifying that carrier delivery is not available. Distribution of Funding The discussion paper illustrates an alarming statistic: 63.4 per cent of the total dollars benefit fewer than five per cent of publications. Based on Appendix B - PCH Funding by Title, the first "small" community paper appears 67th on the list, the second paper appe