LawBytes Podcast, Episode9.mp3 | Convert audio-to-text with the best AI technology by Sonix.ai

Michael Geist:
This is LawBytes a podcast with Michael Geist.

Ian Scott:
This organization has a long tradition of being at the forefront of regulatory change. The many hundreds of men and women who have worked here since 1968 have adopted thoughtful creative, made in Canada approaches to deal with a vast array of complex regulatory challenges.

Michael Geist:
Many Canadians follow telecommunications and broadcast issues at the CRTC from a distance – the cost of wireless services the speed of their Internet access, the availability of broadcasting choice. Others engage more closely on issues such as net neutrality, Cancon regulation or Netflix taxes. But there’s one Canadian who doesn’t just follow the CRTC. She watches it through the use of Access to Information laws that present an insider perspective on the commission that would otherwise remain hidden from view. Monica Auer is the executive director of the Forum for Research and Policy in Communications. She’s been an analyst at the CRTC worked, for what was then Industry Canada obtained two law degrees worked at a major law firm and now heads up an organization that may not be widely known but has had a big impact on our understanding of what takes place behind the scenes at Canada’s telecom and broadcast regulator. This Law Bytes podcast episode features a recent conversation with Monica about insider access, slow reimbursement of costs for public interest groups,the number of CRTC meetings and the commission’s seeming indifference to commissioning original research. The interview is interspersed with comments from current CRTC chair Ian Scott, taken from one of his first public speeches after being named chair in 2017.

Michael Geist:
Not a lot of people are necessarily familiar with the forum. Maybe you can take a moment to introduce yourself and the forum.

Monica Auer:
The forum is a non-profit non soliciting federally incorporated organization which was established in late 2013 to undertake primarily empirical research and policy analysis with respect to broadcasting and telecommunications. Although there are other organizations out there that have also done this a number of them are are focused on a little bit more on the law and we’re trying to bring in more of the empirical evidence.

Michael Geist:
So who’s behind the forum.

Monica Auer:
I have a board of directors who are a wonderful theory are very experienced primarily in broadcasting but also some telecom. We have somebody who was formerly with the auditor general’s office so they’re very interested always in our budgets and the board decides whether or not we should participate in specific proceedings whether they’re before Parliament or the CRTC.

Michael Geist:
You’ve assumed this position as being the CRTC watcher. OK. You are the person, the forum is the place that surely launches a significant number of the access to information requests and is one of the few groups and you’re one of the few people I think that have the depth of knowledge of both the CRTC and the field to be able to take a look at some of the results. When you’re looking at what’s actually coming out of the CRTC and be able to understand and interpret them that’s I think he gets a really rare thing and it’s it’s a pretty amazing contribution because when you when you take a look at what’s on your site and the myriad of requests that you’ve launched over and over now many years it tells some pretty interesting stories that don’t typically capture people’s attention and but they think they should because they tell a really interesting story about the CRTC. So I was hoping to drill down a little bit on some of those. Starting I think with fair play.

FairPlay:
FairPlay Canada wants the CRTC to modernize the tools we use to protect Canada’s economy from online piracy we are proposing a tool similar to that used in dozens of other countries which empowers the CRTC to identify illegal piracy sites and disable them in Canada.

Michael Geist:
This was for those that aren’t familiar an issue that I was actively involved with as well Web site. A web web site blocking proposal led by coalition of groups. But it was particularly Bell it was was very active on it. You submitted on it I submitted on it. Thousands of Canadians actually submitted on it but the aspect that I thought we could focus on was an access to information request that you filed a little bit after the deadline or at least came back a little after the submission deadline.

Monica Auer:
I think it was a little bit after the deadline because we were all racing to meet the deadline and it was triggered by the fact that many people were reading the application and we were somewhat perplexed because we know many of the players involved many of the authors involved and they’re extremely competent they really know their business. And yet this application seemed a little different from the rest. It took an unusual approach to the entire issue which was a serious one. We actually did a survey of Canadians to find out what they thought about the idea of somebody like the CRTC being able to block their access and they were very concerned the majority the overwhelming majority was concerned.

Ian Scott:
As companies continue to innovate in their offerings to Canadians the CRTC will continue to ensure that Canada’s Internet neutrality provisions are respected. Just as the Transport Commission before us get railway lines open for any and all users. The CRTC has set a clear tone in its regulation of content delivery. The owners and operators of the country’s communication systems may not discriminate against content based on its origin or its destination.

Monica Auer:
So the more I thought about it the more I wondered about how the application came about and I wondered if there had been any chance that there might have been some discussion at the commission before the application itself was filed on January 29, 2018. And that’s why I filed the the Access to Information request.

Michael Geist:
And what did you find.

Monica Auer:
I got back two sets of information two packages of information setting out a number of emails and presentations and exchanges that appear to involve the CRTC and non CRTC personnel and I looked at it and I thought my goodness this is this is unusual I had not expected actually to see that in fact there had been meetings before the application is filed. I was unprepared for that I was also unprepared for the idea of what appeared to be a fairly extensive ex-parte communications if you will. Now it’s true ex-parte normally refers to a process something that’s already launched and then the parties discuss with the adjudicator outside of the other parties range. But in this case the CRTC is always in a position of judging things. So in that sense it might be considered ex parte. In any event I looked at that and I thought this is this is an interesting set of documents and I actually didn’t have time to look at. And that’s why I sent everything to you. I didn’t I wasn’t quite sure what could be done with that and the fact of the matter is that although we do have some people interested in our website and it does have some some kind of some fun things on it. I wanted to make sure that people would have as much access as possible to this because it speaks to the nature of informal contact between administrative authorities and society and those they regulate.

Ian Scott:
When any regulator the CRTC included performs its work in the name of the public interest. It must balance various points of view some of which obviously conflict. It’s not always appropriate to lean on one side of the fence or another in the interests of corporations or in defence of what the average Canadian needs or wants the public interest is much more dynamic than that.

Michael Geist:
The CRTC’s reaction was and Bell’s reaction for that matter was that there was nothing to see here. What are your thoughts.

Monica Auer:
I think there was something to see because if there were nothing to see there wouldn’t have been any documents. I think that there was something to see because being told that there is nothing to see is usually a pretty good clue that there actually is something to see and the fact of the matter is that everybody who read the documents knows there was something to see. So for all three reasons I can appreciate the perspective of those who didn’t want to have those things seen. But that’s not the case.

Michael Geist:
And do you think there’s something wrong with Bell being able to call up a CRTC Commissioner seeking the opportunity to present this – as I ask this question and you’ve got a big smile on my face because I feel a little rhetorical – but you know your thoughts on the power that companies have when they can quite literally in this case call up a CRTC commissioner ask for the ability to present something and then ultimately have the ability to meet with staff months before anything ever gets filed.

Monica Auer:
I guess the question is would anybody mind as long as the CRTC were equally open to all parties. Except that I’m aware of a number of non licensee and non telecom companies that call and they can’t get telephone calls returned from CRTC commissioners. So it seems to me when that’s a repeated pattern of behaviour there may not be so much of a level playing field. Secondly there’s no record of that as a general there’s certainly no public record of telephone conversations. And of course even though we can go through the commissioner of lobbyist registry and I think at one point I either have a blog in progress or a plan or a great deal material. The fact of the matter is is that the number of visits made by those who are beholden to the CRTC as licensees or those who are regulated meet regularly they meet weekly with the commissioners.

Monica Auer:
There are no records of those meetings in the sense of you know they’re not recorded. Do we want them recorded do we believe that it’s better for those who are making these decisions to be to be informed behind closed doors do we. Are we concerned that there might be an unusual quid pro quo. Just do this thing here and we’ll take care of that thing there. We don’t know and I think it places the commission in a very awkward position.

Michael Geist:
I think you’re right that that lack of balance or the uneven playing field I suppose may be part of the reason that we’ve got a cost awards system in Canada that’s designed to better facilitate the ability for civil society groups and other groups that are concerned with these issues to participate.

Ian Scott:
We invite indeed encourage stakeholders from across industry the government and the public at large to share their comments and opinions on the issues before us and we do so with a view to building as complete a public record as possible.

Michael Geist:
Can you start I guess by describing a little bit what that cost award system looks like and then I want to get into a little bit with some of your research has shown in recent years about how long it takes for certain groups to be paid off with those cost awarsds.

Monica Auer:
I think the cost awards process was initially effectively launched by the Public Interest Advocacy Centre. They participated in one of the first major telecommunications proceedings in the late 1970s. And for those of your listeners who may not know or those who are in the audience who may not know telecommunications was not always federally regulated. It was until the mid 1970s were like regulated in part by the provinces. And so it was only in the late 1970s that the CRTC itself had jurisdiction and then began to exercise control over it.

Monica Auer:
And so the question arose is how do you ensure that you you don’t just have the parties and then a number of interested members of the public who lack the ability to participate effectively. The issue is not that everybody can’t write the CRTC a letter. The issue is that you have a company like Bell who may have two or three hundred people working in their regulatory affairs department. And to put that in context the CRTC in its entirety has maybe 400 people not half of whom were devoted just to telecom. So what to do.

Monica Auer:
Even if you just assume that the CRTC could could address the public interest on behalf of the public interest there is no mandate within the CRTC act within the telecommunications act nor within the broadcasting act for the CRTC to put the public interest first. Secondly in a way the commission would be conflicted out. It would be like telling a judge well keep in mind what that person there are the defendant has to say and you look after the defendant’s interest. And now we want you to rule fairly. The other side will always have a concern.

Monica Auer:
So there was a cost process set up in the late late 1970s and it was 1979 through the through a draft rules of procedure noticed by the CRTC. And of course the very first cost award was taken to court went all the way to the Supreme Court. And fortunately the Supreme Court recognized the benefit of having non company participants involved. So this proceeded for many years in a in in an unusual kind of way. The CRTC commissioners would appoint a member of their staff to be a costs officer who would then adjudicate costs claims that became very time consuming and because it started to take so much time they decided to streamline the process and make it very fast so you could just apply and the commission staff would go over the application to make sure that it was appropriate.

Monica Auer:
So that was where that’s where the telecommunications process is right now. Applicants who appear who have met the terms of the CRTC’s cost policies apply to have some of their costs not all of them. Some of them reimbursed the broadcasting side. It’s somewhat different. The CRTC set up as a parallel organization but you don’t apply to the CRTC you apply to another party. The issue there is at the CRTC allocated money to this agency and it’s out of money. So in terms of broadcasting by next year perhaps there may be no money for public interest groups to participate.

Michael Geist:
The historical background is really valuable. It’s a system that least on paper seems like a really good. It seems like a great idea. Good to see the Supreme Court thought so too. You’ve been looking into the speed with which these cost awards get paid out because of course what happens based on what you’ve just described is that the public interest group will incur various costs of participation that could include retaining experts to provide further evidence to the CRTC and after it’s done as you mentioned you submit your bill and the CRTC reviews. What did your research find about how long it’s taking in a sense to get paid back for those expenses.

Monica Auer:
The average is nine months and what an average means is that there are some cost claims that are taking two years. Some are taking three years not many but some. To put that into context when the CRTC when I when I I looked at the cost awards from 2013 through to 2018. So that was 182 of them just to look at the time of filing for instance and then the actual date of the decision. And in 2013 for the entire year it took a little over three and a half months for the CRTC to receive the application. think about it and issue a decision. Now it takes nine and a half months.

Michael Geist:
Okay so I was pretty quick. Just a few years ago.

Monica Auer:
Yes.

Michael Geist:
Talking nearly a tripling based on what you just said on average do we have any idea why is the CRTC said anything about why it’s taking so much longer to process this because now we’re talking about organizations that can wait a year or two as you say perhaps even three years to get paid back for money they’ve spent on many of these organizations are not deep pocketed organizations that can in a sense afford the float of having all these accounts receivable outstanding.

Monica Auer:
Yes. And just to address that before I address the other point some people have have suggested well why didn’t you just save money so that from one year to the next you can go. But the fact is that if if I retain an economics expert the economic expert needs to be paid I can’t take that person’s money and then hold it for the next one. It’s not a Ponzi scheme it’s as you have a bill you have to pay it.

Monica Auer:
So to think about why it’s taking so long. I have noticed myself that with respect to the forum’s applications and bearing in mind we started making. I think we made our first application in 2014 and the first one sailed through and sailed through in the sense that nobody objected because the Commission has adopted a practice where they take every application that we make or that any party makes in fact and then they send it to the telcos and telcos have the right to reply. And I find that the certainly the depth and length of the replies has gotten longer and the arguments made are not changing. In other words every time it seems we while you’re not a lawyer. Actually yes I am. You’re not doing legal research. Actually yes I am. You didn’t incur those costs. Well the invoices are there you know. Yes we did.

Monica Auer:
And then while you didn’t contribute anything to the process well that’s up to the CRTC and in fact this is what we did. We did a survey we did economic research. We did charts. We did graphs. We did 150 pages with you know four gazillion footnotes. Actually we did. We think we contributed. So it’s up to the CRTC. And so it would be interesting as well if you remember that the costs that were paid haven’t changed since 2010. In other words the rates that we may charge have not increased in the last nine years and that’s not an issue except when people might think well you’re just going to pad your bill to make. Well we can’t because you know that darn ethical code to which you swear when you become a lawyer. They they require you to follow the rules. You can’t just pad, you live with it and that’s fine. It’s just then you have to carry the bills. And it’s not even you know. Okay. So I own my own house. I don’t have to pay rent. That’s terrific. But you know other people do and other people have office rents. And when we hire a survey company do they really want to wait a year to get paid. That’s so. So how do you ensure that you can have a strong public presence on a level playing field when we don’t have the resources and we can’t. And it’s ultimately we can’t get paid. It’s just I think the commission used to be able to do it quickly. It’s unclear to a number of us why it’s still taking so long.

Michael Geist:
So that’s unclear. One of the other things that you’ve been focusing on is how frequently the commission meets. I don’t know if it’s I don’t know if there’s a connection or not. But that piece of research which is quite recent is extensive in taking a look at just the number of meetings that the CRTC is having maybe you can just start by introducing what it is that you asked for through the access to information system and what did you get back?

Ian Scott:
The job before us as commissioners is to weigh whether times can be contrasting ideas. On the one hand business has its own interests to present and defend it must answer to its shareholders and maximize returns on investment which is entirely appropriate. It’s not business’s duty to always promote the public interest.

Monica Auer:
I thought that when I asked how often is the CRTC meeting I would get back maybe an Excel spreadsheet with just the dates of the meetings. That’s what I thought I would get and then I would just play with that and I say oh look you know they’re meeting the same and more or less. And the reason I asked was because I was wondering could it possibly be that they’re not meeting as much these days and that might be slowing things up and I should preface this by saying that when I worked at the commission, the full commission was regularly in the building every month that seemed to me or every second month there would be a meeting of the entire commission which at that point was not just the ninth night not just the 13th I think was 13 full commissioners but then another up to 15 part time commissioners a lot of people. All right. So I asked the commission for a list of the meetings, the dates on which the commissioners met, and the agendas of the meetings and I thought you know one page agenda. Right.

Monica Auer:
So I received I received a scanned PDF of each month of the year from January 2007 to December 2018 and on many of the days there was a little notation as to what the meeting might have been about. And sometimes it was telling you that there would be no power in the CRTC’s buildings over the weekend which is a regular occurrence. And I found out of the hundred and fifty one pages of calendars once they input all of the data I was looking at 3000 or so meetings from 2007 to 2013 and the interest the most interesting thing I was surprised that the total number of meetings of the CRTC whether the full commission its committee telecom committee any of those panels had decreased by a third over the period.

Michael Geist:
Okay so that the very time when these issues are becoming more front and center it feels like there’s almost a continuous cycle of hearings and issues and re-examination of both telecommunications related issues, wireless issues, broadcast issues. The commission is meeting less as opposed to more.

Monica Auer:
It is meeting less and it is often meeting without any agendas. Roughly a quarter of the meetings happen without an agenda and and a a cynic might say well there’s no agenda because then you can’t ask for the agenda and access to information you can’t get what isn’t there. But I think the more interesting question is what do commissioners if they’re on this mailing list and they’re invited to attend a meeting. What do commissioners do who don’t have a copy of an agenda? Do they have any documents to go with it? Is the commission not thinking that a document that sets out a problem is part of the agenda? I don’t know what it is I’ve asked. The agendas didn’t accompany the calendar pages that is going to take somewhat more time and I’ll see what we get then. As for the the meetings themselves I think the other thing is that when we think of the meeting I was very broad and apparently the commission was too because what they also sent me showed that roughly two thirds of these meetings are done by email. And when you and when you look at what you counted as a meeting I don’t I don’t know.

Michael Geist:
An email exchange is a meeting?

Monica Auer:
I don’t know it would say for instance the notation might be BCMEM broadcast committee meeting email and this was on their list their calendar page showing all of these meetings but and even for the email meetings they decreased in number, the in-person meetings decreased in number, and the email meetings decreased in number over time that’s it.

Michael Geist:
It’s counterintuitive to one what one might think. The other thing that’s somewhat counterintuitive when you take a look at the work you’ve been doing has to do with the number of requests that once again there is no information. So you mentioned there were no agendas in this instance you’ve asked for some really interesting things that one would have thought the commission might have spent some time digging into and consistent with the approach the forum has about where’s the evidence and trying to bring forward the evidence.

Ian Scott:
When this commission makes its decisions it does so based only on the facts it has at its disposal. We depend on the public record to inform the choices we make. And when that record is fully developed and rich with information that the decisions we take are strongest and most supportive of the public interest.

Michael Geist:
I was taking a look at the list I know that you’ve asked about things like how many journalists jobs exist in the country, the impact of foreign investment rules with respect to broadcast, the number of news bureaus in radios radio stations and television stations, studies on any number of different issues that the CRTC has been engaged in diversity of voices balance and news deregulation in advertising and what the common link between all of these issues and requests is at the CRTC said they had absolutely nothing.

Monica Auer:
No records.

Michael Geist:
So just for those that don’t regularly file access to information requests, a no record means that the CRTC says…

Monica Auer:
They they have no information. And when I make an access to information request I try I try for everything. I thought it was unfair to the commission just say Hey I’d like any records about. So I thought I would clarify it. Well perhaps you might have written a memo or an email or you might have had a research study or or a briefing or a presentation. I tried to come up with as many synonyms as I could. And those would count as records under Access to Information case law. And I think they’re all surprising in that you know the very first section of the Broadcasting Act for Canada’s broadcast. Parliament’s very first statement in its broadcasting policy for Canada is that the Canadian broadcasting system shall be effectively owned and controlled by Canadians. And yet when I asked do you have any information on voting shares. I say well we don’t collect it like that. If you want to go to each of the ownership charts that we maintain on our website you can see the non Canadian voting shares there. But those charts are only current. They’re not historical. So if I want to see if there’s any kind of change over time the level of foreign ownership. I can’t. Nor does it easily represent equity which can be a form of debt. It can be a loan we don’t know what it is but it’s not a voting share can be a non-voting share. No information as well and an overall I think a number of people like Dr. Winseck for instance at Carlton have pointed out that Canada has one of the highest levels of concentrated ownership in the communications sector in the world. So it was puzzling to me that the commission has no research on this hasn’t undertaken any studies hasn’t hasn’t commissioned any studies has no information on the impact of concentrated media ownership either in broadcasting it’s bizarre to me.

Michael Geist:
So what do you think that says about the CRTC I know for example that the broadcasting and telecommunications legislative review panel which is ongoing and for which we should get at least an interim report by the summer has itself commissioned a series of different research reports that was the subject of someone else’s access to information requests. So it recognized as it embarked on its review that generating more evidence and conducting some studies was a natural byproduct of being a natural byproduct being actively involved in a comprehensive study and the CRTC would appear based on the requests you’ve made very often seems content to just rely on what it hears from people who submit as part of hearings. Is that what we’re led to conclude?

Monica Auer:
I think it’s not just a conclusion it’s the fact. You’ll recall that we had the basic service obligation proceeding about four years ago five years ago. I was invited along with many other people to the lockup and we were you know if we wanted to ask questions of the senior staff we could and so I said you know you’ve said X here referring to evidence. Could you tell me what research the commission itself undertook or bought about the telecommunications sector for this enormously important review. They said well we didn’t do anything. We had the evidence before us.

Monica Auer:
Well who can afford to do the wonderful types of evidence that they need a good economic study because economists are valuable people and their time is valuable could cost you thirty thousand dollars forty thousand dollars to put it in context a good survey if you can’t analyze survey research results yourself and I am able to because of that otherwise not necessarily very useful undergraduate and graduate degree in political science although I really liked my alma mater there was an excellent university Carlton. A good survey research study might cost with this with the survey included forty thousand dollars. Who has that money. The public interest side and if the commission isn’t undertaking it are they actually relying on public interest groups to come up with these data. And if they are then again the cost order process is not assisting in ensuring that we we can do this. Should the commission be doing more? I think yes. The Commission not only should but of course it could. It has enormously well qualified people. Its rules of procedure specifically state if you’re going to intervene in our proceedings please give us evidence.

Monica Auer:
All right then I think the commission has a duty itself to ensure if it wants to meet its own mandate, if it wants to ensure that it is actually acting properly as Parliament’s delegate I think it has a duty to explain how that’s happening.

Michael Geist:
So that there is a real stream continuity with many of these requests and the findings really really identify a lack of evidence that at a certain level relies upon public interest groups to generate at least a counterbalance to what the commission might hear from more commission by some of the established players and yet there’s challenges to get paid back for some of that. There’s questions about how much the commission is actually meeting on any of these issues. In any event and when they do meet it turns out some of the meetings that they have are these off the record meetings such as the one that we saw in Fairplay raised a lot of concerns. I assume that some of these are the kinds of issues that may be addressed in a forthcoming conference that you’re putting on that examines policy and communications law in Canada. Can you tell us a bit about that.

Monica Auer:
Thank you for allowing me to make my little pitch. We’re holding a conference at the University of Ottawa itself here May 10th May 11th. The focus of the conference is with the proposals that have been made to amend Canada’s broadcasting and telecommunication statutes.

Monica Auer:
As you as you know not many of these submissions that were made to the legislative review panel on January 11th have been made public. We’ve we have a number of people have kindly mentioned to us or they’ve given us consent to post their interventions and so we have I think 57 at this point on our website. And so as we were as I was beginning to look at those and as I was discussing with my board it became clearer that more and more people were interested in having at least an opportunity to discuss what these proposals are and what the implications are and what the new statutes if there are any ought to look like. So we’ve invited a number of interesting people who are going to come and deal with a number of different aspects of of broadcasting and telecommunications in the in the sense of the rights and responsibilities. There are a lot of rights in in both the Telecom Act and the Broadcasting Act and there are also responsibilities both from the corporate perspective and from the audience perspective. It’s not enough just to complain about things you have to be able to prove things and so we’re looking at things like of course whether or not you know we have a duty to to fund and to properly operate a national public content provider which today we call a CBC whether we have actually a right to exercise control over our own communication systems within our borders given the Internet what do we do. Are we going to exercise jurisdiction over Google Facebook Youtube what do we do with that. Or is the era of national control over our borders effectively gone.

Monica Auer:
Do we have the right in an era of fear not so much fake news but news that can be manipulated. Do we have the right to ensure that people can be informed so that they can exercise their democratic credit franchise. And so we have lots of fun people for instance the former chair of the commission Konrad from Finkelstein has kindly agreed to come we have Bram Abramson and formerly of TekSavvy, Janet Lo currently with TekSavvy, we have Brad Danks from OutTV who is an amazing thinker for a lawyer. He’s actually taken a long-term perspective as to what the future of the system might be and I think his company is very much engaged in and working with the new realities they have. We have Tim Denton, Suzanne Lamarre both former CRTC commissioners John Langford from PIAC. We would have invited you except that you won’t be in Canada that time. And so in your stead we’ve invited Dr. Dwayne Winseck because to some extent he has a similar viewpoint in that he is not necessarily as as bound to the Broadcasting Act as I am. And so we’re hoping that he will stimulate conversation with people from ACTRA, DTGC. It should be a lot of fun.

Michael Geist:
Well thanks so much for joining us on the podcast.

Michael Geist:
Thank you very much for inviting me.

Michael Geist:
Policy 3.0. The FRPC upcoming Communications Conference takes place at the University of Ottawa on May 10th and 11th. There is a link to the conference registration page at Michael Geist.ca.

Michael Geist:
That’s the Law Bytes podcast for this week. If you have comments suggestions or other feedback, write to lawbytes.com. That’s L.A. W B Y TE S at P.O. Box dot com. Follow the podcast on Twitter at @lawbytespod or Michael Geist at @mgeist. You can download the latest episodes from my Web site at Michaelgeist.ca or subscribe via RSS, at Apple podcast, Google, or Spotify. The LawBytes Podcast is produced by Gerardo LeBron Laboy. Music by the Laboy brothers: Gerardo and Jose LeBron Laboy. Credit information for the clips featured in this podcast can be found in the show notes for this episode at Michaelgeist.ca. I’m Michael Geist. Thanks for listening and see you next time.

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