CBC's Self-inflicted Cuts to CBC Radio Now Over $50 million

The CBC president pronounced  at a CRTC hearing last November that CBC radio had been largely spared from the budget cuts made by the  federal government in spring 2012.  Here's what he said to the CRTC Commissioners: "when you look also at whether... the television side or the radio side that gets most of the cuts, we actually also protected the radio piece to the tune of -- about 84 percent of the cuts went on the television side, 16 percent of our cuts went on the radio side."  

CRTC implemented a new policy a while back that required all broadcasters, including CBC, to submit annual financial reports on their individual networks.  The CRTC financial reports are useful for understanding the revenues, expenses and staffing of CBC and other broadcasters.  The most recent report for the broadcast year ending August 31, 2012 contradicts what the president said at the CRTC hearing.

Here are some CBC English highlights in the CRTC financial data 2009-2012:

-The management has cut CBC English radio expenditures by some $54 million between 2009 and 2012 which is a 24% cut; total expenditures of the radio service were $171 million in 2012, less than one quarter  the cost of CBC English TV.  The $171 million represents a reduction of some $9 million from the previous year. CBC English TV was not only spared but actually increased expenditures to an all time high of $722 million in 2012, an increase of about $12 million over 2011.    

 -CBC salary expenditures followed suit, with CBC TV increasing and CBC radio decreasing.  Moreover, the number of staff employed by CBC TV increased to 3,199 in 2012, an increase of almost 200 over 2011.  The number of staff at CBC radio fell to 1,348 in 2012, almost 100 fewer than in 2011.  CBC French radio has seen its staff reduced similarly.

-CBC TV has increased its expenditures, as shown above.  However, CBC TV advertising revenue stalled in 2012.  CBC TV ad revenues totaled some $245 million in 2012, a million or so less than in 2011.  Ad revenues accounted for just 34% of the cost of CBC TV in 2012.  

The watering down of CBC radio, including the transformation of Radio 2 from a classical music and arts service to a miscellaneous music mix, the 50% reduction in midday local programming, the numerous same week repeats of network programs, the cancellations of talent contracts for theatre critics, etc., the long periods in summer when regular programs consist of nothing but repeats, the reductions in the depth of radio news and reporting, the focus on low hanging crime news, sports, weather and traffic, have presumably all been done for one over-riding reason: to save money, money which is being used to support the CBC's television service.  The question is: whom did CBC management consult to make these drastic cuts: CRTC, government, Canadians? 

Postscript:  There was no hint in CBC's 2012-13 Corporate Plan, presented annually to the government, that CBC ad revenues were flat.  In fact, the plan, which was issued in August 2012 and relates to the fiscal year rather than the broadcast year, stated:

"On the revenue front, CBC outperformed our target by 7 per cent, driven by incremental advertising revenue, largely from hockey playoffs, and a variety of other revenue items, such as program sales and facility rentals. Self-generated revenues continue to be an important source of funding for CBC."

 

CBC 'Factortions' at CRTC Licence Renewal (Part Three)

At the recent CRTC licence renewal hearing CBC management distorted and contorted basic facts about staffing, salaries, schedule content and revenue models.  To be fair, CBC senior management is facing unprecedented financial challenges but  misconstruing basic facts will not yield a good result for the public broadcaster.  The licence renewal hearing brings into question the efficacy of the strategic planning process at the Corporation.  Below is the third and final factortion presented by the CBC:

Factortion:  Ad revenue for Radio 2/Espace Musique

CBC has requested approval to run commercials on two of its radio services.  The Commission’s decision may be viewed by future historians as a pivotal moment in Canadian public broadcasting. 

CBC engaged Strategic Inc. to forecast the potential revenue of commercials on Radio 2 and Espace Musique.  CAB in turn commissioned two research organizations to prepare estimates of the potential commercial revenue of the two radio services.  Friends of Canadian Broadcasting also asked CMRI to forecast revenues. During the last day of the hearing CBC’s research consultant was asked about the three competing forecasts and discounted them. The other forecasts all strongly suggested that CBC had under-estimated the revenue that would be realized from commercials on CBC radio. This was perhaps the key issue discussed at the hearing. 

The revenue model used by CBC’s research consultant is in all likelihood low-balling the potential revenue, although it is difficult to determine this because Strategic Inc. does not appear to have put its actual calculations on the public record.  The three competing approaches all showed exactly how they made their forecasts.  The limited information that has been filed by CBC contains serious errors, which are discussed below.  While it is tempting to dismiss this as simply “dueling researchers,” the Commission should study the various forecasts and determine which is more credible.

CMRI estimated potential commercial revenue using a well-recognized “top down” approach that employed revenue per tuning hour.  This model was criticized by the consultant because it was “theoretical.” The CBC’s research consultant also dismissed the other two analyses, which used a variation of the Strategic Inc. “bottom-up” approach.  Essentially, the research consultant claimed that all the competing forecasts were theoretical versus the bottom-up “practical” approach used by the CBC’s consultant. 

The consultant explained why she thought the practical approach was superior to the theoretical approach.  She explained the differences in the competing forecasts by virtue of the fact she had “customized” her forecast market by market. In its filing of April 20, 2012 the CBC said “Current audience shares would remain essentially the same” and the revenue projection “assumed…(s)ell out rates…by market” and “calculate(d) rates by station and by hour in the schedule.”  As mentioned, details of how this was done do not appear to be on the public record.  Strategic Inc. did not file a report of its analysis.  However, customization simply means the forecast is based on a greater number of assumptions.  The consultant had to make assumptions for several factors in a series of markets and therefore the CBC forecast has more risk than the market averages used by the CAB in its two forecasts.

CAB’s forecasts and that of Strategic Inc. all used a bottom-up, market by market approach. However, Strategic Inc. in a 2004 report[1], which was submitted to the Commission in a proceeding on local avails, explained the problems of the bottom-up approach: it “relies on several subjective factors” and “The challenges in this approach lie in the accuracy of its component parts and the fact that much of needed information is not publicly available or in an audited form.”

After reading the transcript it is unclear exactly what the consultant said was lacking in the CMRI approach, which used the average revenue/listening hour in private radio to forecast CBC’s potential revenue.  It is not surprising that the CBC’s research consultant had difficulty clearly enunciating weaknesses in the revenue per listening hour approach used by CMRI.  It is because she argued that it was a superior method when Strategic Inc. filed the above research with the CRTC on behalf of CTV in 2004.

Here is what Strategic Inc. said to the Commission in 2004 about the approach used by CMRI: it is “a better approach” than the bottom-up approach and “Using a “revenue per hour of viewing” model recognizes the critical role audience achievement plays and is based on the actual tuning…. In this approach to valuation, factors that affect the ability to generate revenues are built into the model, such as varying demands across markets and sell out rates.”

The last sentence in the quote summarizes the strengths of the approach used by CMRI and explains why the CMRI forecast differs from the bottom-up, practical approach used by Strategic Inc.  The revenue per hour of tuning method requires fewer assumptions, i.e., factors that affect tuning levels, sell out rates, market-by-market demand and seasonal variation are “built into the model” and can be empirically verified.   

After reading the transcript of what the CBC’s consultant said on the final day of the hearing, CMRI examined the data she referred to in more detail. On August 13, 2012 (Appendix C) CBC put limited information about its revenue forecast on the public record, at the Commission’s request.  That document and the one CBC filed on April 20th contained the projected revenues by station and in total for the two radio services.  The August 13th document showed sell out rates by market and projected audience shares, which on the first day of the hearing CBC’s consultant said were used to make the forecast.  In year one sell out rates ranged from about 9% to over 40%, without explanation.  Many markets showed substantially higher sell out rates in the later years but projected revenue did not follow suit.

Most importantly, in that August 13^th filing the CBC’s projected audience shares, which determine revenue, for each CBC station were significantly at odds with the published BBM data sourced by CBC in cities such as Montreal, Ottawa, Windsor and Quebec City. In other words, there were errors in the CBC forecast.  For example, Radio 2’s share in Anglo Montreal was shown in the CBC forecast at 1%, when it has been about 2.5% for the past few years. In Windsor the CBC forecast put Radio 2’s share at 0.004%, when it has been about 1% (250 times higher than the number used in the forecast).  In all cases where there were errors, the audience shares were lower than published BBM data sourced by CBC and this would have had a very substantial negative effect on the revenue forecast.  BBM only publishes select markets, so there may be other discrepancies. In addition, on April 20, 2012, not only did CBC say that “current audience shares would remain essentially the same (as today)” but CBC said about its forecast that “projection of audience growth has been minimal as both services are approaching maturity.”  Yet, the CBC August 13^th filing (Appendix C) showed 5 of 14 of Radio 2 stations more than doubling audience share a few years later, presumably also errors in the forecast.   These errors should invalidate the CBC/Strategic Inc. revenue forecast.

The bottom line: this is not a case of “he said, she said” but a case of “she said, and then she said.”  Strategic Inc. has previously strongly endorsed the top-down revenue/tuning hour approach in a very similar if not identical situation.  Strategic Inc. used it in the 2004-05 CRTC proceeding and referred to it as the best of three different approaches.

Both the facts and history have been contorted. The top-down revenue per listening hour approach has previously been accepted by the Commission and by Strategic Inc.  In this proceeding CBC has used a “subjective” approach, to use the words of Strategic Inc.’s 2004 report, and it should be considered potentially flawed and capable of manipulation.  In fact, a detailed examination of the information CBC filed about the forecast reveals that it is seriously flawed and rife with errors.  Three competing forecasts that fully explained their calculations strongly suggest that CBC has low-balled the potential revenue from radio advertising.

Understanding and incorporating basic and complete facts about the broadcasting environment is critical in strategic planning. The CRTC has an important role to play in helping the CBC understand this environment.  If such serious factual errors and misunderstandings, which have shaped CBC's current strategy, are not challenged by the CRTC, the errors, repeated often enough, will become conventional wisdom and Canadians will be left with a CBC that will not serve their needs.

---

[1] “Impact Analysis

Addition of Commercial Inventory on US Services carried on Cable,” Strategic Inc., October 4, 2004

 

CBC 'Factortions' at CRTC Licence Renewal (Part Two)

CBC’s current management is facing enormous challenges, greater than at any time in the Corporation’s history; the temptation to distort and contort the facts to suit a chosen, seemingly compelling, strategic direction is understandable.  However, the CBC's appearance at its recent CRTC licence renewal hearing brings into question the efficacy of the strategic planning process at the Corporation.  Understanding and incorporating basic and complete facts about the broadcasting environment is critical in strategic planning and CBC's disdain for the facts will not serve it well.  Here is the second of three serious factortions CBC made at the hearing: 

Factortion:  CBC TV Sports Programs

During the Friends of Canadian Broadcasting November 23, 2012, appearance before the Commission at the CBC's licence renewal hearing Ian Morrison made the interesting point that in the 8 months of the year when CBC TV carries NHL hockey (i.e., October to May) there are about 1,000 hours of prime time available (4 hours/night X 30 days X 8 months).  Mr. Morrison made the observation that professional sports or related programming accounts for about 400 prime time hours during those eight months.  He said 400 hours represents 40% of CBC’s prime time in those eight months, something that Friends’ tens of thousands of supporters are concerned about.  Even if the number of hours is only 300, this is still 30% of the primetime schedule in the highest viewing months.

The last day of the hearing CBC contorted this information by wrongly claiming that the Friends had said there were 1,000 hours of prime time sports programming on CBC TV, adding that since there are about 1,500 hours of prime time per year (in 12 months),  this would mean CBC’s schedule would be two-thirds sports (1,000/1,500 hours per year).  If CBC management didn’t care enough to attend or monitor the hearing, they could have read the transcript to learn precisely what Mr. Morrison had said.   Instead, CBC dismissed this useful observation by Friends by contorting and distorting basic facts presented to the Commission. 

Moreover, CBC stated that only 10% of its 2012 schedule was amateur or professional sports programming.  CBC didn’t make it clear that this number was for the whole day, not prime time.  An examination of CBC’s program logs would reveal that the amount of professional sports alone exceeded 20% in prime time in 2012, over 90% of which was hockey-related and all broadcast in the eight months Mr. Morrison referenced.  CMRI urges the Commission to review the program logs of CBC and the CRTC public data on CBC expenditures in sports programming to help it determine if CBC is too reliant on sports.

CBC 'Factortions' at CRTC Licence Renewal (Part One)

 

The CRTC has completed an arduous two week hearing process to renew CBC licences, having heard from CBC senior management and many Canadians.  CBC is Canada’s most important cultural organization and its management, facing the most challenging period in CBC’s history, must ensure that it has properly weighed all the facts about its own organization and the role it plays in the broadcasting system as a whole.  These final comments are in response to the information that CBC management provided on the final afternoon of the hearing and serve to underscore some deficiencies in strategic planning at CBC. 

The term “factortion,” or the contortion and distortion of facts, was used in the Toronto Star earlier this year to describe an ailment that has afflicted CBC management in the past.  In the final day of the hearing CBC presented three serious factortions, each of which related to central issues at the hearing and demonstrate that current management have failed to incorporate some basic facts about the current broadcasting environment in their strategy.  There were other questionable statements made by CBC during this process, the most flagrant being that it was once the only radio operator in Canada.  Here is the first of three factortions CBC made at it final appearnce before CRTC:  

Factortion:  CBC’s efficiency compared to the private sector

Several interveners from private radio urged the Commission to consider that private radio is more efficient than CBC radio, providing evidence in the form of staff numbers per station and average salaries.  Their point was that rather than commercialize its radio services CBC should become more efficient.  CBC’s response was to dismiss this by first pointing out that the CRTC salary data contained overtime, benefits, etc.  CBC implied that overtime or benefits explain the high CBC salaries.

More importantly, CBC said on the last day that it was a large company and a fairer comparison would be to examine CRTC salary data for large private radio companies.  This is a valid point. It is true that CBC radio, according to CRTC data, only pays about $10,000 more per annum per employee when compared to Astral, BCE, Rogers, Corus and Cogeco, the largest private radio companies.  In fact, the CRTC data show CBC radio in total had far fewer staff than private radio stations in 2011, which had four times as many employees.  CBC radio had approximately 2,500 employees, about two-thirds of them in English radio.  Yet, in TV, CRTC data reveal that CBC/Radio Canada had as many staff, about 6,000, as all private conventional TV combined in 2011.  More importantly, the data reveal that the Radio Canada television service had more employees than CBC English TV.  CBC referred the Commission to the CRTC staff data and so we examined it and confirmed this important discrepancy in CBC radio and TV staff levels, which indicates that CBC can find more efficiencies, having done so in radio.

There are many good reasons why CBC radio and TV have a large number of staff: you can’t create quality programs without people. However, when the above-mentioned analysis of CRTC staff and salary data was published in the Star earlier this year one recently retired CBC staffer added some perspective: “I hate to disabuse you but what you say was the average salary last year was about one-third of what I was paid….Actually, as you know, averages are just that. The average would include all the low paid copy clerks and junior technicians, of whom there are many, and all of the high paid talent and producers, of whom there are few. Fortunately for public consumption that helps to bring the average down.” 

Those low-paid CBC clerks and technicians work very hard for their money and are worth every cent, providing an invaluable service to many, if not most Canadians.  However, the CRTC staff and salary data also reveal that CBC total salary expenditures showed a large annual increase in 2011, despite budget cuts.  The increase paid by CBC in salaries last year was just under $50 million, according to the CRTC data the CBC referred to in its final appearance. This is more than twice the amount CBC says it would generate from commercials on radio.

Some areas of CBC, especially management, may be over-staffed and paid more than the rest of the industry.  More than 600 managers, according to CBC, are in a category that makes them eligible for bonuses; this number has grown exponentially in the last decade.  Salaries of on-air staff and those of senior producers may be overly generous compared to the rest of the industry and CBC could find efficiencies. The Commission should carefully examine the staffing data CBC referenced in its final appearance to determine if efficiencies are preferable to further commercialization of CBC services, namely Radio 2 and Espace Musique.

How to Fund the CBC: A Modest Proposal

Canadians spend an exceptional amount of their discretionary income on communications and media. Canadian households spent just over $3,000 in 2010 on communications and media, which includes phone service, cell phones, internet, cable/satellite TV, purchase of new TV sets, DVDs, iPods, tablet and personal computers, etc. This is summarized in the table below:

Also shown in the table is that Canadian households spent (through their taxes) $88 on CBC/Radio Canada TV and radio, which represented just under 3% of total communication and media expenditures.

The federal government recently cut the budget of CBC by about 10% and CRTC cancelled a local programming fund that cable and satellite subscribers pay.  These cuts will come into full effect over the next two years.  To offset these cuts and to provide a source of future funding for CBC/Radio Canada, the government through an Order in Council should implement a voluntary levy on all communication and media services.  All cable, satellite, phone, cell phone and internet companies, as well as retailers of audio and video equipment, would be required to ask customers in each billing period if they would like to make a voluntary contribution to maintain and improve national and local programs on CBC TV and radio. Smaller purchases at Best Buy, etc. would not be included.

CMRI's Media Trends Survey reveals that a percentage of Canadians willingly donate to PBS and other public broadcasters, as shown in the chart below:   

CBC TV and radio attract substantial audiences and our surveys over the past decade have shown that Canadians of all political stripes are very supportive of CBC. A voluntary communications levy would function much like requests for charitable donations at liquor stores or other retailers, which appear to be very successful.  Because this program would be ongoing and apply to all major purchases, retailers and service providers would be paid a commission for collecting the levy.

CBC’s loyal listeners and viewers would likely be willing to make voluntary contributions to maintain CBC services and it is possible that the recent cuts in CBC funding would be made up with a communications levy.  Who knows, maybe such a levy could raise all the funding that CBC requires in future years and the government would no longer have to fund it through general tax revenues?

The 2011 survey results are from CMRI's Media Trends Survey conducted November-December 2011 among a representative national sample of approximately 900 Anglophone respondents aged 18-plus.  Margin of error +/-3.3%.  The Media Trends Survey has been conducted for ten consecutive years and has surveyed over 15,000 Canadians in total. In our analysis we usually only report Anglophone results.   Both Anglophones and Francophones have been surveyed in this period, using questionnaires in each respective language.  Francophones have been surveyed in 5 of the 10 years.  To compensate for poorer response rates among younger adults results are statistically weighted in keeping with industry standards.  It is the only survey to have measured media use and attitudes continuously over this decade. The Media Trends Survey is not sponsored by any one industry or affiliated with a media company.

Is CBC a Sports Channel?

How much do CBC and the other networks spend on sports programming?  How much advertising revenue do these networks generate?  Does CBC lead all networks in sports expenditures and advertising revenues?

The table below summarizes Canadian sports program expenditures of CBC, CTV and the sports specialty channels in the years 2008 to 2011:

CBC in 2008, a year it held Olympic rights, spent $180 million on sports programming.  This declined to $139 million the following year, the first year of the CBC’s current NHL contract, and increased to about $150 million by 2011.  CTV, as expected, spends very little on sports; it spent virtually nothing in the 2011 broadcast year.  Only in 2010, the year CTV and Rogers shared rights for the Vancouver Olympics, did CTV spend heavily on sports.  That year CTV identified spending $137 million dollars on sports programming, meaning it paid dearly for the Vancouver games. 

The three sports specialty channels, despite having to fill 24 hours a day with sports, each spend less on Canadian sports programming than the CBC.  In 2008 and 2009 TSN and Sportsnet had total program expenditures of between $92 million and $122 million.  In 2010 expenditures of TSN/Sportsnet, who also aired the Vancouver Olympics, increased noticeably and in 2011 both were at $140 million.  RDS spends roughly half what its English counterparts spend, some $66 million in 2011.  So in terms of expenditures on Canadian sports, CBC leads all networks, including the three all sports channels.

The table below shows the total ad revenues of CBC TV, CTV and the sports networks in the past four years:
 

In 2008, with the help of the Beijing Olympics, CBC had ad revenues of $253 million.  Revenues declined precipitously in 2009, as did the revenues of most companies during the 2008-09 financial crisis; they rebounded in 2010.  Last year total ad revenues of CBC were $246 million.  Sports probably accounts for something like $150 million in ad revenues on CBC TV, or presumably at least as much as CBC spends on sports.  CTV, one of CBC TV’s main competitors, generates much higher ad revenues, $784 million in 2011.  (Global TV, the other main competitor in the marketplace generated just under $500 million in ad revenue last year or about double that of CBC TV.)  But neither CTV nor Global normally derive much revenue from sports.  

Interestingly, even with the hundreds of NHL games carried on TSN/Sportsnet/RDS and the thousands of hours of other professional sports, the total ad revenues of the sports specialty channels are relatively modest, accounting for between $63 million and $129 million in 2011.  So in terms of advertising revenue derived from sports CBC TV generates more ad revenue than its main competitors and the all sports channels.  Of course, the sports channels make additional money from subscription revenues, which come in even when the NHL locks out its players. 

CMRI Responds to Nordicity

CMRI’s critique of Nordicity’s study dealing with the role of advertising on CBC has generated a reply from Nordicity.  Nordicity’s reply was picked up by at least one news outlet.    In its reply Nordicity was very selective about the facts and made false statements about CMRI’s analysis. 

Nordicity’s reply to the CMRI critique did not deal with most of the major issues raised by CMRI:  the assumptions made about the cost of replacing ads, the claim that with as much as seven times the budget, CBC/Radio Canada’s audience share would possibly shrink to the levels of TVO/Tele-Quebec, etc. Instead Nordicity chose to deal with the following less important items.

Nordicity’s reply claimed that its report was not primarily about audiences: “Quite to the contrary, audience is a secondary concern of our analysis.  The primary concern is clearly stated in conclusion #4 on page 13:”  Here is that conclusion: “Conclusion #4: The PBS operating structure, revenue model, and program production financing could not be readily replicated in Canada.  If CBC/Radio Canada managed to do so, it would likely decline in audience terms to PBS’s niche presence in the market.” In its reply to CMRI Nordicity omitted to reproduce the second part of this conclusion, which seems ultimately to be all about audiences. The fact is that the word “audience” is mentioned over 30 times in the 27-page Nordicity report.

Nordicity’s reply claimed it did not confuse the term “rating” with audience “share:” “Your article implies we misled readers about PBS’s viewing level…In fact, we clearly state on page 13 of the report that PBS has a 1.3% rating:” This is a false statement: the word rating does not appear in the Nordicity report.  The word ratings does but is used in the generic sense. Putting aside the fact that the number 1.3% was two lines away from the word “ratings” in the actual report, Nordicity doesn’t mention that the sentence just prior to 1.3% read: “As a result, PBS now has a very limited audience share and impact on the U.S. market.”      

And, just what did Nordicity mean when it claimed PBS had a limited impact on the U.S. market?  If tonight the PBS news hour, a science program, an arts program and a drama were watched by different people and each program had a 1.3% rating, then the audience reach of PBS would be 5.2% (1.3%X4).  If this was repeated for the next week, the audience reach would be over 35%, which, assuming the programs were of high quality, would likely result in a very substantial impact on the market.     

Nordicity went on to compare PBS and CBC audiences: “In fact, CBC TV’s prime time audience share is double, which in audience terms is a very significant difference.”  CMRI originally pointed out that PBS has a very substantial following in Canada and it does so with no local stations, staff or infrastructure.  Hopefully CBC English TV with numerous stations and a large infrastructure, as well as about three quarters of a billion dollars in annual operating revenue, will draw a larger audience than PBS. 

Nordicity also took issue with our questioning Nordicity’s “estimate” of the cost of selling ads on CBC.  Nordicity put the cost of sales at about $25 million annually. CMRI pointed out that CRTC data showed that it was likely many times higher.  Nordicity in its reply said:  “In fact, we cited the CRTC as a source for our estimate in our report on page 16, Table 1.”  CRTC was mentioned along with four other sources for the table in question but Nordicity did not discuss the CRTC sales data at all. Moreover, why was Nordicity “estimating” the cost of CBC sales?  Why didn’t it just ask the CBC, its client?

Finally, Nordicity makes a blanket statement about CMRI’s competence: “In addition to these factual misrepresentations of our work, you make basic audience research errors and misrepresent your own survey data.” 

In its critique CMRI clearly referred to 10 years of data from its annual survey regarding attitudes toward TV advertising. Nordicity made the following false statement in its reply about CMRI’s annual survey: “Your survey cannot purport to state any facts about Canadians, since your survey is of “900 Anglophone respondents” and by definition excludes all francophone Canadians.”  In our analysis we usually only report Anglophone results and CMRI clearly stated: “The Media Trends Survey has been conducted for ten consecutive years and has surveyed over 15,000 Canadians in total in this period.”  Approximately 2,600 of those surveyed were Francophones, who responded to a separate French-language questionnaire in five of the last ten years.  Francophones have had almost identical feelings toward advertising but Nordicity falsely claimed we had no such data.

Nordicity’s reply to CMRI’s critique appears to be an attempt to deflect attention away from the major issues about advertising on CBC.  In our view Nordicity’s reply only casts further doubt on the validity of the original study about CBC and advertising.