On the CRB's Proposed Census Reporting And Actual Total Performances01/10/2008
Chapter 2: Census Reporting
The first big proposed change is a move from periodic reporting to census reporting.
Specifically, the CRB notes that:
... the relevant reporting period is limited to two periods of seven consecutive days for each calendar quarter of the year. This results in an estimate of the use of a sound recording rather than a report of actual use. The failure to report the full actual number of performances of a sound recording is at odds with the purpose of the recordkeeping requirement to the extent that, as a result, many sound recordings are under-compensated or not compensated at all from the section 114 and 112 royalties.
To remedy this, the CRB proposes a shift from "quarterly" reporting to "census" reporting, which means stations would instead have to submit data for every single song they play, all the time, 24/7/365.
This represents a sixfold increase in station recordkeeping.
The current system, where stations report two 7-day periods each quarter, gives stations ample extra time to compile and prepare their reports of use. This is also convenient because:
a) In order to properly "... reflect as much as possible the programming typically offered by the Service" it is better to let stations the leeway to pick the weeks they report. Fundraising weeks, for example, contain a completely different mix of programming than 'average' broadcast weeks.
b) Some stations still compile and submit reports by hand. A 2-week report window is advantageous for these stations so they can designate "SoundExchange reporting weeks" in order to alert DJ's and mandate their playlist logging.
More reports = greater frequency of submission
Rather than waiting to submit this data once per quarter, the CRB proposes that stations would submit their census reports every month, adding to station workload. (For those of you wondering, yes, it would mean an increase in the RadioActivity.fm subscription pricing.)
Without rehashing all of the arguments I laid out previously regarding the difficulties stations can encounter while trying to compile their reports of use, I'll just reiterate that it is often very difficult for DJ's to broadcast a show and simultaneously log their playlists, even if just for these two 7-day periods. Increasing that logging requirement to 365 days a year places an unfair burden on stations and DJ's.
Part 1: Introduction|
Part 3: Actual Total Performances
Part 4: Adoption Rate And Participation
Part 5: A Process Badly In Need Of Transparency
Part 6: Final Thoughts