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These archive versions of The Session are posted as initially published. Deadlines, contacts and links have not been updated. Please keep this in mind when using this resource. In some cases, updates can be found in a more recent edition of The Session.

December 2004

Industry News
  • Canadian industry calls for renewal of Canadian Music Fund and revision of Copyright Act - "We're asking for two straightforward measures," comments Canadian Recording Industry Association President, Graham Henderson.  "First to renew the Canadian Music Fund and, second, to ratify the WIPO treaties."  Federal funding of the independent music community, he adds, has directly lead to phenomenal success stories for decades.  "It is often forgotten that Canadian artists bring millions of dollars of foreign currency earnings into the country each year," says Mr. Henderson.  In addition, Mr. Henderson calls for the government to press ahead with revisions to Canada's copyright legislation to ensure that the intellectual property of rights holders are brought in line with the challenges of the digital age.  Mr. Henderson elaborates, "The Prime Minister, Ministers of Canadian Heritage, the House of Commons Committee on Canadian Heritage and the Supreme Court of Canada have all called for the Copyright Act be brought into the 21st century.  We are asking the government to do so honouring Canada's long standing commitment to ratify the WIPO treaties."  CRIA joined the Music in Canada Coalition in Ottawa ­ an unprecedented gathering of associations representing more than 46,000 talented and skilled Canadians working in all aspects of Canada's music business.  The WIPO (World Intellectual Property Organization) treaties will make it easier for traditional copyrighted materials like music, literature, art, audiovisual materials and software to be accessed legally on the Internet.  Over 50 other countries ­ including Canada's major trading partners - have implemented or ratified the treaties.  In 1997, Canada agreed to ratify the treaties by modernizing its Copyright Act.  (Excerpted from hawkestone communications press release)
  • The 17th Annual International Folk Alliance Conference, Strictly Mundial, will be in Montreal February 24-27, 2005.  Details can be found at www.folk.org.  Strictly Mundial ("strictly worldwide") is this year's theme and allows them to travel through not only North America, but around the world for music, dance and opportunities.  The Hyatt Regency Montreal is their conference hotel, and can be reached at 1-800-233-1234.  They've added the Marketplace Stage - a performance stage in the exhibit hall in Montreal, run during the all-day exhibit hall hours, and right next door to the Marketplace café.  Sign up each day onsite to perform.  All(most) Star Cafe (open mike) moves uptown to the lobby bar of the Hyatt Regency hotel.  The EFWMF (European Forum of Worldwide Music Festivals www.efwmf.org) is an organization of 60 member festivals (and additional other colleagues) who present events year-round featuring world and roots music across Europe.  Their members, like festival presenters here in North America, are coming to Montreal to hear great new artists, and to meet their colleagues and contacts in the music world.
  • Long time recording industry President Brian Robertson steps down: The Board of the Canadian Recording Industry Association (CRIA) has announced that its President will step down and has named his successor.  Mr. Brian Robertson stepped down as CRIA President in mid-November.  He has served as the President of CRIA since 1974.  During his tenure, Mr. Robertson was one of the founders of the Canadian Academy of Recording Arts and Sciences (CARAS) and has been a strong supporter of Canadian artists and culture.  Through his many contributions, he is credited with moving the recording industry forward in a time of tremendous change and growth.  "This is the 30th year of my relationship with CRIA and the Canadian recording industry.  I am deeply grateful to the current and past CRIA board members for allowing me the privilege of assuming this challenging but rewarding role for such an extended period and I look forward to continuing in a consulting role," said Mr. Robertson.  Mr. Robertson will remain with CRIA in a consulting capacity into 2005 as the Chairman Emeritus.  Mr. Graham Henderson, formerly a music industry lawyer in private practice and Senior Vice-President of Business Affairs and eCommerce at Universal Music Canada Inc., assumed the role of President on November 15th.  Mr. Henderson has been a passionate advocate for the Canadian artistic community throughout his career and was a founder of the Recording Artists Associations of Canada.  He brings with him a wealth of experience from his work with artists, writers, record labels and developing e-commerce entities.  (CRIA news release)
  • eBay to Open Download Store - eBay in the U.S. has launched a pilot music download service in partnership with Tennessee-based PassAlong Networks who will supply the tracks.
  • Canadian Music Week (CMW) is Canada's largest annual entertainment event dedicated to the expression and growth of the country's music, media and entertainment industries.  Combining two information-intensive conferences, a cutting-edge trade exposition, five awards shows and the Canadian Music Week Festival, CMW spans over a four-day period from March 2-5, 2005 at the Sheraton Centre Toronto, attracting participants from across the globe.  For more information, visit www.cmw.net.
  • Status of the Artist Update: Canada Council of the Arts presented a Pre-Budget Submission to the Standing Committee on Finance.  Titled "The Artist is at the Centre of Everything" (a nod to comments made by incoming Minister of Canadian Heritage Liza Frulla to CBC TV), the submission makes six key recommendations to the standing committee.  These recommendations were arrived at following input from CCA's members.

    Recommendation 1:
    That the government of Canada move immediately to renew its investment in the cultural sector and that it ensure there is adequate, stable, multi-year funding for the future so that cultural institutions and agencies, in all their diversity, are able to improve their stability, sustainability, and capacity building abilities.

    Recommendation 2:
    That the government of Canada recognize the economic contribution of the cultural sector by extending access to reasonable operating lines of credit for small and medium-sized non-profit and/or charitable organizations.

    Recommendation 3:
    That the Department of Finance take a leading role in a full and comprehensive study into self-employment in today's Canadian labour market, examining public and private sector models from a variety of situations and countries, with particular emphasis on access to social benefits and developing a framework for extending employment insurance in one form or another to self-employed workers.
    Recommendation 4:
    That the government of Canada, through the Department of Finance, institute without delay a system of income back averaging on a 5 year basis, to address the unique needs of the growing numbers of self-employed individuals in Canada, both within the cultural sector and in other sectors of the economy, who experience substantial income fluctuations.

    Recommendation 5:
    That the government of Canada introduce an income tax exemption of up to $60,000 of annual copyright income, on a sliding scale similar to that which currently exists in Quebec, for Canada's professional artists and creators, who form the nucleus of Canada's cultural industries and institutions.

    Recommendation 6:
    That, following the implementation of the above-mentioned tax exemption on copyright income, the government of Canada give serious consideration to extending such an exemption to apply to up to $60,000 per annum of ALL artistic income.

    The full text of the CCA's Pre-Budget Submission is available at http://ccarts.ca/ en/ advocacy/ publications/ policy/ pre budget 2004.htm.  For more information: info@ccarts.ca or www.ccarts.ca.  (Canada Council of the Arts bulletin)
  • RIAA's Appeal Rejected - The U.S. Supreme Court has refused a request by the Recording Industry Association of America (RIAA) that Internet Service Providers (ISPs) be compelled to disclose the names of suspected file traders when served with a subpoena issued by a court clerk.
  • Music Industry Network Canada, also known as MINC, announces new relationships with Music and Film in Motion and the Urban Music Association of Canada (UMAC) - the latest associations to participate in promotional activities with the MINC website.  Members of participating associations receive full access to the MINC website at www.mincanada.com.  The website delivers valuable tools designed to facilitate new business opportunities within the music industry including the ANR Lounge, a free service for recording artists to send electronic press kits to over 140 radio stations across Canada and the Music Pages, the nation's largest online contact database for the music industry.  With the addition of MFM and UMAC, the total number of music industry associations participating in the project increases to 15.
  • Counterfeiters in east caught - Investigators representing the Canadian Recording Industry Association (CRIA) and the Canadian Motion Picture Distributors Association (CMPDA), working with the RCMP and local law enforcement officers, have seized over 6,500 copies of alleged counterfeit and bootleg feature film and concert video DVDs.  RCMP raided an apartment in Quebec City and seized almost 4,000 DVDs as well as computers, burners and printers.  Over 2,000 alleged counterfeit DVDs were seized by representatives of the Durham Region Police and the RCMP Bowmanville Customs and Excise Unit, from a booth at the Pickering Market in Pickering, ON.  Gerald David Kearney has been charged with fraud and the police also intend to lay Copyright Act charges.  Police returned to the market a week later and arrested Mr. Kearney's wife, who was operating the booth with a new supply of alleged counterfeit and bootleg product.  She has been charged with fraud.  "The widespread availability of inexpensive DVD burners and printers has escalated this type of activity in recent months," said Brian Robertson, CRIA President.  "We are also witnessing more blatant retail exposure of it.  The quality level of these reproductions is generally deplorable, so with the exception of the seller, everyone is on the losing end - the artists, the producers and of course, the buyer".  (Excerpted from hawkestone communications news release)
  • Now in its 39th year and located in the conference mecca of Cannes, France, MIDEM is the world's largest music market with over 9,000 music professionals and 2,100 exhibitors from 94 countries. Whether you are interested in worldwide recording, publishing, or distribution deals; looking to license music to video game, film or TV companies; creating new revenue streams; or seeking to reach some the world's largest and most important festival producers, MIDEM is the place to be; January 24-25. 
  • MuchMusic has teamed up with Rogers Wireless to develop the MuchPhone cell phone, a pay-as-you-go handset containing exclusive prepaid content allowing users to customize their handsets with graphics and ringtones.  The MuchPhone gives users access to concert listings, up-to-date information about albums and artists, and live VJ and program updates.  The MuchPhone also contains a song identification application called TuneTracker that sends a text message with the name of a song and information about the artist directly to the phone. The handset also contains games.  (CIRPA: Abstracted from Much Goes Mobile, Canadian Music Network, November 4-10, 2004)
  • Virgin Digital became the latest online music store to launch in the U.S., with over one million tracks for consumers to browse.
  • Sony-BMG Merger Approved - The U.S. Federal Trade Commission (FTC) approved a merger of Sony Corp. and Bertelsmann AG.  The FTC determined that the merger is not in violation of U.S. antitrust laws.  An FTC spokesman expressed some reservations about the merger, however, as the merger reduces the number of major record labels from five to four.  The spokesman suggested, however, that the growing clout among music retailers will counteract the collective market power of four major players.  The U.S. approval came one week after the European Commission (EC) also approved the merger after concluding there was not sufficient evidence overall to oppose the merger.  The EC had been particularly concerned about potential collusion among major record labels in the areas of pricing, online licensing and distribution.  The EC also examined the possibility that Bertelsmann's TV and radio interests might favour artists on Sony/BMG labels over artists on competing labels.  A similar situation regarding Sony's digital download service Sony Connect was also probed.

    The merger creates a 50-50 joint venture called Sony BMG that will control about one-quarter of worldwide record sales.  The merger is expected to result in annual savings of about $350 million (U.S.).  No comment on reports that about 2,000 jobs will be cut.  Both companies have already recently undergone a restructuring process that resulted in job losses and artists dropped from labels. 

    The deal does not include the music publishing businesses of either Sony or Bertelsmann, nor does it include Sony's Japanese music business.  Music manufacturing and physical distribution were also not included in the deal.  In a statement issued July 20th announcing its approval of the merger, the EC said it would closely monitor the European music market.  In addition, any future proposal that would result in further concentration of the recorded music business will be closely scrutinized by the Commission.

    Update -
    European independent label trade organization IMPALA will appeal the decision by the European Commission to approve the merger.  In its press release, IMPALA expressed its concern that increased major label consolidation in the marketplace will seriously reduce retail and radio exposure of independent music.  IMPALA also believes the merger is a threat to European and global cultural diversity and self-determination.  IMPALA's announcement also addressed the issue of U.S. cultural, political and economic dominance throughout the world.  IMPALA was established in April 2000 and has more than 2,500 members.  It represents independent record labels and national trade associations in Europe and the U.K.  (CIRPA: Abstracted from Indie Labels to Appeal Approval of Sony-BMG Merger, by Jeffrey Goldfarb, Reuters, November 3, 2004; and European Independents Appeal Sony/BMG Merger, IMPALA Press Release, November 3, 2004; Bertelsmann, Sony Merger Approved, by James Rowley, Bloomberg News, July 29, 2004; FTC Clears Way for Sony-BMG Merger, Associated Press, July 28, 2004; EC News Release, July 20, 2004; Giant Step for Sony-BMG, by Emmanuel Legrand and Wolfgang Spahr, Billboard, July 31, 2004; EC OKs Sony-BMG Deal, to Eye Music Sector Closely, by Jeffrey Goldfarb and Jeff Mason, Reuters, July 20, 2004; Merger of Sony, BMG Music Labels Wins Endorsement of European commission, by Chuck Philips, Los Angeles Times, July 20, 2004; EC Approves Sony-BMG Music Merger, CNN.com, July 20, 2004)
  • Puretracks Launches in U.S. - Canadian digital music download service Puretracks is now available in the U.S.  It is included as a stand alone service in Microsoft's recently launched Windows Media Player 10 Digital Media Mall.  Puretracks will also continue with its strategy as a business-to-business (B2B) enabler of digital music services, the same strategy it has successfully employed in Canada.  Despite competition from Quebec's Archambault and the Canadian arm of Napster, Puretracks hopes to double its revenue in Canada next year.  However, there are suggestions that Apple may launch a Canadian version of its popular iTunes very soon.  (CIRPA: Abstracted from Canadian Puretracks Enters US B2B Market, Digital Music News, October 14, 2004; and Music Service Puretracks Opens Up Shop in the U.S., Canadian Press, October 13, 2004)
  • Subpoenas issued in payola case - The New York State Attorney General has served subpoenas on the four major record labels as part of an investigation into the labels' practice of paying independent promoters to promote songs to radio stations in New York State.  The subpoenas seek access to contracts, billing records and other information that document the labels' ties to these promoters.  By using middlemen, record labels are working around U.S. laws banning payola ­ the practice of directly paying radio stations to play certain songs.  However, paying middlemen to promote songs to radio stations is seen by many as simply another form of payola.  The middlemen pay radio station owners annual fees, which in some cases exceed $100,000 (U.S.), to obtain advance copies of station playlists.  For each new song that shows up on these playlists, the middlemen bill the record labels.  Overall, the practice ends up costing record labels tens of millions of dollars each year.  It has been going on for decades.

    The use of middlemen was prevalent during the 1980s and most of the 1990s.  However, in 1996 the U.S. government deregulated the radio industry, leading to the rise of powerful broadcast groups who used their power to choose specific promoters to act as exclusive representatives for their radio stations.  Fees paid by promoters to station owners increased but the promoters had less influence over songs chosen for airplay.  In 2002, the Recording Industry Association of America (RIAA) became concerned about the practice and asked the U.S. government to look into the situation and toughen anti-payola laws.  In response, two of the country's biggest radio broadcasters, Cox Radio and Clear Channel, announced they would not renew the contracts of their promoters.  Because promoters no longer have the big radio broadcasters as their clients, record labels have cut back on payments.  However, it is estimated that use of promoters costs record labels about $30 million (U.S.) annually.  (CIRPA: Abstracted from Record Labels Said to Be Next on Spitzer List for Scrutiny, by Jeff Leeds, The New York Times, October 22, 2004; and EMI to Face Spitzer Music Industry Probe, by Adam Pasick and Kenneth Li, Reuters, October 22, 2004)
  • Denise Donlon Leaving Sony BMG - Previous to taking the top position at Sony Music Canada, Ms. Donlon held various positions at Canadian video music channels MuchMusic and MuchMoreMusic where she rose to the position of vice-president and general manager.  Ms. Donlon was described by Shift magazine as "the most important woman in music" and was inducted into the Canadian Association of Broadcasters' Hall of Fame in 2002.  Lisa Zbitnew, president of BMG Canada, will take over Ms. Donlon's post but the title will change to President, Sony BMG Music Canada.  (CIRPA: Abstracted from Denise Donlon Leaving High-Profile Post as Head of Sony Music Canada, Canadian Press)
  • Online retailer CD Baby reports that it has paid out more than $10 million U.S. to independent artists whose CDs were sold through cdbaby.com.  The payout represents 1.2 million units sold, with artists receiving between $6 and $12 per CD.  Operating on a consignment system, CD Baby selects and warehouses independent artists' CDs, and provides artists with access to worldwide sales and distribution.  With music from more than 75,000 artists and labels, the company describes itself as the largest seller of independent music on the Internet.  CD Baby is also one of the primary suppliers of music to legal digital download services such as Apple iTunes, MSN Music, Napster, Rhapsody, Sony Connect and MusicMatch.  (CIRPA: Abstracted from CD Baby Pays $10 Million to Musicians for CDs Sold, Music Industry News Network, October 23, 2004; and CD Baby Payouts Surpass $10 Million, Digital Music News, October 25, 2004)
  • U.S. Radio and ASCAP Set Royalty Fee - Radio stations in the U.S. will now pay a set royalty fee to the American Society of Composers, Authors and Publishers (ASCAP) instead of a percentage of yearly revenue.  The approximately 12,000 commercial radio stations in the U.S. will pay $1.7 billion (U.S.) to ASCAP over six years.  Included in the agreement is the right for commercial radio stations to simulcast their programming over the Internet.  However, radio broadcasters who choose to do so will still have to pay a separate royalty fee to record labels as well.  Both parties described the deal as the largest licensing deal in the history of U.S. radio. The Radio Music License Committee reached a similar deal with BMI last year involving $1 billion (U.S.).  ASCAP has a repertoire of 7.5 million songs and represents about 190,000 songwriters and publishers.  (CIRPA: Abstracted from Radio Industry, Songwriters Agree on Plan, Michael P. Regan, Associated Press, October 18, 2004; and Web Radio Gets $1.7 Billion Boost, by Matt Hines, CNET News.com, October 18, 2004)
  • European file trading suits - Music industry associations in five European countries and the U.K. have initiated legal action against 459 people who illegally upload large volumes of copyrighted music onto the Internet for the purposes of file trading.  The people being sued face either criminal or civil action, and music industry associations in each country will seek compensation from each person averaging "several thousand euros," according to the International Federation of the Phonographic Industry (IFPI) which co-ordinated the lawsuits.  Illegal file traders had already been warned, particularly in France and the U.K.  During the past year, music associations in both countries had undertaken educational campaigns informing people of the consequences of illegal file sharing.  In the U.K., one IP address alone was detected to have uploaded 7,000 titles.  (CIRPA: Abstracted from Europe Upload Attack, by Juliana Koranteng and Emmanuel Legrand, Billboard.biz, October 16, 2004; Legal Action Against File-Sharers Spreads Though Approaches Vary Among Territories, Music Week, October 16, 2004; BPI: Lawsuits Are a Vital Weapon, Martin Talbot, Music Week, October 16, 2004; and Music Industry Wins Court Ruling Against Song-swappers, The Guardian, October 14, 2004)
  • CRIA Renews Agreement With SoundScan - The Canadian Recording Industry Association has renewed its agreement with Nielsen SoundScan to be provided with Canadian retail sales data.  CRIA president Brian Robertson stated that the new agreement will permit CRIA and its members to establish and market charts of best-selling recordings in Canada.  CRIA will work with partners in network television and syndicated radio to launch weekly chart programs in the upcoming season.  (Source: hawkestone communications press release)
  • Sales slide slowing - The International Federation of the Phonographic Industry has released first-half 2004 figures for worldwide sales of recorded music.  Value of sales is down 1.3 percent overall, to $13.9 billion.  However, unit sales increased 1.7 percent to 1.22 billion.  The figures show the smallest rate of sales decline in four years.  By comparison, the value of sales for first-half 2003 declined 10.7 percent over the previous year.  The U.S. market alone represents 40 percent of total volume globally and sales in that country increased 3.9 percent compared to a drop of 12 percent in first-half 2003.  Meanwhile, sales of music DVD worldwide increased by more than 20 percent during the first six months of 2004 and now account for 7.2 percent of total recorded music volume.  First-half sales account for only 40 percent of total yearly sales.  Meanwhile, Nielsen SoundScan reports that Canadian sales of CDs and cassettes from January to mid-August 2004 are up by 4 percent.  So far 25 million units have been sold, an increase of one million units over the same period last year.   (CIRPA: Abstracted from U.S. Music Sales Rebound, Help Stem Global Slide, by Jeffrey Goldfarb, Reuters; Canadian Music Sales Swing Upward, by Peter Brieger, Financial Post)
  • Issues With iTunes - Independent labels in the U.K. are upset that very few independent artist tracks are available for download on iTunes.  Independent labels complain they have difficulty establishing a relationship with iTunes and that iTunes is slow getting back to them after the labels have submitted their contracts.  The labels are concerned that the absence of their tracks on iTunes will affect how their artists' rank on the recently-launched U.K. official downloads chart.  Given iTunes' dominance in the digital download market, the labels are anxious that this problem be resolved soon.  (CIRPA: Abstracted from Indies "Disillusioned" as Apple Drags Heels, by Robert Ashton, Music Week, September 25, 2004; iTunes UK Under Scrutiny for Overcharging, Digital Music News, September 16, 2004; and The iTunes UK Investigation: Is Apple the Culprit?, by Walter Hough, Digital Music News, September 23, 2004)
  • New Radio Service Targets Young Adults - An increasing number of Canadians between the ages of 18 and 24 are turning away from radio, preferring instead to obtain music from the Internet or to listen to their favourite songs on portable digital music players.  Taking advantage of the preference for Internet music is Iceberg Media of Toronto, with a new online radio site called FatPipeRadio.com aimed specifically at young adults between the ages of 18 to 24. The site features 11 specialty music channels, such as alternative rock and unedited hip hop, as well as artist interviews, a comments weblog and pop-culture columnists. Listeners who wish to purchase a song as they listen to it simply click on an icon that directs them to the Puretracks site.  Iceberg Media.com is a division of Canadian broadcaster Standard Radio Inc.  Another source of digitally streamed music aimed at Canadians between the ages of 18 and 34 is CBC's Radio 3.  (CIRPA: Abstracted from On-line Radio Steps Up, by Richard Bloom, The Globe and Mail)
  • More Than One Billion Counterfeit CDs Sold Last Year - The International Federation of the Phonographic Industry (IPFI) reports that, worldwide, more than one out of every three consumer purchases of music CDs was counterfeit.  Over one billion illegally-copied CDs were sold last year. Estimated value of these purchases was $4.5 billion (U.S.), or about 15 percent of the worth of the global recorded music market.  Growth in units of counterfeit CDs was 4 percent over 2002.  The global market value of legitimate music sales is $32 billion.  (CIRPA: Abstracted from Study: Global CD Piracy Trade Tops $4.5 Billion, by Bernhard Warner, Reuters)
  • The Canadian Conference of the Arts' 2004 national policy conference on Status of the Artist (SofA) issues was held in Regina recently.  It was, by all accounts, a pivotal event - an opportunity for 150 members of the arts and cultural communities from across Canada to come together for in-depth discussions and exchanges of information on what is widely acknowledged to be a challenging subject.  The CCA's 2004 conference partner was the Saskatchewan Arts Alliance, whose input into content and organization was invaluable.  The objectives of the conference were to discuss how the existing federal legislation on SofA could be improved; to examine the need for a national council on Status of the Artist and how it could be reinstated; to act as a catalyst for provincial development of SofA outside Quebec.

    The two day conference was structured to bring a broad variety of voices to the table and to examine the existing legislation through a wide-angle lens ­ how it affects individual artists and arts organizations, how similar legislation can be developed at the provincial level, what sort of links must be made between the two levels of government jurisdiction, and what we can learn from other places where SofA legislation is more developed.

    An additional important element of the conference was the launch of a campaign for fair tax treatment for artists, to ensure that all professional artists will be presumed to be self-employed for purposes of their artistic activity; that artists and the organizations which engage them will be free to negotiate a contract of service (employer-employee relationship) if they explicitly agree; and to have a community-agreed test of "professionalism" replace the "reasonable expectation of profit" test now in use.

    Workshops were held on the final afternoon to provide delegates with the opportunity for in-depth discussion in four key areas: a council on Status of the Artist; amendments to existing federal legislation; development of provincial SofA; and issues for Aboriginal professional artists under SofA legislation.  Some of the conclusions which flowed from the workshops include:

    - Confirmation of the need within the sector for a national council on Status of the Artist
    with a mandate to advise the Minister of Canadian Heritage, but also with the credibility to advise other government departments.

    - Proposed amendments to Part I of SofA legislation to allow for a presumption of independent contractor status, tax measures, and other socio-economic measures.

    - Proposed amendments to Part II of the Act should provide for first contract negotiation and arbitration; a requirement for federal government agencies to insist on union agreements; and, if provincial SofA legislation includes bargaining, authority could be delegated to the Canadian Artists and Producers Professional Relations Tribunal (CAPPRT).

    - Development of provincial SofA legislation would be assisted by strong national leadership through the CCA, which could help in identifying the milestones and priority areas, and providing clear communications.

    - CCA support for a major national meeting to discuss the formation of a national alliance (similar to a national arts service organization) to be held by the Aboriginal arts community and which would reflect the Aboriginal model of association, including a place for elders in the discussions.

    Progress on this work will be reported on their website, www.ccarts.ca.

 

 

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