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Faculty of Law, 78 Queens Park, Toronto, ON, Canada M5S 2C5
 A 
RIEL
 ATZ
 
 A
SSOCIATE
P
ROFESSOR 
I
NNOVATION
C
HAIR 
, E
LECTRONIC
C
OMMERCE
 
December 10, 2010
- BY EMAIL -
 Mr. Gilles McDougallActing Secretary GeneralThe Copyright Board of Canada56 Sparks Street, Suite 800Ottawa, OntarioK1A 0C9Dear Mr. McDougall,
Re: Access Copyright’s Post-Secondary Educational Institutions Proposed Tariff (2011-2013); Application for an Interim Decision Imposing an Interim Tariff 
 
Pursuant to the Copyright Board Notice and Ruling, dated Dec. 3 and 8, 2010 respectively, Ihereby make this submission regarding Access Copyright’s Application for an interim decisionimposing an interim tariff. As per the Board’s suggestion, this submission focuses mainly on the preliminary question of whether the Board should grant the Application, although I note that thisquestion cannot be fully separated from the other questions suggested by the Board.I will begin by protesting the fundamental procedural unfairness surrounding this application,which I pointed out in my earlier two submissions of Nov. 30, 2010 and Dec. 6, 2010.Exceptionally tight deadlines such as those imposed by the Board, during an extremely busy andstressful period in the life cycle of the academic year, would cast doubt on the procedural fairnessof any hearing. Those difficulties were compounded by the constant modifications to itsapplication made by Access Copyright, with the result that it is not even clear which documentfiled by Access Copyright constitutes the application. Therefore, it is my position that at this point, any decision by the Board other than one dismissing the application would violate the“general responsibility of the Board to act in accord with the principle of fairness.”
1
 In addition, and without prejudice to my right to further oppose or challenge the validity of aninterim tariff imposed by the Board, and without limiting or waving any argument that I mayraise against the approval of the (final) Approved Tariff, I am of the opinion that that the Boardhas no power to grant the application and approve an interim tariff, or issue any other order having similar effect. In the present case, an interim tariff would contravene the expresslanguage of the
Copyright Act 
and the legislative scheme created by Parliament, would exceed
1
 
Society of Composers, Authors & Music Publishers of Canada v. Canada (Copyright Board)
, 47 C.P.R. (3d) 297,61 F.T.R. 141 (1993) at para. 41.
 
2
Faculty of Law, 78 Queens Park, Toronto, ON, Canada M5S 2C5
the powers vested by the Board as an administrative tribunal and would contradict the Board’sown prior ruling on similar issues.In the present case, an interim tariff would impose what would, in effect, be an enormouslyinvasive and expensive mandatory injunction, whose legality and constitutional validity isquestionable. The tariff would impose enormous costs and restrictions on the entire post-secondary educational framework in Canada (outside of Quebec), against the will of academicinstitutions and other individuals affected by such tariff, and in clear deviation from the statusquo.Even if the Board had the power to mandate such an extreme measure—and it does not—AccessCopyright presented not a shred of evidence that such measure, which will benefit a privateorganization to the detriment of academic institutions, their teachers, staff and students, isnecessary or even desirable. The Board should refrain from doing so and dismiss the application.Furthermore, even if the Board is convinced that an interim measure in the form of a tariff suchas the one requested by Access Copyright is necessary or justified, there is no evidentiary basison which the Board can approve such a tariff, even if on an interim basis. A tariff must relate toa specific repertoire and there is not a single piece of evidence before the Board about the worksto which the proposed tariff will apply. The Board cannot set a fair tariff without knowing whatit is that the tariff would apply to. Proceeding to a determination of this kind, in the absence of such evidence, would be arbitrary and unreasonable.
2
The Board should refrain from makingsuch a decision.I elaborate on these issues in the following sections.
I.
 
The Proposed Draft Interim Tariff is a New Licensing Scheme
The
Copyright Act 
specifies very clearly the procedure for filing and approving tariffs in caseswhen previous tariffs exist and in cases of tariffs applied for the first time. According to s.70.13
(2),
“A collective society referred to in subsection (1) in respect of which no tariff has beenapproved pursuant to subsection 70.15(1) shall file with the Board its proposed tariff,in both official languages, of all royalties to be collected by it for issuing licenses, onor before the March 31 immediately before its proposed effective date.”
3
 
S. 67.1(5), via s. 70.14, provides that,
“As soon as practicable after the receipt of a proposed tariff filed pursuant tosubsection (1), the Board shall publish it in the
Canada Gazette
and shall give noticethat, within sixty days after the publication of the tariff, prospective users or theirrepresentatives may file written objections to the tariff with the Board.”
4
 
A collecting society cannot file a proposed tariff by the statutory deadline and then propose adifferent licensing scheme for the same effective date. This is what Access Copyright is trying todo in the present case. The application should therefore be denied.
2
 
Society of Composers, Authors & Music Publishers of Canada v. Bell Canada
, 2010 FCA 139 at para. 27.
3
Copyright Act, R.S.C. 1985, c. C-42, s.70.13(2).
4
 
 Ibid 
.
 
3
Faculty of Law, 78 Queens Park, Toronto, ON, Canada M5S 2C5
Access Copyright filed the Proposed Tariff on March 31, 2010 with an effective date of January1, 2011. The Proposed Tariff was published in the
Canada Gazette
on June 12, 2010 andobjections were filed by August 11, 2010.
The Proposed Tariff did not contemplate anyobligation on prospective users on an interim basis. Instead, as we learned from AccessCopyright’s letter of October 7, 2010 and its appendices, Access Copyright sought to securecontinued funding for itself as of January 1, 2011 by means of an “Interim Agreement”. The plandid not work; only a very limited number of institutions signed this Interim Agreement.
5
 Therefore, on October 7, 2010 Access Copyright asked to Board to issue an interim decision,which is in effect an interim tariff. Access Copyright modified the terms of the tariff severaltimes, most recently on December 5, 2010. By requesting that the Board approve an interimtariff effective January 1, 2011, Access Copyright proposes a
new
Licensing Scheme within themeaning of s.70.1. It sets out
 
new
classes of uses that it seeks to authorize, with
new
royaltiesand
new
terms and conditions
for the effective date of the Proposed Tariff. Given the anticipatedlength of the proceedings (which by Access Copyright’s own estimate make take more than fiveyears),
6
and given that this period will exceed the period of the Proposed Tariff, in practice, theinterim tariff might well be that only tariff with additional payment imposed sometime in thefuture on a retroactive basis. This cannot be done: the statutory deadline has elapsed; thelanguage requirements were not followed; and no notice and opportunity to object as mandated by the
 Act 
were given. Granting the application would circumvent the clear framework created by the
 Act.
 
II.
 
The Power to Make an Interim Decision Does Not Extend to Ordering anInterim Tariff 
It is well established that an administrative tribunal cannot issue an order or directive unless it isexpressly authorized to do so by its empowering legislation.
7
Further, since express powerscannot be implied, the power to make a particular kind of order cannot be read into or inferredunder the
 Act 
, even if a tribunal thinks such a power is necessary to fulfill its mandate.
8
 
5
Unlike all the other documents that it mentioned in its Application, Access Copyright did not attach a copy of this“Interim Agreement”. A copy of what I believe to be this proposed “Interim Agreement” is attached to thissubmission as Appendix A. It is easy to understand why very few institution signed this agreement, why many other rescinded their signatures, and why Access Copyright’s current solicitor advised the Board in an email sent on Nov.30, 2010 at 2:39 pm that Access Copyright decided to treat some of these signed agreements as null and void (seeAppendix B). The Interim Agreement would require the signing institution to continue paying as before, continuereporting as before, but for nothing. Clause 3(i) made it clear that Access Copyright did not grant any license inreturn.
6
Access Copyright, “Application for an Interim Decision on the Access Copyright Post-Secondary EducationalInstitutions Tariff (2011-2013) [
 AC Application
], Appendix C, at p. 4
7
 
 Bell Canada v. Canada (Canadian Radio-Television and Telecommunications Commission)
, [1989] 1 S.C.R. 1722at para. 50 [
 Bell Canada
];
Curly Posen and Motion Picture Theatres Association of Canada v. Minister of Consumer and Corporate Affairs Canada
, [1980] 2 F.C. 259 at paras. 5-7;
Matthews v. Canada (Attorney General)
, [1996]F.C.J. No. 1077 at paras. 27-31,
aff’d 
[1999] F.C.J. No. 830,
leave to appeal. denied 
[1999] S.C.C.A. No. 412.
8
 
 Nova Scotia Construction Safety Assn. v. Nova Scotia (Human Rights Commission)
, [2006] N.S.J. No. 210 at para.143.
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