After eight-months of letters, faxes, e-mails and phone exchanges with three different Department of Canadian Heritage officials regarding her magazine’s Publications Assistance Program eligibility, ON Nature editor-in-chief Victoria Foote has conceded defeat. As a result, the association quarterly will lose about $13,000 in postal subsidies. “The bureaucracy has become so tangled up in their own wording that they no longer see what the intent of the policy is or whether or not it has been truly carried out,” Foote says. “Our magazine is a casualty of that.”

Association mag ON Nature originally qualified for PAP funding in 2005 but a review earlier this year by the Department of Canadian Heritage led to eight-months of haggling between the two parties. ON Nature editor Victoria Foote has decided not to make the required changes. PAP officials are being "overzealous in their interpretation of the criteria," Foote says.

On May 31, 2007, Foote received an e-mail from a the Department of Canadian Heritage staing, “On Nature, does not meet the association publication requirements.”  The e-mail set an Aug. 31 deadline for ON Nature to make all necessary changes to its subscription forms.

The qualify for PAP funding, an association membership form must include the following information:

1. Costs of membership fee and magazine subscription are identified separately;
2. Costs of the magazine subscription is the same amount for association members and non-members; and
3. Allows existing and new members to choose or opt out of the subscription.

ON Nature, which is published by the Federation of Ontario Naturalists (Ontario Nature), was granted PAP funding effective Jun. 1, 2005, after it made several changes to its subscription and membership forms.

Foote managed to get her deadline extended to Nov. 30. On Nov. 14, Foote sent a package to the DCH, outlining changes made to ON Nature and Ontario Nature subscription and membership forms. On Nov. 30, however, Foote was informed that ON Nature still did not meet PAP requirements. As a result, the magazine would be de-registered.

At this point, Foote sought the guidance of Magazines Canada. She says Mags Canada recommended that Ontario Nature would offer a full monetary refunds to members who opt not to receive the magazine as part of membership. (As a matter of policy, MC does not publicly comment on private communication between MC and individual members and the business activity or the business decisions of individual members.) After receiving these recommendations, Foote consulted with Ontario Nature executive director Caroline Shultz, who agreed to move ahead with the proposal. DCH rejected this proposal in a letter dated Dec. 14.

According to PAP officials, to qualify for funding, the magazine would have to identify specific membership and subscription costs separately. This would mean removing the subscription price from membership fees. It also means that all subscribers who are also members would be not be counted as paid subscribers for PAP purposes. “I can launch a subscription drive—which costs money and time—and I can re-solicit their subscription. I’m not going to rely on chance,” Foote says. “It is very possible that I would get a very high response rate from that. But that would take time. And during that lull, I will have lost all the people who are both members and subscribers because they are automatically de-subscribed. I have to remove their subscription a re-solicit it.”

After she failed to make any headway with PAP officials, Foote gave up. “At this point it looks like I will be losing the subsidy,” she says. ON Nature’s final deadline will expire at the end of this month. “I think the original intent of the program is to support Canadian magazines that are available to the public. I should not have to be fighting with the DCH for months on end.”

For its part, DCH said: “We have been working with this client since May 2007 to illustrate ways in which they could meet our criteria and continue to qualify for funding. Our rules on association membership are applied to all magazines. If they choose not to make the changes we have outlined, this is their business decision.”

Asked whether a larger review of magazines is underway at DCH, a spokesperson replied: “As announced on December 13, 2006, by the Minister of Canadian Heritage, the Department of Canadian Heritage will examine its current periodical policies and programs to arrive at long-term solutions to ensure delivery of Canadian periodicals for all Canadians.  Further information on this review is forthcoming.”