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Independent public record

Scott Mills

Audio engineer and software engineer, Saskatchewan, Canada

Document
Public consultation submission
To
Innovation, Science and Economic Development Canada
Filed
20 September 2026
Window
23 July to 23 September 2026
Status
Public document. May be posted by ISED.

The finding

Present audio detection should not be the enforcement basis for a per-work labelling mandate. It performs well on clean, fully-generated tracks and degrades sharply on hybrid and post-processed material — which is precisely the case ISED's own discussion paper puts at the centre of this question.

The rest of the submission depends on that finding. Hybrid and post-processed music is the case the discussion paper names. Detection and watermarking do not hold there. Per-component attribution of a full-mix generator output is a category error: those systems never produce a per-instrument representation.

Who is submitting this

I am an audio engineer and software engineer in Saskatchewan. I have used generative music tools at high volume — thousands of tracks generated and released through commercial distribution — and I spent the past year attempting to verify, attribute, decompose, and transcribe the results, which is what produced the submission.

Until early 2026 I moderated a Suno practitioner community of approximately 50,000 members. I no longer hold that role. Observations drawn from that experience are labelled where they appear. I can describe what that population does with these tools, and I can serve as a research subject. I cannot convene it on the government's behalf, because I am no longer part of it.

Instruments named in the submission

Two of the tools described in the accompanying field report are public and inspectable.

  • tab-agent-pro

    Named in the submission. Public and inspectable. Audio-to-tablature for guitar and bass.

  • stem-midi-pro

    Named in the submission. Public and inspectable. Stem separation and MIDI from mixed audio.

Other public software

  • sgm-suno-workflow — REAPER scripts used in the volume practice described in the submission.
  • 30-agents — Self-hosted multi-agent orchestration. Public source.
  • apc-mcp — Build and test tools for audio plugin projects.

What I asked ISED to take from this

  1. Make the Code's detection commitment condition-specific, and publish accuracy by condition.
  2. Do not condition per-work labelling on per-component attribution of a full mix.
  3. Prefer process disclosure to decomposition.
  4. Require the stem-export disclosure from full-mix generators — one sentence, no new instrument.
  5. Keep training-data manifests in scope, and do not present them as per-output attribution.
  6. Add provenance loss to the incident categories, with a channel that accepts de-identified reports.
  7. Treat practitioners as an evidence source, not only as an audience.

Full argument, recommendations, and sources are in the submission.

Contact

I am available to appear, to provide data, to serve as a research subject, or to be contacted for follow-up.

scott@sgmstudios.ca

github.com/sgm-audio