MAC CRTC Submissions

MEDIAC 2009-614 final reply

18 December 2009

Mr. Robert Morin
Secretary General
Canadian Radio-television and
Telecommunications Commission
Ottawa, Ontario
K1A 0N2

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Dear Secretary General

Re: Broadcasting Notice of Consultation CRTC 2009-614

Thank you for the opportunity for MEDIAC INC. to follow-up on questions asked during our appearance at the public hearings on 11 December 2009.

1. MEDIAC INC. is a Canadian accessibility specialty firm providing research, analysis, standards development and marketing services in the communications, entertainment and cultural industries. We made both written and verbal submissions in the December proceeding.
2. During our appearance before the Commission, Chairman von Finckenstein asked how much Canadians would or should be prepared to pay in order to retain their local television services.
3. In our view, neither consumers in general nor Canadians with accessibility issues should have to pay additional fees to retain their local television services. First, BDUs should absorb such fees as part of their costs of doing business. Second, Canadians already pay for their local television services directly through Parliamentary appropriations for the CBC, and indirectly through TV advertising (as the costs of TV advertising are passed through to those who buy the goods and services being advertised; and because TV advertising imposes non-financial costs on TV audiences who must accept the advertising so as to receive the 'free' TV content).
4. Nevertheless, the evidence on the record of this proceeding clearly establishes that our existing television system requires direct intervention from the CRTC in the shape of additional revenue streams.
5. The CRTC's licensing of hundreds of new television programming services since the late 1980s has fundamentally altered the over-the-air TV business model first introduced half a century ago. Canadians who rely on their local television services not just for daily news and entertainment, but also for emergency notifications, simply cannot risk the loss of yet more TV stations because of changes in the business model of TV which were brought about by the CRTC.
6. MEDIAC therefore recommends that the federal government direct the CRTC to resume more direct supervision and regulation of BDU rates, as it is clear from BDUs' significant rate increases in the last decade that competition in this sector has still not yet progressed to the point where marketplace competition between BDUs restrains price increases. Meanwhile, competition in the TV sector has progressed past the point where local TV stations have been shuttered. By regulating basic service rates the CRTC would ensure that BDUs do not merely pass through rates increases purely to generate additional profits, and that Canadians' ability to pay is respected.
7. MEDIAC also recommends that the federal government direct the CRTC to provide over-the-air TV broadcasters with access to a value for signal negotiation regime, and we support the Chairman's suggestion of a $0.25 per signal, per subscriber monthly fee as we assume that the Commission has evidence to justify this figure.
8. However, MEDIAC also recommends that the federal government ensure that $0.05 per signal, per subscriber, per month be allocated to an accessibility fund, to ensure that all Canadians - with or without accessibility issues - are able to access the over-the-air programming services for which they would now be paying. We note that the creation of this fund would ensure that Canadians receive more accessible for their monthly subscription fees, than they do now, and would also benefit TV broadcasters and BDUs by providing them with information and tools to improve the quality and quantity of the accessible content they must provide to Canadians.
9. MEDIAC therefore asks that the CRTC report to the federal government our recommendation that it should direct the Commission to establish a fund to
   1. Establish and maintain open/non-proprietary best practices for the production of accessible content
   2. Coordinate collaboration of industry stakeholders to increase levels accessible programming content
   3. Create and implement marketing plan for an accessible Canada the puts Canada in the international arena
   4. Participate in technical standards development, and work toward international and national harmonization of accessible production standards through engineering and standards development committees
   5. Educate and support consumers with accessibility issues about the analog-to-digital transition, and convergence between broadcasting and telecommunications
   6. Receive and respond to accessibility-related complaints
   7. Audit the descriptive video and closed-captioning production industry, and certify accessible content production houses
   8. Work with tools developers
   9. Provide quantitative and qualitative reports on accessibility in Canadian programming
   10. Broker, on behalf of the broadcasting industry, government and independent producers, large volume content buys through RFP's for volume discount.
   11. Assist in identifying and supporting the creation of access content production tools for multi platform distribution
   12. Work with academic institutions to develop curriculum for captioning and descriptive video writers and editors, and
   13. Advise government, CRTC and others on key issues related to accessibility in broadband industry
10. Challenging times such as these offer the best opportunities for change that can benefit all Canadians, and all industry sectors.
11. MEDIAC therefore invites the CRTC to use this proceeding to report to the government about the fundamental necessity of policies, standards, compliance methodologies, liaison and support that consumers and producers require to ensure the availability of high-quality accessible content. Our no-cost proposal for funding an accessibility monitor will ensure that all Canadians - not just those with excellent hearing and vision - can access our broadcasting system.

Thank you for allowing MEDIAC INC. and other parties to provide their final recommendations in this proceeding. Should the CRTC require additional information about the accessibility fund proposed by MEDIAC, for the purposes of its report to the Governor in Council, MEDIAC INC. would be happy to provide this information.

Sincerely yours,

[original signed by]

Beverley Milligan
President and CEO
MEDIAC INC.
110 Pricefield Road
Toronto, ON
M4W 1Z9
416-488-9521 [tel]