Re: PN CRTC 2012-0509-7 CBC Analog Transmitters

Jun 18, 2012

Mr. John Traversy
Secretary General
Ottawa, ON
K1A 0N2

Dear Mr. Traversy:

  1. Friends of Canadian Broadcasting is an independent watchdog for Canadian content supported by 175,000 Canadians. Friends is not affiliated with any broadcaster or political party.
  2. Over-the-air (OTA) analog television connects 9.7% of Canadians to our television system:
  3. Among OTA viewers, CBC Television is the most popular station:
  5. And CBC Television is judged to offer the best local news:
  7. Hence the Commission should ask CBC tough questions about their audience claims, in particular their claim that 7% of Canadians have tuned out of television and have no TV.
  8. The programming offered by CBC is intended by statute to be accessible to the greatest possible number of Canadians. As CACTUS has pointed out, the purpose of CBC programming is different from that of specialty channels. Its goal is universal access.
  9. Friends deplores CBC's decision to cut off free OTA service to large numbers of Canadians who pay taxes and thus support CBC's services. Those left out are in the majority rural Canadians, among them the most disadvantaged in cultural and economic terms.
  10. CBC asserts that cutting off service to these Canadians will save it $10 million annually, about 1% of its parliamentary allocation. This is a small price to pay to satisfy the Broadcasting Act's requirement that its services "be made available throughout Canada by the most appropriate and efficient means and as resources become available for the purpose".
  11. It is a gross misinterpretation of "efficiency" to require rural and smaller-city Canadians to subscribe to a costly variety of television services in order to receive the programming of their national public broadcaster.
  12. Nor has CBC informed its viewers of this impending loss or the present proceeding.
  13. The Commission should require CBC to inform its audience of this impending loss of service and should defer a decision on the application for five months until the Corporation's network licences are reviewed.
  14. The Commission should also require CBC to make any surplus facilities available for public use along the lines demonstrated recently by TVOntario in similar circumstances.

Yours sincerely,


cc: CBC

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