Mr. Robert A. Morin
Secretary General
CRTC
Ottawa, ON
K1A 0N2

Dear Mr. Morin:

1. Friends of Canadian Broadcasting welcomes the opportunity to comment as part of the Commission’s review of policies for community television.

2. Friends wishes to express concern that an invaluable study Community Television Policies and Practices Around the World by TimeScape Productions,¹ which the Commission placed on the public file on December 1, 2009 was subsequently withdrawn from the public file in response to representations from licensees of broadcasting distribution undertakings (BDUs) alleging ‘conflict of interest’.²

3. We note that a similar research report commissioned in 2007 and placed on the public record as part of the Commission’s review of regulatory frameworks for broadcasting distribution undertakings and discretionary programming services by Laurence Dunbar and Christian Leblanc paid tribute to the legal counsel to Rogers Communications “for his guidance throughout the project, the contributions he made to the report and for sharing his knowledge of the Canadian broadcasting sector with us.” They added that this person “was indispensable to this project and worked tirelessly to help see the report to fruition”. ³

4. Anyone is free to allege conflict of interest regarding any report which the CRTC commissions and places on its public file. However, the Commission is under an obligation to evaluate such claims judiciously and to make its decisions in a consistent fashion.

5. As the TimeScape report documents, Canada has moved from a world leadership role in community television to a position where, with a few exceptions, community TV has been purloined by cable monopolies intent on using their editorial control of content as a marketing tool in their respective territories. The result: the Canadian public has been progressively excluded from community television production in most parts of Canada.⁴

6. Friends endorses the arguments of the Canadian Association of Community Television Users and Stations (CACTUS) submission Putting the Community Back into Community Programming.

7. This entails returning to community control, non-commercial sources of funding and re-directing regulatory-controlled funds to independent production funds. We endorse CACTUS’s analogy of community televisions stations to public libraries and its insistence that a community station should be available in all towns with over 10,000 population, of which there are 171 in Canada. We note that such coverage would reach approximately 90% of Canadians.

8. Even if cable were required to respond to community needs and community control, its penetration rate is low enough to exclude one in three Canadians from enjoying community television. We therefore support CACTUS’s call for the Commission to ensure frequency allocation for community television in the digital transition.

9. Public policy should ensure that community channels operate under community control as already exists in Canadian community radio, and in many other democratic countries. That this is Parliament’s intention is clear from Section 3(1)(b), (e) and (i)(iii) of the Broadcasting Act.

10. Friends also supports CACTUS’s proposal that the $116 million currently spent by cable on “community channels” should be re-directed to a community access media fund to which communities could apply.

11. As CACTUS notes, “if you are a cable customer, you already pay for community expression on your cable bill”.⁵

Yours sincerely,

Spokesperson
Ian Morrison

For information: Jim Thompson 613-447-9592

¹ http://www.friends.ca/news-item/9132

² BN of Consultation CRTC 2009-661-2 (December 1, 2009) & BN of Consultation CRTC 2009-661-3 (January 6, 2010).

³ http://www.crtc.gc.ca/eng/archive/2007/n2007-10-1.htm

⁴ A significant exception is the Province of Saskatchewan.

⁵ http://cactus.independentmedia.ca/node/401