Submission to the CRTC 2007-10: Keep Community TV in the Basic Cable Package

Here is a copy of my submission to the CRTC's call for comments about removing community television from the basic cable package. The deadline for submitting comments was today. Michael Lithgow

PS. The IMAGE accompanying this blog is from the poster for Too Art for TV, Too.

CRTC October 19, 2007
Ottawa, Ontario K1A 0N2

Re: CRTC 2007-10 / 2007-10-2

1. I do not want to appear at the hearing.

2. In paragraph 73 the Commission writes that it “considers that it might be appropriate to eliminate the regulatory requirement that the community channel, if offered, be distributed as part of the basic service” and asks for comments.

3 I want to strongly urge the Commission to maintain the current regulatory requirement that the community channel, if offered, be distributed as part of the basic service.

4 Community access television was created in Canada as a way for cable companies to contribute to Canadian culture in return for privileges awarded through telecommunications policies, privileges that have allowed them to grow into some of the largest and most profitable companies in Canada, and into competitive and profitable participants in global markets.

5 The community channel, from its inception, was also intended to play a critical role in the Canadian broadcasting system – in fact, the third part of a three sector system alongside private and public broadcasting, as delineated in s. 3 of the Broadcast Act.

6 The community channel is recognized in s. 3 of the Broadcast Act because of its ability to do what neither the private nor the public aspects of the Canadian broadcasting system can do: namely, allow Canadians to participate in cultural expression through the important medium of cable television and ensure that local expression makes up a part of the cultural reality of Canada’s broadcast system.

7 The Commission has recognized over the years -- and it is widely recognized among experts in telecommunications in Canada - that the private and public aspects of the broadcasting system are structurally disposed to certain kinds of exclusions; that is, there are aspects of Canada’s diverse cultural reality that do not appear in the commercial broadcasting system. Perhaps most glaringly, there is a chronic and ongoing lack of local cultural and public affairs programming. Commercial broadcasters and the public broadcaster consistently make cuts from local coverage first. It is expensive to produce: broadcasters’ economies of scale make it attractive to produce programming centrally and re-distribute geographically. One regional newscast reproduced a dozen times is much less expensive to organize than a dozen local news casts.

8 And while such a model of centralized regional programming serves the needs of broadcasters, Canadians and the Commission must ask if this serves the needs of Canadians. Are broadcaster needs synonymous with community needs, when it comes to the Canadian broadcasting system?

9 Community television is recognized as the third pillar in the Canadian broadcasting system because it provides a solution to this structural problem. If broadcaster economies favour centralized regional programming and dis-favour local cultural expression, then community television provides a system-wide balancing mechanism than ensures that Canadians will have access both to the means of contributing to Canadian culture through broadcast and cable technologies and also to viewing and consuming local and diverse forms of cultural expression.

10 Community access television is not a specialty channel – it has a different legislative history whose roots are found firmly in the public policy concern for balance and diversity within the Canadian broadcasting system and mass media’s role in Canadian democratic society. This is altogether different from, say, the pet channel or science fiction channel. People watch community programming largely because it is there – they discover it when flipping through the dials, and are pleased or surprised or intrigued by the unique form and local content of what makes up most community programming.

11 Specialty channels attract viewers by competing in commercial markets using the tools of market competition, i.e. marketing and promotion. Community access channels do not have the resources or the expertise to promote their services, nor would this be an appropriate use of community channel money – resources that are earmarked to facilitate community participation. The point of community access television, what makes it the third pillar of the Canadian broadcast system, is that it is not organized within the commercial framework. Community programming is intended to complement not replicate commercial programming. If community television is required to compete on commercial terms, it will inevitably come to resemble commercial programming. Community television serves the structural weaknesses in the commercial framework that tend to result in the exclusion of local reflection and expression, and to narrow the cultural and social diversity that eventually makes its way into programming.

12 The removal of the community channel from the basic cable package (where offered) will for all intents and purposes restructure community access television into community specialty television. Mass distribution is the cornerstone of community access television’s effectiveness in maintaining healthy and diverse informational and cultural flows of local expression in the Canadian broadcasting system.

Thank you.

END OF DOCUMENT