20 February 2020 Mr. Claude Doucet Secretary General Canadian Radio
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20 February 2020 Mr. Claude Doucet Secretary General Canadian Radio-television and Telecommunications Commission Ottawa, Ontario K1A 0N2 Broadcasting Notice of Consultation CRTC 2019-379 Submitted electronically: CRTC Intervention Comment Form Dear Mr. Doucet, 1. This is the submission of ACTRA in the matter of the renewal of the licences of the Canadian Broadcasting Corporation/Société Radio-Canada. ACTRA wishes to appear at the public hearings to present its views, to address matters raised by other intervenors and to engage with the Commissioners. 2. ACTRA brings to this process the perspective of over 25,000 professional performers working in the English-language recorded media sector in Canada. For more than 75 years, ACTRA has represented performers living and working in every corner of the country who are pivotal to bringing Canadian stories to life in film, television, videogames, sound recording, radio and digital media. EXECUTIVE SUMMARY 3. ACTRA is strongly supportive of the CBC. ACTRA is encouraged by the CBC’s most recent efforts to keep itself relevant in the digital world, including a robust website and the launch of its streaming service, Gem, and to reflect the needs of a richly diverse and scattered population that speaks many languages. ACTRA fully supports CBC efforts to achieve gender equality. ACTRA urges the CRTC to require the CBC to provide detailed financial and other information about all facets of its operation and programming to allow Canadians to track the CBC’s progress against these, and other, objectives. 4. ACTRA believes the CBC can and should do more, particularly as we deal with the shift to online on-demand consumption of cultural content and the continuing erosion of the traditional broadcasting model. The CBC should have a singular focus on providing high- quality and distinctive Canadian programming content. Alliance of Canadian Cinema, Television and Radio Artists ACTRA National Office Affiliated with the Canadian Labour Congress (CLC) 625 Church Street ∙ Suite 300 ∙ Toronto ON M4Y 2G1 and the International Federation of Actors (FIA) Toll free 1-800-387-3516 ∙ Tel (416) 489-1311 Branch Offices: Vancouver ∙ Calgary ∙ Regina ∙ Winnipeg Fax (416) 489-8076 ∙ E-mail [email protected] ∙ www.actra.ca Toronto ∙ Ottawa ∙ Montreal ∙ Halifax ∙ St. John’s 5. Of most particular concern to ACTRA is the CBC’s obligation to drama and scripted comedy, the type of programming most underrepresented in the Canadian system, but most needed for cultural reasons. 6. With respect to Programs of National Interest (PNI), ACTRA supports the CBC’s proposal to increase its obligation to 10 hours per week and to acquire at least 80 per cent of it from independent producers. If appropriate rules can be developed for an online release, including an audience metric or threshold, and to confirm the CBC has a substantive involvement in its production, ACTRA is prepared to agree to the CBC having flexibility, for the additional one hour of PNI, to release it on its linear television service or online. ACTRA opposes the CBC’s request to eliminate the requirement that at least two hours of its weekly PNI obligation must be devoted to each of category 7 and category 2(b). 7. With respect to the CBC’s children and youth programming, ACTRA supports the CBC’s proposal to change the definition of child to someone under 13 years of age. ACTRA opposes the CBC’s request to reduce its programming aimed at children/youth. Further, ACTRA urges the CRTC to require the CBC to provide a minimum of 64 hours per year of original Canadian programming aimed at children or youth. Of this total, 12 hours per year may be released on the linear service or online, subject to the implementation of an appropriate audience metric/threshold and investment criteria for the online release. ACTRA supports the proposal that 80 per cent of children’s and youth programming be from independent producers. 8. With respect to the CBC’s local/regional programming obligations, ACTRA urges the CRTC to retain the CBC’s 14 hour per week local/regional programming obligation in metropolitan markets and to retain the requirement that a minimum of one hour each week of this programming must be non-news or information. ACTRA urges the CRTC to retain the CBC’s seven hour per week local/regional programming obligation in non- metropolitan markets. ACTRA further urges the CRTC to require the CBC to provide an additional one hour of programming each week in both metropolitan and non- metropolitan markets, which programming may be scheduled on its linear service or released online, subject to agreement on an appropriate audience metric/threshold. 9. ACTRA soundly rejects the suggestion the CRTC should consider regulating the programming activities of the Corporation in a manner that focuses solely on the provision of content via traditional television and radio services. GENERAL COMMENTS 10. Arising from concerns about U.S. radio broadcasters expanding into Canada, the Canadian Radio Broadcasting Commission (now CBC) was established in 1936. Speaking in support of its creation, Conservative Prime Minister R.B. Bennett said: “This country must be assured of complete Canadian control of broadcasting from Canadian sources. Without such control, broadcasting can never be the agency by which national consciousness may be fostered and sustained and national unity … strengthened.” 11. Almost 85 years later, we face the same challenge. Canadians enjoy a limitless supply of audiovisual content from around the world, on all of our screens, particularly from our much larger southern neighbour with whom most of us share a language and cultural reference points. The key question today is: how do we ensure Canadian stories, music and entertainment; local, regional and national news and information; as well as our perspective on global events, are provided to Canadians wherever they are and however they access their cultural content? The CBC was created in 1936 to address this challenge and continues today to be a critical part of the answer. 12. ACTRA and the CBC have grown up together. ACTRA’s roots can be traced to the announcers engaged by CBC radio in studios across the country beginning in the early 1940s. As television came on the scene in the next decade, ACTRA organized and represented the actors, hosts, singers, announcers and other performers the CBC needed to bring programming to the airwaves. Historically, ACTRA’s collective bargaining agreements negotiated with the CBC set the standard for all other broadcasters and producers. Many of the personalities and stars the public associates with the CBC over the decades were, and continue to be, ACTRA members. 13. As the industry has changed so too has our relationship with the CBC. Most importantly, as broadcasters began to commission programs from Canada’s developing independent production sector, rather than producing them in-house, ACTRA’s Independent Production Agreement (IPA) supplanted the CBC television agreement as the most important in our industry. The IPA now establishes the rates, use rights and working conditions for most of those engaged to speak into the microphone or to appear before cameras in the English-language Canadian dramas, comedies, public affairs, documentaries and entertainment programming content you find on your television, cinema and digital screens. 14. While we have had our disagreements over the decades, ACTRA remains strongly supportive of the CBC. ACTRA is encouraged by the CBC’s most recent efforts to keep itself relevant in the digital world, including a robust website and the launch of its streaming service, Gem, and to reflect the needs of a richly diverse and scattered population that speaks many languages. ACTRA fully supports CBC efforts to achieve gender equality in all facets of its operations and programming. 15. ACTRA, however, believes the CBC can and should do more. Particularly as we deal with the continuing erosion of the traditional broadcasting model, a central element of which is the acquisition and scheduling of foreign programming, specifically from the U.S., by Canadian broadcasters. Broadcasters obtain substantial advertising revenues from this programming that they use to subsidize the acquisition, production and distribution of Canadian content. 16. In the digital era, the CBC can and must remain relevant. This means it must focus on its core mandate, which is making and acquiring high-quality Canadian programming of all kinds and making that programming available to Canadians regardless of the technologies we use to consume that content. The CBC must focus on Canadian stories, entertainment and music, as well as our local, regional and national news, and our perspective on global events. 17. In this day of virtually unlimited access to the best content the world has to offer, the CBC should have a singular focus on Canadian content. This does not preclude it from engaging with the rest of the world. The CBC should offer our programming to audiences everywhere, so others can learn about us and our perspective on world events. The CBC should work with foreign partners to bring Canadian stories to life or bring us excellent foreign programs offering a unique global perspective. But the CBC should not be in the business of bringing us programming from abroad that is otherwise readily available. Funding 18. Given the geographical breadth of Canada, the need for it to operate in English, French and Indigenous languages, and the need to be locally, regionally and nationally relevant, funding is a key challenge, even with the budget increase announced by the Liberal government in 2016 and its more recent commitment to do more. 19. ACTRA was extremely disappointed the CRTC’s study of other public service media (PSM)1 did not include comparative information about the source and amount of funding other PSM receive from public and private sources.