Rogers Cable Communications Inc

Broadcasting Notice of Consultation CRTC 2009-661 Review of Community Television Policy Framework Submission of Rogers Cable Communications Inc. February 1, 2010 Table of Contents I. EXECUTIVE SUMMARY.................................................................................................... 3 II. COMMUNITY CHANNEL OBJECTIVES........................................................................... 6 III. THE CABLE COMMUNITY CHANNEL MODEL ........................................................... 21 a) The Existing Model Works and Must be Maintained........................................................... 21 b) Ownership of the Community Channel................................................................................ 23 IV. OTHER COMMUNITY-BASED TELEVISION UNDERTAKINGS................................ 25 V. THE POLICY IS WORKING .............................................................................................. 26 a) Funding for BDU-Operated Community Channels.............................................................. 26 b) Promotion of Access Opportunities...................................................................................... 28 VI. QUESTIONS AND ANSWERS ......................................................................................... 29 1. OBJECTIVES OF THE 2002 COMMUNITY TV FRAMEWORK................................... 29 a. General Objectives........................................................................................................... 29 b. BDU-Operated Community Channels ............................................................................. 32 c. Independently-Operated Community-Based Television Services ................................... 33 d. Direct-to-Home Satellite Services ................................................................................... 36 2. ACCESS PROGRAMMING............................................................................................... 38 3. FUNDING OF COMMUNITY PROGRAMMING............................................................ 40 a. Advertising....................................................................................................................... 40 b. Local Programming Improvement Fund.......................................................................... 43 c. BDU Contributions .......................................................................................................... 44 4. NEW TECHNOLOGIES..................................................................................................... 48 a. VOD ................................................................................................................................. 48 b. New Media....................................................................................................................... 49 c. Official-Language Minority Communities (OLMCs)...................................................... 51 d. High-Definition Content .................................................................................................. 52 2 I. EXECUTIVE SUMMARY 1. Rogers Cable Communications Inc. (Rogers) believes that a review of the Commission’s policy framework for community television is an important exercise and is pleased to provide comments in reference to Broadcasting Notice of Consultation CRTC 2009-661.1 As with other elements of the Canadian broadcasting system, community programming must evolve if it is to remain relevant to Canadians and continue to play an important part of the Canadian media landscape. While the existing policy has been a great success – due in large part to the CRTC’s policy changes of 2002 – this is an opportunity to assess the framework in the larger context of the entire broadcasting system. 2. The Broadcasting Act (the Act) makes two references to community broadcasting. Section 3(1)(b) states that: “the Canadian broadcasting system, operating primarily in the English and French languages and comprising public, private and community elements, makes use of radio frequencies that are public property and provides, through its programming, a public service essential to the maintenance and enhancement of national identity and cultural sovereignty”. Section 3(1)(l)(iii) notes that “the programming provided by the Canadian broadcasting system should…include educational and community programs.” 3. Forty-three years ago, the cable industry pioneered the concept of community access programming. We did not do this at the insistence of the government or the Commission. Rather, we recognized that a community channel plays an important role in providing our customers with an opportunity to express themselves and to connect with their neighbours. Since 1969, Rogers has shown unwavering commitment to community programming in the markets that we serve. Our 34 community channels, which are referred to as Rogers TV, serve as a vital outlet for truly local expression. Indeed, in many of the markets we serve in Ontario, New Brunswick and Newfoundland, Rogers TV is the only television outlet for local expression. We fill a void in communities where conventional television has either never operated or has reduced or eliminated local programming in recent years. 4. In 2002, the Commission set out an integrated policy framework for community- based media2 (the Policy) with the following core objectives: to ensure the creation and exhibition of more locally-produced, locally- reflective community programming; and 1 Broadcasting Notice of Consultation CRTC 2009-661 – Review of Community Television Policy Framework, dated October 22, 2009 (http://www.crtc.gc.ca/eng/archive/2009/2009-661.htm) (BNC 2009-661). 2 Broadcasting Public Notice CRTC 2002-61 – Policy framework for community-based media, dated October 10, 2002 (http://www.crtc.gc.ca/eng/archive/2002/pb2002-61.htm) (BPN 2002-61). 3 to foster a greater diversity of voices and alternative choices by facilitating new entrants at the local level. 5. Further, the Commission reiterated specific roles and objectives for cable community channels. Since the Policy was established, Rogers’ community channels have met and often exceeded the Commission’s expectations. Since 2002, Rogers TV has produced 103,915 hours of original, local programming, and 135,387 community groups have accessed our channels to participate directly in the community programming process. 6. Rogers is very proud of these achievements. In meeting and, in many cases exceeding the objectives of the Act and the Commission’s Policy, Rogers TV has made immense contributions to the broadcasting system and, most importantly, to the communities we serve. 7. In the 2008 Diversity of Voices policy,3 the Commission stated its intention to review the Policy with the objective of ensuring that it continues to support the development of a healthy community broadcasting sector. The Commission also observed that stable funding was important in supporting the production of quality community programming. 8. In Section II of our submission, we outline how Rogers TV has embraced each of the Commission’s objectives under the Policy, establishing a local presence that is more relevant to members of the communities we serve than ever before. Some parties have recently called for an “open access” community television model that would exclude the participation of cable companies. In Section III we challenge that position and discuss how the coordinated access model, which has been the hallmark of successive Commission policies, strikes the right balance between maximizing direct community access to the television lineup and producing programming that is of high standard. Cable companies have long demonstrated their commitment to the production and presentation of quality community programming that complies with broadcasting industry codes, as well as the Commission’s policies on prohibited content. In Section IV, we discuss the policy for other community-based television undertakings. 9. Throughout this document, Rogers demonstrates that the Policy works. We also demonstrate that few changes are required to the Policy. In Section V, we propose a small modification in how cable companies are to promote the availability of access programming opportunities that enhances the intent of this objective. We also underline that in order to maintain the success that has been achieved to date, it is imperative that the Commission continue to provide cable community channels with an appropriate level of funding at 2% of broadcasting distribution undertaking (BDU) revenues. The Commission’s Policy, particularly the 2% funding mechanism, has been a success story and enables BDU-operated 3Broadcasting Public Notice CRTC 2008-4 – Diversity of Voices, dated January 15, 2008 (http://www.crtc.gc.ca/eng/archive/2008/pb2008-4.htm) (BPN 2008-4), paragraphs 169-173. 4 community channels to operate as effective providers of true local programming in hundreds of communities across Canada. 10. Finally, in Section VI, Rogers addresses the Commission’s specific questions. In the course of providing our answers, we set out our position on a number of key issues that can be summarized as follows: Rogers believes that provided that funding for community channels remains at the existing level of 2% of gross broadcasting revenues, the Commission should maintain its policy on advertising. The continued stable funding provided by the 2% BDU contribution, combined with the current use of credit, sponsorship or contra messages as promotional

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