Redefining Diversity in the 21st Century Media Universe Submission to the CRTC by the Canadian Association of Broadcasters Broadcasting Notice of Public Hearing CRTC 2007-5 Diversity of Voices Proceeding The goal of the CAB is to represent and advance the interests of Canada’s private broadcasters in the social, cultural and economic fabric of the country. A Submission to the Canadian Radio-television and Telecommunications Commission With respect to Redefining Diversity in the 21st Century Media Universe Broadcasting Notice of Public Hearing CRTC 2007-5 Diversity of Voices Proceeding and Broadcasting Public Notice CRTC 2007-41 Call for Comments on the Canadian Broadcast Standards Council’s Proposed Journalistic Independence Code Prepared by July 18, 2007 July 18, 2007 Via Epass Mr. Robert A. Morin Secretary General Canadian Radio-television and Telecommunications Commission Ottawa, Ontario K1A 0N2 Dear Mr. Morin: Re: Broadcasting Notice of Public Hearing CRTC 2007-5: Diversity of Voices Proceeding and Broadcasting Public Notice CRTC 2007-41 (PN 2007-41): Call for comments on the Canadian Broadcast Standards Council’s Proposed Journalistic Independence Code, The Canadian Association of Broadcasters (CAB) is pleased to offer the enclosed submission to the Commission, entitled “Redefining Diversity in the 21st Century Media Universe”, in which we provide comments in response to the Diversity of Voices Proceeding, Broadcasting Notice of Public Hearing CRTC 2007-5 (NPH 2007-5) and the Call for comments on the Canadian Broadcast Standards Council’s Proposed Journalistic Independence Code, Broadcasting Public Notice CRTC 2007-41 (PN 2007-41). The CAB requests the opportunity to appear at the public hearing. Sincerely, Original signed by Glenn O’Farrell President and CEO TABLE OF CONTENTS Preamble................................................................................................................................................1 PART I ..................................................................................................................................................2 Redefining Diversity in the 21st Century Media Universe.............................................................2 Executive Summary.........................................................................................................................2 Introduction .....................................................................................................................................5 An Holistic View of the Media Landscape................................................................................11 Diversity Cannot Be Narrowly Defined.....................................................................................14 i) Idea diversity.....................................................................................................................16 ii) Format diversity ...............................................................................................................18 iii) Demographic diversity ....................................................................................................19 A Competitive Marketplace Fosters Diversity ..........................................................................22 Competitive Metrics in Other Countries ...................................................................................27 Media Consolidation is a Response to Fragmentation.............................................................29 Public Policy Must Enhance the Competitiveness of Canadian Media Companies............32 The Proposed Journalistic Independence Code .......................................................................33 Conclusions ....................................................................................................................................34 PART II: CAB Responses to Specific Issues for Consideration ................................................35 Part III: Appendices............................................................................................................... 44 Preamble The Canadian Association of Broadcasters (CAB) is the national voice of Canada’s private broadcasters, representing the vast majority of Canadian programming services, including private television and radio stations, networks and specialty, pay and pay-per-view television services. The goal of the CAB is to represent and advance the interests of Canada’s private broadcasters in the social, cultural and economic fabric of the country. The CAB is pleased to offer this submission to the Commission, entitled “Redefining Diversity in the 21st Century Media Universe”, in which we provide comments in response to the Diversity of Voices Proceeding, Broadcasting Notice of Public Hearing CRTC 2007-5 (NPH 2007-5) and the Call for comments on the Canadian Broadcast Standards Council’s Proposed Journalistic Independence Code, Broadcasting Public Notice CRTC 2007-41 (PN 2007-41). This submission is in three parts: • Part I, in which we present our main arguments and commentary on key issues raised in NPH 2007-5 and PN 2007-41; • Part II, in which we offer detailed responses to specific questions raised in NPH 2007-5, and; • Part III (Appendices), in which we provide supplementary factual support and technical information, as follows: o Appendix A: Strategic Inc. – Report on Television, Radio, Internet and other Media Diversity in 2007 o Appendix B: CAB Backgrounder – Select International Media Ownership Rules The CAB requests the opportunity to appear at the public hearing to be held in connection with the Diversity of Voices proceeding. The CAB’s participation in the oral phase of this proceeding will enable a full examination of the position of the private broadcasting sector with respect to the Commission’s stated objective in conducting this proceeding, namely, to ensure that the Canadian broadcasting system provides Canadians with the greatest possible diversity of voices, including editorial voices. 1 PART I Redefining Diversity in the 21st Century Media Universe Executive Summary It is clear that the Internet, because of the proliferation of web sites, blogs, podcasts and diverse news sources, is having a profound effect on the diversity of opinion and news available to Canadians. [Hon. Beverley J. Oda, Minister of Canadian Heritage, to the Senate Committee on Transport and Communications, April 18, 2007] Ensuring media pluralism implies all measures that ensure citizens’ access to a variety of information sources, opinion, voices, etc. in order to form their opinion without the undue influence of one dominant opinion forming power. [Media Pluralism in the Member States of the European Union], Commission of the European Communities, Brussels, 16 January, 2007] 1. The Commission’s examination of Diversity of Voices in the broadcasting system is timely and appropriate in the wake of the radical transformation of the media content landscape in recent years. 2. By soliciting the views of the public and other interested parties, the Commission will be in a better position to bring clarity to an issue that has long been discussed and debated in Canada, and that currently is in need of critical re-examination. This is so, because the fundamental assumptions that underpin the Canadian broadcasting system have changed, irrevocably, as a result of the migration of the world of content to the new digital universe. 3. In this submission, the CAB identifies three key considerations that must influence the lens through which we measure and understand Diversity of Voices in its contemporary, 21st century context. (i) An holistic view of the media landscape is required 4. First, it is essential that any policy discussion be framed by an holistic view of the media landscape. 5. Diversity of Voices is invariably misunderstood when seen under a microscope applied to the regulated component of the media landscape alone, to the exclusion of everything else. There has been an unprecedented explosion of content choices within reach of contemporary Canadian audiences. These content choices are accessible across multiple platforms, many of them in what could be described as an unregulated, parallel media universe which competes with the regulated sector for audiences and advertising dollars. 2 6. Any discussion of Diversity of Voices in today’s media landscape must therefore bring the two parallel universes (regulated and unregulated) of content creation, distribution and consumption into sharp focus. In this context, it is clear that Diversity of Voices cannot be measured simply by counting up the number of regulated media outlets and dividing by the number of owners. Instead, we must assess Diversity of Voices across the entire range of content offerings, taking an holistic, platform-agnostic perspective. 7. The CAB submits that the regulated and unregulated sectors taken together offer a level of Diversity of Voices never seen before. Indeed, the level of diversity across the Canadian system is an example for other countries to emulate. (ii) Strong Canadian media companies, able to compete in the new environment, are needed 8. The second key consideration is the need for strong Canadian media companies that can compete effectively in the new media environment. 9. Audience fragmentation is a significant and irreversible fact, with concomitant impact on advertising revenues and the resource base available for production. Canada has developed a strong and competitive broadcasting system