Brief
Response to CRTC Notice 2001-3 Regarding TV Station Renewal Applications
March 2001
Via E-Mail: procedure@crtc.gc.ca
Ms. Ursula Menke,
Secretary General
Canadian Radio-television and Telecommunications Commission
Ottawa, Ontario K1A 0N2
Re: Notice of Public Hearing CRTC 2001-3 Licence renewal applications for various television stations owned by CTV Inc.
Dear Ms. Menke:
- The National Federation of the Blind: Advocates for Equality ( NFB:AE) is pleased to file the following comments in response to the above-noted licence renewal applications of CTV Inc. (CTV).
- The NFB: AE is a national organization of blind, deaf-blind and vision-impaired Canadians, along with parents of blind children and other sighted persons who support our work. Founded in 1992, the NFB:AE's work focuses on advocacy and public education to expand the rights and opportunities for all blind, deaf-blind and vision-impaired Canadians to participate fully in all aspects of Canadian society. The NFB: AE has submitted briefs to this Commission in prior proceedings dealing with cable rate increases sought by NBRS, the BCE Purchase of CTV, an amendment to a license held by Pelmorex and a request for funding by CNIB to support telephone access to Its Information Centre for the Blind. The NFB: AE has also submitted materials and made presentations to a number of administrative tribunals and government departments on a number of other issues.
- In Public Notice CRTC 1999-97, The Commission expressed its expectations regarding the introduction of DVS programming and the obligation of television broadcasters in Canada to meet the unique needs of Canadians with vision impairments: "Licensees are strongly encouraged to adapt their programming to include audio description wherever it is appropriate and to take the necessary steps to ensure that their customer service responds to the needs of the visually impaired."
- The NFB:AE submits that it is timely and in the public interest for the Commission, by Condition of Licence renewal, to require CTV to broadcast four (4) hours each week of Canadian described (DVS programs) in Peak Viewing Time beginning in the first year of this renewal period, and that one additional hour ofDVS programming be added in each succeeding year of this licence renewal period.
- The NFB:AE further submits that all Canadian television networks should be required to broadcast the described versions of programs from other countries whenever they contain a described version.
- The NFB:AE requests the opportunity to appear at the public hearing to support our call for specific commitments by CTV to broadcast DVS programming.
- Why is the NFB:AE requesting the Commission to require described video as a condition of further licence renewals? Television provides a broad range of information and entertainment to Canadians. Currently, persons who are blind or otherwise vision-impaired are often denied the full benefits of such programming due to the visual nature of some of its content. The purpose of DVS is to minimize the effect of this current barrier that blind and vision-impaired Canadians currently face in accessing the same range of information as others who are able to see the television screen. DVS provides audio description of key visual elements in programming inserted into natural pauses in the audio track of a program. It is designed to make television programs more accessible to the many Canadians who have vision disabilities, and all Canadians should have this access.
- The NFB:AE believes that it is in the public interest that all of Canada's English- and French- language television networks, Class 1 cable distributors and DTH distributors be required, as a condition of any future licence renewals, to broadcast and distribute DVS programming.
- The NFB:AE submits that the broadcast of 4 hours per week of described Programming in Peak Viewing Time during the first year of this licence renewal period would represent a good start towards achieving the objectives of the Broadcasting Act.
- The NFB:AE submits its proposals are reasonable and economically feasible given the availability of described video services through the National Broadcast Reading Service (NBRS), As a result, in great measure, of the BCE/CTV benefits monies designated for NBRS and video description.
- The NFB:AE believes the inclusion of video description should make such Canadian programming more attractive for resale to the U.S. market, where Video described programming will soon be a requirement.
- In conclusion, the NFB:AE wishes to reiterate its recommendation that the Commission require all major television broadcasters in Canada to include an increasing level of DVS programming in their schedules.
Respectfully submitted by:
Robert J. Fenton, President,
National Federation of the Blind: advocates for Equality
cc: Ms. Trish McQueen, President and CEO
CTV Inc.
tmcqueen@ctv.ca
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