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CRTC 2010 License Renewals

Monday, February 7, 2011

BRIEF TO: The Canadian Radio-television Telecommunications Commission(CRTC)

RE: Licence Renewals and Amendments from:

  1. CTV globemedia Inc. 2010-1261-6
  2. Shaw Media Inc. 2010-1307-8
  3. Corus Entertainment Inc. 2010-1350-8
  4. Shaw Cablesystems Limited 2010-1306-0
  5. Rogers Broadcasting Limited 2010-1253-3

As contained in Broadcasting Notice of Consultation CRTC 2010-952-1

February, 2011


The applicants to this proceeding are many of Canada’s largest communications companies. As such, they must be leaders in promoting and delivering full accessibility for all Canadians, including Canadians who are blind, deaf-blind or partially sighted. While these applicants have built various plans for expanding audio description into their proposals, the AEBC believes the CRTC must require more be done, and we request the opportunity to appear at the public hearing to further outline our position.


The Alliance for Equality of Blind Canadians / L'Alliance pour l'égalité des personnes aveugles du Canada (AEBC) is a national organization of rights holders who are blind, deaf-blind and partially sighted who have come together to speak for ourselves. The work of the AEBC focuses on improving public attitudes and providing input on public policy issues affecting members of our community. For further background on the philosophy and work of the AEBC, please visit our website at:


Audio Description (AD) is additional verbal narration which explains what’s happening visually on screen during television, movies, DVDs or live performances. Delivered during gaps in the dialogue, this can include description of scenes, settings, costumes, body language, facial expressions and ‘sight gags’ – anything that is important to a more complete appreciation of what is happening in the performance. With AD a person who has significant vision loss gains a greater appreciation of a show's content, and can share entertainment experiences with family and friends, without having to ask ‘What happened?’


Persons with disabilities believe we are our own best spokespersons, as we who live our own disability know our needs and aspirations best. The current television industry working groups do not contain a majority of people with disabilities, or experts who are mandated to properly represent our interests. As a result, we are often forced to fight hard to get our point of view heard and incorporated. The process is not collaborative or consistent with the priorities of the disabled community or the coalition being spearheaded by Access 2020 of which AEBC is a participant. The AEBC believes going forward, that the work of standards and best practices should NOT be led by the television industry, but rather, by a more collaborative process involving rights holder organizations and Media Access Canada, whose sub-committees are currently collaborating with the television industry. AEBC currently participates on their Descriptive Video Production and Presentation Best Practices Sub-committee, and expects this Sub-Committee will publish a draft DV best practices by end of May 2011. Further, once the MAC sub-committees are fully funded, AEBC would be able to participate more fully on additional sub-committees that will impact 100% accessibility for blind Canadians by 2020.


Back in 1981, the United Nations spearheaded the International Year of the Disabled Person under the forward-looking theme of "full participation and equality." Even a cursory examination of the history of Canadians with disabilities - and Canadians with disabilities do have a history - reveals clearly that reliance upon the voluntary approach and the marketplace has failed us and our needs, continues to fail us and, thus, there is no reason for us to expect a miraculous turnaround to this ongoing trend. This is partly due to the industry's refusal to work collaboratively with the disabled community. As a result, we are forced to turn to, and rely upon the CRTC and other regulatory bodies to help us achieve the elusive goal contained in the motto of the IYPD.


The UN Convention on the Rights of Persons With Disabilities (CRPD), Canada's Charter of Rights and Freedoms, and the Canadian Human Rights Act all support full and equitable access to Canadian society for individuals with various disabilities. As such, the AEBC believes the CRTC must take a more proactive approach and make increased use of its regulatory authority to help make all telecommunications programming and services fully accessible, including audio description of all television programming, whether over-the-air, by satellite or online regardless of the financial circumstances of the licensee or its licensed undertakings. This must be accomplished within a specified period of time not to exceed 10 years.


  1. The CRTC require as a condition of licence for each applicant an increase in accessibility to all its programs and services in an incremental manner to guarantee the achievement of 100% accessibility, including full audio description, by 2020 on all stations and in all programming, both regular and specialty channels;
  2. Provide fully accessible web sites including television programs that are fully described and captioned;
  3. The CRTC require as a condition of licence the submission of annual report cards on increased accessibility, that will include annual monitoring of quality and levels of accessible program content;
  4. Improve accessible content production technology to reduce accessibility costs; 5 Increase Curriculum development for students who want to learn how to closed caption or audio describe programs, including with digital environments;
  5. Establish an Accessibility Trust Fun run by the accessibility community and accessibility experts. The Fund's income would be specifically dedicated to accessibility activities;
  6. The CRTC require as a condition of licence that broadcasters work collaboratively with the disabled community, especially rights holder organizations such as the AEBC in the implementation of full accessibility within the next 10 years.


The broadcasting industry, including all regulatory bodies, has had many, many years to make television fully accessible to all Canadians, including Canadians with disabilities. Existing approaches haven’t worked. Canada’s disability community believes it's time the broadcasting sector stopped making excuses for its failure to discharge its moral and legal obligations, and work with us in a fully collaborative manner to bring about full accessibility within a specified period of time, not to exceed 10 years. we must accelerate the pace moving more quickly towards attaining full inclusion, so that 100% access, including full audio description, is in place no later than 2020. We call upon the CRTC to use its regulatory authority to help make this a reality. Our time has come!

Copies to:

CTVglobemedia Inc.
299 Queen Street West
Toronto, ON M5V 2Z5

Shaw Media Inc.
121 Bloor Street East
Suite 1500
Toronto, ON M4W 3M5

Corus Entertainment Inc.
Corus Quay
25 Dockside Drive
Toronto, ON M5A 0B5

5125 Steeles Avenue West
Toronto, ON M9L 1R5
E-Mail: and

Shaw Cablesystems Limited
102- 10th Street
Keewatin, ON P9X 1C0

Rogers Broadcasting Limited
333 Bloor Street East
7th floor
Toronto, ON M4W 1G9

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