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Canadian Association of Broadcasters November 12,1999 Canadian Radio-television and Telecommunications Commission Ottawa, Ontario K1A 0N2 Attention: Secretary General Re:: Notice of Public Hear CRTC 1999-10 Application (199812524) by Jan Pachul for a broadcasting licence to carry on an English-language low power television programming undertaking at Toronto. Introduction The Canadian Association of Broadcasters is pleased to have this opportunity to provide its comments with respect to the application by Jan Pachul (199812524) for a broadcasting licence to carry on an English-language low power television programming undertaking at Toronto. The CAB is the representative of the majority of Canadian programing services - including private television and radio stations, and networks, and specialty television services. The CAB is opposed to this application on the basis that the application does not conformi to the Commission's policies with respect to low power television undertakings or to its definition of community television. Application is Deficient The Commission's policy with respect to low power television undertakings defined in Public Notice CTRC 1987-8 (Regulations Respecting Television Broadcasting) The thrust of the Commission's policy is to promote the extension of television services to remote or underserved communities. In that policy, the commission sets out four criteria that define a low power TV undertaking. Those criteria, in summary, are that: i) the undertaking should serve a community which has no competing local or regional television service; ii) the community has no local cable community channel(s); iii) the undertaking be delivered through a low power transmitter; and iv) the undertaking be characterized by the local nature of its ownership, its programming and the market it is designed to serve. The applicant appears to only meet one of the criteria that define a low power television undertakirig - being delivery through a low power transmitter. With respect to the first criterion, the applicant is proposing to serve the Toronto metro market, which already has competing local and regional television services. Secondly, the applicant would be servirig a substantial market that is already served by cable commmunity channels. It is debatable whether the applicant meets the spirit of the fourth criterion since the proposed program line up has, with the exception of three of its proposed shows - Public Forum, Sports on TV and Toronto City Hall Coverage, little to do with the community the applicant is proposing to serve. Role of Community Television The Commission's objective for community television as described in Public Notice CTRC 1986-176 and further enunciated in the coxtext of its proposed policy framework for community radio (Puiblic Notice 1999-75) is to encourage the developmeny of community broadcasting: * that is different from and complements that of other stations in the market; * that is not-for-profit in nature and whose service is based on community access; and * which is owned and controlled by an organization whose membership is made up primarily of citizens of the cornmmunity. The proposed service does not sufficiently distinguish itself from some of the program offerings of existing community channels or local broadcasters. Likewise, the applicant has not put forward any research to demonstrate what the community's level of interest is in receiving such a service or participating in such a service. The applicant has proposed rio approach to encouraging or dealing with public access. The applicant has not structured the proposed service to effective1y allow for the community to own and actively participate in defining the service. Conclusion For all of these reasons, we believe the application is seriously deficient. While we support art the Commission's objective to encourage the development of community based television services in remote and underserved communities, we do not believe that this application fulfills what is expected of a community-based service and we do not believe that the metro Toronto market can, in any way, be described as underserved. Therefore, we ask that the Commision deny this application. A copy of this intervention has been provided to the applicant. Sincerely, Michael McCabe. President & CEO c.c. Jan Pachul |