North Star Media
February 19, 1997
Mr. Allan J. Darling Secretary General
Canadian Radio-television and Telecommunications Commission Ottawa, Ontario K1A 0N2
Dear Mr. Darling:
Please consider this an application for an exemption from the Broadcast Act for a technical and marketing trial as specified in CTRC Public Notice 1996-59 "Policy Regarding the Use of Exemption Orders."
PURPOSE OF TRIAL
1. To demonstrate the viability of local advertiser supported community channels on low power UHF and the Internet providing universal access. The new broadcast distribution regulations no longer require outlets to run community channels. Local broadcasters run very few locally produced programs during prime time preferring to simulcast American programming already available on U.S. channels. Every American show on a Canadian channel means a Canadian was denied access for his / her show. Local just is not seen as profitable, with investors and advertising agencies showing no interest. This is the status of local access today in Canada. This trial is designed to demonstrate that the local community can be involved in the broadcast communication process and local talent can be showcased. Television and computers can be agents for positive social change. We will demonstrate that local people will support local channels and that community television is a sound investment. Local prime time works.
2. To evaluate new locally manufactured low cost transmitter technologies. North Star Media has been cooperating with Tin Lee Electronics in developing new transmitter technologies for use in the UHF band. Generally a transmitter is the single biggest expense a channel would have to begin operation. We have been experimenting with new GasFet technologies to have a "made in Canada" solution to the high cost of transmitters.
3. To demonstrate new interactive Internet and radio communication technologies providing the public with unprecedented interactivity with the channel. We want to create virtual town meetings, local interest news and videoconference groups interacting with live broadcasts. Video call-ins via the Internet are possible as is video on demand. Our Internet site will feature companion text presented simultaneously during programs, experimental Internet video broadcasts using Quadrant International "Buster" technology. As the bandwidth of the Internet grows, cable and over the air broadcasting will eventually be obsolete. We will be confronted with a five million channel universe, not the 500 channels anticipated. New low cost communication links will permit live on location local broadcasting. A local event could be a shared reality with shut-ins and others that are not able to participate in person. Old technology will be the bridge to the brave new global village.
4. To demonstrate new solutions for improved service to the hearing impaired including audio processing technology, new technologies for computer generated closed captioning, and new high powered software for the generation of alphanumeric text. In 1992 the Canadian Hard of Hearing Association commissioned a study into the difficulties experienced by the hard of hearing in viewing and listening to broadcast television. It should be noted that about 90% of the hard of hearing have sufficient hearing ability to listen to broadcasts with assistance devices. The problems most cited were louder commercials, background music and sound effects, static, and rushed speech. Audio processing can smooth audio levels and remove static. Programming can be designed to be friendly to the hearing impaired. Voice recognition software will permit effortless closed captioning. As the Canadian population ages, the need for service to the hard of hearing grows.
5. To explore various issues regarding violent and offensive programming. North Star Media will establish an advisory group on programming content. This group will develop guidelines regarding the cultural environment of the channel. Also, the group will monitor content on an ongoing basis. The resulting guidelines and practical experience will serve as a model of how a channel can approach cultural environment issues.
6. To develop training programs allowing newcomers to the television business to participate and unemployed professionals to upgrade to the digital era. Our computer technology is leading edge. We plan to use a digital computer server model for both graphics and traditional audio and video. It is necessary to institute an ongoing training program for the constantly evolving software and our digital structure. We have many highly skilled individuals that have expressed a desire, in writing, to participate in the technical side of the trial. The high skill level found is a direct result of thousands of layoffs in television broadcasting, and related fields, during the last years in Toronto. These individuals can easily adapt to this new style of working and their contributions can be immense. Also, there are many members of the community who have little experience in television and computers who would like to start from the ground up. These people, too, have a place at the community channel. North Star Media will provide ongoing weekly training during the trial on two levels; professional upgrades to current digital methods, and beginner level that starts with the basics of camera operation. The emphasis will be hands-on experience.
7. To develop plans for sustained emergency operation in case of a natural or man made disaster. Something that has been overlooked in the development of broadcast regulations in Canada has been emergency broadcasting. We do not know of a Canadian broadcast outlet that has any emergency plans in the event of a disruption in power and / or a disaster. In Toronto if the transmitters at the CN tower become inoperable for any reason, most broadcast facilities would be off the air. Large operations would be difficult to sustain after a short period of time. Our proposed transmission tower site is on high ground, on a solid 32 floor concrete building and about 10 km away from the CN tower. We have made provisions for easy conversion to generator power, a bunker like control room, extensive downlink and communication capabilities. With the disruption of land lines low power over the air UHF broadcasting may provide the only sustainable TV pictures. Familiar local faces delivering the facts will be a comfort to citizens undergoing extreme danger and adversity.
DESCRIPTION OF CLASS
This undertaking could be described as a marriage between traditional over the air UHF broadcasting and the new computer technologies. The envisioned structure of the class is similar to a U.S. low power UHF station. There is also some similarity with Canadian cable community channels. We propose this service have 100% local Canadian content from 6:00 p.m. to 11:00 p.m. Companion information would be simultaneously available on an Internet worldwide web site featuring channel news groups, Internet videconferencing, and on line interactivity during live public forum shows. We propose that these new community channels be made available free of charge to any distribution outlet including local cable. The maximum transmitter power of this class could be limited to 1000 watts to lessen the impact on existing broadcast outlets. The exemption for this class of programming undertaking could be similar to the existing one for teleshopping. At the present time there are hundreds of UHF frequency allocations available across the country. The high availability of UHF frequencies nationwide is a testament to the weakness of the present licencing system . These existing UHF frequencies could be made available for the type of use described on a first come first served basis, with relaxed spacing requirements based on the limited reach of the signal. This exemption could spur the development of broadcast outlets that could be owned by the common man. The high cost of even a very low power UHF facility will still greatly limit the use of these dormant frequencies. With the advent of digital broadcasting even more spectrum space will be made available with one 6mz UHF channel being able to support four program undertakings. We propose an upgrade migration exist whereby an individual could start with a very low power one to 10 watt transmitter with a broadcast exemption, radio communication license exempt, to a licensed full power commercial station. This service will provide opportunities for local businesses to advertise on television when the prohibitive cost previously barred their access to television advertising. In areas where only regional TV stations are available no local television advertising services exist. An advertiser that has 90% of his customers within 20 square blocks doesn't need his commercial broadcast regionally. The cost burden of the present cable community channels would be shifted from cable companies and subscribers to a previously untapped pool of television advertisers. UHF will provide universal access to the services of a community channel, not the limited access only available to cable subscribers as is presently the case. As cable's influence declines with M.D.S., D.B.S., D.V.D., and the Internet, the need for our proposed UHF service grows. The U.S. experience has shown that low power community broadcasting is indeed a viable service with 1300 stations currently on the air. The use of the Internet for broadcast purposes should enjoy a perpetual exemption from regulation. As the Internet's ability to deliver full motion audio and video grows, present day television broadcasting will some day be rendered obsolete. The Commission should allow this embryo project to grow unimpeded allowing maximum opportunities for freedom of speech and diversity.
THE PROPOSED DURATION AND SCOPE OF THE TRIAL
We propose that the trial last a period of three years. The trial has many facets that need to be explored in depth. Some of the technologies studied are in their infancy stage and require long term development. The development of a new TV advertising user requires substantial lead time for sales and the preparation of advertising materials. The development of Internet broadcasting will be ongoing until full motion, full size video capability is achieved. The time frame will also allow the participants an opportunity to derive some fruits from their initial sacrifices during the trial start-up. The participant members are concerned citizens and groups that feel East Toronto should have its own local community voice. They are an amazing pool of talent covering all the disciplines required to run the channel. Many have had previous jobs in the industry but became casualties in Toronto's major media downsizings. To them North Star Media's proposal is their best opportunity in a industry of bleak prospects. These individuals have made written commitments to participate in the trial in their area of expertise. Their commitment is initially volunteer until a time when the channel generates income. We propose that the trial have the use of UHF channel 30, a dormant frequency allocation in Toronto at a transmitter power of 1000 watts. This power will limit the grade "A" coverage of the signal to a 5-km radius of Danforth and Main Streets in Toronto.
THE PROGRAMMING SOURCES
The channel will feature local family oriented programming with an emphasis on under served programming categories. These would include local sports coverage, children's programs and in depth local public information programming. North Star Media has the resources and commitments from individuals to produce the following local programs:
1. Public Forum ten hours per week Daily local public affairs program, live, interactive, regular contributors on issues of local interest.
2. Local Sports four hours per week Various local sporting events, live and recorded
3. Tiny Tot Time one hour per week Live amateur hour for children.
4. The Computer Show five hours per week Live, interactive advice show on computing with the emphasis on development and use of our Web site.
5. The Creature Double Feature four hours per week Old sci-fi movies combined with a local host acting as an alien character with his unique perspective on the human race.
6. Global Event Coverage two hours per week or more We want to be East Toronto's window to the global village. North Star media will undertake live coverage of global events via satellite and the Internet as circumstances warrant. We will provide live local interpretation and interaction.
7. Emergency Broadcasting Varies As part of this trial North Star Media will have a plan in effect in case it becomes necessary to have continuous emergency coverage for the public welfare.
8. Satellite Filler Varies We propose to fill in non-local hours with various family oriented satellite feeds originating in Canada and the U.S. with a Canadian emphasis when available. This material would not include any programming that is presently available locally.
LOCAL PRODUCERS
In addition we have commitments from independent producers for the production of the following local programs. It should be noted that most of these individuals have been denied access to local broadcast outlets.
1. Urban Ecology Issues one half hour per week Producer: Ashbridge Bay Watershed Council. Ecosystem perspective on urban issues.
2. "tomorrow TODAY" one hour per week Producer: Air Time Multimedia. Science and technology news.
3. Streeters one hour per week Producer: Les Nirenburg. Street side public discussions of local topics.
4. T.V. Eye one hour per week Producer: CKLN 88.1 Radio. Profile of Canadian and independant music
5. Dancing to the Oldies one hour per week Producer: North Star Media. Live weekly dance show based on 1950's - 1980's music.
IN CONCLUSION
North Star Media has existing facilities at 204 Main Street, Toronto to undertake this trial. We haven been performing ongoing research and development of video computer technologies and transmitters for several years already as part of our regular industrial equipment and production business. North Star Media has functioned as an independent producer for many years in Toronto and knows first hand the barriers that exist to local broadcast access. A striking amount of talent is not contributing their expertise to the community because there is no outlet. We propose to be that outlet, a place where social responsibility and not profits count. This trial will foster community participation in the broadcast process, give hope to many highly trained and talented individuals now currently unemployed, provide a link between old technology and new, give free speech a new voice. The East Toronto community has embraced this project. Sustained momentum is needed. North Star Media is ready to begin the trial now. We therefore ask for an interim exemption to begin.
Sincerely,
Jan Pachul