Brief

To the CRTC Regarding Public Hearing 2003-3

April 2003

Ms. Diane Rheaume
Secretary-General
Canadian Radio-Television and Telecommunications Commission
Hull, QC K1A 0N2

Dear Ms. Rheaume:

Re: Broadcasting Notice of Public Hearing CRTC 2003-3 covering the following applications:

Application No. 2002-0896-9: Application by THE COMEDY NETWORK INC. to renew the licence of the national English-language specialty television service known as The Comedy Network

Application No. 2002-0895-1: Application by CTV TELEVISION INC. to renew the licence of the national English-language specialty television service known as CTV Newsnet

Application No. 2002-0897-7: Application by 1163031 ONTARIO INC. to renew the licence of the national English-language specialty television service known as Outdoor Life Network

Application No. 2002-0891-9: Application by THE SCORE TELEVISION NETWORK Ltd. to renew the licence of the national English-language specialty television service known as The Score

Application No. 2002-0974-3: Application by ROGERS SPORTSNET INC. to renew the licence of the national English-language specialty television service known as Sportsnet

Application No. 2002-0942-0: Application by TELETOON CANADA INC. to renew the licence of the national English and French-language specialty television services known as Teletoon

Application No. 2002-0889-4: Application by HISTORY TELEVISION INC. to renew the licence of the national English-language specialty television service known as History Television

Application No. 2002-0952-9: Application by CHUM LIMITED to renew the licence of the national English-language specialty television service known as MuchMoreMusic

Application No. 2002-0890-2: Application by HGTV CANADA INC. to renew the licence of the national English-language specialty television service known as Home and Garden Television Canada

Application No. 2002-0948-8: Application by LEARNING AND SKILLS TELEVISION OF ALBERTA LIMITED (LTA) to renew the licence of the national English-language specialty television service known as Canadian Learning Television

Application No. 2002-0939-7: Application by GLOBAL COMMUNICATIONS LIMITED AND PRIME TELEVISION HOLDCO INC., PARTNERS IN "PRIME TV, GENERAL PARTNERSHIP", to renew the licence of the national English-language specialty television service known as Prime TV

Application No. 2002-0955-3: Application by CHUM LIMITED to renew the licence of the national English-language specialty television service known as Space: The Imagination Station

Application No. 2002-0956-1: Application by CHUM LIMITED AND 3661458 CANADA INC., PARTNERS IN PULSE 24, GENERAL PARTNERSHIP, to renew the licence of the regional (Ontario) English-language specialty television service known as Pulse 24

Application No. 2002-0894-3: Application by CTV TELEVISION INC. to renew the licence of the national English-language specialty television service known as Report on Business Television

Application No. 2002-0954-5: Application by CHUM LIMITED to renew the licence of the national English-language specialty television service known as Star!-TV

Application No. 2002-0898-5: Application by CTV TELEVISION INC. to renew the licence of the national English-language specialty television service known as Talk TV

Application No. 2002-0907-4: Application by YTV CANADA INC. to renew the licence of the national English-language specialty television service known as Treehouse TV

1. The National Federation of the Blind: Advocates for Equality (NFB:AE) is pleased to have the opportunity to comment on each of the licence applications contained in the above list, and hereby requests these comments be considered in connection with each of these applications.

2. The NFB:AE is a national non-profit organization OF blind, deaf-blind and partially sighted Canadians, founded in 1992, who have joined together to increase the level of public understanding of issues and concerns affecting our lives and to work collectively to increase our opportunities to participate equally in, and benefit from, all aspects of Canadian society. This must include full access to information and programming available on television throughout Canada.

3. The NFB:AE appreciates the work of the Commission to date in expanding access to television programming for Canadians with various disabilities, including blindness. An example of this access is the programming currently available with video description to blind and vision-impaired television viewers via the second audio program (SAP).

4. Based on the 1991 Census, there are over 600,000 blind and low-vision Canadians and over 2.0 million print-restricted Canadians living in all parts of Canada.

In addition, the article "Report: Age-Related Blindness Expected to Double," by Kathleen Fackelmann, USA TODAY, March 21, 2002, reports "the number of blind Americans will double in the next few decades as the boomer generation ages, says a government report." Canada can expect to see a similar level of increase of individuals living with significant vision loss.

5. "Video Description" provides verbal description of those portions of any television broadcast that contain extensive breaks in spoken content of the program. It utilizes a separate channel that does not interfere with the regular audio channel. This service provides the blind viewer with information that permits a fuller understanding and better appreciation of what is being presented in visual form only. This includes description of action and choreographics, the setting, costume and facial expressions, car chases, visual peripherals, periods where extensive special effects appear, or any segment of a program that lacks spoken dialogue. While this description is currently broadcast over the second audio channel, in a more perfect world, it could be included in the regular soundtrack and broadcast over the regular channel. In trials in movie theatres where the audio description was broadcast openly to all patrons, many sighted individuals found they also benefit from the added information which is provided by this type of description.

6. "Audio Description" provides an audio track which verbalizes alpha information that currently scrolls across the television screen, and includes sub titles of English translations of dialogue from other languages, phone numbers, sports scores, stock market quotes, and weather. This information, more often than not, is currently provided only in an alpha format, especially during commercials.

7. Both the Canadian Charter of Rights and Freedoms and the Canadian Human Rights Act prohibit discrimination against persons with disabilities. The Broadcasting Act provides for accessible programming for the disabled, programming and employment opportunities for all people through equal rights, and varied and comprehensive television content.

8. As noted above, the aging process is leading to an ever-increasing number of persons who have diminished vision, who would benefit directly from both video and audio description of television content. In a practical sense, most Canadians gain a tremendous amount of their current information and entertainment from television programming. There is often discussion of television shows around the office or in various social settings. In addition, sometimes television provides information on job opportunities or products for sale. Therefore, in order to achieve our goal of "full participation and equality" in all segments of Canadian life, we must have direct access to information from television. Such information access promotes full inclusion.

9. Section 3 (1) (up) of the Broadcasting Act states that "[programming accessible by disabled persons should be provided within the Canadian broadcasting system as resources become available for the purpose."

The NFB:AE believes that all broadcasters, including specialty channels, must be required, as a condition of licence renewal, to provide all viewers with equal access to the content of all regular programming, including providing both audio and video description of information currently available only to sighted viewers through visual presentation. In this way, the needs of all viewers, sighted and not, can be met.

10. Section 3 (1) (d) (iii) of the Broadcasting Act states that the Canadian broadcasting system should "[through its programming and the employment opportunities arising out of its operations, serve the needs and interests, and reflect the circumstances and aspirations, of Canadian men, women and children, including equal rights."

As people with disabilities fall into the above general statement, we support this statement of equity.

The unemployment rate within the blindness community is approximately 70 per cent, though advances in assistive technology enable blind and vision-impaired persons to engage in an increasing range of occupations. We wish to ask each applicant to detail what programs are currently in place, or new ones planned, that will lead to the increased employment of persons with disabilities, including individuals who are blind, low-vision or Deaf-blind in their operations. We also ask the Commission to require, as a condition of licence renewal, that any that do not currently have such initiatives develop them within three (3) months following any licence renewal.

11. Section 3 (1) (I) of the Broadcasting Act states: "the programming provided by the Canadian broadcasting system should (I) be varied and comprehensive, providing a balance of information, enlightenment and entertainment for men, women and children of all ages, interests and tastes."

This "variety" must include increased content that depicts persons with disabilities, both in news stories and in regular programs. Such depictions should portray persons with disabilities, including persons who are blind and vision-impaired, in a realistic light. Such true-to-life portrayals would serve the valuable purpose of public education by showing the abilities of people who have a disability.

12. In conclusion, the NFB:AE again wishes to thank the Commission for the opportunity to present our views and recommendations for increased access and specific content in any licence renewal of specialty television channels. Our recommendations would not only benefit the blind and vision-impaired audience, but also the broadcast industry and individual programmers by promoting inclusiveness and equality and demonstrating to all, the blindness community and the population at large, that they are committed to reaching and satisfying every member of their audience.

John Rae
President
National Federation of the Blind: Advocates for Equality

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