CCD Comments on BCE Purchase of CTV

January 11, 2011

Mr. Robert A. Morin
Secretary General
Ottawa, ON
K1A 0N2

Dear Mr. Morin,

Re: Broadcasting notice of consultation CRTC 2010-926, BCE Purchase of CTV

The Council of Canadians with Disabilities (CCD) is pleased to submit the attached intervention in response to Broadcasting notice of consultation CRTC 2010-926. A copy of the intervention has been e-mailed to Mirko Bibic of Bell Canada. CCD supports the position being taken on this issue by the Alliance for Equality of Blind Canadians (AEBC), one of its member organizations. The AEBC is seeking an improved standard of video description from Canadian broadcasters. Indeed, CCD supports improved access to broadcasting for all people with disabilities who continue to encounter barriers.

We encourage CRTC to also address the specific needs of the Deaf community and engage them in appropriate hearings related to broadcast services.

If you have any questions, please do not hesitate to contact me.


Laurie Beachell
National Coordinator

CC: Mirko Bibic

Canadian Radio-television Telecommunications Commission(CRTC)

Council of Canadians with Disabilities (CCD)
926-294 Portage Avenue,
Winnipeg, MB
R3C 0B9

TITLE: CCD Comments on BCE Purchase of CTV

11 January 2011

1. INTRODUCTION: The UN Convention on the Rights of Persons with Disabilities, the Canadian Human Rights Act and the Charter of Rights and Freedoms establish that Canadians with disabilities have a right to accessible services, including broadcasting. Bell Canada Enterprises (BCE) is seeking to purchase CTV’s over-the-air and specialty television services and its radio stations. Like other organizations in the disability community, the Council of Canadians with Disabilities (CCD) is concerned that Bell has not built any information regarding its plans for expanding accessibility into its purchase proposal. This lack of information and concrete steps makes it impossible for the CCD to support Bell's application as it is currently constituted.

2. WHO IS THE CCD?: CCD is a national human rights organization of people with disabilities working for an inclusive and accessible Canada.

3. WHAT IS AUDIO DESCRIPTION?: Audio Description (AD) is verbal narration which explains what’s happening visually on screen in television, movies, DVDs or live performances. Delivered during gaps in the dialogue, this includes description of scenes, settings, costumes, body language and ‘sight gags’ – anything that is important to a better understanding 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?’

4. A RIGHTS FRAMEWORK: 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 people with disabilities. Like other organizations in the disability community, CCD has been urging the CRTC to use a human rights lens when analyzing the questions that come before it. During the thirty-five year history of the disability rights movement, we have learned that market forces alone do not deliver accessibility to people with disabilities. Regulatory bodies, like the CRTC, have the power to set standards that deliver access to persons with disabilities. CCD urges the CRTC to use this opportunity to improve access to television programming for people with disabilities.

5. WHAT CCD IS SEEKING: CCD encourages the CRTC to undertake the recommendations made to it by the Alliance for Equality of Blind Canadians (AEBC). AEBC's recommendations are as follows:

5.1.1 A clear requirement from the CRTC for Bell to provide a plan with concrete steps, including specific hours and expenditure allocations on accessibility programs that increase incrementally to achieve 100% accessibility, including full described narration, by 2020 on all CTV stations, without compromising the quality of this accessibility.
5.1.2 Accessible web sites where television programs on web sites are captioned and described.
5.1.3 Accessible mobile telephone designs, so that television content is captioned and described.
5.1.4 Improved accessible content production technology to reduce accessibility costs.
5.1.5 Curriculum development for students who want to learn how to closed caption or describe digital environments.
5.1.6 Annual monitoring of quality and levels of accessible content.
5.1.7 Annual report cards on accessibility.
5.1.8 In support of these and other access initiatives, the AEBC recommends the CRTC to direct the establishment of an Accessibility Trust Fund run by the accessibility community and accessibility experts, whose income would be specifically dedicated to accessibility activities.

5.2 When addressing the BCE application, CCD encourages the CRTC to support the Deaf community's objective of 100% captioning of television programming and that captioning be of high quality. CCD encourages the CRTC to solicit direct communication from Canada's Deaf community on this matter.

6. CONCLUSION: Television programming, usable by Canadians with disabilities, is an essential component of an accessible and inclusive Canada.

End of document

Copy to Mirko Bibic: