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

The Alliance for Equality of Blind Canadians / L’Alliance pour l’ÉgalitÉ des Personnes Aveugles du Canada (AEBC)

January, 2011

RE: BCE APPLICATION TO PURCHASE CTV

1. INTRODUCTION:

Bell is one of Canada’s largest communications companies. As such, it must be a leader in accessibility for all Canadians, including Canadians who are
blind, deaf-blind or partially sighted. BCE has offered to buy CTV’s over-the-air and specialty television services and its radio stations, for
$3.2 million. The AEBC is concerned that Bell has not built any information regarding plans for expanding accessibility into its purchase proposal. This
lack of information and concrete steps makes it impossible for the AEBC to support Bell’s application as it is currently constituted, and we request
the opportunity to appear at the public hearing to further outline our position.

2. WHO IS THE AEBC?

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.

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. BELL’s PREVIOUS COMMITMENT:

In the CRTC’s 2009 hearing on disability and accessibility, Bell said that “Effective social regulation requires a critical mass of understanding,
mutual trust and buy-in from all parties.” The AEBC supports this comment.
However, if this is Bell’s view, it makes it doubly difficult to understand why Bell has not provided any information on its plans for increasing
accessibility should it obtain control of CTV ­ Canada’s largest English-language broadcaster.

5. AEBC’s EXPECTATIONS OF THE CRTC:

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
proactive approach and use its regulatory authority to help expand accessibility to all telecommunications services, including audio
description of television programming, whether over-the-air, by satellite or online regardless of the financial circumstances of the licensee or its
licensed undertakings. Our history teaches us in clear terms that relying on the voluntary approach has failed to work in the past, is not working
presently, and as a result, there is no reason to expect this situation to suddenly change and, thus, we call upon the CRTC’s to make increased use of
its regulatory authority.

6. TANGIBLE BENEFITS:

Tangible Benefits are funds traditionally allocated to benefit the entire broadcasting system, and are supposed to cover costs above and beyond those
that a broadcaster would normally incur in the course of doing business. Based on CRTC policy, $230 million should be spent on tangible benefits for
this acquisition, yet BCE is offering only $220 million in tangible benefits, and all of this appears to be earmarked to support their own
operations, rather than for initiatives that are above and beyond its current operations. Why should Bell be given a discount, and why shouldn’t some of the tangible benefits funds be used to support increased access?

7. AEBC’s EXPECTATIONS:

  • 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 audio description, by 2020 on all CTV
    stations, without compromising the quality of accessibility provided
  • 2. Accessible web sites where television programs on web sites are captioned and described
  • 3. Accessible mobile telephone designs, so that television content is captioned and described
  • 4. Improved accessible content production technology to reduce accessibility costs
  • 5. Curriculum development for students who want to learn how to closed caption or audio describe digital environments
  • 6. Annual monitoring of quality and levels of accessible content
  • 7. Annual report cards on increased accessibility
  • 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, including organizations of rights holders like the AEBC, whose income would be specifically
    dedicated to accessibility activities

CONCLUSION:

The broadcasting industry, including all regulatory bodies, has had many years to make television fully accessible to all Canadians. Existing
approaches haven’t worked. Canada’s disability community believes it’s time we began moving more quickly towards attaining full inclusion, including
audio description, so that 100% access is achieved not later than 2020. We
call upon the CRTC to use its regulatory authority to help make this a reality. Our time has come!

Copy to Mirko Bibic: Mirko.bibic@bell.ca
The Alliance for Equality of Blind Canadians / L’Alliance pour l’ÉgalitÉ des Personnes Aveugles du Canada (AEBC)
P.O. Box 20262, RPO Town Centre
Kelowna, BC V1Y 9H2
E-mail: info@blindcanadians.ca
Website: www.blindcanadians.ca