Joe Clark: Accessibility | Design | Writing

Intervention in CRTC application Nº 2006-1667-5

This intervention in the application by CTV Globe Media is submitted by Joe Clark, Toronto, dated 2007.04.05.

Permanent location

This intervention is permanently located at the address:

It is additionally archived at the Open & Closed Project site.

Qualified support

I support the application, despite its significant demerits, if and only if CTV Globe Media funds the Open & Closed Project.

As everyone knows by now, the Project will research and test a set of standards for captioning, subtitling, audio description, and dubbing, all through an open process. We’re the only people remotely interested in carrying out this work and the only people competent enough to do it. We’re independent and nonprofit, and we’re what global broadcasting – and viewers with disabilities, among others – sorely need.

We’ve got a pretty simple proposition: Accessibility is in bad shape and can only be fixed by independent, nonprofit research and testing. CTV and CHUM channels, not to mention other networks, face significant quality problems. After settling one human-rights complaint concerning captioning, CTV and other broadcasters are known to face further complaints. The only way to solve all those problems – and, especially, to insulate against complaints and litigation – is to support the independent development of accessibility standards.

The Project has been in the works for several years and is massively supported by industry, broadcasters, and the grassroots. In fact, over 200 people donated small sums of money to make this application possible, and dozens of them wrote individual support letters. No other accessibility project in Canada has this level of support – or will give this much bang for the buck.

CTV’s submission stated that it is interested in funding a mix of new and existing enterprises. We are well situated for funding as a new research body. We make much more sense than a media-monitoring organization, which can’t monitor what isn’t standardized and isn’t needed or wanted.

CTV must disburse its unspent social-benefits money

“Appendix 1A (Supplementary Brief) to BGM Reorganization Application” (CRTC 2005-1504-1) states that the company that is now CTV Globe Media “will continue to support the $230 million benefits package approved as part of [its] acquisition of control of CTV in 2000,” and as part of other transactions, “until August 31, 2008.” We are reliably informed that $40 million to $50 million remains unspent. We apply for full funding of the Project’s entire term under that envelope.

In fact, we petition the Commission to force CTV Globe Media to disburse all its unspent social-benefits funding, starting by funding us.

Social-benefits spending under the current application

Failing the foregoing, we apply for the full $1.5 million earmarked for “research” (“Application to Effect a Change in Ownership and Control of CHUM Limited – Appendix 1A”). If not, the funding envelope for diversity ($3 million) could be partly directed to fund the Open & Closed Project’s first-year operations.

Fund us anyway

Failing either of the above, the Project deserves funding on its merits. We submit that CTV Globe Media will receive excellent value for money at minimal cost – through better quality of work and protection from human-rights complaints – by funding the Project’s first-year operations out of corporate general revenue.

CTV has already stated its interest in “quality”

In testimony during a recent licence application, CTV president Rick Brace stated: “Our only concern is that the quality of [audio description] be top-notch.”

Well, at present that’s not going to happen by hiring AudioVision Canada – nor, presumably, by hiring any other existing supplier. There are no quality standards for audio description that were based on research and evidence, developed in an open process, and actually tested. A few suppliers have written down their current practices and passed them off as standards, and there are a few closed processes underway that will result in exactly the same thing, but there are no general quality standards. That’s what we’re going to write.

If Rick Brace is serious about his commitment to quality, he has to put CTV Globe Media’s money where his mouth is and fund the only organization that will actually solve the quality problem.

Original application

We filed a separate application to CTV Globe Media for funding.

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