Joe Clark: Accessibility | Design | Writing

Request for extension of deadline in broadcasting renewals, March 2006

At time of writing (2006.03.23), the CRTC has invited comments on license-renewal applications for MuchMusic, Food Network, and YTV and an application to change the ownership of Bell ExpressVu.

It is surely coincidental that all these multi-million-dollar broadcast and distribution businesses stated that their renewal and application documents could be viewed solely at their offices. No, they aren’t online – not even in unpublished formats like Microsoft Word or inaccessible formats like scanned PDF. If you want to read them, you have to be able to visit their offices. (How do you do that if you don’t live in Toronto, or, in the ExpressVu case, in any of a few other cities? What happens if you need to copy some of the documents for reference?)

So today I filed a petition with CRTC chair Charles Dalfen to extend the response deadlines in those applications and to require online filing in these and all future applications:

I note that the Commission has permitted the applicants in the above-named proceedings to limit public viewing of their license-renewal documents to their own offices. As such viewing is convenient and reasonable only for those who work in such buildings, i.e., the applicants themselves, I object to this effective evisceration of the public consultation process.

It is advantageous for the applicants to limit availability of license-renewal documents; the less the public knows about their proposals, the fewer the interventions opposing them. The Commission already faces recurring allegations of conflict of interest given that many Commissioners come from the regulated broadcasting sector, or leave the Commission and later take up work in that sector (or, in the current case, ultimately become Minister of Heritage). The relationship between the Commission and regulated broadcasters already appears too close to meet any modern ethical standard. It adds insult to injury for the Commission to permit its regulated broadcasters to effectively conceal renewal documents from the public.

Accordingly, I petition the Commission:

  1. to require all applicants, including those cited above, to provide all license-renewal documents in electronic form on the Web (as on the CRTC’s own site)
  2. to extend the deadline for comments in all the above proceedings by 21 days after such documents in (1) are posted (where such extended deadlines may vary according to individual release dates)
  3. to clarify its regulations to require such convenient electronic dissemination of relevant documents and prohibit any restriction of access, as by limiting viewing of documents to a specific office

I renew my objection to the Commission’s and broadcasters’ habit of posting documents solely in unpublished proprietary formats that require a certain operating system or commercial software to read. This habit, which is unrelated to the provision of alternate formats, suits and abets the close relationship between the CRTC and broadcasters. Nonetheless, even documents of that sort would be an improvement over the current state, where the Commission seems willing to permit broadcasters to effectively conceal documents of public interest.


I had already requested the materials by E-mail to the CRTC nearly two weeks before, which elicited no response. I’ve asked for extensions before and not gotten them, and I fully expect the CRTC to maintain its tradition of favouring incumbent corporate interests by denying my petition. I will update this page with any news.

Posted: 2006.03.23

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