Second Report of the Simultaneous Substitution Working Group - Report to the Canadian Radio-television and Telecommunications Commission - December 22, 2015

A. Introduction

  1. In the first report of the Working Group filed in August 2015, we outlined the key issues that led to simultaneous substitution errors and enumerated several measures we had begun to adopt, or planned to adopt, in order to address those issues. The Working Group has been implementing and refining those measures throughout the fall.  We are pleased to report that our efforts have yielded tangible results: as set out further below, the number of complaints by Canadians to the Commission related to substitution errors in the fall of 2015 decreased by 59% from the same time period in the previous year. As the Working Group continues to develop tools for reducing errors, we are confident that we will continue to improve the experience of watching substituted programming for our viewers and customers.

B. Status of New Measures to Reduce Errors


  1. Mediastats is the third party company that coordinates substitution requests for all broadcasters in Canada. In our first report we indicated several process changes that Mediastats would be instituting in the coming months to enhance its processes for doing so. The status of those changes is as follows:

    1. Move “mon beg”, “mon end” and “HD” designations from the title of the program to their own data fields

  2. As detailed in our first report, the Working Group resolved to have Mediastats move the instructions to broadcasting distribution undertakings (BDUs) to monitor the beginning (“mon beg”) or the end (“mon end”) of a program, as well as the indication that a program was in HD, into their own data fields. This change will make the data more visible to BDU operators, making it easier for them to analyze and act upon. Mediastats has completed most of the work involved in these changes and it expects to introduce the new data fields in January or February 2016.

    1. Add seconds to the start and end times for simultaneous substitution requests

  3. Since not all programs are scheduled to begin on the minute mark, the Working Group decided to add seconds to the start and end times of substitution requests in the Mediastats reports. This will enable broadcasters to request substitutions to the second as opposed to the minute, resulting in more accurate substitutions and a more seamless viewing experience. The Working Group agreed to prioritize this change. In the week of December 7th Mediastats deployed this new data across the system and BDUs are currently in the processing of adopting it.

    1. Add a comments data field

  4. A comments field in the Mediastats reports will allow broadcasters to provide additional information to BDUs regarding their substitution requests. For instance, comments such as “live game”, “follows live game” and other selections will be available from a standardized drop-down menu to provide further context regarding monitoring instructions and to support BDUs in the execution of manual interventions. Mediastats has completed most of the work related to this change and it will be launched in January or February 2016.

    1. New summary reports of change and cancellation requests

  5. The Working Group asked Mediastats to distribute a daily summary report which condenses all communications with respect to changes and cancellations. This change was implemented in the summer of 2015. Mediastats circulates these reports on a daily basis from Monday to Friday. BDUs in the Working Group find it useful to check these daily summaries against their own lists of scheduled substitutions to validate that all changes have been captured.

    1. Availability of Mediastats after regular business hours for last-minute changes

  6. Mediastats now makes itself available in two ways to support broadcasters in communicating last-minute changes related to substitution requests. Whenever there is a programming schedule change that will affect substitutions after Mediastats’ daily change requests have already been distributed, Mediastats will issue an urgent last-minute change request to all BDUs with the advisory that it must be “read immediately”. Such change requests used to be sent out in batches several times a week, but are now sent as soon as the last-minute request is made by the broadcaster.  Mediastats reports, however, that it is sending fewer urgent memos than in the past because broadcasters are providing more advance notice of changes to substitutions.

  7. Secondly, Mediastats is an active member on the Working Group’s online messaging tool, described further below. As such, it is a party to the live communications between broadcasters and BDUs, and can step in to clarify if there is any confusion about a substitution request change.

Communications Tools

a) Off-Air Plans

  1. Broadcasters make “off-air plans” for how they will react in the event that a live program runs long or short. At the time we filed our last report, broadcasters had already begun to share these plans with BDUs in advance of live event programming that may not end at its scheduled time.

  2. Currently, broadcasters employ different methods to relay their off-air plans to BDUs, depending on the nature and volume of information to be communicated. For example, both CTV and City, which broadcast NFL games and request substitutions over US channels for those games, provide additional information to BDUs about their off-air plans for these broadcasts. CTV sends its highly-detailed plans to BDUs via email as well as uploading them to the Working Group’s online messaging tool. Please find a sample of these plans from December 6th, 2015 enclosed as Appendix C.Footnote1 CTV has also introduced a telephone listen line for BDUs to call during broadcasts, described further below. City also shares its plans with BDUs via email and makes itself available to BDUs for real-time communication on the online messaging tool during the broadcast.

  3. Global continues its practice of calling and emailing large BDUs every day to review its plans for the substitutions to be executed that day, and also participates on the online messaging tool during the broadcast of live events and any substituted programming that may be affected by a live event.

  4. BDU members of the Working Group consistently report that obtaining this supplemental knowledge of broadcasters’ plans is of great assistance in the implementation of substitutions.

b) Simsub Live Event Communication Tool

  1. As we advised in our first report, the Working Group tested a real-time online messaging tool in July that we refer to as the Simsub Live Event Communication Tool (SLECT). We have since adopted SLECT and developed a guide outlining the best practices for its use. The tool went live on September 6th and quickly proved to be an invaluable resource to broadcasters and BDUs. Feedback on the tool has been overwhelmingly positive. SLECT currently has 58 members, 26 of them regularly active on the site.  For the week of November 30th, SLECT members uploaded 4 files and sent 208 messages.

  2. The exchange on SLECT from November 26th excerpted below provides a good illustration of how this tool helps broadcasters and BDUs to avoid substitution errors. On that evening, CBS was airing a live NFL game scheduled to end at 8:00 PM EST.  Instead, the game aired until 8:03 PM. BDUs may have expected CBS to make up those minutes during the course of the next program, Big Bang Theory. Instead, CBS pushed back the rest of the evening’s programming by three minutes. Since City alerted BDUs to this change on SLECT, they were able to promptly adjust or cancel all impacted substitutions. Commission staff has advised that no complaints were received regarding substitution errors on that evening.

    ctv_programming_bonc [1:47 PM] Hi everyone, please note that CBS has NFL airing until 8pm. As we have Big Bang Theory starting at 8pm, we have asked Mediastats to send memos requesting a monitor beginning on the show. Thanks.
    city_omni_programming [1:52 PM] We're doing something similar. We have Life in Pieces, Mom and 2 Broke Girls requested over CBS tonight. In the event that the game runs long and CBS shifts programming, we will chase the simsubs up to a couple minutes. Mediastats will be sending memos with more detailed instructions Thank you.
    global_qualitycontrol [2:37 PM] Hi, we also are requesting Elementary over CBS tonight .We will chase up to four minutes, we will have further communication of what's going on over Slack tonight.
    [2:38 pm] thanks
    tnotossatelliteops [3:15 PM] THanks for the notice. We will monitor all programs following NFL games on each of the CBS, NBC and FOX stations today/tonight.
    richard_jones [7:53 PM] CBS appear to be on time for everyone's networks.
    operations_city_west [8:02 PM] Thank you!
    operations_city_west [8:20 PM] We contacted CBS here in Calgary and they have told us the shows have now been offset by 2.48 on top of the 1 minute offset and that it will continue throughout the night. We have therefore adjusted our start times to reflect this for CHMI.
    [8:21 pm] West coast feeds will be on time
    city_omni_programming [8:36 PM] @rogers_simsubs: hey Rogers, we're obviously off by about 30 seconds or so. if you're able to do so, can you match us up at a commercial break? thank you!
    global_qualitycontrol [9:12 PM] Hello Everyone,
    We have confirmed with CBS BOC the start time for tonight's Episode of Elementary will be 22:02:54. CBS will be airing a 5s Colbert Promo prior to the show at 22:02:49.
    We are modifying our system to air at the same time as CBS to maintain our Simulcast.
    ctv_programming_steve [9:40 PM] CBS east will be starting James Corden at 12:40am ET tonight. CTV Two Ontario and Atlantic will match this start time to retain simulcast.
    eastlink_noc [9:48 PM] Eastlink simsubs for Elementary (Central) have been adjusted
    eastlink_noc [9:57 PM] Late Late Show adjustments made as well. Thank you.
    ctv_programming_steve [10:01 PM] Thanks @eastlink_noc
    tnotossatelliteops [10:02 PM] Adjustment for Late Late Show will be done at time of launch for Shaw Direct. Will the western CBS stations also be delayed?
    ctv_programming_steve [10:03 PM] My understanding is no, CBS west is on time.
    tnotossatelliteops [10:05 PM] okay, thanks.

  3. This excerpt is just one of many examples where real-time communication among broadcasters and BDUs has helped to avoid issues that may have caused viewer disruption. The Working Group plans to convene a sub-committee in early 2016 to further refine our protocols for the use of SLECT, including identifying the circumstances when its use is appropriate, and the key words to be employed when alerting members of various situations.

c) Listen Line

  1. In our first report we advised that the Working Group was evaluating other methods of real-time communication. CTV subsequently instituted a listen line, whereby BDUs can call in and listen to dialogue at CTV Master Control as live event coordinators discuss the progress of the event, making note if it is running long and describing any changes to CTV’s broadcast plans arising during the course of the broadcast.

  2. CTV’s listen line has been in effect every NFL Sunday since the season started on September 13th, as well as during the Emmy Awards in September and the American Music Awards in November.

  3. Feedback on the listen line is that the additional information is helpful, although the majority of BDUs report that they more frequently use the SLECT tool to obtain information, as it is easier for them to follow.  CTV has not used SLECT for NFL games this season due to the multiplicity of games at the same time, but is considering this option for next year.

d) Meetings

  1. The Working Group continues to hold bi-weekly conference calls to keep its members updated on the progress of measures to reduce errors, and to troubleshoot any issues.  The calls were hosted by Rogers from February to August 2015 and are currently being chaired by Shaw.  In April 2016 a new Working Group member will assume responsibility for hosting the calls and their frequency will be reduced to once a month as the new practices and procedures are finalized. Meetings may be held more frequently or on an ad hoc basis if necessary.

  2. The Working Group agrees that these regular meetings have been instrumental in improving the execution of simultaneous substitutions. The calls serve as a regular forum where members can discuss challenges, brainstorm solutions, ask questions, and receive direction from both the Commission and each other. By meeting regularly throughout the year, we have strengthened relationships and interactions among broadcasters, BDUs and Mediastats. This, in turn, has helped to improve the substitution process and reduce the amount of errors.

Changes by Individual Broadcasters and BDUs

  1. As a result of the Working Group’s discussions since it was established earlier this year, and in response to some specific incidents, several broadcasters and BDUs have implemented changes at the company level in how they handle substitutions. 

  2. For example, in September an error occurred when Shaw Cable and Videotron implemented substitutions of The Late Show with Stephen Colbert that cut off the end of an NFL game. Shaw Cable subsequently began to circulate weekly internal emails to all operations staff outlining the substitutions in the week ahead and highlighting those requiring particular attention. Shaw also now monitors the beginning and end of all live and highly-impacting events – that is, any which enjoy high viewership and carry the potential to disrupt other substituted programming – regardless of whether monitoring has been requested by the broadcaster. Finally, Shaw has begun its transition to CPS, the substitution control software provided by BCI to over 90% of Canadian BDUs, which allows for easier last-minute changes to substitutions. This transition will be complete by the end of February 2016.

  3. Following the NFL/Colbert error noted above, Videotron clarified its policies with staff regarding whose responsibility it is to place “holds” on programs that require the beginning to be monitored.

  4. CTV changed its strategy this year with respect to its substitution of NFL games. Previously, CTV would leave a game once it had concluded, even if it was before the scheduled end time. This year, CTV is remaining with NFL coverage until the US broadcaster’s scheduled end time (even when that means including US post-game coverage), or until the end of game, should it run longer than scheduled. This change provides greater certainty to BDUs regarding when a substitution should be removed, minimizing the potential for errors. Both CTV and BDUs report that this change has reduced their volume of complaints about NFL-related substitution errors from previous years. 

  5. CTV has also stopped requesting substitutions over CBS for The Late Late Show with James Corden by east coast BDUson Thursday evenings during the NFL season, since the game that precedes it almost always runs long. For the same reason, Global has stopped requesting the substitution of The Late Show with Stephen Colbert on Thursday evenings by BDUs serving Eastern time zones. On Sundays, if CBS is airing any football game that has the potential to end past 7:00 PM EST (i.e. starts at 4:00 PM or later), Global will not request the substitution of Madam Secretary at 8:00 PM or The Good Wife at 9:00 PM by east coast BDUs over any CBS affiliate carrying that 4:00 PM game.

  6. Global has changed its approach to be more judicious in requesting monitor beginnings and monitor endings, so that the designations will have greater meaning to BDUs when they are included in a Mediastats report. More generally, when broadcasters see that a substitution is at risk, they are increasingly staying with their planned schedules instead of trying to “chase” the substitution.

  7. All these decisions by broadcasters have not been made lightly, given the importance they place on protecting their program rights and maximizing advertising revenues. However, these changes have been made in order to ensure that viewers enjoy the best possible viewing experience. Not only does this reduce the burden on BDUs of making last-minute changes to substitutions, but also provides greater certainty for the increasing number of viewers who PVR programs to be watched at a later date. BDUs in the Working Group have expressed their appreciation for these changes, which made the implementation of substitutions a less demanding task for them this fall.

C. Tangible Results of the Efforts of the Working Group

  1. We are pleased to report that the efforts described above have had an impact, as the number of complaints filed with the Commission regarding substitution errors are declining. Commission staff has advised the Working Group that for the period of September 17, 2014 to December 1, 2014, the Commission registered 212 complaints regarding simultaneous substitutions. For the same period in 2015, only 87 complaints were registered, a reduction of 59% year over year.

  2. Since the Commission’s receipt of a complaint does not necessarily mean that a substitution error was made, these numbers do not indicate precisely how many errors occurred this past fall as compared to the previous year. Regardless, fewer complaints strongly suggests that fewer errors were made.

  3. As we noted in our first report to the Commission, given the unpredictability of live programming, the technological limitations faced by some BDUs in implementing last-minute changes to scheduled substitutions, and the possibility for human error inherent in manual interventions, the risk of a simultaneous substitution error cannot be completely eliminated. However, the Working Group's objective is to minimize errors to the greatest extent possible, by putting in place improved practices and procedures. The results reported here demonstrate that we are meeting this objective.

D. Next Steps

  1. The Working Group will continue to meet regularly to assess and refine the initiatives described above, as well as to consider any additional measures that will improve Canadians’ experience of substituted programming. As noted above, we will also be convening a sub-committee to clarify the protocols for using our online communications tool, which has been one of the most successful new measures instituted by the group.

  2. Please find an updated Working Group membership list enclosed as Appendix A, along with an updated action plan enclosed as Appendix B. A new member has recently joined the group and we welcome the addition of further members.

  3. We remain open to further dialogue and new suggestions about ways to reduce errors and to enhance Canadians’ understanding of how simultaneous substitution works and why it remains integral to Canada’s broadcasting system.

Appendix A

Simultaneous Substitution Working Group
Member Companies and Organizations, December 2015

Access Communications Co-op
Bell Canada
Bragg Communications Inc. (Eastlink)
Canadian Cable Systems Alliance (CCSA)
Canadian Radio-television and Telecommunications Commission (CRTC)
Channel Zero
Cogeco Cable Inc.
Dougall Media
Hastings Cable Vision
Mediastats Inc.
MTS Inc.
Public Interest Advocacy Centre (PIAC)
Quebecor Media Inc.
Rogers Communications Inc.
Shaw Communications Inc.
TELUS Communications Company
Yes TV
Zoomer Media

Appendix B

Activity Measures Timeline Expected Results
1. Meetings Bi-weekly conference calls hosted by Rogers February 24, 2015 - August 26, 2015

Discussions and exchanges between members of the industry, the CRTC and consumer groups to identify the key issues regarding the simultaneous substitution processes and practices.

Collective identification of solutions to address errors arising from the simultaneous substitution process.

Half-day in-person meeting hosted by Rogers May 12, 2015
Bi-weekly conference calls hosted by Shaw September 9, 2015 - March 23, 2016
Monthly conference calls, host TBD April 6, 2016 - TBD
2. Implementation of new measures to address key simultaneous substitution issues Communication tools  

Fulfill the Simultaneous Substitution Working Group mandate to improve processes and practices in an effort to reduce recurring, substantial simultaneous substitution errors.

a. Description of off-air plans for live events provided to BDUs via email

Implemented  June 2015

b. Live communications during events:

  • Live chat via Slack

  • CTV listen line

Tested July - September 2015

Implemented Fall 2015

Mediastats Process Changes:
  • Phase 1 – seconds field

  • Phase 2 – other

December 2015 - January/February 2016
3. Reports to the CRTC Collectively prepare reports to be submitted to the CRTC

Progress Report filed August 31, 2015

Update Report filed December 22, 2015

Submit reports on the work completed by the Simultaneous Substitution Working Group and provide updates on its activities to the CRTC.
4. Raising public awareness Explore opportunities to collaborate as an industry to inform and educate Canadian television viewers on simultaneous substitution Ongoing Inform and educate Canadians on the purpose of simultaneous substitution, its process and the efforts of the industry to improve that process.

Appendix C



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