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Ottawa, 31 January 2014

Manon Brouillette
President and Chief Operating Officer of Videotron
612 St-Jacques Street
Montreal, Quebec H3C 4M8
manon.brouillette@videotron.com

Dear Ms. Brouillette,

As you are aware, there are a number of misconceptions and a certain frustration among Canadian television viewers regarding simultaneous substitution. These are often expressed at this time of year—specifically, during the NFL playoffs and in the run up to the Super Bowl game.

The Broadcasting Distribution Regulations require that at the request of a rights holding local station, a distributor substitute the programming service of that local station over that of a non-Canadian television station.

Canadian broadcasters enjoy simultaneous substitution since it allows them to protect the rights of the programs they have acquired for broadcast in our country. Canadian distributors benefit by having a large quantity and diversity of content to distribute to their subscribers. In addition, simultaneous substitution contributes to the Canadian economy through the jobs created by broadcasters and advertisers, as well as the taxes paid by these companies and their employees.

As such, members of the broadcasting industry—both broadcasters and distributors—must share in the duty of ensuring that simultaneous substitution is done correctly. They must also share in the responsibility of explaining to Canadians the policy’s benefits and in correcting misinformation in the public sphere.

There is an important distinction to be made between authorizing broadcasters to substitute signals and forcing them to do so and the time has come for broadcasters and distributors to start speaking up on simultaneous substitution rather than simply passing blame onto the CRTC. We do recognize however the efforts that you have demonstrated in tweets posted yesterday.

In an effort to ensure Canadians do not receive contradictory information from the CRTC and Videotron it would be appreciated if you could remind your customer service representatives that broadcasters choose whether to substitute signals and that both the broadcaster and the distributor are responsible for the quality of the substitution.

I would also ask you to provide a report outlining the training your customer service representatives receive on this issue, as well as copies of fact sheets or other materials at their disposal.

This information will assist the CRTC in its ongoing monitoring of Canadians’ concerns regarding simultaneous substitution and other issues relating to their television system.

I thank you in advance.

Origianl signed by

Sincerely,
Scott Hutton
Executive Director, Broadcasting

CC: Peggy Tabet
Director, Regulatory Affairs, Videotron
tabet.peggy@quebecor.com

 

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