ARCHIVED - Broadcasting Procedural letter addressed to Ms. Peggy Tabet (Québecor Média inc.)
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Ottawa, 19 July 2018
Our reference: 2017-1028-6
Ms. Peggy Tabet
Québecor Média inc.
612, rue Saint-Jacques
Montréal, Quebec H3C 4M8
Subject: Request for additional information regarding the application by Québecor Média inc. with respect to the provision of described video
Dear Ms. Tabet,
On 1 November 2017, Québecor Média inc. (Québecor), on behalf of Groupe TVA inc. (Groupe TVA), filed a Part 1 application with the Commission regarding the provision of described video as set out in Broadcasting Regulatory Policy CRTC 2016-436, Standard requirements for television stations, discretionary services, and on-demand services, 2 November 2016.
In order for the Commission to fully assess this application, further information is required from Québecor.
Accordingly, Commission staff requests that Québecor respond to the attached request for information no later than 20 August 2018, serving a copy to all other parties to the proceeding. Please respond to all questions in one document.
A copy of this letter will be added to the public record of the proceeding.
Parties will be able to submit comments in reply to Québecor’s responses no later than 30 August 2018.
Procedures for filing
As set out in Broadcasting and Telecom Information Bulletin 2010-961, Procedures for filing confidential information and requesting its disclosure in Commission proceedings, Québecor may designate certain information as confidential. It must provide an abridged version of the document involved, accompanied by a detailed rationale to explain why the disclosure of the information is not in the public interest.
All submissions are to be made in accordance with the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure, SOR/2010-277.
Original signed by
Social and Consumer Policy
Consumer Affairs and Strategic Policy
c.c. Rémi Savard, CRTC
Association des personnes handicapées visuelles de Lanaudière email@example.com
Association des personnes handicapées visuelles de l'Estrie
Canadian National Institute for the Blind firstname.lastname@example.org
Confédération des organismes de personnes handicapées du Québec email@example.com
Les Amirams de la Vallée firstname.lastname@example.org
Regroupement des aveugles et amblyopes du Montréal Métropolitain email@example.com
Regroupement des aveugles et amblyopes du Québec firstname.lastname@example.org
Attachment – Request for Information
In Broadcasting Decision 2017-147, the Commission noted that the costs relating to described video can prove significant and impact programming; however, it considered that Québecor did not demonstrate that it faced sufficiently significant financial difficulties to justify the exception it sought to the Commission’s policy on providing described video, which aims to improve access to the broadcasting system for Canadians with visual impairments.
Accordingly, the Commission imposed the following requirement on TVA Group’s discretionary services and television stations: to provide described video for all French- or English-language programming that is
- broadcast during prime time (i.e. between 7 p.m. and 11 p.m.) and
- drawn from the following program categories (“DV categories“)
- 2(b) Long-form documentary,
- 7 Drama and comedy,
- 9 Variety,
- 11(a) General entertainment and human interest and
- 11(b) Reality television, and/or
- is programming targeting preschool children (0-5 years) and children (6-12 years).
This policy change was reflected in Quebecor’s COL, which came into effect on 1 September 2017.
In its application, Quebecor, on behalf of TVA, requested a modification such that this COL would only apply to new programs that are first aired after 1 September 2019, noting that this was the same request that the Commission denied in Broadcasting Decision 2017-147, but that it was now providing additional arguments.
- Hours of DV during prime time
Staff seeks more information on the difference (i.e. reduction in described video) between the condition of licence in Broadcasting Decision 2017-147 (i.e. DV required during prime time for DV categories) and the amendment sought by Quebecor (i.e. DV required only for newly produced programming during prime time for DV categories).
Considering that there are 1,460 hours of prime-time programming in a broadcast year, provide the following information for all the services subject to Broadcasting Decision 2017-147:
DV requirement in 2017-147 Service 1 Service 2 Service 3 … Total for all services Hours of prime time programming in DV categories in 2016-2017 Hours of prime time programming in DV categories as % of total prime time hours in 2016-2017 Quebecor’s proposal – Projection for 2019-2020 Service 1 Service 2 Service 3 … Total for all services Hours of newly produced prime time programming in DV categories Hours of newly produced prime time programming in DV categories as % of total prime time hours Hours of DV’d rerun and acquired prime time programming, as well as DV’d prime time programming shared between services, in DV categories Hours of DV’d rerun and acquired prime time programming, as well as DV’d prime time programming shared between services, in DV categories as % of total prime time hours
Do you consider that your last complete broadcast year (2016-2017) represents a typical year in terms of the following:
- the hours or prime time programming in DV categories; and
- the hours of newly produced prime time programming in DV categories?
Explain why, and provide evidence to substantiate your position.
- Methods of producing DV
There are several methods of producing and acquiring DV content, and associated costs may vary by method.Footnote1 Assume, for the purpose of this question, that you remain subject to the condition de licence set out in Broadcasting Decision 2017-147. For the upcoming broadcasting year (2018-2019), fill out the following chart, using estimates.
DV requirement in 2017-147 Service 1 Service 2 Service 3 … Total for all services Hours of prime time programming in DV categories Hours of DV’d rerun prime time programming in DV categories Method(s) of producing/acquiring DV Cost for providing DV for prime time programming in DV categories Quebecor’s proposal Service 1 Service 2 Service 3 … Total for all services Hours of newly produced prime time programming in DV categories Hours of DV’d rerun prime time programming in DV categories Method(s) of producing/acquiring DV Cost of providing DV for newly produced programming only in primetime in DV categories
- Official documents demonstrating costs
In your application, you provided cost estimates for meeting your obligations with respect to described video under your current COL and under your proposed revised COL.
These estimates provided total estimated annual costs and hours to provide the required level of described video. However, Quebecor did not provide official documentation to support these estimates.
Provide the Commission with official documentation, in the form of a signed contract or official quotes, that show the cost and time required to have described video included in new/first-run programing (i.e. during production) and inventory programing (i.e. post production).
The official documentation should show the total estimated cost of (a) meeting Quebecor’s existing obligations (i.e. all programming in the DV categories during prime time) and (b) associated with Quebecor’s proposed modification to its COL.
If dealing with multiple companies, provide contracts or quotes from all companies.
For DV content to be produced by Quebecor or vertically integrated affiliates for the services targeted by this application, provide internal corporate documents demonstrating costs incurred, a copy of the accounting policies, as well as an attestation, signed by your corporate office, to the effect that the costs demonstration filed is accurate.
Official documentation must include the following:
- the name of the company/affiliate providing the described video service;
- the cost per hour of described video service;
- the total cost for described video services per broadcast year;
- the amount of hours of original described video being provided per broadcast year, and the dates for which the service is being provided.
- Vertical Integration Impact
In your last complete broadcast year (2016-2017), what percentage of the programming subject to the DV requirement in Broadcasting Decision 2017-147 was shared between two or more of your services?
In broadcast year 2018-2019, what percentage of the programming subject to the DV requirement as written in Broadcasting Decision 2017-147 do you expect to be shared between one or more of your services? How is this reflected in your analysis of the costs to provide DV? What would be the situation for broadcast year 2019-2020?
- CIPF DV obligation
In Broadcasting Regulatory Policy 2016-343, the Commission required that all programming funded by Canadian Independent Production Funds (CIPFs), regardless of its distribution platform, be closed-captioned and described.
Provide the following information for all the services subject to Broadcasting Decision 2017-147:
- for broadcast year 2016-2017, list all the programs broadcast during prime-time that received funding from a CIPF and thus, must be offered with described video;
- list all programs that were broadcast during prime-time and that have received CIPF funding since the end of broadcast year 2016-2017;
- list all programs that you plan to broadcast during prime-time, in the near future (now until the end of broadcast year 2018-2019), and that should receive funding from a CIPF and thus, will have to be offered with described video;
- provide, as a percentage, the proportion of the programming identified as newly produced prime time programming in DV categories (see table in question 1) that would receive funding from a CIPF and, therefore, require described video, in each of the three years of your proposed plan;
- an explanation as to how your contracts with independent production companies and programming providers have been updated to reflect the requirements set out in Broadcasting Regulatory Policies 2015-104 and 2016-343, as well as following Broadcasting Decision 2017-147.
- Date modified: