Broadcasting - Staff Letter addressed to the Distribution List
Ottawa, 1 November 2024
References: 1011-NOC2024-0137
BY E-MAIL
Distribution List
Subject: Broadcasting Notice of Consultation 2024-137 – Request for additional information regarding closed captioning provided by online undertakings
On June 25, 2024, the Canadian Radio-television and Telecommunications Commission (CRTC) launched its call for comments on the development of a regulatory policy for closed captioning provided by online streaming undertakings (Broadcasting Notice of Consultation 2024-137). On September 10, 2024, the CRTC extended the period for the submission of interventions to November 13, 2024.
After examining the record of the proceeding so far, CRTC staff requires further information from advocacy groups, industry organizations, and online undertakings.
Recipients of this letter are asked to respond to the questions contained in the appendix to this letter and to file those responses with the CRTC using GCKey by no later than 13 November 2024.
Parties that have not yet filed an intervention may respond to these questions in their interventions in addition to the questions set out in the Notice of Consultation. Only parties who file interventions may file a reply to matters raised during the intervention phase. Replies are due on December 13, 2024.
As per section 25.3 of the Broadcasting Act, a person may designate certain information as confidential. As set out in Broadcasting and Telecom Information Bulletin CRTC 2010-961, Procedures for filing confidential information and requesting its disclosure in Commission proceedings, a person designating information as confidential must provide a detailed explanation on why the designated information is confidential and why its disclosure would not be in the public interest, including why the specific direct harm that would be likely to result from the disclosure would outweigh the public interest in disclosure. Furthermore, a person designating information as confidential must either file an abridged version of the document omitting only the information designated as confidential or provide reasons why an abridged version cannot be filed. All documents must be received, and not merely sent, by the dates indicated, and all submissions are to be made in accordance with the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure, SOR/2010-277.
Responses to this request for information will be added to the record of Broadcasting Notice of Consultation 2024-137.
Yours sincerely,
Nanao Kachi
Director, Social and Consumer Policy
Distribution List
David Errington, Accessible Media Inc., david.errington@ami.ca
Kevin Goldstein, Accessible Media Inc., kevin@goldsteincommunicationslaw.com
Joanne Pitkin, Amazon Prime Video, joabpitk@amazon.com
Gabriella Levkov, Amazon Prime Video, crtc-regulatory-contacts@amazon.com
Lisa Anderson, Anderson Accessibility Research and Consultation, anderson.access.arc@gmail.com
Roberta Westin Rubinstein, Apple Canada Inc., robertawestin@apple.com
Monika Ille, Aboriginal Peoples Television Network Inc., mille@aptn.ca
Hélène Messier, Association québécoise de la production médiatique, rbrousseau@aqpm.ca
Jeanne Choquette, Audition Québec, presidence@auditionquebec.org
Jonathan Daniels, Bell Media, bell.regulatory@bell.ca
Terra Noble, Blue Ant Media Inc., terra.noble@blueantmedia.com
Kimberley Hayes, Bragg Communications Inc., regulatory.matters@corp.eastlink.ca
Richard Cavanagh, Broadcasting Accessibility Fund, richard@baf-far.ca
Eric Lieberman, Buena Vista International (Walt Disney Company), eric.lieberman@disney.com
Christa Dickenson, Cable Public Affairs Channel Inc., cdickenson@cpac.ca
Kimberly Wood, Canada Deaf Grassroots Movement, canadadeafgrassrootsmovement@gmail.com
Richard Belzile, Canadian Association of the Deaf, info@cad-asc.ca
Bev Kirshenblatt, Canadian Broadcasting Corporation/Radio-Canada, bevkirshenblatt.regaffairs@cbc.ca
John Roman, Canadian Communications Systems Alliance, jroman@ccsaonline.ca
Alain Strati, Canadian Media Production Association, patrick.smith@cmpa.ca
Megan McHugh, Canadian National Society of the Deaf-Blind, mchugh.mm@gmail.com
Carl Beaudoin, Le Conseil provincial du secteur des communications du Syndicat canadien de la fonction publique, hhafer@scfp.ca
Karen Gifford, Corus Entertainment Inc., corus.regulatory@corusent.com
Matt Thompson, Corus Entertainment Inc., corus.regulatory@corusent.com
Ben Haskey, DAZN Limited, legalnotices@dazn.com
Terri Nolt, Deaf-Blind Planning Committee, dbpc2.0@gmail.com
Jeffrey Beatty, Deaf Wireless Canada Committee, regulatory@deafwireless.ca
Winnie Luk, Disability Screen Office, winnie.luk@dso-orphe.ca
Arun Krishnamurti, Google LLC, akrishnamurti@google.com
Joel Fortune, Independent Broadcast Group, jfortune@fortunelaw.ca
Stephane Cardin, Netflix Inc., scardin@netflix.com
Rachana Bhowmik, Netflix Inc., rbhowmik@netflix.com
Mohit Sethi, Netflix Inc., msethi@blg.com
Susan Makela, Paramount Global, susan.makela@paramount.com
John Lawford, Public Interest Advocacy Centre, jlawford@piac.ca
Frédérique Couette, Québecor Média Inc., frederique.couette@quebecor.com
Lucie Nault, Réseau québecois pour l'inclusion sociale, direction@reqis.org
Robert Ranger, RNC Media, robert.ranger@rncmedia.ca
Susan Wheeler, Rogers Media Inc., susan.wheeler@rci.rogers.com
Jared Sher, Roku Inc., jsher@roku.com
Kevin Spelay, Saskatchewan Telecommunications, document.control@sasktel.com
Megan Bruce, Sony Pictures Entertainment, megan_bruce@spe.sony.com
Dominic Gourgues, Télé-Quebec, dgourgues@telequebec.tv
Lecia Simpson, Telus Communications Inc., regulatory.affairs@telus.com
Carolyn Forrest, Tubi Inc., cforrest@tubi.tv
Marie-Philippe Bouchard, TV5 Québec Canada, david.cantin@tv5.ca
David Cantin, TV5 Québec Canada, david.cantin@tv5.ca
Stephanie Ubogu, Universal Pictures Subscription Television Limited, stephanie.ubogu@nbcuni.com
Appendix
Questions for advocacy groups and industry organizations
- To address issues that may remain unresolved following this proceeding, comment on the feasibility or appropriateness of creating an industry-led working group focused on the provision of closed captioning by online undertakings. What group or organization should lead or coordinate the working group? How should the working group operate (i.e. how often should it meet, who should take part, how often should it report to the CRTC)?
Questions for online undertakings
- Are advertisements, promotional content or other short-form content that appear on your platform(s) closed captioned? If not, explain why and comment on what an appropriate timeframe would be to require closed captioning of this content.
- What percentage of your content library is original programming and what percentage of your platform’s content is third-party content? Provide a breakdown for pre-recorded and live programming for each platform or service you operate.
- Are there instances in which closed captioning cannot be made into a contractual requirement for third-party content? If yes, provide examples.
- What timeframe would be feasible to ensure that closed captioning is included in the contractual agreements on a going-forward basis for all third-party content acquired by each of your online platforms?
- Some online streaming services allow users to search for programs with a filter for closed captioning. Does your platform include such a feature? If it does not, comment on the feasibility or appropriateness of adding it, including timelines for implementation.
- Some online streaming services have a tool that allows users to flag problems or errors with closed captions while viewing a program. Does your platform include such a feature? If it does not include this feature, comment on the feasibility of adding it, including timelines for implementation.
- In the case of a complaint about the closed captioning of a program, confirm if it is possible to retain a copy of that program while the complaint is being addressed, particularly after the program is no longer available for public consumption on the platform.
- To address issues that may remain unresolved following this proceeding, comment on the feasibility or appropriateness of creating an industry-led working group focused on the provision of closed captioning by online undertakings. What group or organization should lead or coordinate the working group? How should the working group operate (i.e. how often should it meet, who should take part, how often should it report to the CRTC)?
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