OTTAWA – With the very future of the Canadian Television Fund in question, the CBC along with the independent production community are urging the CRTC to postpone its plans to review funding for new media in September. The CRTC has put out a call for comments (Broadcasting Public Notice CRTC 2008-62) regarding its proposed changes to its public benefits policy that would create new funding streams for new media within the CTF.
In just the last few weeks, the Harper government has cut tens of millions in funding to arts program and has so far given no indication if it will continue supporting the Canadian Television Fund and the Canada New Media Fund beyond March 31.
Bev Kirshenblatt, senior director, regulatory affairs, CBC/Radio-Canada wrote last Friday to Robert Morin, secretary-general of the CRTC, requesting the public comment process be delayed “until after the Department of Canadian Heritage has determined the future structure of the Canadian Television Fund and the commission has carried out its review of new media and rendered its decision on the proper regulatory treatment for new media.”
Without knowing what the future funding for the CTF will be and without a completed review of new media, Kirshenblatt contends that “interested parties would be required to comment on a wide range of hypothetical scenarios involving possible CTF structures and possible regulatory approaches to new media – each of which would raise its own unique policy concerns.”
She added that even if the CBC could cover all possibilities and issues in its submission it is “still conceivable (indeed likely) that many parties would fail to identify the exact scenario which will ultimately ensue with respect to the CTF and new media. Consequently, many parties would never actually be given a proper opportunity to comment on the appropriate benefits policy for that scenario.”
Canada’s independent production community consisting of the CFTPA, ACTRA, DGC, DOC and the WGC have joined to support the CBC’s call to postpone the review.
In a letter to the CRTC Wednesday they also asked the commission to postpone its call for comments (Broadcasting Public Notice CRTC 2008-58) on its proposal to amend the criteria of the CRTC’s Certified Independent Production Funds in order to provide these funds with greater flexibility to support new media. They write, “From the independent production community’s perspective, seeking comment on proposals such as the one to amend the criteria of the CRTC’s Certified Independent Production Funds in order to provide these funds with greater flexibility to support new media is akin to putting the cart before the horse.”
Kirshenblatt comments that the review of new media is “to assess what kind of impact the Internet has had on traditional media; to determine the kind of role new media plays when it comes to broadcasting content; to assess whether new media broadcasting content should be supported; and, if so, to determine how such support should be provided and at what level.”
She adds that “until those questions have been both asked and answered in the new media proceeding and the commission’s subsequent decision, it would be premature to amend the benefits policy.”
Furthermore, the CBC notes that the CTF’s new media pilot project is still at the proposal stage and, in particular, eligibility criteria have not yet been established. “CBC/Radio-Canada questions how parties are supposed to comment on the merits of directing benefits to this fund when it isn’t clear what shape or direction CTF’s new media fund will take and, indeed, whether it will even exist under the CTF’s final structure as determined by Canadian Heritage,” writes Kirshenblatt.
In fact she says its “inappropriate for the commission to solicit public comment – and presumably make a determination on – its proposal to allow applicants to designate whether their benefit contributions would be directed to the private sector fund of the CTF or the public sector fund” since the department of Canadian Heritage has still not ruled on the commission’s recommendation for a public/private split in the CTF.
Kirshenblatt cautions that such a split “would seriously undermine CBC/Radio-Canada’s Canadian production capacity, add an unnecessary layer of administration and require the development of an entirely new set of funding criteria to establish what will ultimately be an artificial and counterproductive distinction between “popular” and “cultural” programming.”
If the commission still decides to proceed with the comment process the CBC says it expects an opportunity to make a second round of submissions once the structure of the CTF and the regulatory regime for new media have been finally determined.
