September 28, 2015

By fax: (819) 994-0218

Mr. John Traversy Secretary General CRTC,Ottawa, Ontario, K1A 0N2

RE: A review of the policy framework for local and community televisionBroadcasting Notice of Consultation CRTC 2015-421

Dear Sir,

1. The Community Media Policy Working Group (the “Policy Working Group”) will participate in the above-noted proceeding and will be filing comments with respect to the Commission’s formal review of itscurrent policy framework for local and community television. The Policy Working Group is composed ofrepresentatives of the Canadian Association of Community Television Users and Stations (CACTUS), the ,the Fédération des Télévisions Communautaires Autonomes du Québec (the Fédétvc), community radiopractitioners, community online media (the Media Coop) and gaming (Hand Eye Society). It is overseen byan academic researcher from Carleton University, Dr. Kirsten Kozolanka and a steering group composed ofDr. Kozolanka and Dr. Dwayne Winseck, Carleton University, Robert Hackett, Simon Fraser University, Dr.Florian Sauvageau,University of Laval and author of the 1986 Report on the Task Force on Broadcastingand Clifford Lincoln, author of Our Cultural Sovereignty, the 2003 report by the Standing Committee onCanadian Heritage. For the reasons set forth below, the Community Media Policy Working Group herebyrequests that the Commission extend the filing date for comments in the above noted proceeding fromOctober 29, 2015 to December 11, 2015.

2. The Community Media Policy Working Group is conducting research under a Social Sciences andHumanities Research (SSHRC) grant to develop policy proposals to ensure that the community element inthe Canadian broadcasting system can maximally fulfill its potential and role as defined under theCanadian Broadcasting Act. This work was undertaken this year, following the CRTC's “Let's Talk TV”proceeding with two purposes:

i) to examine the needs of community mediaincluding issues of convergencein the digitalenvironment, and to articulate a policy proposal to enable it to meet the potential expected of itunder the Broadcasting Act

ii) with the knowledge that the CRTC intends to review its community TV policy within the 2015/16year.

3. The first phase in this research is almost complete. In August of 2015, community media practitionersand academics and researchers that study community media were invited to participate in an onlinesurvey and to participate in focus groups in major Canadian cities to collect information about theirusage of community media, their perception of the strengths and weaknesses of community mediaorganizations in their communities, and proposals to strengthen those organizations and enable them tobetter meet their mandates. The Policy Working Group will be meeting during the second week ofOctober, 2015 to review the results and to begin to generate policy proposals that respond to thesuggestions of the more than 400 respondents to the survey—by far the largest survey of this kind everundertaken. The focus groups are still on-going, and the data generated during those sessions will beadded to the data set.

4. During the second phase, the Policy Working Group—relying on subject matter experts as needed—willgenerate a draft policy proposal based on the feedback and data collected during Phase I. We anticipatethat this phase will take one month, and be concluded by mid-November. This document will becirculated back to the survey and focus group participants to see whether it addresses the issues theyraised.

5. In phase III, community media practitioners from across Canada (TV, radio, online and gaming) will meet inOttawa on November 22 and 23, 2015 with researchers, policy-makers, and international invited expertsto examine a range of individual policy issues in panels, culminating in a policy forum to review, discussand finalize the draft policy proposal on the third day (Nov. 24, 2015). Our intent is to incorporate thefeedback garnered live at the policy forum into the policy proposal and to submit it to the CRTC's reviewof its community TV policy, in addition to other government agencies whose policies affect communitymedia.

6. The purpose of this letter is therefore to request an extension to the deadline for written comments forthis proceeding to enable this research to be concluded. We are of the opinion that it would be in thepublic's and in the Commission's best interest to have access to this research in the decision-makingprocess. We note that such an extension to the deadline for written comments would not prevent theoral portion of the consultation from proceeding as planned on January 26, 2016.

7. We believe it is pertinent to draw to the Commission's attention to the panel topics that were developedin April, 2015 as part of the SSHRC grant-writing process and which will form the first two days of theconference. They correspond closely to the questions asked in the Commission's public notice ofconsultation, and therefore both the Commission and individual stakeholders who may wish to respond tothe questions will benefit from access to the information presented. We attach the full program for thetwo days of panels at the end of this document, but would draw your attention in particular to thecorrespondence between the following Commission questions and the panel topics planned:

Commission Observation or Question Panel Topic

“The Canadian broadcasting system should:...

provide a reasonable opportunity for

the public to be exposed to the

expression of differing views on

matters of public concern; and

The first stream is entitled “Government, Democracy and Community Media” and includes panels about community media's role in supporting open government, community media and public discourse, and the role of community media in an environment of intense media ownership concentration.

provide a wide range of programming

that reflects Canadian attitudes,

opinions, ideas, values and artistic

creativity”

Regarding 'artistic creativity', the “Content” stream includes a panel entitled “Getting Outof the Box: Exploring New Programming Formats” that will explore the role of community media in encouraging new uses of traditional media, that push its boundaries.

“The Commission has developed different regulatory approaches for the local and community programming provided by conventional television stations on the one hand and community programming services ...These approaches are due primarily to the different role played by these types of programming services. However, many similarities also exist in the local programmingoffered by both types of service. “

The Community Media Festival to be held during the three evenings of the Community Media Convergence will showcase the qualitative difference between 'community programming' and 'local programming'. We anticipate that the submissions will meet the Commission's definition of “compelling” programming

and encourage its staff to familiarize itself with the output of the sector it seeks to regulate in this proceeding.

Much of the public notice concerns funding for local and community content, and the notice states: “It has since become easier for Canadians to access the means of production while the complexity involved in creating content has decreased. Moreover, Canadians now have access to the Canadian broadcastingsystem in ways they never have before, for example, by uploading their own content on Internet platforms.”

One of the goals of the Community Media Convergence is to help community media organizations leverage the array of new technologies at their disposal to facilitate citizen access, and to find ways to fund these new technologies, including digital HD production, editing, playback and distribution equipment, and to meet the increasing (rather than decreasing) need for Canadians to receive adequate training and support to use these new tools. Two streams (with multiple panels each) aredevoted to these issues: “Funding” and “New Technologies.”

“Q5. Is a physical local presence still needed in the digital age? In considering this question,are studio facilities and local staff required to provide meaningful locally reflective and

locally relevant programming? “

Stream 4 offers four panels about “Staff and Volunteer Management,” and why places in the community wherecommunity members can congregate are as vital (if not more, in a digitally networked world) than ever.

A number of the Commission's questions deal with the regionalization of BDU community channels, for example: “Consolidation within the distribution sector has led BDUs to centralize their operations, including community channel production and administration, to realize cost efficiencies.”

In the “New Technologies” stream, a panel is planned entitled “Distributed Hub Structure or Multiple Locations for Public Access”, which will explore how community-based media organizations are enabling more hyperlocal access to production equipment, training, and support through collaborations among them. The opposite trend is occurring to that in the BDU sector: not regionalization, but hyperlocalization.

“The centralization of BDU operations and the consequent regionalization of services has hadthe additional effect of making it difficult to monitor, particularly for members of the public, whether BDUs are meeting their expenditure and exhibition requirements in each community.”

Panel 3 in the “Funding Stream” will deal with “Financial Accountability” of community media organizations and “Lessons from the Community Radio Fund of Canada”.

“In light of the technological, cost and market changes for community access programming and the community channel, it is important that the Commission’s approach to ensuring access by Canadians to the broadcasting system is forward looking and takes into account new forms of distribution and consumption. “

The first panel in the “New Technologies” stream will deal with “Multiplatform Distribution”. The fourth panel is entitled “Gaming and Interactivity: CommunityMedia 3.0” and will deal with how more and more video content is being created and consumed at the community level via gaming.

Q18. What measures should be taken to ensure that programming from diverse linguistic groups including OLMCs and ethnic groups as well as Aboriginal groups is made available and is reflective of the communities BDUs serve?

The “Content” stream will offer a panel focusing on “Multilingual Programming”.

At both questions 10 and 20, the Commission asks, “How should the Commission and Canadians measure the success of any framework that is proposed?”

Stream 6 examines how to “Maximize Community Impact and Engagement”, including measurement toolsand assessment parameters for community media and community media organizations.

The Commission provides a summary of the development of its community TV policy over time; for example, this statement: “The Commission’s long-standing approach to the funding and support of the community channel has relied on BDUs across the country providingboth the funds for its operation and the infrastructure to support it. “

The final stream in the two days of panels is entitled “International and Historic Perspectives on Community Media” so that conference attendees can better understand the Commission's current and past policies with regard to the community element in light of trendsin other countries.

The Commission's notice fails to raise two additional themes that will be raised at the convergence andwhich the Policy Advisory Committee believes to be important and germane to the policy review,including the archiving and preservation of community media (Stream 8), and the creation and deliveryof community media services in a holistic fashion, so that Canadian citizens can 'one-stop-shop' fortraining and support to function and get their messages out in the digital environment. While theCommission raises the issue of multiplatform distribution for community-generated video content (aka'community TV') and the conference will deal with Multiplatform Distribution in Stream 2 (“NewTechnologies”) as noted above, Stream 2 also deals with the “Integration of Production Technologies”,whereby training and access for the production of video, radio, online and new media content including

gaming is increasingly being offered from the same community-based facilities. i.e. The Commissionnotice anticipates the impact of additional platforms for the output of community media, but the noticeappears to miss the impact of the convergence of production technologies or input of community media.This reality (the digital environment) is the driving force and provides the overarching context for howthe conference has been organized, and we believe it will offer the Commission's review of its communityTV policies an important digital context.

8. In summary, it is our belief that the Community Media Convergence planned for Nov. 22-24, 2015 isentirely germane to the Commission's planned review of its community TV policy, and that the researchand views to be presented and formulated during the three days should be available to all stakeholdersand to the Commission in its deliberations.

9. We note that Chairman Blais and the CRTC staff have recently expressed their desire to better engagescholars; for example at the Canadian Communication Association conference in June. Community mediais a particularly under-researched area in Canada. This conference presents an important opportunity forpractitioners, policy-makers and scholars to remedy that lack.

10. For all these reasons, the Policy Working Group submits that extending the filing deadline for commentsto December 11, 2015 will be in the public’s and Commission’s best interest, and will prejudice no party.The extension will give all parties that attend the conference sufficient time to submit their views andresearch to the proceeding, including the Community Media Policy Working Group, which will submit theresults of the Policy Forum—which incorporates the survey and focus group research on-going this fall.

11. Thank you for your consideration of our request. Please feel free to contact us if you require any additional information.

Sincerely,

Principal Investigator: Dr. Kirsten Kozolanka, Associate Professor, School of Journalism and Communications, Carleton University. Author of Alternative Media in Canada. with Patricia Mazepa & David Skinner, eds. Vancouver, BC: UBC Press, 2012.

...from the SSHRC Steering Group:Dr. Dwayne Winseck, Professor, School of Journalism and Communications, Carleton University. Author of Communication and Empire, winner of the Canadian Communication Association’s ‘book of the year’, 2008.

Dr. Robert Hackett, Professor, School of Communications, Simon Fraser University. Co-founder, Media Democracy Days. Co-director, NewsWatch Canada. Winner, Dallas Smythe award, Union for Democratic Communications, 2015.

… from the Community Media Policy Working Group:Catherine Edwards, Executive Director, the Canadian Association of Community Television Users and Stations. Author, Community TV Policy and Practices Worldwide, commissioned by the CRTC, 2009.

Amélie Hinse, Directrice, Fédération des Télévisions Communautaires Autonomes du Québec (the Fédétvc)

André Desrochers, Past President, Fédération des Télévisions Communautaires Autonomes du Québec (the Fédétvc), current member and co-founder of CSUR community TV in Vaudreuil-Soulanges.

David Murphy, Hand Eye Society and PhD Candidate, Communication and Culture, York and Ryerson

Darryl Richardson, Editor, the Media Coop.

Dr. Michael Lithgow, Course Lecturer, Carleton University, School of Journalism and Communication. Author of Transformations of Practice, Policy, and Cultural Citizenships in Community Television” (Chapter 6 in Alternative Media in Canada Kozolanka, Kirsten, Patricia Mazepa and David Skinner. 2012. Vancouver: UBC Press.)

Dr. Christopher Ali, Assistant Professor, Department of Media Studies, University of Virginia. Author of Media Localism, an analysis of local and community media policies in Canada, the United States and the United Kingdom.

Community Media Convergence: The First National Professional and Policy Development Conference in Canada

November 22-24, 2015

Three days of presentations, professional development and skill sharing workshops, awards and screenings, culminating in a policy development assembly.

The CMC is a multi-stakeholder conference, bringing together community media practitioners from TV, radio, online media, and gaming with researchers, scholars, and policymakers.

The CMC has two goals: 1) to build professional and sustainable community media practices for the digital age; and 2) to explore the pros and cons of a more integrated approach to community media policy in the digital environment.

The CMC will enable community media to flourish: 1) by informing the community media policyreview being conducted by the Canadian Radio-television and Telecommunications Commission (CRTC) in 2015-2016; and 2) by increasing the capacity of individuals, activists, journalists, not-for-profits, libraries, small businesses, First Nations, third-language communities, and local governments to create, distribute, fund, and archive community media.

PARTICIPATING ORGANIZATIONS include:The Canadian Association of Community Television Users and Stations (CACTUS)School of Journalism and Communications, Carleton UniversitySchool of Communication, Simon Fraser UniversityUniversité de Laval, QuébecACTRA, CMPAFédération des télévisions communautaires autonomes du QuébecThe National Campus and Community Radio Associationl'Association des Radios Communautaires du CanadaThe Ruth and Henry Good Fund for Social and Environmental JusticeCWA/SCA Canada, Canadian Media Guildrabble.ca, The Media Co-opFriends of Canadian BroadcastingPublic Interest Advocacy CentreMinistère de la Culture et Des Communications, QuébecNational Film Board of CanadaIndependent Media Arts Alliance (IMAA/AAMI)The Ontario Public Service Employees' UnionThe Department of Canadian Heritage

WORKSHOPSThe first two days of the CMC will offer professional development and skill sharing workshops held concurrently along the following eight streams:

Stream 1: Government, Democracy, and Community Media1) Community Media to Support Open Government; 2) Other Local Government Programming 3) Community Media and Public Discourse 4) Community Media and Media Ownership Concentration

Stream 2: New Technologies1) Multiplatform Distribution 2) Integration of Production Technologies 3) Distributed Hub Structure or Multiple Locations for Public Access 4) Gaming and Interaction: Community Media 3.0?

Stream 3: Content 1) Open-Access Policies, Coherency and Professionalism 2) Multilingual Programming; 3) Getting Out ofthe Box: Exploring New Programming Formats 4) New Partnerships, New Media: The Public Broadcaster and Libraries

Stream 4: Volunteer and Staff Management1) Volunteer and Staff Management 2) Community Media as a Training and Experimental Space for the Professional Industry 3) Equity and safe spaces 4) Governance

Stream 5: Funding Topics include: 1) Funding Community Media 2) Leveraging Infrastructure 3) Financial Accountability 4) Lessons from the Community Radio Fund of Canada

Stream 6: Maximizing Community Impact and Engagement1) Strategies for Community Engagement 2) Integrating Social Media into your Marketing Plan 3) Audience Meansurement

Stream 7: Archiving Community Media

Stream 8: International and Historic Perspectives on Community Media

Each workshop will provide a space for debating and reviewing the working document proposed for thepolicy development assembly.

POLICY DEVELOPMENT ASSEMBLY

The third day will be a policy development assembly to explore the pros and cons of a more integrated approach to community media policy in the digital environment. This day-long forum will inform a working policy document developed prior to the assembly with the participation of community media stakeholders. The CRTC and Heritage Canada will be invited to include the outcomes of the assembly inupcoming media policy reviews.

TABLING & TECHNOLOGY FAIRA tabling & technology fair will accompany the CMC, featuring demonstrations by technology companies supplying low-cost community solutions for radio, TV and online media; and tabling by government agencies, educational bodies, and other organizations with a stake in community media.

EVENING SCREENINGS & AWARDS PROGRAM These events will showcase community media productions and achievements.

REMOTE PARTICIPATION IN CONFERENCESessions will be streamed live, to enable remote participation. Community license-holders will be invitedto play the streams live, available nationally on Bell ExpressVu, on the FM dial, via the Internet, and archived on the conference web site.

LANGUAGE ACCOMODATIONThe workshops and policy development assembly will be facilitated in French and English with simultaneous translation.

For more information: Jessica Wind 613-883-0698 or jessica@ComMediaConverge.ca