The way I understand it, is that the channel has to be carried over the air to require the simsub.
IE. In Edmonton last year CTV had an HD station, but it wasn't OTA. Shaw didn't have to simsub it. Also Calgary already had an OTA CTV HD channel at the time (same time zone), they didn't have to simsub that into Edmonton either.
I'm pretty sure the simsub rules are directly tied to the channel being available over the air in your area. The problem with victoria is were right on the cusp of being able to get CTV HD. For the most part you can't, unless you're in a higher elevation and have a good outdoor antenna.
Last edited by downbeat; 2012-02-09 at 01:33 PM.
Reason: Quote removed