Excerpts from comments submitted to CRTC
As we wait for the CRTC's ruling, I present below some excerpts of comments submitted to the Commission from Canada's media companies and some ancillary groups.
Of particular interest to members of this forum is information from some firms about their intentions relating to DTV conversion in non-mandatory markets.
Culled from
http://support.crtc.gc.ca/applicant/applicant.aspx?pn_ph_no=2010-169&lang=E
Re-arranged in alphabetical order by name of intervener.
Astral
(Direct quote) Astral’s intention is to convert its Dawson Creek and Terrace stations, as well as its Prince Rupert repeater, to digital by August 31, 2011.
Astral’s intention to convert these stations, however, is conditional upon the future resolution of two issues: (a) the renewal of its affiliation agreements with the Canadian Broadcasting Corporation (“CBC”); and (b) reducing costs associated with the capital expenditures for a new transmitter and new studios.
Canadian Media Guild — Union representing media workers
(Direct quote, with modification where indicated by parentheses) We therefore have four main recommendations during this proceeding:
• Commit to maintaining a universal system of free, OTA television after the transition to digital
• expand the list of mandatory markets to include all originating stations, with a more flexible transition deadline for the stations in the smaller markets.
• launch a multiplexing trial in a smaller community that is not on the current list of mandatory markets for digital conversion, in addition to the conversion trial(s) that you propose take place in the mandatory markets. Such a trial could be financed in part by the small market local programming fund.
• establish a DTV transition committee, primarily to co-ordinate and monitor the public awareness campaign for the transition; participants should include the Commission, broadcasters, Industry Canada and consumer/citizen groups.
(None of the statistics take) into account TV sets in all households, including supplementary sets in BDU households, that are not connected to a BDU service.
The results of a survey conducted by the CMG in Kamloops, B.C., (…) indicate that there is latent interest among cable viewers to switch to OTA viewing. Among existing cable viewers, 20% said they would prefer to watch 3 channels over the air than to pay for cable. The figure jumped to 33% if 6 channels were available, something that would be possible with digital multiplexing.
Canwest
(Direct quote) As indicated in Table A below, our current plan (subject to change) is to discontinue the operations of thirty-five (35) over-the-air analog broadcast transmitters effective 31 August 2011 (with no digital replacement). Eleven (11) of those transmitters are full power as per the above-noted definition of that term.
(The following is my synthesis of Canwest's supplied list in Table A.)
B.C.: Skaha Lake, Salmon Arm, 100 Mile House, Bowen Island, Canoe, Oliver (CHBC-TV-3), Brackendale, Williams Lake, Castlegar, Nelson, Creston, Whistler, Squamish, Revelstoke (x2), Taghum, Grand Forks, Enderby, Quesnel, Santa Rosa, Pritchard, Apex Mountain.
N.B.: Miramichi City, Woodstock, St. Stephen.
N.S.: Antigonish, Mulgrave.
Alta.: Brooks, Burmis, Drumheller, Banff, Coleman, Pincher Creek, Waterton Park.
Sask.: Fort Qu'Appelle.
Note that many of the affected transmitters are operating near or past their useful lives and replacement parts and equipment are increasingly difficult to source and install. Where practical, our intention would be to harvest some of the equipment from the above-listed sites for possible use at other analog sites.
At the remaining analog transmitter sites in the non-conversion markets (see Table B below), our intention is to continue to provide an analog signal until it is no longer possible or viable to do so.1 In those cases, we would then have to decide whether to repair the analog transmitter if parts were available and/or can be salvaged from other analog transmitters, or forego an over-the-air analog signal in that particular market. That is, in these cases, transmitter decisions would be made on a case-by-case basis if and when the analog transmitter in operation is no longer viable.
(The following is my synthesis of Canwest's supplied list in Table B.)
Ont.: Peterborough, Bancroft, Midland, Fort Erie, Sarnia, Owen Sound, Sudbury, North Bay, Sault Ste. Marie, Timmins.
B.C.: Kelowna, Penticton (CHKL-TV-1 and CHBC-TV-1), Kamloops, Courtenay, Wilson Creek, Oilver (CKKM), Vernon (CHBC-TV-2 and CHKL-TV-2), Prince George, Trail, Chilliwack.
Alta.: Red Deer.
Man.: Minnedosa.
N.S.: Sydney, Wolfville, Bridgewater, Truro, New Glasgow, Yarmouth, Shelbourne.
Note that our plan was specifically designed to reflect the Commission’s transmitter policy in non-mandatory conversion markets as outlined in paragraphs 183-191 of BRP CRTC 2010-167. This policy requires an OTA broadcaster to operate a transmitter in a given market if it wants to avail itself of certain regulatory “protections,” such as simultaneous substitution and mandatory carriage. Canwest has argued in past proceedings that this policy requires reconsideration.
CBC
(Direct quote) CBC/Radio-Canada intends to continue broadcasting in analog in smaller markets. The Corporation has 18 transmitters that operate in the UHF Channel 52-69 spectrum in non-mandatory markets, of which 15 are located within the Canada-US coordination zone. We are currently assessing whether it will be possible to continue to operate on analog by way of a change in channel in these markets.
CACTUS — A group representing community TV stations
(Direct quote) We suggest that in any market or community where a public or private broadcaster elects to discontinue service after the digital transition in August of 2011, that the transmission equipment used by that broadcaster either be a) donated to the community or b) space on that tower and access to the existing analog transmitter be granted in perpetuity so that the community would have the choice to:
• Maintain the equipment and offer rebroadcasting services for the departing public or private broadcaster should the community so wish, and/or
• Use the equipment (tower and transmitter) to offer an over-the-air community programming service.
We consider that this would at least partially compensate such smaller markets for the withdrawal of service, and equip them to deal with similar shifts in the communications environment in future.
CCSA (Canadian Cable Systems Alliance)
(Direct quote, with modification where indicated by parentheses) (OTA viewer estimates) contain no allowance for those viewers who receive Canadian cable or satellite services illegally, who pirate foreign satellite services or who rely solely on US off-air border stations.
In short, CCSA believes that the number of legitimate OTA-dependent viewers outside the mandatory markets, those who stand to be truly disenfranchised, has been significantly overstated.
Corus
(Direct quote) At present, it is our expectation that we would apply to convert CKWS-TV Kingston and CHEX-TV Peterborough to digital high-definition (HD) transmission during the 2011/2012 broadcast year. In the meantime, it is our intention to provide a direct HD feed of our Kingston and Peterborough signals by Fall 2010 to Cogeco Cable, the cable licensee serving these markets.
Corus is currently reviewing the implications of converting the remaining five stations to digital at some point in the future. We will advise the Commission of our plans in this regard once we have determined the appropriate course of action.
CTV
(Direct quote) In the non-mandatory markets, CTVgm’s stations will transition to digital as the equipment in the respective locations wears out, assuming that these local stations are financially sustainable. In the meantime, these stations will continue to operate using their analog transmitters after August 31, 2011.
Vancouver would be the most easily achievable as a trial market given that technical resources are available in the region. Vancouver, with its mountainous terrain and tall buildings, would also be a good sample market for other centres across the country.
Jim Pattison Group
(Direct quote) The JPBG stations are not currently mandated by the CRTC to have OTA HD transmitters. JPBG may take a look at that once the decision from this current proceeding is issued, again based on the above-noted assumptions regarding carriage and funding. Accordingly, we currently have no plans to establish digital OTA transmitters; however, we continue to review the matter and will advise the Commission as appropriate if our plans change.
Rogers
(Direct quote) In these non-mandatory markets, we intend, at least in the short term, to align our plans with the majority of other broadcasters: to convert to digital, maintain analog transmitters, or provide a direct feed to BDUs.
We believe that it is in consumers’ best interests for broadcasters to take a consensus approach with respect to transmitters in non-mandatory markets – in our case, Red Deer, Alberta and Courtenay, British Columbia. We are concerned that if we convert our analog transmitter in Red Deer to digital and our competitors do not, then we will confuse consumers and subject ourselves to a competitive disadvantage.
TVA
(Translation) TVA expects its competitors — especially other conventional broadcasters — to follow the guidelines set forth by the CRTC. For example, if CBC does not convert in mandatory markets within the prescribed timeframe, TVA should be compensated for whatever competitive disadvantage to TVA arises from the CBC's non-conformity with regulations.
TVO
(Direct quote) TVO intends to transition to DTV facilities in the six mandatory markets identified by the Commission in Broadcasting Regulatory Policy 2010-167, subject to receiving funding from the provincial government. With respect to the issue of the digital transition outside of mandatory markets, TVO’s plans are at the present time not yet finalized. TVO in many cases shares towers and related facilities with other over-the-air broadcasters. A final determination on the steps taken in these markets will be influenced in part by the steps that other broadcasters will take in this regard.
