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Application to CTV for funding of the Open & Closed Project

Because you need us as much as we need you

A bit of background first

On 2006.07.12, a Canadian broadcasting/publishing conglomerate, Bell Globe Media (later renamed CTV Globe Media), announced an intent to buy another Canadian broadcasting conglomerate, CHUM Ltd., for $1.7 billion. That would give CTVGM control of two large television networks and many “specialty channels,” although, for various legal reasons, some of those would have to be sold to third parties. In any sale of a TV station in Canada, an extra 10% of the purchase price must be directed toward “tangible social benefits.”

We’ve been trying to get our hands on benefits money for years. And, on 2007.04.02, we made an application for money from this transaction and, as you’ll see, from previous ones, too. (Also available as PDF.)

See also

Actual application

This is an application for funding of the Open & Closed Project from tangible social benefits flowing from the proposed CTV Globe Media acquisition of CHUM Ltd. or from other sources.

We’ve got a pretty simple proposition for you:

The only way to achieve (e)quality is to research and test a set of standards. We’re the only people who want to do that, or are even remotely capable of it. We’re independent, nonprofit, and extremely well supported by industry and the grassroots. And we’re not asking for a ton of money.

What we’re going to do

We’re going to solve the problem of lousy captioning. And lousy audio description. And lousy subtitling and dubbing.

We’re going to do that by writing standards for those four fields. And unlike the CAB and broadcasters, we aren’t going to write down our current practices and pass them off as a standard. (We couldn’t. We aren’t in that business. We’re independent.) Instead, we’re going to develop standards based on research and evidence. If those are missing, we’ll carry them out ourselves.

We’ll write the spec, in an open process to which anyone may contribute, and we’ll spend a year testing the standard in the real world to make sure it works. (That process will be open to public comment, too.) After the standards are finalized, we’ll develop training and certification procedures for practitioners. It will finally be possible to become a certified captioner, for example.

And once we’re done, there won’t be 20 kinds of accessibility from 20 different providers. Everyone who signs on to the standard will do their work in exactly the same way, with natural variations for medium (TV is different from film) and language (English differs from French). You won’t have to relearn how to watch TV with every program and commercial.

For a broadcaster, you’ll actually know for sure you’re getting good work from qualified people as opposed to whatever work comes out of the lowest bidder’s shop. This kind of assurance of money well spent is something CTV Globe Media sorely needs.

Quantity vs. quality

CTV has already negotiated a human-rights settlement concerning quantity of captioning. Do you want to go through that all over again, for all your networks (including the ones you acquire from CHUM), not only on captioning but on three other grounds too? Because it can happen, and in fact it probably will: One blind group has already publicly stated it is preparing human-rights complaints against broadcasters on the topic of audio description.

How might a company head that off at the pass? Well, increasing quantity to 100% isn’t going to do it. (100% is never really 100%, either; there’s always an exemption, like overnight programming, or outside commercials, or promos and bumpers, or anything you don’t feel like including.) This time you’ll be dealing with complaints not merely about how much accessibility there is but how good it is. In captioning as it stands now, quality is where CTV would lose right away.

Ever since BCE took over Netstar, CTV networks have inched lower and lower on the totem pole when it comes to captioning. CTV fired its high-quality real-time captioning house, one that was beloved by staff at Discovery, in favour of somebody cheaper – and worse. CTV networks farmed out offline captioning to a company that doesn’t even have a phone listing and that does all captioning not only in scrollup, a feature that will lose a human-rights case right there, but in centred scrollup, in all capitals, using transcriptions strewn with errors. It is debatable whether or not those programs are actually “captioned.”

And while the company pinches pennies there, it proposes to spend a thousand million dollars buying a rival broadcaster. People have noticed that disparity and are going to do something about it.

Now, if CTV supported the independent, nonprofit development of standards for captioning, audio description, subtitling, and dubbing, and, in the interim, ceased certain practices that were known to be harmful, maybe those human-rights complaints wouldn’t even be filed. Or you’d negotiate a much more favourable settlement than in the previous case.

A way to show corporate responsibility

And at any rate, it is time to take accessibility seriously. We know you think you take it seriously already, but actions speak louder than words, and in this case, a bit of funding can speak even louder. CTV and CHUM networks and stations still have a great deal of uncaptioned programming and an immense amount of poorly-captioned programming. Barely anything is described for the blind. And, through its combined French-language channels, subtitling and dubbing threaten to become a real problem.

Taking accessibility seriously does not mean hiring the lowest bidder. Really, in 2007, it doesn’t. It means taking captioning and description, for example, as seriously as picture and sound, since captions and descriptions are picture and sound for viewers with disabilities. Picture and sound are rather important to CTV and CHUM – look at the investment in HDTV. Can we carry that concern for high quality to its ultimate end? Can we be so concerned with quality that we want to pay for outside research to make sure the entire industry is doing it right?

(Incidentally, you already pay for research, as with viewership ratings. This isn’t all that different, except in one way: It directly benefits real viewers.)

The Open & Closed Project has massive support

The Open & Closed Project has been in the works for five years and has attracted massive support.

Importantly, nobody has come out in opposition.

A research project has to have researchers lined up, and we do. We have a verbal cooperation agreement with the Adaptive Technology Resource Centre at the University of Toronto. We already have an actual scientific methodologist on board. We know other researchers in related fields, like psychology of reading, which is somewhat important when two of the four fields involve written words. These researchers can be expected to stay loyal to us. We’re the only game in town.

We’ve got this pretty much all sewn up. What we need now is money, and not a lot of it.

Budget

We need $500,000 for Year 1 and $7 million for the entire four- to six-year project. Half a million is what CTV gave to a single audio-description company in a previous transaction, so there’s a direct precedent. (Plus we’d be delivering more bang for the buck. That company described a few TV shows without open standards; we’re researching and developing those standards for a global industry.)

We have detailed budgets available for confidential review.

Funding

We see three mechanisms by which CTV Globe Media could fund the Open & Closed Project.

Unspent social-benefits funding from previous transactions
“Appendix 1A (Supplementary Brief) to BGM Reorganization Application” (CRTC 2005-1504-1) states that the company “will continue to support the $230 million benefits package approved as part of BCE’s acquisition of control of CTV in 2000,” and as part of other transactions, “until August 31, 2008.” We are reliably informed that $40 million to $50 million remains unspent. We apply for full funding of the Project’s entire term under that envelope.
Social benefits arising from the acquisition of CHUM
Failing the foregoing, we apply for the full $1.5 million earmarked for “research” (“Application to Effect a Change in Ownership and Control of CHUM Limited – Appendix 1A”). If not, the funding envelope for diversity ($3 million) could be partly directed to fund the Open & Closed Project’s first-year operations.
Fund us anyway
Even if neither of the above funding envelopes were appropriate, the Project deserves funding on its merits. We submit that CTV Globe Media will receive excellent value for money at minimal cost – through better quality of work and protection from human-rights complaints – by funding the Project’s first-year operations out of corporate general revenue.

An idea whose time has come

It’s time for the entire industry to get serious about true accessibility for people with disabilities – not captioning from the lowest bidder, not audio description from untrained companies, not subtitling outsourced to low-wage countries, but researched and tested standards that apply across the board. It’s the only way to genuinely serve viewers with disabilities, it’s the only rational insulation against human-rights complaints and litigation, and it’s the only way a corporation like CTV Globe Media can be sure it’s getting its money’s worth.