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Application to Rogers 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 (BGM), announced its intention to buy another Canadian broadcasting conglomerate, CHUM Ltd., for $1.7 billion. That would give BGM 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. Rogers Broadcasting has come forward as a buyer of some of those stations and channels.

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 Rogers acquisition of A-Channel and related stations 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 the research is not available, we’ll do it ourselves. If the evidence is not available, we’ll get it 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 Rogers sorely needs.

Quantity vs. quality

On the topic of captioning (only one of several topics the Project will address), Rogers is known to shop on price. The result is poor-quality and unstandardized captioning, done entirely in scrollup in capital letters – the sort of captioning that seems OK to someone who doesn’t actually watch captioning, or like it.

Low-quality captioning is a magnet for human-rights complaints. So is an absence of audio description; one blind group has already publicly stated it is preparing complaints against broadcasters on the topic of audio description. Rogers stations broadcast practically no programming with description.

How might you 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 Rogers would lose right away.

And while the company pinches pennies on captioning, it proposes to spend a hundred million dollars buying a rival broadcaster. People with disabilities, and others, will notice that disparity and may be incensed enough do something about it.

Now, if Rogers were to support 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.

A way to show corporate responsibility

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. Rogers and the CHUM networks and stations you propose to buy still have a great deal of uncaptioned programming and an immense amount of poorly-captioned programming. Barely anything is described for the blind.

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 Rogers 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 five- to seven-year project.

We have detailed budgets available for confidential review.

Funding

We see two mechanisms by which Rogers could fund the Open & Closed Project.

Social benefits arising from the acquisition of A-Channel and related stations
In round numbers, Rogers will be obliged to spend $13 million on tangible social benefits. Our entire project needs about half that, and our first year needs only 1/26 that sum. We believe we can fit comfortably within that envelope.
Fund us anyway
The Project deserves funding on its merits. We submit that Rogers 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, 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 Rogers can be sure it’s getting its money’s worth.