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The Canadian Association of Broadcasters (CAB) is the national voice of Canada’s private broadcasters, representing the vast majority of Canadian programming services, including private radio and television stations, networks, specialty, pay and pay-per-view services. The goal of the CAB is to represent and advance the interests of Canada’s private broadcasters in the social, cultural and economic fabric of the country. The CAB appreciates the opportunity to comment on the future direction of the Canada Media Fund (“CMF” or “the Fund”) on behalf of the majority of our members, some of whom are submitting complementary responses to the CMF’s briefing notes.Private broadcasters have been partners in the Fund since its 1994 inception as the Cable Production Fund. Along with the Government of Canada, independent producers, public broadcasters, broadcasting distribution undertakings (BDUs), and film distributors, Canada’s private broadcasters have collaborated in the governance and design of the funds that preceded the CMF. Together, through a governance structure that encouraged extensive discussion of industry issues, collaboration, compromise and consensus, key stakeholders have arrived at shared solutions and policies for the funding of high-quality, popular and identifiably Canadian television programming. While the solutions have not always been perfect for all players, broadcasters, producers and distributors have crafted mutually acceptable policies to license and fund over 25,000 hours of programming over the years. The CAB urges the CMF Board of Directors and staff to recognize these areas of past consensus in implementing the new CMF. In many key policy areas, the industry has already crafted workable, successful solutions. Now is not the time to dismantle them.
Private broadcasting has been critical to the CTF and will be for the future of the CMF. From the initial concept to the final production, private broadcasters are closely and actively involved in the productions they trigger from the Fund, and private broadcasters represent one of the largest financiers of Fund-supported productions. Attracting approximately three-quarters of Canadian television viewing1, private conventional and specialty and pay television will continue to be essential to delivering on the Minister’s objective of supporting programs Canadians want to watch.
At the same time, however, private broadcasters rely more on volatile advertising markets than do other broadcasters. Private broadcasters’ ability to sustain significant investments in Canadian programming must be tempered by the fact that a major source of our revenue, advertising, has been decreasing. The picture for 2008-09 will very likely show sustained ad revenue declines for conventional television, and a softening ad market for specialty television2. Planning programming schedules and investments is even more challenging in such an economically volatile environment. We urge the CMF Board and staff to be prudent in implementing gradual, incremental changes to CMF policies and guidelines.
The CMF consultation is ambitious, addressing 13 issues and over 70 questions for stakeholder feedback. A number of these issues represent, to use the CMF’s term, key elements that provide new opportunities, including the convergent stream, video on demand (VOD), marketing and promotion, the experimental stream, broadcaster-affiliated and in-house production, and certain aspects of audience success and return on investment (ROI). These elements that provide for new opportunities have not been addressed by the Canadian Television Fund (CTF) in the past, or they reflect specific directions identified in the March 9, 2009 announcement by Minister Moore. The CAB believes that these elements require considered, inclusive consultation from key stakeholders, to ensure that the CMF’s directions are realistic and consistent with the Minister’s desired direction.
The challenge for the CMF Board and staff will be to achieve the Minister’s objectives, phasing in policy changes that reflect the need for change, while minimizing the inevitable disruption to the industry. Some issues, particularly those “key elements that provide new opportunities”, should be addressed on a priority basis for the 2010-11 funding year. Areas for priority consideration in 2010-11 should therefore include the following:
. Digital media and video content for multiple platforms
. Genre allocations and definitions
. Audience and ROI
. Broadcaster-affiliated and in-house production
Each of these areas is addressed below. In addition, the CAB provides responses to each of the CMF’s questions in Appendix A.
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