February 20, 2018
Chairperson Ian Scott
Canadian Radio-television and Telecommunications Commission (CRTC)
Ottawa, Ontario K1A 0N2
RE: COMMUNITY MEDIA ADVOCACY CENTRE (CMAC)
Dear Mr. Scott,
1. The Community Media Advocacy Centre (CMAC) extends a warm welcome to you as Chair of the CRTC. CMAC’s Board of Directors and consulting staff share their kindest regards as we take this opportunity to introduce our mandate and areas of work.
2. CMAC is a non-profit organization formed in 2015 to offer advocacy and support for Indigenous and community organizations interested in licensing, funding, and launching non-profit broadcasting organizations. CMAC is uniquely comprised of academics, legal advisors, policy consultants and community media practitioners from across Canada, who prioritize the perspectives, voices and experiences of Indigenous peoples, linguistic and ethnic minorities, and disAbility communities. CMAC promotes community-access media by advocating for community-based, nonprofit and noncommercial broadcasting; Indigenous- and community-owned communications infrastructure; and media produced by volunteers and/or under-represented communities.
3. CMAC’s mandate is to support self-determination in Indigenous and community media through research, relationship-building, advocacy, and learning. To this end, CMAC engages in CRTC proceedings affecting community and Indigenous media; builds relationships with other non-profit organizations serving community and Indigenous media; and participates in research projects and conferences to advance practices, knowledge, and policy for Indigenous and community media in Canada and internationally. This past year, CMAC was invited to share expertise by the Independent Communications Authority of South Africa and the Federal Telecommunications Institute in Mexico.
4. CMAC has engaged in multiple CRTC proceedings over the past three years, submitting eleven interventions and participating in three Commission hearings. Based on these experiences, as well as CMAC’s broader research and advocacy work, we respectfully propose several initiatives to foster a more equitable CRTC and broadcasting system.
5. Appointing Commissioners reflective of the diversity of Canada, including balanced representation of women, racialized peoples, Indigenous peoples, people with disabilities and those with experience in non-profit community media, is CMAC’s primary recommendation for fostering equity at the CRTC.[1] The Commission’s lack of diverse representation creates the perception of an echo-chamber, where only culturally dominant voices are reflected and amplified by decisions.
6. In tandem with diversifying the Commission, the CRTC could adopt more inclusive and proactive public engagement strategies to connect with diverse communities. Accessible approaches might include community-based research, community media relations, online engagements and local consultations.[2] The expertise of community and Indigenous broadcasters and media scholars could also be engaged to inform CRTC deliberations and policy development. Increased communication and engagement would increase public awareness of and interest in CRTC proceedings, enhancing the vibrancy and accountability of this public service.
7. Since 2016, CMAC has urged implementation of anti-racism education and training for CRTC commissioners and staff. The Commission has yet to formally respond to allegations of systemic and overt racism brought against it during judicial proceedings associated with the termination of Raj Shoan, one of only three racialized individuals ever appointed to the Commission.[3] A third-party process to investigate and address these and other allegations of racism at the Commission[4] would complement anti-racism training to ensure racialized peoples are equitably served by the CRTC. Such actions could also help to inform a much-needed review of the “Ethnic Broadcasting Policy” (CRTC 1999-117).
8. The CRTC has an opportunity to align its policies and practices with the United Nations Declaration on the Rights of Indigenous People (UNDRIP)[5] and the Truth and Reconciliation Commission Calls to Action.[6] A committee of Indigenous radio, television and telecommunications producers and advocates could determine how CRTC policies and practices can support reconciliation and protect the rights of Indigenous people.[7] This type of review and consultation could also inform a long-overdue review of the “Native Broadcasting Policy” (CRTC 1990-89).
9. As with UNDRIP, the CRTC has an opportunity to align its regulatory efforts with Canada’s obligations under other international declarations and conventions, including the United Nations Educational, Scientific and Cultural Organization’s Convention on the Protection and Promotion of the Diversity of Cultural Expressions [8] and the United Nations Convention on the Rights of Persons with Disabilities.[9]
10. Last but not least, there is an urgent need to reassert the vision and value of Canada as the “birthplace of community media,”[10] recognizing the community sector as a complementary and essential pillar of the broadcasting system. To this end, the Commission could assess the impact of the “Policy Framework for Local and Community Television” (CRTC 2016-224) on the right to reflection within community media;[11] and of the “Campus and Community Radio Policy” (CRTC 2010-499) on the commercialization of non-profit radio station practices. Former Commissioner Morin’s dissenting opinion[12] on the latter policy predicted commercializing practices that have negatively impacted community access to community radio.[13] Guaranteeing an equitable place for nonprofit, noncommercial community, ethnic, Indigenous, and disAbility media will strengthen Canada’s media landscape and social fabric.
11. CMAC’s Board of Directors and consulting staff value your consideration of these matters as your stewardship of the Commission creates an opportunity for a renewed and more equitable CRTC. We look forward to working with you, and are available to discuss these issues further upon request.
Respectfully Yours,
Kristiana Clemens, President, CMAC
Zoë Ludski, Vice-President, CMAC
Cc. The Honourable Mélanie Joly, Minister of Canadian Heritage
Footnotes
[1] Only once since 1968 has the CRTC Chairperson not been a white man: http://frpc.net/appointments-to-the-crtc/
[2] For example, in the 1970s “the CRTC established the Committee on Extension of Service to Northern and Remote Communities which included representatives from provincial governments and northern native associations. After holding extensive public hearings throughout the North and considering over 400 submissions, the Committee issued its report [know as the The Therrien Report] in July 1980” (emphasis added), quoted from: https://crtc.gc.ca/eng/archive/1984/PB84-310.htm
[3] https://www.newswire.ca/news-releases/heritage-minister-asked-about-the-recent-dismissal-of-a-crtc-commissioner-and-racism-at-the-crtc-593134551.html
[4] CMAC letter re CRTC 2017-1: https://www.newswire.ca/news-releases/action-must-be-taken-to-ensure-the-crtc- supports-racial-equity-and-the-sovereignty-of-indigenous-peoples-620350933.html
[5] http://www.un.org/esa/socdev/unpfii/documents/DRIPS_en.pdf
[6] http://www.trc.ca/websites/trcinstitution/File/2015/Findings/Calls_to_Action_English2.pdf
[7] For example, see the report prepared by the Truth and Reconciliation Committee of the Canadian Federation of Library Associations (CFLA-FCAB): https://www.newswire.ca/news-releases/access-to-indigenous-knowledges-and-their-cultural-materials-depends-on-decolonizing-libraries–cultural-memory-institutions-and-their-services-report-620262853.html
[8] http://portal.unesco.org/en/ev.php-URL_ID=31038&URL_DO=DO_TOPIC&URL_SECTION=201.html
[9] https://www.un.org/development/desa/disabilities/convention-on-the-rights-of-persons-with-disabilities/ convention-on-the-rights-of-persons-with-disabilities-2.html
[10] https://crtc.gc.ca/eng/archive/2008/pb2008-4.htm
[11] The Standing Committee on Canadian Heritage also recommends this priority, see Recommendation 9 (p. 44): http://www.ourcommons.ca/Content/Committee/421/CHPC/Reports/RP9045583/chpcrp06/chpcrp06-e.pdf
[12] Former Commissioner Morin wrote in 2010, “My concern, based on submissions made during this proceeding, is that community radio may gradually become something more akin to a commercial venture.” See CRTC 2010-499 for full dissenting opinion: https://crtc.gc.ca/eng/archive/2010/2010-499.htm
[13] http://montrealgazette.com/news/local-news/montreal-community-radio-station-cibl-fm-lays-off-all-its-employees, http://montrealgazette.com/news/local-news/radio-centre-ville-at-centre-of-power-struggle, and https://nowtoronto.com/music/goodbye-chry/
Link to download CMAC Letter to Welcome Chair: http://cmac.gwradio.koumbit.org/wp-content/uploads/2018/02/CMAC_Letter_to_Welcome_Chair.pdf
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