Please see the letter below sent to the Canadian Radio-television and Telecommunications Commission. To read a PDF copy, click on this letter to CRTC.
Dear Chairman Blais and CRTC Commissioners:
As the Union representing over 12,500 members in television and other media, we are writing on an urgent matter that requires both your attention and your action. On January 29, 2015, the CRTC released Broadcasting Regulatory Policy CRTC 2015-25 regarding simultaneous substitution for the Super Bowl in 2017 and beyond. In the almost two years since this decision, thousands of Canadians and several interested groups have voiced their concerns with the decision and its likely impact. To allow sufficient time to review and evaluate those concerns, we ask that you take immediate action to reverse this decision or delay its implementation date.
Creators, broadcasters, advertisers, Members of Parliament and thousands of Canadians have come together to highlight the significant concerns with the CRTC’s decision. As you know, the Super Bowl provides an unparalleled platform for Canadian firms and advertisers to speak to Canadians.
Equally, it provides an unmatched opportunity for Canadian creators who depend on often scarce creative work an opportunity to not only work, but to be exposed to the largest TV broadcast audience of the year. Add to this the deep challenges Canada’s broadcast industry is facing in every region of Canada and you can understand why so many Canadians are concerned about ending simultaneous substitution in the Super Bowl. There is also the matter of ongoing legal uncertainties around the decision itself, which impairs the industry’s ability to fully prepare for and adjust to the potential impact.
All of this is unfolding while the Government of Canada is undertaking a sweeping review of Canada's broadcast policies under the leadership of Canadian Heritage Minister Joly. Instead of having dueling initiatives that confuse consumers and harm Canadian creators, it makes eminent
sense to suspend the implementation of the CRTC’s Super Bowl decision, and all of the challenges it creates, out of deference to the comprehensive review the government is currently undertaking.
Therefore, we urge you to reverse your Super Bowl decision or delay its implementation, so that its effects can be further explored and considered ahead of Super Bowl LII, on February 4, 2018, rather than keep implementation on the current timetable, which would see the ending of simultaneous substitution for Super Bowl LI on February 5, 2017, only a few weeks from today.
This simple change of the implementation date would provide Canadian creators, advertisers, broadcasters, and all those who depend on this important broadcast event for their livelihood an opportunity to be equal partners in the discussion about the future of broadcasting in Canada, including the future of simultaneous substitution. By delaying the Super Bowl decision, the CRTC can demonstrate that it has heard the concerns of Canadian creators, the Canadian broadcast industry, and others – and that it is willing to engage in a constructive dialogue about those concerns in connection with such a far-reaching decision.
Our system of simultaneous substitution works. We again ask you to reverse your decision or simply delay this policy to allow the legal uncertainties to be settled and further considerations vetted, and to fulfill the CRTC’s mandate of respecting simultaneous substitution policy, while balancing the needs of both creators and consumers.
Jerry Dias, National President