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Broadcasters and advocacy groups are at loggerheads over the need for widespread public service announcements (PSAs) to inform the public about the upcoming transition to digital television broadcasting - and it's not clear where the two sides might agree.
Broadcasting advocacy groups say the CRTC should create a coordinated, national campaign using PSAs to educate the public about the transition.
But broadcasters say they're concerned that airing too many ads will annoy the public and hurt the companies' bottom lines.
"Only about 7% of Canadian households will be directly impacted by the transition; as such, the expected communications program is extremely aggressive for such a small potential impact," Shaw Media Inc. told the commission in a submission for the CRTC's consultation on the matter.
Last week, the CRTC closed its call for comments on proposed regulations for the transition. The proposed rules would require broadcasters affected by the transition to air PSAs and notices about service loss starting six months prior to the switch to digital.
The PSAs would contain information on the transition, who will be affected, and what they must do to continue receiving service, as well as the precise date and time that analog broadcasting will stop and the broadcaster's contact information.
Service loss notices would provide a description of the geographic areas where the loss of service is likely to occur, as well as what steps a viewer must take to continue receiving over-the-air signals, and other information.
The commission recommended that the PSAs be broadcast six times per broadcast day, increasing to eight times per day on Aug. 1. At least 25 per cent of the 30-second announcements must be broadcast between 7 p.m. and 11 p.m. Service loss notices must be broadcast at least once a day, the commission proposed.
The CRTC has also suggested that broadcasters be required to post updated information about the transition on their websites.
All requirements would end once a broadcaster has completed its conversion to digital. The deadline for the switch from analog to digital over-the-air television broadcasting is Aug. 31, 2011.
In separate comments filed with the commission, broadcasters Shaw, Quebecor Media Inc. (QMI), CTVglobemedia Inc., CBC, Rogers Communications Inc., TVO and V Interactions Inc., said they are concerned the requirements go to far.
"We are very concerned that the Commission's proposed detailed approach to PSAs will actually result in more customer confusion, increases the potential for inappropriate consumer purchasing decisions (i.e., of unnecessary household equipment), and raises possible liability risks for participating broadcasters (and perhaps for the government itself)," Shaw wrote.
Shaw said the PSAs would broadcast yet-to-be-confirmed information far in advance of the transition deadline, which could lead to confusion. For example, a viewer living in a non-mandatory market could unnecessarily feel hurried to buy a digital tuner even though analog broadcasting would continue in their area for an unspecified time after the deadline.
The company recommended that the PSA obligation be spread over a broadcast week rather than one day, and that the announcements contain more general information. Shaw also suggested that broadcasters not be required to air service loss announcements.
Shaw said it is concerned that a mandated communications plan will require the production of PSAs, service staff training, and the use of valuable airtime to broadcast the ads.
CTV told the commission that airing the PSAs would cost between $3 million and $6.5 million in lost advertising revenue.
"Requiring conventional broadcasters to air the PSAs during prime time represents a loss of valuable commercial airtime that would otherwise be used to generate advertising revenue at a time when such revenue is desperately needed by conventional television broadcasters," CTV wrote.
CTV said it is concerned that making broadcasters responsible for the education campaign exposes them to potential liability and complaints if the transition hits road bumps.
"Since the government is mandating the switch from analogue to digital, we find it strange that the government isn't doing anything to educate the public and help with the transition," Mike Woollatt, CTV's vice-president of government relations, said by email.
QMI told the commission that airing the PSAs on its TVA stations would cost about $3.305 million.
"This proposed regulation would certainly have a negative impact on TVA's advertising revenues and will inevitably cause considerable losses for the whole industry, which is already weakened by the recent financial crisis," QMI wrote.
"The number of broadcasts required by the commission would encroach in a significant way on advertising time. And the advertising inventory for winter and spring, which is essential to TVA's survival, has already been sold."
QMI said the commission should lighten its proposed regulations so that broadcasters are encouraged, not compelled, to broadcast PSAs.
The company proposed broadcasting the PSAs during its morning and evening news broadcasts and two times during the broadcast day, when possible.
CBC told the commission the PSAs should be simplified, reduced to 15 seconds, and broadcast only four times a day for six months to avoid annoyed viewers.
The CBC added that the PSAs should be supplemented with a website and toll free calling services.
The recommendation is line with the proposals put forward by advocacy groups, which contrast starkly with those of the private broadcasters.
The Canadian Association for Community Television Users and Stations (CACTUS), the Canadian Media Guild, OpenMedia.ca and broadcasting expert Gregory Taylor told the commission in similar submissions that it should establish a coordinated national education campaign that requires all broadcasters to show the PSAs.
CACTUS suggested that the campaign be funded with $10 million from the tangible benefits package BCE Inc. is contributing as part of its acquisition of CTV.
"Using these funds, we recommend that the Commission immediately convene a working group that includes representatives of the government, public and private OTA broadcasters, consumer groups, community television organizations, and other industry stakeholders," CACTUS wrote.
CACTUS spokeswoman Catherine Edwards said in an interview that broadcasters would have a better opportunity to discuss what they think is an appropriate requirement for PSAs if they are included in the working group.
"But I don't think it's unreasonable - [that is] the general principle of asking the broadcasting industry to air PSAs of national interest at particular times," she said.
Edwards added that the education campaign should not be left to the broadcasters to organize, adding that it should be the government's responsibility.
Ian Morrison, spokesman for the watchdog group the Friends of Canadian Broadcasting, said in an interview that if the transition continues without stepping up the education campaign, the government will find itself faced with upset consumers.
The government, he said, should take a more proactive approach.
"The people who are going to be the most affected are the least likely to be accessed by all these technological things. There is a group of Canadians that is effectively going to wake up on Sept. 1, and they are not going to be sad. They are going to be really angry," he said.
Morrison said he expects broadcasters and the public to pressure the commission to extend the deadline.
The CRTC is expected to publish its decision on the PSA requirements in February.
Source: The Wire Report, 01/18/2011
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