Secretary General
CRTC
Ottawa, Ontario
K1A 0N2
Re: 2002-0420-7
Regarding Shaw cable rate deregulation in greater Vancouver, I don't
think Shaw should use deregulation as the first step to get out of supporting
Canadian television production. In particular, I think the cable levy should
support independent community television production, as is now proposed
(2001-129) by the CRTC.
The calculation used by Michael Ferras, Shaw's director of regulatory
planning, depends on loopholes such as counting subscriber losses while
not counting subscriber gains. There's ambiguity over the audit, over whether
it was the Rogers audit that was used, and over what was counted.
The CRTC rule exists to promote fair competition among broadcast distributors.
In the greater Vancouver area Shaw has over 600,000 customers. Novus, the
other licensed cable company, has about 3,000. Did Shaw lose the claimed
12.8% of subscribers to Bell Express Vu, the competing satellite provider,
or did most of them go to Star Choice, Shaw's own subsidiary satellite company?
Is Shaw complaining about competition from its own subsidiary?
Raising rates may not be the only goal of this deregulation. Shaw has
already shown, by its commercialization of the community channel, that it
only obeys the regulations it likes. Advertising on the community channel
turns it into a fast growing revenue source instead of a public service.
If the company can dominate the regulator, then perhaps the CRTC's emphasis
on a distinctively Canadian voice in our broadcasting system can also be
ignored.
If the governments we elect fail to protect the public interest, then
soon those governments will be too weak to protect the same companies that
now want deregulation. Deregulation can never be a long term solution. The
Canadian people think of the CRTC as our broadcast guardian. The CRTC has
to find a compromise here, ideally one that leads to genuine competition.
Sincerely
Richard Ward
Executive Director, C.M.E.S.
Community Media Education Society | 
