Re: CRTC decision to limit practice of simultaneous substitution

March 12, 2015

Sent by mail and email

The Honourable Shelly Glover
Minister of Canadian Heritage and Official Languages
House of Commons
Ottawa, ON K1A 0A6

Dear Minister Glover,

Re: CRTC decision to limit practice of simultaneous substitution

On behalf of 5,000 Unifor members working in Canada’s broadcast and film industries, I am writing to request that you consider reversing the CRTC’s January 29 decision that disallows distributors to perform simultaneous substitution on speciality television services and during the Super Bowl. Not only will this decision needlessly remove much needed revenue from the Canadian television system, we anticipate it will result in a net loss of Canadian jobs. In light of this severe outcome, our union believes such an intervention from your office, and the federal Cabinet, is warranted.

The practice of simultaneous substitution, as outlined in the Broadcasting Distribution Regulations, has been a useful revenue-generating policy for many years. Enabling Canadian broadcasters to secure advertising revenues by swapping U.S. programming feeds to air commercials geared to the Canadian market makes good sense. Based on the Commission’s own estimates, signal substitution generates approximately one quarter of a billion dollars in revenue, each year. According to a recent study of broadcast policy changes on jobs, the full-scale elimination of signal substitution would equate to the loss of 1,050 jobs (measured as full-time equivalents) by 2020.1

Our union was heartened that the CRTC chose to maintain the practice of ‘simsub’ (after contemplating its complete elimination during the Let’s Talk TV hearings) for over-the-air stations, but found it difficult to make sense of the Commission’s denial of future requests of the Canadian broadcast rights holder (in this case Bell Media) for signal substitution during the Super Bowl starting in 2017 and other sporting events broadcast over speciality stations.We view this approach as unfair, both for the rights holder, but also to the integrity of the policy. It is crucial that intellectual property for creative content is protected in the Canadian system.

It is also hard to defend the Commission’s decision as serving the public’s interest (as per the Broadcasting Distribution Regulations). In order to appease a select audience for (what is essentially) a single sporting event, the Commission has hacked away at an important revenue tool that supports Canadian programming and Canadian jobs.

Minister, we urge you to raise this important matter with the federal Cabinet, and exercise government powers to intervene and reverse this decision. As you are fully aware, Canada’s conventional television industry is undergoing a significant period of restructuring. Canadians still demand important local television services, and support Canadian content and expression on our screens, but the revenue model that underpins these services is under severe strain.

Unifor believes that Canada’s television system must continue to evolve and adapt to changing technologies, to ensure all audiences are served. But Unifor does not believe that knee-jerk policy changes that undermine the system’s revenue-generating potential should be taking place. Not with important Canadian programming services and jobs hanging in the balance.

The decision to disallow signal substitution – largely to appease a select group of American football fans – threatens to make this transition all the more painful to audiences (through programming cuts) and workers (through job losses).

We appreciate your consideration of this matter, in advance. And we look forward to your response.

Jerry Dias
National President



Jean-Pierre Blais, CRTC Chairperson (
Pierre Nantel, Heritage Critic, NDP (
Hon. Stéphane Dion, Heritage Critic, Liberal Party of Canada (
Mario Beaulieu, Leader, Bloc Québécois (mbeaulieu@bloc.o