If Rogers succeeds in harnessing digital technology to modernize its cable television service, it means that the CRTC can continue to impose the Canadian content regulations it imposes today. These have served Canadian cultural industries well. For example, 55% of a television network's content has to be Canadian. However, if all television content migrates to the Internet, Canadian television will lose the benefit of Canadian content quotas.
We need the CRTC to adopt flexible policies to aid us in this transition, and with one notable exception they have. They have allowed us to put television programs on video-on-demand and to insert fresh ads so that broadcasters will have an incentive to provide programming to us. They have not imposed taxes or fees on our Internet service. They have indicated a willingness to allow us to sell ads on our U.S.- originated cable programming to pay for a targeted ad system, as U.S. operators do.
The one area of concern we have is the CRTC's recently announced value-for-signal decision. This will require us to pay large amounts for linear television at a time when customers are increasingly moving away from linear TV to watching on-demand and online.
There are also policies the federal government could adopt. For example, pursuant to section 19 of the Income Tax Act, Canadian firms cannot claim advertising expenses as an income tax deduction when they advertise in U.S. magazines or border TV stations.
The same rule should apply to U.S. websites. This will make it more expensive to place ads, for example, on Hulu, if it comes to Canada. The aim should be to make sure that Canadian advertisers prefer Canadian-owned and -operated services.
Federal tax credits should also be available for online content. The existing rules only allow credits for filmed entertainment production. Some provinces have moved in this direction, such as B.C., Ontario, and Quebec.
Canadian copyright payments are also out of control. We pay more copyright both for online and traditional media than U.S. media companies pay. This makes it hard for us to adapt and compete. For example, digital copies of music are more costly to download online than if purchased on a CD because of copyright tariffs and levies. Piling on additional copyright payments for digital media will continue to drive consumers to acquire music and other copyright products through unlawful file sharing on the Internet and to unregulated U.S. over-the-top providers like YouTube.
It is also a mistake when copyright discourages broadcasters from modernizing their operations. For example, if a radio station plays CDs, they face two different copyright payments. If they load the CDs into a server, they could have to make four more payments. Canadian radio stations pay twice as much in copyright payments as American radio stations. This is particularly disturbing since over half of the copyright payments go outside of Canada.
Canadian copyright payments need to be kept in check or Canadian radio broadcasting will not be able to compete against the Internet or other new technologies. This is one reason why we don't have Internet radio stations, and are now inundated with foreign services from more cost-effective territories.
In the U.S., PVRs are becoming more cost-effective by using the network PVR. A PVR is just a digital cable box with a hard drive in it. The network PVR centralizes the hard drive at the cable company's primary headquarters. This means that all digital boxes can be PVRs, giving all customers the flexibility of the PVR at a greatly reduced cost.
The last version of amendments to Canada's Copyright Act, Bill C-61, specifically prohibited the use of the network PVR by cable operators. We think this a mistake that should be corrected in the next copyright bill.
Rogers recommends a balanced approach to copyright reform and implementation of the WIPO treaties that will continue to reward innovation and creativity.
If we succeed in our vision of providing customers with television on any platform, it clearly will be good for our business. As discussed before, it will also allow the continuation of the Canadian content regulatory system. It will also allow creators of artistic and cultural content to be compensated for their works. An environment where all content is available free on the Internet does not provide the creator the ability to be compensated for their works. Our model will preserve the existing value chain and allow all providers to be compensated.
We do not believe changes to foreign ownership rules will have an impact on Canadian culture and content. Canada's foreign ownership rules can be changed for telecommunications carriers and cable companies. These businesses are primarily pipes that carry content. The foreign ownership rules can be preserved for the content providers. Radio and TV stations and specialty channels can remain in Canadian hands. This would provide the capital-intensive distributors with lower-cost access to foreign capital while ensuring that the vital content producers are Canadian.
Thank you.