Yes, absolutely.
The first recommendation is to have a definition. We assume they're redefining what a BDU is to take in online platforms. We suggest a definition for community broadcasting that defines it as not for profit and includes participation by community members in administration, day-to-day operations and programming. We've provided the wording for that in the brief.
There is a definitions section at the beginning of the act. That's where we'd like that. The words “community elements” and “community programs” are used twice in the act but never defined. In fact, the private and public sectors aren't defined either, but I leave that to them if they want to ask for it. A clearer definition would help.
Secondly, that doesn't tell everybody what community media does. We've had questions here today about what it does. Our suggestion is that there was a paragraph 3(1)(r) that used to refer to alternative programming services. It has been dropped in the current draft, but it almost exactly described what the community sector actually does. As low-hanging fruit, it could be just slightly adapted to do what we need.
For example, if I look at that, it already had four elements that are needed.
One, paragraph 3(1)(r) said such programming should “be innovative and be complementary to the programming provided for mass audiences”. Well, that's what we do. That's what it said before.
Two, the act used to say that alternative programming services should “cater to tastes and interests not adequately provided for by the programming provided for mass audiences, and include programming devoted to culture and the arts”. That's what we do.
Three, they should “reflect Canada’s regions and multicultural nature”. That's what we do.
Four, those services should “be made available throughout Canada” on all platforms. That's what we do.
We suggest adding to these, because “alternative media services” doesn't necessarily embody the idea of community participation. We would add a new subparagraph 3(1)(r)(iv): “be produced by and for local communities through their not-for-profit participative structure”.
As “alternative media services” didn't refer to our training role, we would add a new subparagraph 3(1)(r)(v): “support the development of Canadian creative talent”.
On the last one, somebody asked why it is not okay for for-profit community media to exist, or where the conflict is. Almost all the 30 to 40 years of audiovisual archives of our small communities that cable companies collected over time—to their credit, back in the day they worked—have all been put in dumpsters now. Many communities have no audiovisual record of their council meetings or their festivals. It's all gone. Therefore, we would add a new subparagraph 3(1)(r)(vii) to that, that the programming should “be made available for archival purposes to Library and Archives Canada”.
The loss of cable community TV archives is one of the single biggest cultural losses in Canadian history that nobody is talking about; therefore, there is a slight modification in terms of that.
Lastly, describing a role doesn't always capture what we do, so we've suggested a few other places where existing wording could be clarified so that our role is clearer.
The strongest ones you can see are in paragraphs 3(1)(o) and 3(1)(p). We've beefed up the language to make sure there's programming within the system for indigenous and disabled persons. The realistic way to make that real is to recognize that in smaller communities and for smaller, niche groups, we actually give them the resources and opportunities to develop their own content. They don't have to wait around for someone else to do it for them, and that's how they develop their voices.
We have other examples, but those are some really strong ones, to give you an idea.
