A Submission to the Canadian Radio-television and Telecommunications Commission With respect to Broadcasting Public Notice CRTC 2004-2

Introduction to Broadcasting Decisions CRTC 2004-6 to 2004-27 renewing the licences of 22 specialty services

Prepared by

Canadian Association of Broadcasters 

August 16, 2004

Table of Contents


The Canadian Association of Broadcasters (CAB) - the national voice of Canada's private broadcasters, representing the vast majority of Canadian programming services, including private television and radio stations, networks and specialty, pay and pay-per-view televisions services - is pleased to present its Action Plan for examining issues concerning the presence, portrayal and participation of persons with disabilities in television programming, in response to Broadcasting Public Notice CRTC 2004-2 Introduction to Broadcasting Decisions CRTC 200-6 to 2004-27 renewing the licences of 22 specialty services (PN 2004-2).

In PN 2004-2, which introduced the decisions renewing the licences of 22 specialty services originally licensed in 1996, the Commission addressed a number of issues concerning these services in general. Among the issues raised was the question of the presence, portrayal and participation of persons with disabilities in television programming. These issues had been raised by several intervenors at the hearing and discussed with the CAB during its intervention. In PN 2004-2, the Commission requested that the CAB develop and file a plan outlining the process it would propose to examine these issues.

The CAB Process

The CAB's Joint Societal Issues Committee (JSIC) brings together members from all sectors of the broadcasting industry - radio, television and pay and specialty services - to deal with social policy issues that affect the industry. JSIC is mandated by the CAB membership to prepare recommendations and approaches on such issues for presentation to the CAB's Board of Directors. It is also responsible for the preparation and review of industry codes as well as assisting broadcasters in meeting their obligations with respect to social policy issues.

Two members of the JSIC, its Chair, Rita Cugini, Vice-President Regulatory Affairs and Business Development of Alliance Atlantis Broadcasting, and member, Valerie Morrissette, Vice-President of Human Resources for Pelmorex Inc. were mandated by the JSIC to undertake preliminary consultations with national associations representing persons with disabilities and other interested stakeholders in order to gain a better understanding of the issues prior to the development of the CAB Action Plan.

A number of formal and less formal consultations were held with a wide range of representatives from various disability communities. Two round tables were held, one in Ottawa at the CAB's offices and one in Toronto at the offices of the Weather Network. In addition, a number of single consultations with groups unable to attend the roundtables were held. A list of the various parties consulted is attached as Appendix I. In preparation for the consultations, the CAB forwarded background material and a number of questions to the participants. These questions are included as Appendix II.

The CAB would like to thank the Office of Disability Issues of Social Development Canada (ODI) as well as the Council of Canadians with Disabilities (CCD) for their guidance in selecting associations to consult. The CAB recognizes that its consultations were not exhaustive but believes them sufficiently comprehensive to allow it to develop its Action Plan. The CAB would also like to express its appreciation to the many people who attended our formal and informal consultations.

Overview of Disability Issues

Disability is not easily defined, nor is the collective of data on disability straightforward. In Canada, people are considered to have a disability if their condition restricts their ability to perform common activities such as working, going to school, travelling, communicating or performing daily tasks at home. Over the years the definition has changed and, along with it, so too has the perception of disability changed within Canadian society. At present, many observers have adopted the view that persons with disabilities are restricted in performing daily activities because of a complex environment with some elements related to the person and others to social and political context.

One issue in the collection of data on persons with disabilities is that most of the statistics come from self-identification, which may result in some under-reporting. For example, persons with hearing loss or arthritis may not identify this as a disability. In other cases, a person living with a disability may not want to self-identify to an employer, fearing possible consequences for their employment status or career development.

In 2001, the Government of Canada sponsored a national survey of persons with disabilities in Canada - the Participation and Activity Limitation Survey (PALS) 1  focusing on Canadians who have an activity limitation or a participation restriction associated with a physical or mental condition or health problem. PALS considers people to have a disability if they have a physical or mental condition or a health problem that restricts their ability to perform activities that are normal for their age.

The Study provides a wide range of information on persons with disabilities in Canada and serves as the basis for some of the data in this section. PALS demonstrates the diversity of the disabled community in Canada and some of the challenges faced by persons living with disabilities.

With reference to the many kinds of disability that are experienced by Canadians, PALS outlined 5 types for children under the age of 5, 10 types for children aged 5-14 and 11 for adults (15 years of age and older). The total number of 11 for adults is made up of the following categories of reported disabilities:

Graph 1: Percentage of Specific Types of Disabilities
Among People with Disabilities in Canada

The numbers in brackets represent the percentage of adults 25-54 who reported the particular type of disability. The numbers do not add to 100% since respondents could include more than one type.

Graph 1: Percentage of Specific Types of Disabilities. Data above.

PALS provided a variety of population and demographic statistics about persons with disabilities, including the overall Canadian population, various age groups and other demographic data. The chart below shows the percentages of various demographic groups who report disabilities of one kind or another.

Table 1: Statistical Profile of Persons with Disabilities

Demographic Group

% with disabilities

Employment rate of persons with disabilities

Household Income*
As a percentage of those without disabilities

All Canadians











91.8 %



45.7% (verses 56.6% for those without disabilities)

92.8 %



51.2% (verses 82.3% for those without disabilities)




27.3% (verses 56.2% for those without disabilities)










*Where at least one person who is earning income has a disability

Graph 2: Percentage of People with Disabilities in Canada

  Graph 2: Percentage of People with Disabilities in Canada . Data in Table 1 above.

Graph 3: Employment Rate of Those with Disabilities
Verses Those without Disabilities

Graph 3: Employment Rate of Those with Disabilities. Data in Table 1 above.

Graph 4: Income of People with Disabilities as a Percentage of Those without Disabilities.

Graph 4: Income of People with Disabilities as a Percentage of Those without Disabilities. Data in Table 1 above

In 2002, the Government of Canada released another report, "Advancing the Inclusion of Persons with Disabilities" which reported on many of the statistics from PALS and included some additional statistical information. The report noted that among Aboriginal people in Canada 15 years and older, the rate of disability was approximately 31%, more than double the rate in the overall population.

Employment equity legislation recognizes four designated groups - women, Aboriginal people, visible minorities and persons with disabilities. It is worth noting that persons with disabilities can equally belong to one, or even two, of the other designated groups. Unfortunately, programs or initiatives targeted at one designated group may not take into account the potential for multiple representations across these groups. For example, while programs may be developed for Aboriginal women, it is not always guaranteed that they will take into account Aboriginal women who have disabilities.

The Economic Reality of Persons with Disabilities

As demonstrated in Table 1, persons with disabilities often have lower participation rates and lower incomes than the rest of Canadian society. In the core working demographic of 25-54, for example, the numbers of people not in the labour force is much higher than that of Canadians without disabilities. In addition, the unemployment rate of people in the workforce is higher for those who have disabilities.

The household income of persons with disabilities is also significantly lower than that of persons without disabilities. This can be explained in part by the lower participation rates in the job market. However, many persons with disabilities are concerned about underemployment as well, where they are employed in positions that do not take full advantage of their skills and abilities. In addition, PALS indicates that the education levels in the 25-54 age group are lower for persons with disabilities.

While 18% of persons without disabilities aged 25-54 have less than a high school education, this number rises to 30% for persons with disability. Conversely the numbers with university degrees are 14% for persons with disabilities as compared to 25% for those without disabilities.

Barriers to Participation in Society

Through the course of its consultations, many representatives of disability associations told the CAB that the low level of participation among persons with disabilities in certain industries could in part be attributed to the guidance offered to students within the school systems. For example, students with disabilities often are not encouraged to pursue a career in broadcasting or related fields.

Clearly, there are many factors that may block full participation of persons with disabilities in all areas of endeavour including:

Issues Specific to Television Broadcasting


The CAB's consultations identified three key barriers to the participation of persons with disabilities in the broadcasting industry:


In June of 2004, Women in Film and Television - Toronto (WIFT-T) released a report entitled Framework: Employment in Canadian Screen-Based Media - a National Profile (WIFT Framework). The survey provides a wealth of information concerning employment levels for the four designated employment equity groups in Canadian television, film and TV production, new media and related fields. It also provides information on the profile of the teachers, students and graduates of various media schools, including broadcast (or radio and television) arts. While there is more information provided on the roles of women, there is ample information on the participation of persons with disabilities.

PALS indicates that persons with disabilities make up approximately 12.8% of the Canadian population, 9.2% of the core working demographic of 25 to 54 year olds and 21.8% of the older people of working age (54-65). According to the statistics provided in the WIFT Framework, the representation of persons with disabilities in the workforce is 5.6%. The representation of persons with disabilities is lower than their presence in the workforce when we look at all companies that fall under the Employment Equity Act , at 2.3%.

The participation of persons with disabilities in broadcasting, film and television production and other screen-based media is even lower than their representation in the workforce. The chart below is a regrouping of information provided in a number of charts from the WIFT Framework.

Table 2: Representation of Persons with Disabilities in the Workforces of Various Components of Screen-Based Media 2001



% of Persons with Disabilities

CBC-Radio Canada



Large private broadcasters



Small private broadcasters *



Film and television production - employee identified



National Film Board of Canada



New Media - paid employees



*WIFT-T's data sources were taken from publicly available Employment Equity data, obtained from HRSD (CANADA), plus Census 2001 data. Small private broadcaster data came from the CRTC which is derived from unaudited annual return information, and includes all broadcast licensees, radio, television and BDUs. Due to concerns regarding the reliability of CRTC data, the number here is an average of 2002-03.

Graph 5: Representation of Persons with Disabilities in the Workforces of Various Components of Screen-Based Media 2001

Graph 5: Representation of Persons with Disabilities in the Workforces of Various Components of Screen-Based Media 2001. Data above. 

It should be noted that the only area of the media where the representation of persons with disabilities starts to approach their representation in the workforce is in the new media sector. Persons with disabilities comprise 4.6% of the workforce in the free-lance division of the new media sector. In fact, persons with disabilities had significant representation in some of the higher salaried positions including 9.1% of other technical employees, 6.3% of programmers and 5.7% of creative directors. In addition, persons with disabilities fared well in medium salaried positions representing, for example, 10% of the writer-researchers.

Most employers identified workforce shortages in a wide variety of skilled positions in all areas of screen-based media. This could represent good news to the designated groups as employers will need to take a wider view of whom they want to employ in order to ensure tomorrow's workforce. However, in order to be employed in a skilled position, both training and experience are required. The WIFT Framework's review of broadcasting and other training schools indicates that persons with disabilities are under-represented.

Table 3: Representation of persons with disabilities in various roles in post-secondary institutions for the school year 2002-2003. Demonstrates the participation rates in both broadcast studies and film and television production schools across the country.

Post-secondary role

% of Persons with Disabilities

Teachers - film


Teachers - television


Students - film


Students - television


Graduates - film


Graduates - television


Source: WIFT-T Survey of Education and Training Institutions, 2003/4, and 2001 Census.

Table 3: Representation of persons with disabilities in various roles in post-secondary institutions for the school year 2002-2003. Demonstrates the participation rates in both broadcast studies and film and television production schools across the country. Data above.

While the percentage of persons with disabilities is somewhat lower among younger people than in the population in general, these statistics are disquieting since they indicate that the labour pool from which broadcasters and producers will draw in the future is small, in some cases lower than the representation in the broadcast television workforce.

The CAB does not have access to statistics on the participation of persons with disabilities in theatre schools or young theatre companies. However, during our consultations it was suggested that young people with disabilities are not encouraged to seek out roles in school plays. One participant noted that most drama teachers could not envisage Hamlet in a wheelchair. Theatre in the schools is where people generally "catch the bug" for acting and go on to pursue more advanced training. If this is not seen as a viable possibility for young people with disabilities, the talent pool available to television and film producers will be limited.

The CAB notes that some broadcasters have developed initiatives to encourage the participation of persons with disabilities in their workforces. The following are a few examples:

Despite these efforts, the participation rates in our industry remain low. Since the numbers come from self-identification, it is possible that the actual participation levels are somewhat higher but it is clear that additional efforts must be deployed to ensure a greater presence of persons with disabilities in the broadcasting workforce.


Our consultations and a review of literature revealed a wide range of concerns about the representation, reflection and portrayal of persons with disabilities in television programming.

The majority of the individuals the CAB consulted were uniformly of the opinion that the primary reason for the lack of sensitivity and understanding of the above-noted issues is that very few newsrooms, production studios, and/or programming teams include persons with disabilities. Some noted that the inclusion of journalists with disabilities on various editorial boards would ensure that issues are dealt with in a more inclusive manner.

The CAB's Approach

The CAB believes that the media, and particularly television, can play a strong role in changing public perspective on social issues. Increased visibility, more accurate portrayal and positive messaging can all have a strong impact on forming more inclusive practices in all areas of society.

A Steering Committee from JSIC

The CAB believes it is important for senior broadcast executives to have an opportunity to meet with knowledgeable people from various disability communities in order to have a better understanding of the existing concerns and areas for advancement. Such contact will also ensure that senior levels of the industry will buy into the process and its outcomes.

For this reason, the CAB will create a subcommittee of the Joint Societal Issues Committee (JSIC). This Steering Committee will be a relatively small group of senior executives from the broadcasting industry who will oversee the implementation of the CAB's Action Plan and its report to the CRTC. Reporting to the JSIC as a whole, the Steering Committee will ensure a strong presence of the major broadcasters in the implementation of the CAB's Action Plan. All proposals will be vetted first by the JSIC, which will in turn make recommendations to the CAB's Television and Specialty & Pay Boards, ensuring that all members endorse the approach taken.

The Outreach Committee

The Steering Committee will approach a number of people to serve as an ongoing advisory group on the implementation of the CAB's work plan and proposals. We envisage including representatives from the independent production sector, industry guilds and/or trade associations, representatives from national disability organizations and others with expertise in issues related to disability and the media. These experts will be asked to provide feedback on various proposals put forward to advance the presence, portrayal and participation of persons with disabilities within the industry. The CAB's approach is aimed at a wider audience than just broadcasters. For this reason, the CAB believes that the inclusion of related industry associations and organizations in its Action Plan provides greater opportunities for partnering.

Statistical Research

It is clear from the statistics generated by WIFT-T and from PALS that the participation of persons with disabilities in the workforces of Canadian broadcasters is minimal. In fact, the WIFT-T study clearly shows that while participation from other designated groups is lower than their overall participation in the workforce, the under-representation of persons with disabilities is still more pronounced. Moreover, the problem is even more acute when we consider the much lower rates of participation in the workforce and higher rates of unemployment among persons with disabilities.

This low level of employment in our industry inevitably results in much lower visibility of persons with disabilities on screen. It is interesting that this is not only true in broadcasting but also in film and television production.

One participant during the CAB's consultation provided an interesting illustration of how persons with disabilities are next to invisible in publicly funded documentaries. In 2002, Telefilm Canada's annual report included a list of all the documentaries it funded in that year along with a description of the documentary and an accompanying picture. Of the 246 documentaries in the catalogue with 460 photographs of people - in some cases more than one photo accompanied the description of the documentary - only 3 showed persons with disabilities, and one of these was a senior citizen who may or may not have had a disability 2 . This is not meant as a scientific study - rather the point is that the publicly funded support mechanism for film has not provided significant support for films about persons with disabilities and has funded few, if any, films made by persons with disabilities.

For the reasons outlined above, the CAB does not believe it would be worthwhile to conduct an extensive content analysis of broadcast television programming. The data provided earlier makes it very clear that there is an obvious absence of persons with disabilities among the employees of Canadian television broadcasters. Undertaking an extensive content analysis would not shed any new light on this situation.

In order to address concerns regarding the presence, portrayal and participation of persons with disabilities in television programming the CAB believes that its approach must be both tactical and short term and strategic and longer term.

CAB Research Strategy

In the short term, it will be important to provide information to broadcasters on a wide range of topics, including appropriate language and portrayal. The development of tool kits that deal with issues such as how to ensure that persons with disabilities are welcome in their workplaces, where to find skilled persons with disabilities for jobs within the industry and training targeted at a broader understanding of portrayal and other issues. By improving portrayal and increasing the presence of persons with disabilities in television programming, broadcasters can help remove negative stereotypes and encourage more participation from persons with disabilities in broadcasting and its related industries.

In the longer term, the CAB will work with its industry partners to develop a strategy to attract more people to broadcasting. The CAB believes this involves action at four levels:

The CAB's approach will have four major components:

  1. Leadership - The CAB will assume a leadership role within the industry by highlighting the importance of employment initiatives and concerns regarding the fair and accurate portrayal of persons with disabilities in television programming.
  2. Employment - Identify and remove barriers to employment as well as providing outreach to persons with disabilities at all levels of the industry. Ensuring transparent and accessible information will be integral to increasing representation of persons with disabilities in the industry.
  3. Portrayal Strategy - Provide broadcasters with tools to ensure appropriate use of terms and images. For example, coordinating workshops that focus on the "dos and don'ts" of portrayal, the development of producer guidelines for in-house, acquired and/or commissioned programming, and other relevant tools.
  4. Educational Strategy - Initiatives aimed at encouraging students with disabilities to consider a career in broadcasting or related fields.

Possible Products and Deliverables

A Tool Kit for Broadcasters

The " Broadcaster Tool Kit" would include a comprehensive set of materials to help broadcasters advance the presence, portrayal and participation of persons with disabilities in the industry. This tool kit would be updated regularly and would be a dynamic package changing over time to reflect the most pressing challenges in the following areas:

Outreach to Disability Communities

The CAB will explore the best means to ensure regular feedback from disability groups and communities, including a wide spectrum of national organizations, individual broadcasters and producers. This will require a wider range of consultations expanding the contacts to more disability organizations and also to related industry stakeholders who are addressing the same issues. For example, the CAB notes that ACTRA has made some efforts to develop ideas for their membership and that the National Film Board has started programs to encourage participation from filmmakers with disabilities.

The CAB will also look into developing a resource centre for persons with disabilities that would provide information about our industry and relevant initiatives. In addition to information on employment opportunities, the centre could provide the latest information on new programming initiatives, broadcast technology developments and consumer information that would be of use to persons with disabilities both as consumers and as potential employees in the broadcast industry.

Educational Information

The CAB will partner with industry stakeholders and educational institutions to develop materials to encourage the participation of persons with disabilities at the various levels in the industry.

In consultation and partnership with organizations such as, but not limited to, the Canadian Film and Television Production Association (CFTPA), Association des producteurs de films et de télévision du Québec (APFTQ), Alliance of Canadian Cinema, Television and Radio Artists (ACTRA), Union des Artistes (UDA), Writers Guild of Canada (WGC), Association des réalisateurs et réalisatrices du Québec (ARRQ), Directors Guild of Canada (DGC), Radio-Television News Directors Association of Canada (RTNDA), Canadian Independent Film Caucus, Telefilm Canada, Société de développement des entreprises culturelles (SODEC) and the Canadian Television Fund (CTF), the CAB will endeavour to provide information on existing industry programs or funding mechanisms available specifically to persons with disabilities and other related professional development programs. Given the high incidence of disabilities within the Aboriginal population, the CAB will also seek to engage these communities by outreach to the Assembly of First Nations, APTN and other relevant stakeholders. The goal of this initiative is not only to facilitate and increase the flow of information regarding specific industry programs but also to ensure a harmonization of efforts in this regard.

Within the broadcast education community, the CAB will consult various educational institutions as well as the umbrella organization, Broadcast Education Association of Canada (BEAC) to determine ways to encourage better participation among persons with disabilities. For example, the development of entrance scholarships, internship programs for students with disabilities, and the establishment of mentorship networks within our industry.

The CAB will also seek out partnerships with national and provincial teachers associations, educational umbrella organizations, the National Education Association for Disabled Students and other related educational institutions to develop a set of materials for students with disabilities in middle school and secondary school that encourages a career in the broadcasting industry.


The Steering Committee would oversee and conduct three main streams of work for inclusion in a report to the CRTC.

Comprehensive Consultations  - These consultations would be much wider and even more representative than the consultations conducted to date and would focus on the following areas:

Focus Group Research  - Including persons with disabilities from both inside and outside the broadcasting industry

Best Practices Research  - Comprehensive research on initiatives in a number of areas:

Time Lines

The CAB proposes the following tentative schedule:

Action plan submitted to CRTC

16 August 2004

Approval by CRTC

October 2004

Striking of Steering and Outreach Committees (to be announced at CAB convention)

October - November 2004

First Meeting of Steering Committee (Mandate, Terms of Reference, Work Plan)

December 2004

Research Phase (Review of Initiatives, Focus Groups etc..)

January to February 2005


January to March 2005

Final Report to CRTC

June/July 2005

Appendix I - List of Persons Consulted



Canadian Association of Independent Living Centres

Maria Kononpeskas
Jihan Abbas, Researcher
Sandra Carpenter, former Executive Director

Canadian Paraplegic Association

Martin Belliveau, Director of Advocacy and Communications

Canadian National Institute for the Blind (CNIB)

Bernard Nunan, Researcher/Writer, Consumer and Government Relations
David MacDonald, Manager of Rehab Ontario Division

Learning Disability Association of Canada

Diane Sullivan, Project Officer

Alliance of Canadian Cinema, Television and Radio Artists (ACTRA)

Leesa Levinson

Fireweed Media Productions Inc.

Don Peuramaki, President

National Network on Mental Health

Richard Chenier, Consultant

National Federation of the Blind: Advocates for Equality

John Rae, President

Ryerson RBC Institute for Disability Studies Research and Education

Catherine Frazee and Melanie Panitch

Council of Canadians with Disabilities

Mr. Laurie Beachell - Executive Director
Jim Dirksen, Past Chair Human Rights Committee

Canadian Hearing Society

Gary Malkowski, VP, Consumer, Gov't, and Corp Relations

People First of Canada

Shelley Rattai

Social Development Canada

Office of Disability Issues

Fraser Valentine
Michel Regnauld
Phil G Vangelis
Genevieve Proulx

Appendix II - Questions for CAB Consultations

Employment practices

1. What are the major barriers to participation in the workforce for the group you represent?

2. Are there any industries that you feel have done a good job in including your group in their workforce? Any particular individual companies? Could you outline what they did that was right?

3. Have you any experience with broadcasting companies in the area of employment? If so, what were your experiences?


4. How well do you think the group you represent is portrayed on television?

5. Are there particular issues with portrayal that one may be more evident than others?

6. Are there any particular programs that you feel do a good job in the portrayal of persons with disabilities? If so, please outline why you think so?


1 The complete report Disability in Canada: A 2001 Profile can be found at the website of Social Development Canada's Office of Disability Issues - http://www.sdc.gc.ca/asp/gateway.asp?hr=en/hip/odi/documents/PALS/PALS000.shtml&hs=pyp 

2  Of the photos 132 were of women, 24 were of Aboriginal people and 82 showed people from various ethnocultural communities.