Religion and Broadcasting A Review of the Policy on Religious Broadcasting

Religion and Broadcasting A Review of the Policy on Religious Broadcasting The Social Action Commission of the Evangelical Fellowship of Canada Brief to the Canadian Radio-television Telecommunications Commission August 1992 1. Introduction The Evangelical Fellowship of Canada (EFC) previously made an intervention (August, 1987) to the Canadian Radiotelevision and Telecommunications Commission (CRTC) in support of the application of VISION TV. We agree with the decision to license VISION TV and see it as an important first step in coming to grips with the issue of religious broadcasting. We are pleased that the CRTC has now taken the next step in reviewing its policy regarding religious broadcasting. We thank the CRTC for this opportunity to address this issue. In 1983, the CRTC issued its policy on the licensing of programming which it considered to be primarily religious and devoted to a single religion, denomination or sect. The CRTC decided such undertakings were contrary to the requirements of the Broadcasting Act, particularly in the matter of balance. Interpreting the requirement of balance as being applicable to each individual broadcaster and combining this interpretation with a concern that religious programming services be accessible to all Canadians, the CRTC affirmed its policy not to license independent religious broadcasters, but to license a national Canadian interfaith religious programming service. It is our view that the CRTC s interpretation of the Broadcasting Act s requirement of balance with respect to what the CRTC calls religious broadcasting has resulted in a discriminatory policy which is not required or stipulated by the Act. And while there have been changes to the broadcasting Act and changes in the broadcasting environment which prompted this review, our chief concern lay in the CRTC s understanding of religious broadcasting and its interpretation of the Act in matters of balance and diversity, the recent changes notwithstanding The policy toward religious broadcasting results in an undue restriction on the rights of freedom of expression and the ability of Canadians to receive programming which expresses their vision and philosophy of life. We welcome this review of balance, the licensing policy for religious broadcasting and religious programming. We are greatly concerned that the CRTC should interpret the Broadcasting Act in a way that would not discriminate against religious broadcasters either by their exclusion or by placing restrictions on religious broadcasters not placed on other broadcasters. Consequently, we will address many of our remarks to questions of religion and balance. The Evangelical Fellowship of Canada is a national association of 28 evangelical denominations, churches, mission agencies, educational institutions and individuals across Canada. As a national association EFC serves its constituency by representing its concerns to national government, debating on public media, publishing reports, briefs and the newsfeature magazine Faith Today as well as giving leadership in special projects. It is estimated there are some 2.5 million evangelicals in Canada. II. Religion in Broadcasting Introduction We believe that many items usually grouped under the general category of religious are different and should not be subsumed under the same definition. In particular, we ask that the CRTC distinguish between what we will call churchrelated programming, denominational programming and religious programming and that attention be given to the rightful place of each in broadcasting. 1

A. The Meaning of Religious (i) The secular view of religion. The question of religion is complex. In today s secular and rationalized world, religion is usually assumed to be referring to only certain types of people who are deemed to be religious and only certain types of activities, like prayer or worship, which are considered to be religious activities. William James defined religion as the feelings, acts and experience of individual men in their solitude as far as they apprehend themselves to stand in relation to whatever they consider the divine. In Public Notice 1983-112, the CRTC agreed and defined religious as anything directly relating to, inspired by, or arising from man s relationship to divinity, including related moral or ethical issues.... But this notion of religion is by no means universal; in fact it is sectarian and culturally bound. It is a particular type of secular, Western orientation which ends up ghettoizing religions. It is both unhelpful and unfair. Religion must be understood in a broader way. (ii) Other views of religion. Very few of the traditional world religions are monotheistic. Indeed, some, like Buddhism, are, in some of their varieties, atheistic or have no place for distinctions like theistic or atheistic. Clearly, we cannot restrict religion to questions of God or deity or divinity and the relations of things to divinity. Not all religious expressions can be properly categorized as theological, nor be reduced to a theological dimension of belief or commitment. Sociologists of religion have frequently pointed out that political movements like fascism or communism, which attempt to articulate an ordered understanding of the whole world, bear all the sociological marks of otherwise traditional religion. Indeed, it is not only these types of political movements that can be understood as religious; nearly all states and societies seek to understand and express themselves in terms of ultimate meaning. Terms like freedom, democracy and human rights, when considered in any depth, reflect a particular understanding of the nature of human beings and their place in the nature of things. Hence, religion should be understood as referring to a person s or group s basic beliefs and commitments. This understanding of religion is common, even dominant, in modern theology. Paul Tillich characterized religion as the ground of our being. Such a broader understanding has been accepted in law in certain jurisdictions, for example, that governing conscientious objectors who are atheist or agnostic. Thus, whether someone believes in the autonomy of the human person or in God or another divinity, each is a religious belief which affects other beliefs, commitments and ways of life. To categorize one as being religious or theological and the other not is to misunderstand the nature of religion and fails to account for not only ideologies, but faiths such as Buddhism. Indeed, we would argue that it is difficult to understand certain new developments in North American television and radio broadcasting unless we adopt the proposed wider understanding of religion. Consider the sorts of programs being offered by religious broadcasters in the United States. These include soap operas, drama, documentaries, news, music and variety shows. Likewise, in its Decision CRTC 87-900 concerning VISION TV, the CRTC affirmed the VISION proposal to offer programming under two categories, one of which was called CORNERSTONE which would include general interfaith programming including nightly news, public affairs, children s programs, music, drama, documentaries, interviews and entertainment, all of which is to have a religious orientation. These examples illustrate that a varied religious commitment in broadcasting can lead not only to programs about a certain area of life, but to a different orientation across the whole spectrum of broadcasting. B. Religious Programming is Diverse in Expression The above mentioned diversity of programming demonstrates that anything which relates to, is inspired by or arises from a person s relationship to divinity includes a diversity of things. Indeed, it pertains to all things and includes the same variety of programming that is offered by conventional broadcasters who are considered non-religious. Religious broadcasting is broader than that which is church-related. As we argued above, the understanding that all that pertains to one s relationship to divinity can be circumscribed and divorced from other aspects of life is itself a peculiarly modern and secular understanding of what religion is. The belief and the expression of belief in a divinity is not merely an additional dimension of life which can be excluded when considering music, political affairs, business matters, humour, interpersonal relationships - that is, those things on which programming focuses. Religion should be understood as referring to the deepest commitment of a person or group. Such an expanded concept of religion allows us to take account of the fact that all programming reflects and is rooted in a particular view of the meaning of life, of the nature of society, of what human beings really are, of their essential responsibilities, whether to self, 2

society or another source. Therefore, the question of religious programming (as distinct from church-related programming) is not a question of whether we should have more or fewer church services or more or fewer evangelists. The question is rather one of diversity of programs. Religion does not refer to a particular area of life but rather to a view of all of life, a view that shapes all the things we do. The question of religious programming, and of religious diversity in programming, is a question about the nature of all programming, whether that be news, documentaries, church services, drama, music or sitcoms. It is a question of what ultimate commitments will shape the patterns of broadcasting. C. Religious Programming and Denominations Although the CRTC has considered religious broadcasting as necessarily denominational, we believe this identification is quite misleading. We have already tried to suggest that what is usually considered religious broadcasting is, in principle, no different than any other sort of broadcasting: all broadcasting and all programming reflects, and is rooted in, a particular view or sets of views. Only a portion of what is typically considered religious programming is church-related; that is programming concerned with, for example, the singing of hymns, church services, evangelistic programs and the like. While we maintain that programming from an ideological or religious point of view should not be confused with what is churchrelated, we also wish to argue that church-related programming (whether concerned with news, entertainment, or church-related subjects) ought not to be confused with what is denominational in orientation. In Public Notice 1983-112, the CRTC defined a religious program as one which deals with a religious theme, including programs that examine or expound religious practices and beliefs or present a religious ceremony, service or other similar event. This definition includes what we consider to be two types of programming: church-related and denominational. Many of the most important dividing lines among people who consider themselves Christians, for example, do not follow denominational or church division lines, but instead cut across them. This is most obviously the case, perhaps, with respect to the pentecostal and evangelical movements, but also with issues such as the views and activities of Christians toward social justice or native rights. In these cases the same transcendence or cutting through of denominational lines is quite obvious. This is to say that generally (at least outside of the rather narrow area of churchrelated programming) broadcasting points of view do not necessarily coincide with denominational lines, any more than any given commercial program sponsors hold similar or different points of view. Indeed, by and large, the explicitly religious groups who have at times made appeals to the CRTC for licenses are not denominational at all. They are, rather, groups of people of shared belief, of different denominations or of no denominations, who want to offer a particular category of broadcast programming. D. Diversity of Views of Broadcasting The Broadcasting Act states that the Canadian broadcasting system should encourage the development of Canadian expression by providing a wide range of programming that reflects Canadian attitudes, opinions, ideas, values and artistic creativity....(cf. 3.(d)(ii)) Thus the CRTC must continue to deal with the question of plurality and diversity in broadcasting and help ensure that the various commitments or beliefs which exist in Canada are represented on the public airwaves, both in radio and television, as well as on cable. Even if the CRTC is not prepared to follow our definition of religion as a basic commitment, the CRTC should still accept the principles of fairness and justice which are involved in ensuring that a wide range of programming is offered. It may decide to call these realities which shape programming by a different name, and decide to use the word religion to refer only to a specific area of life. Even so, the CRTC must still deal with the question of various commitments and beliefs in broadcasting and the fact that these unquestionably shape the nature of the programs produced and the variety of programs offered. III. The Question of Balance Prior to the decision to license VISION TV, the CRTC (and before that the Board of Broadcast governors) refused licenses to religious groups because, inter alia, they did not see how such groups could fulfil a mandate to provide a balanced opportunity for the expression of differing views. The Commission has held the view that a religious or denominational station would, by definition, carry a particular point of view and therefore find it extremely difficult to satisfy the balance requirements of the Act. The matter of balance was also fundamental in the decision to license VISION TV as an interfaith network with stipulations on the range of faith perspectives represented in programming, 3

in ownership, and on the board to ensure that one faith perspective does not dominate. Clearly, the question of balance is central to the CRTC s policy on religious broadcasting. A. The CRTC s Policy on Balance The CRTC, in its review of the question of balance (cf. Public Notice 1988-161), affirmed that it does not require that any one program be balanced. However, it does require balanced treatment on controversial issues and matters of public concern from each broadcaster. The notice states that the balance requirement is satisfied in the following manner: a) Each undertaking must comply with the requirement of the Act regarding balance in its own programming. b) Not all programming need be balanced, only that relating to matters of public concern. c) In general, balance need not be attained in each program or series of programs but rather in the overall programming offered by each undertaking over a reasonable period of time. d) To attain balance, equal time need not necessarily be given for each point of view. Rather, it is expected that a variety of points of view will be made available in the programming offered by the undertaking to a reasonably consistent viewer or listener over a reasonable period of time. Moreover, the CRTC has decided that it is the broadcaster s responsibility to decide whether an issue is one of public concern and to determine how balance will be achieved. While we note that the new Broadcasting Act no longer specifically requires a balanced opportunity for the expression of differing views, it does say that programming should be varied and comprehensive, providing a balance of information, that a reasonable opportunity be provided for the public to be exposed to the expression of differing views on matters of public concern, and, as mentioned above, that a wide range of programming be provided that reflects Canadian attitudes, opinions, ideas, values and artistic creativity. Diversity and balance continue to be important themes in the consideration of programming. EFC supports a policy of fair and balanced access to, and use of, the airwaves for all groups. Hence, we support the Commission s intention to keep the public airwaves open to contributions from all the diverse sectors of Canadian society and its intention to prevent these airwaves from being monopolized by or being disproportionately controlled by, any particular group or groups. However, we believe that the CRTC has sometimes interpreted its mandate to ensure balanced programming in such a way that the result is often unfair and unbalanced. It is our view that diversity and balance are not requirements of the broadcaster but rather of the system. Secondly, placing the burden of diversity and balance on the existing range of broadcasters is not sufficient to ensure that all the attitudes, ideas and values held by Canadians will be fairly represented on the public airwaves and on cable as required by the Broadcasting Act and guaranteed in section 2 of the Charter of Rights and Freedoms. B. Two approaches to Balance: The Objective and Proportional There are, broadly, two approaches to ensuring balance. One way is to make sure that objectivity is attained through the presentation of differing views from a balanced point of view. This view we will call the objective approach. The other approach is to allow and encourage, in a roughly even proportion, the expression of a diversity of particular perspectives represented in the broad cast region so that the people and groups in question are allowed to express their own point of view. This view we will call the proportional approach. These two approaches represent two different stances with respect to balance. In particular they focus on the question of where and at what level in the system that balance should be sought and when balance has been achieved. C. The Objective Approach One problem with this approach is that it requires someone or something to determine what a balanced view ultimately is on any subject, and then to judge programming by this standard. But who decides what is balanced? The CRTC has placed this burden on the broadcaster. It is the broadcaster who is responsible to decide whether a matter is of public concern and to determine the manner in which balance is to be achieved. (cf. Public Notice CRTC 1988-161, p.4) But can we assume that the licensee will be neutral or objective? We contend that, quite frankly, no such balanced or objective point of view is possible. The CRTC has itself distinguished between distortion and having a point of view and noted that the latter appears to exist at every point in the making of practically any program of public concern. (CRTC Public Announcement re Air of Death, Ottawa, July 9, 1970, pp. 12-13) We accept this distinction and, moreover, would emphasize that it is impossible not to have a point of view and impossible for this point of view (or someone else s) not to shape the programs one produces. 4

Any and every program inevitably requires the selection of materials from a broad background. Any such selection always reflects someone s beliefs about what is important, pertinent or interesting. Such a situation does not reflect in any adverse way on journalistic competence or integrity; it is a simple and unavoidable fact of human life. When we switch on the news, we receive someone s point of view as to what is important. The announcer may control her/his tone, the camera angles may be neutral, the language may even be clinically detached, but the fact that we are hearing and seeing this story rather than another, reflects the fact that someone thinks this story - or a particular aspect of a story - is one of the most important of the day s events. On any day s news we usually are told, implicitly, that the doings of politicians and governments are the most important events of that day. The absence of any reference to Cuba s activities on that day, or to Billy Graham s statements, shows that someone does not believe that these are pivotal events - and it is crystal clear to a communist or an evangelical that whoever shapes the newscaster does not have the same point of view that they have. We are suggesting that the point of view with which a broadcaster approaches matters of public concern, and thus controversial issues, is itself shaped by his or her religious or ideological commitment as we have described it above. Requiring balance of a broadcaster will only result in the presentation of the spectrum of views which the broadcaster deems to be relevant. Whether the subject matter of the news reflects the point of view of a few or even most Canadians is not at issue here. All programs are inevitably shaped by, and do in fact reflect, a particular point of view. Given that this is the case, we suggest that the search for an objective style of programming is ultimately futile. D. The Proportional Approach The other way to achieve a balance is to admit that all programming reflects particular points of view and then to allow (as far as possible) a diversity of points of view representing the beliefs and commitments of the population in the broadcast region. In light of our understanding of the religious or ideological root of all broadcasting, we are concerned that each broadcaster will be unable to achieve proportional balance. Not only will the broadcaster approach a particular matter from a particular point of view, there is also a multitude of points of view to be considered (not just both sides of a question - few questions are simple enough to have only two sides). How could they all be given access? Some points of view have more adherents than do others, and some points of view are very close to others. What would be an equitable division of air time between this and that view? A proportional approach across the system, while not problemfree, does begin to achieve balance by acknowledging that a diversity of points of view exists, that such a diversity cannot be conjured away and most importantly that programming inevitably reflects points of view. In addition to proportional diversity, the notion of proportionality can also be applied to the manner in which broadcasting licenses are distributed. The distribution of licenses within the broadcast system should be representative of those points of view held by the population in the broadcast area. We would therefore suggest that the CRTC consider adopting some form of what we have called a proportional approach and apply it to the broadcasting system. The key issue is effectively one of ensuring a proportional diversity of broadcaster s points of view within each telecommunications media region, each functioning broadcasting system, that represents the points of view held by the population. E. The Broadcasting Act We believe that the Broadcasting Act allows and even encourages the sort of approach we suggest: the Act does not require diversity and balance from each broadcaster; rather, the Act emphasizes diversity and requires balance from the broadcasting system as such. The pertinent section (3.1(i)(iv)) reads: The programming provided by the Canadian broadcasting system should (i) be varied and comprehensive, providing a balance of information, enlightenment and entertainment for men, women and children of all ages, interests, and tastes, (iv) provide a reasonable opportunity for the public to be exposed to the expression of differing views on matters of public concern... Diversity and balance is a demand the Act places on the broadcasting system, not on each broadcaster. The responsibilities of each broadcast undertaking pertain to the creation of Canadian programming (3.1(e)), Canadian content (3.1(f)), programming of high quality (3.1(g)), and responsibility for the programs they broadcast (3.1(h)). The Act does not require them to provide all the elements of diversity and balance within their own programming. Rather the requirement of diversity and balance is one that the Act puts on the system as a whole. Hence, we would suggest that the approach we advocate is squarely in line with the broadcasting Act. 5

F. The CRTC and Representative Proportional Diversity The approach of proportional diversity is one that the CRTC itself has taken from time to time. Indeed, the Commission appears to have adopted a mix of the two approaches to balance as we have outlined. At times it has urged that particular programs contain more balanced content within themselves. At other times the Commission has emphasized the importance of allowing other, very narrow types of programming. Its criteria for programming on community channels has been that the programming is different and presents an alternative to what already exists. It has licensed FM stations which provide material for only a very narrow range of interests, on the grounds that where there are many stations, there should be a variety so that listeners can choose what they like best. In these cases, it is the balance of the system that has been the major concern and programming is offered which is representative of the attitudes and tastes of the population. Hence, what we advocate has already been an aspect of CRTC policy in some areas. G. The CRTC and Proportional Diversity in Religious Programming However, in the case of what is commonly referred to as religious broadcasting, the CRTC has tended to adopt a rather different guideline for judging licence applicants. In the past, it had a policy of denying applications for radio licences from religious organizations and special interest groups on the grounds that the public property comprised by the radio frequency spectrum should not be used for narrow or sectarian purposes. (cf. Decision CRTC 80-423, p.5) An apparent turning point in this treatment came in the hearings in 1981/82 on religious broadcasting. As one consequence of these hearings the CRTC in 1983 called for a broadly based network programming service devoted to serving the varied religious practices and beliefs of Canadians on a national interfaith basis. We welcomed this decision. But we do not believe it answers all the questions we have raised about religion and diversity. While the decision goes a little way in this direction, several of our concerns still remain. In particular, it appears that the CRTC currently requires diversity and balance with regard to so-called religious proposals that it does not require from so-called secular ones. One illustration of this discrimination may be seen in its Public Notice CRTC 1984-124 which forbade the distribution of non-canadian religious stations. This policy was followed by the denial of actual application for such continuance. Given the clearly discriminatory nature of that decision we are thankful that the CRTC subsequently rescinded this decision. We also note that, for example, while conventional television stations do carry church-related programming, in broadcasting such programming they are not obliged to observe the same requirements concerning balance to which VISION TV is subject. The CRTC has also placed much more onerous demands on religious applicants than on secular applicants. In the case of VISION TV it has required that the ownership and the membership of the Board be representative of a variety of faith perspectives, a requirement it has not made of conventional broadcasters. In other areas the CRTC has allowed stations or networks to provide a particular point of view or service. Sports channels are not castigated for ignoring Canadian religious faith; news channels are not required to service those interested in drama; MTV has not been asked to serve all the varied musical needs of Canadians. Each of these has been licensed on the proper ground that it provides a further choice. They are not required to take care of all the needs not previously met by existing networks. The CRTC can also do this with religious broadcasters and still be fair to the parties involved and, in fact, better conform to the requirements of the Act. We believe that similar fair requirements should be asked of any new religious broadcaster as well. H. Balance and Controversial Programming Discussions and decisions on questions of balance and fairness often are made to revolve around the issue of controversial questions. To be fair or balanced, for example, a documentary on metropolitan zoning decisions ought to allow all points of view on this controversial issue to receive some acknowledgement. Controversial issues ought to be aired in a fair and balanced manner, although the CRTC has acknowledged that the maker of a documentary, for example, is not required to do the impossible and pretend to not have any position at all on the issue. The CRTC has rightly been concerned about fairness and balance in the treatment of controversial issues. Indeed, the Commission has referred to this as the fundamental problem with regard to religious stations. Our concern is that, given our understanding of the nature of that which is religious, the fundamental problem of fairness and balance which the CRTC has identified as peculiar to religious broadcasting applies to conventional broadcasters as well. As the CRTC understands controversial to be that which is likely to elicit differing views... (Public Notice CRTC 1983-112), controversy is not peculiar to religious views. The same requirements of balance should apply to all 6

broadcasters. Issues of fairness and balance are of critical importance far beyond the limited range of controversial programming. The fact that an issue is controversial implies that the issue is already widely and generally known and is a matter of public debate. But the broadcast media are themselves the most widespread and influential means of making issues widely known and debated. The media play a large part in determining what is, or is to become, controversial. Hence, if we are preoccupied only with controversial questions, then we run a grave risk of being preoccupied only with matters to which the media have already called attention. We would be concerned with balance and fairness only in regard to what the media have already decided to cover. Such an approach gives the existing broadcasters the power to decide what the issues are, and only then requires that those issues be dealt with in a balanced way. Clearly, such an approach leaves the door wide open for many other sorts of imbalance. What about all the issues which never become controversial because they are never widely known? What about controversial issues which broadcasters feel are unimportant, or which they are too afraid to touch? What about issues that are controversial for some people but not for others? What about an issue which broadcasters are incompetent to touch because it lies beyond their abilities or outside their usual area? What about issues that are not controversial but on which there are different viewpoints? All these are areas of potentially unbalanced coverage. We have already made clear our view that programming always involves points of view, a position which, in principle, the CRTC has acknowledged. We urge the commission to go beyond the present limitations on what kinds of issues are presented to the public - on what sorts of matters are allowed to become controversial, or for that matter, commonplace - and open up the broadcasting system to a wider range of points of view. We recommend that the Commission consider balance and fairness in a variety of interests, approaches and viewpoints. It is one that concerns the whole spectrum of broadcast material. I. Conclusions We suggest that the best approach to achieving balance in programming is by allowing a representative diversity of points of view to be broadcast. We maintain that: the broadcasting system, rather than a particular program or broadcaster, should be balanced; the Broadcasting Act allows and encourages this sort of approach; that the CRTC itself has, at times, taken this sort of approach in areas other than religious broadcasting; while the CRTC itself has, at times, taken some steps in this direction with respect to religious broadcasting, the Commission is still unduly restrictive with respect to this area of broadcasting. IV. The Present Canadian Broadcasting System A. Balance and the Portrayal of Religion We have suggested that the best way to approach balance and fairness is by allowing and encouraging a proportionate diversity of views and programs across the system. The CRTC has followed something of this approach with respect to regional programming, programming in the official languages, programming for native peoples, multicultural programming, community channels, specialized radio stations and diversity of types of shows. But we believe that the Canadian broadcasting system still reflects great unfairness. Most broadcasting in this country is done by a narrow range of special interest groups - that is, by commercial broadcasters. Such interests see broadcasting as a business and the programming they produce is shaped by this commitment. The lack of balance across the Canadian broadcasting system may also be seen in the portrayal of religion itself. As evangelicals we feel some of this most keenly, so perhaps the portrayal of evangelicals may serve as an illustration. In using such an illustration, however, we want to emphasize that our concern is with the fair portrayal of all groups. The fiascos in the United States concerning so-called televangelists brought discredit to many TV preachers. Much of the resultant criticism is thoroughly deserved. However, we are concerned that the beliefs and styles of the TV figures in question are often taken as representative of evangelicals in general, when they are, in fact, atypical. In particular these scandals are misused to confirm a false stereotype already commonly portrayed in the media. It is difficult to name one christian, let alone an evangelical Christian, who has been depicted in a network program in a modern setting, as a warm, loving, intelligent, compassionate person. There is a dearth of positive presentation. Of course, there are hypocrites and shysters enough, and they should be known and portrayed. But such a uniform stereotyping of an entire group of people is surely a far cry from the type of balanced portrayals the Act has charged the CRTC with developing. Another consequence of the present approval is that much religious broadcasting has been taken over by those with much money and little accountability - such as so-called televangelists. Canadians can be thankful that we have been spared some of the excesses south of the border, but the CRTC has not helped in this. Its past impeding of the development of good religious broadcasting, which reflects the faiths of 7

Canadians, leaves the door open to less scrupulous foreign operators. B. Canadian Content and Viability As mentioned above, we believe that there should be no separate policy for what is currently referred to as religious broadcasters. The same requirements, such as those pertaining to Canadian content, which apply to conventional broadcasters should apply to religious broadcasters. We also note that Canadian content restrictions do not prohibit the inclusion of foreign programming on Canadian stations; neither do such restrictions prohibit foreign stations and networks from being carried by Canadian cable companies; nor do they prohibit Canadians from receiving foreign broadcast signals with respect to conventional television and AM and FM radio. A greater diversity of perspectives should be represented among licensed broadcasters. In the case of cable which offers a great number of channels, cable channels should be assigned to religious broadcasters in addition to VISION TV in order to encourage diversity and to allow for a proportional representation of points of view which are held by a significant number of Canadians in a wide range of programming. With respect to conventional television and AM and FM radio, where frequencies are available or under review, consideration should be given to religious broadcasters who represent a significant proportion of the population in the broadcast area. Particularly in rural areas where there is a demand for a certain type of programming but where the number of persons wanting the programs are not numerous enough to viably support an independent Canadian station and where the signal of a Canadia station providing such programming outside of the region cannot be rebroadcast, licences should be issued to rebroadcasters of foreign programming. V. Recommendations We believe that the CRTC should approach the question of diversity and balance in broadcasting by allowing and encouraging, in a proportionate way, different programmers and broadcasters to broadcast according to their particular points of view. The changes in the Broadcasting Act have not altered the fact that balance and the opportunity for expression of differing views is required of the system, and not individual broadcasters. We recommend: 1.That the CRTC recognize that all broadcasting has an ultimately religious character in that it inevitably reflects a particular view of the world and a particular commitment in life; 2.That the CRTC recognize that religious or ideological perspectives are expressed in a wide range of programming, and not just in church-related or denominational programming; 3.That the CRTC ensure that the various commitments, beliefs and points of view which exist in Canada are represented on the public airwaves, both in radio and television, as well as on cable; 4.That the CRTC attempt to deal equitably with this diversity not in requiring of each broadcaster a (mythical) balanced perspective but by requiring that fair access be allowed to distinctive points of view and approaches in broadcasting; 5.That the CRTC allow an equitable and proportional diversity of points of view to be represented among licensed broadcasters; 6.That the allocation of broadcast licences in a given region be based on the representative demand in that region for programming expressing various points of view; 7.That the CRTC, wherever possible, open radio or TV channels to what is currently called religious broadcasting; 8.That in areas where there is significant demand for alternative programming but where numbers cannot sustain an independent Canadian station or service, and where the signal of another Canadian station offering such programming cannot be rebroadcast, that consideration be given to rebroadcasters of foreign broadcasting; and 9.That the CRTC should not demand of religious broadcasters what it does not demand of other broadcasters. The limited amount of good programming dealing with Canadians faith across the system means that any desire by the CRTC to follow the broadcasting Act in maintaining balance and increasing diversity must give greater room to religious broadcasters. The present discriminatory secular bias needs to be redressed. Respectfully submitted August 7, 1992 Dr. Paul Marshall, Co-chair of the Social Action Commission, The Evangelical Fellowship of Canada Copyright, The Evangelical Fellowship of Canada, 2000. May be photocopied without permission, providing acknowledgment of EFC as the source of the document is retained. 8