Intervention, observation ou réponse de l'intimé / Intervention, comment or answer by respondent

Date reçu / Date Arrived: 2022-08-03

Numéro de processus public / Public Process Number: 2022-182
Numéro d'intervention / Intervention Number: 7
Demande(s) / Application(s):
Cas / Case: 299900

Demande à comparaître à l'audience publique / Request to appear at the public hearing: Oui/Yes
Intimé / Respondent: Non/No

Commentaire / Comment
Montreal, August 3, 2022

Transmitted electronically

Mr. Claude Doucet
Secretary General
Ottawa, ON K1A 0N2

Object: Intervention by the Documentary Organization of Canada with regards to the Broadcasting Notice of Consultation CRTC 2022-182

Mr. Secretary General,

The Documentary Organization of Canada (DOC) is the collective voice of Canada’s independent documentary creators, representing over 1,000 members across six chapters from coast to coast. DOC’s mandate as a member-driven organization is to advocate for an equitable, sustainable environment for documentary production and to strengthen the sector within the broader cultural industry.

DOC spent two years urging CAVCO to modify its treatment of stock footage as these costs were often unavoidable foreign expenditures for documentary productions. Unfortunately, stock footage services are often difficult to source from Canadian suppliers and this has resulted in many difficulties for documentary productions. Fears of foreign stock footage costs have resulted in some productions never being made. The documentary community breathed a collective sigh of relief when CAVCO announced its modifications on April 22nd, 2022.

On July 6th, the CRTC published a notice of consultation regarding the treatment of stock footage costs as part of the Canadian program certification. DOC strongly urges the CRTC to adopt the same modification to the treatment of stock footage costs as CAVCO. Specifically, that these costs be considered as “other” costs rather than “services” costs when calculating the breakdown of costs of a production.


Sarah Spring
Executive Director
Documentary Organization of Canada

Raisons pour comparaitre / Reasons for appearance
I would like to have the opportunity to explain why so many documentary films use stock footage, why these costs are often necessarily sourced outside of Canada, and how difficult it would be for documentary productions if the CRTC does not implement the same modifications as CAVCO.

Copie envoyée au demandeur et à tout autre intimé si applicable / Copy sent to applicant and to any respondent if applicable: Non/No

Information du client / Client information

Nom / Name: Sarah Spring
Titre / Title: Executive Director
Au nom de la compagnie / On behalf of company: Documentary Organization of Canada
Adresse courriel / E-mail address:
Adresse postale / Address: 401 Richmond St. West Suite 392, Toronto, ON, Canada
Code postal / Postal code: M5V 3A8
Téléphone / Telephone: 647-846-7638
Facsimilé / Fax: