Comically Tight Deadline at CRTC Consultations Had Negative Impact on Submissions

With the deadline past on two consultation on the Online Streaming Act, the deadline clearly impacted public participation.

Two of the CRTC public consultations are already closed. This despite only days earlier, the government merely released a draft public policy direction that is clearly subject to change. Between the tight deadline and the sorry state of the policy direction from the government, numerous organizations asked for an extension for all three. In response, the CRTC denied two of the three requests, leaving only one consultation open for public feedback.

When I made submissions for consultation 140 and 139, I honestly wasn’t sure if they were going to ultimately be that great. It took a good portion of my experience as an English major to process huge amounts of information quickly and directly respond to what was asked. It really felt like my days of last minute cramming for handing in large essays. I didn’t exactly feel great about what the submissions looked like partly because I had no idea what is generally expected or what goes in to formulating a good response. After all, this is the first time I had ever intervened in a CRTC consultation.

Today, however, in looking over the other interventions, I actually felt a heck of a lot better about what I was able to submit in the tight deadline. In my intervention, I had managed to formulate a response directly to the actual questions being asked. What’s more, it was formatted to make it easy to actually read why I was responding in the way that I was. I had quoted parts of the consultation and addressed the points. What’s more, I had even slipped in a few citations for my sources on top of it all. Afterwards, I had mentally had all the characteristics of writing a final exam: mental fatigue, sluggishness, and a craving for carbs and sugar. It was a feeling I had hoped I would have never felt again after graduation, but here I am today experiencing those symptoms.

In reading other people’s interventions, however, it was very obvious I was far from the only one struggling to come up with a response to make it inside of the deadline. Indeed, there was a number of interventions that seemed to have not even bothered reading the companion document to address what was actually being asked. In one instance, it looked as though someone thought it was an e-mail inbox to MP Rachel Thomas.

Others, however, seemed to actually understand the consultation process. A number of organizations that normally are quite thoughtful with their responses offered small documents. Some were seemingly offloading their main arguments for the event that they are called to appear in person. This appears to be a tactic to buy some time to be better prepared. This would be quite the gamble since there is always the risk that the individual or organization would not be called in the first place, meaning the submission was nothing more than a husk that offered nothing in particular. It’s easy to see the thinking because one doesn’t want to say something foolish and have to explain later that the deadline was exceedingly tight and it was hard to offer something thoughtful.

In those cases, however, the fault clearly doesn’t lie with the organizations and individuals intervening. The fault was on the CRTC for not giving adequate time to allow these individuals and organizations enough time to prepare their submissions in the first place. Submissions had to be made in haste and a number of interveners made it a point to complain about this (I was one of them to point out the excessively short deadline).

The inherent problem is the fact that submissions to these consultations would be lowered. What was submitted would be of lower quality, barring proper consultation in the first place. By rejecting the deadline extension requests, the CRTC made it clear through action that it wanted to limit the number of people participating in these consultations in the first place. What’s more, it offers further evidence that the CRTC has already made up its mind on what it wants to do and that the consultation was nothing more than a box ticking exercise rather than a serious effort to solicit feedback from the public.

All of this puts the validity of the consultation into serious question. The CRTC may try and say that they had their consultations with the public, but the process itself was conducted in such a way to prevent public participation. As others have said, this whole sorry affair weakened the public record. Worst of all, we aren’t even close to seeing how the CRTC intends on responding. With everything we’ve seen so far, things are not looking promising with how the regulator will respond.

Drew Wilson on Twitter: @icecube85 and Facebook.

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