I would like to share a criticism of the DOC’s talking points (see the bottom of this post), which were released in advance of the CRTC’s upcoming workshop on re-defining CanCon.  I intend to criticize because I don’t believe the talking points are adequate to address the crisis that we face as documentary filmmakers, and I believe that constructive criticism can improve them.  I also intend to make my critique without malice or anger, and without pointing fingers.  I don’t have any serious disagreement with what DOC has presented; the talking points aren’t wrong or harmful.  I simply don’t believe that they address the issue in a way that will be meaningful.

What is the issue?  CanCon is fundamentally about culture, which means it is about relevance:  CanCon is content that is relevant to Canadians.  As Canadian filmmakers, we have been in a fight for cultural relevance for at least the last quarter century, and we have been losing.  For most of my professional career, discussion around CanCon has framed cultural relevance as “discoverability”:  The need to ensure that the films we create are seen — “discovered” — by Canadians.  I will return to this idea later, but for now, let me just observe that discoverability does not ensure relevance.  In fact, discoverability assumes that CanCon (undefined) is relevant, and the problem is one of access:  Canadians simply don’t have easy access to their culture.  This is absurd.  Our culture comes from us; we can’t be separated from it so easily.  The separation is in fact a disconnect between CanCon — the films, the “content” we create — and culture.  In plain terms, the content we create under the CanCon regime is mostly — with a few exceptions — not Canadian culture.  Despite our best efforts, many or most of the films we create are not relevant to most Canadians.  Figuring out how to change that, how to make sure that the billions of dollars spent on CanCon produces films that Canadians watch and care about, needs to be at the centre of this conversation.

But it’s not.  The talking points the DOC has shared do not make either culture or relevance central.  In fact, they have very little to say about what Canadian culture is; they simply assert that, whatever it is, it is made by Canadians as long as we are the ones making creative decisions.  They assume that, because our films were made by Canadians, they are therefore relevant.  This is more or less the same definition of CanCon that we’ve had for the last 30 years.  It is the same definition that has seen the erosion of CanCon and the loss of cultural relevance for most of the creators working within the CanCon system.

Based on what I heard at the recent webinar, this is not an accident.  As I understand it, DOC’s position is that the definition of CanCon isn’t the problem, but our independence as Canadian creators is threatened by outside actors — primarily the streaming giants — who wish to weaken the ownership and control of CanCon by saying that it simply need to be about Canadians, regardless of who is making the creative decisions.  Therefore, DOC’s efforts are intended to ensure that CanCon funds are available specifically and exclusively to independent documentary creators.  In other words, DOC’s advocacy efforts are about money, and ensuring that some portion of the CanCon funding is carved out specifically for documentary filmmakers in a way that ensures it cannot be co-opted by the behemoth streamers and broadcasters.  This understanding is not reflected in the talking points, but based on what I heard in the webinar, I believe the talking points are intended to help ensure funding for documentary.  Personally, I don’t see the connection — I don’t understand how maintaining and defending a status quo definition of CanCon will bring money into our pockets — but this is my best understanding of what DOC is advocating for.

I believe that DOC’s approach misses the point.  Focussing on money, important as that is, sidelines any discussion of culture or relevance.  Yes, we are all struggling to raise money, and no, we cannot do our work without a reliable source of funding.  But money cannot buy relevance.  Money is necessary for creation, but it is not sufficient to create culture.  Our CanCon system has been assuming that simply paying Canadians to create is enough to produce Canadian culture for the last 30 years.  DOC’s talking points also make this assumption.  They are silent on the key point:  What makes our creations culturally relevant?  They barely mention the word “culture”, and they do not give any sense of how DOC thinks of culture, or what policies might support it — what policies would help make our work relevant.  They assume that the act of creation by a Canadian is enough to produce cultural relevance.

I believe this approach is backwards.  In fact, cultural relevance produces money, not the other way around.  When our films do generate enough attention to be culturally relevant, they also generate income.  They become commercially viable.  Perhaps there is some work to do to ensure that the money it generates makes it way back to us as creators, but the point is that the relevance comes first, not the money.  Thus, I believe that DOC should be advocating for a definition of CanCon that explicitly defines what Canadian culture is, what makes it relevant, and that explains how that relevance is generated.  I want to acknowledge that Sarah did talk about the importance of including a cultural element in the definition of CanCon in today’s webinar.  She said that she has heard this concern from many filmmakers, and she praised the fact that the CRTC is, for the first time in decades, considering a cultural aspect of the definition as well as an economic one.  I agree, seeing the CRTC single out culture in this way gives me a great deal of hope; it makes me excited to take place in their consultation.  And it makes me all the more frustrated that DOC’s talking points are silent on this point.  If it is true that this point is known and understood by many of us already, it needs to be reflected in our talking points.

If CanCon is to have any cultural worth, DOC (and Canada) needs a theory of where culture comes from and how it is generated.  That theory needs to spell out a definition of CanCon that is capable of creating films that are culturally relevant, and which therefore justifies government funding for CanCon.  As filmmakers and artists, we are supposed to be the guardians and creators culture, yet for decades we have struggled for cultural relevance and this struggle has worsened.  So, here is a theory:

At the most fundamental level, culture is something that is shared:  Shared values, shared experiences, shared food, shared conversations, etc.  Canadian culture is something that is shared by Canadians.  In our vast, diverse, cultural mosaic of a country, there are very few universals, so it doesn’t have to be shared by all Canadians, but it needs to be shared by enough of us that it, whatever form “it” takes, is recognizably shared by a Canadian group.  A piece of Canadian culture is shared by at least one, and preferably multiples of the many tessarae that make up our cultural mosaic.  Canadian culture is relevant to the extent that it is shared among Canadians:  The more it is shared, the more relevant it is and the stronger that piece of culture is.  So, the fundamental questions we need to be asking are these:  “What causes Canadians to share with each other?” and “What produces shared experiences and where does that sharing come from?”  These questions bring us back to the idea of discoverability, but framed in a more useful way.  They make us ask “What captures our attention as Canadians, and how do we choose to spend our time?” and “What do we care about?”

Solving discoverability means looking at the problem from the point of view of ordinary Canadians — from an audience perspective — rather than the creator’s point of view.  The question is not “how can we force Canadians to pay attention to our work?”, the question is “how do Canadians decide what to pay attention to?”  This question has an answer in the present day, but solving it requires a historical perspective.  In the present day the internet, and social media in particular, have come to dominate our attention.  There are many flavours of this, and no one entity dominates the attention of Canadians or of any particular individual.  But there are some powerful players.  We ask Google to direct our attention when we are looking for information.  We give social media our attention when we want to know what the people we care about are doing or thinking.  We rely on Netflix to take care of our attention when we are seeking entertainment and don’t want to pay attention to anything in particular.  I won’t go too much deeper into this; others have written extensively about this, and some of our members have made films about it.  Suffice to say, a great deal of our attention — and thus, a great deal of our culture — is being directed by what has come to be called the “attention economy”.

The attention economy is the answer to my questions about relevance.  As our social lives have moved increasingly online, it is the internet that mediates the things that Canadians share.  Our shared experiences — our culture — happen online and on social media.  We increasingly choose to direct our attention on the basis of algorithmic recommendations, and the things we care about are dictated by the people we meet online and the experiences we have there.

All of this is, I think, fairly obvious.  What’s perhaps less obvious is what these online behaviours have replaced.  We have forgotten how we used to direct our attention before the attention economy took over.  So, let’s look at that.  Before the internet, news media, libraries, and universities were our sources of information.  Our cultural leaders were journalists, editors, and professors.  Instead of social media, we were simply social (in person, by phone) when we wanted to interact with people, and we relied on tabloids and daytime television for our understanding of “who’s who”.  We had a star system of celebrities that dominated our attention in those media.  For entertainment, we had film and television, and the cultural relevance of those media needs no explanation:  it is the same cultural relevance we are trying to recapture today.

What’s different about the previous system is not the fact that we had different media, but the geographical boundaries and the way that attention was directed within those media.  We have always struggled to resist American cultural hegemony (i.e. we have struggled to form shared experiences that are uniquely Canadian rather than borrowing American or English culture).  Prior to the internet, two things were different.  One:  we had strong, protectionist rules around Canadian ownership of media outlets, as well as restrictions on concentration of ownership in regional Canadian markets and across different forms of media.  The ownership rules helped ensure that decisions about what was seen were made by Canadians, and regional market rules made sure that there were a multitude of competing editors making those decisions.  Two:  Our cultural leaders — our “influencers” in today’s parlance — were selected by a cultural élite, not by algorithm, and only partially by “popularity” (as determined by market success).  In other words, the decisions about who and what got to be on television — who got attention, and therefore cultural relevance — were made by gatekeepers, and their decision were driven more by curation and a sense of Canadian nationhood, and less by “data”.  Decisions about what culturally importance were made by actual human beings, who made judgments about what they thought was important and relevant.  While there were certainly market pressures at play, by and large, ratings and sales data wasn’t specific enough to know exactly what content was popular at any given moment, so programming decisions were driven by the subjective, curatorial instincts of those gatekeepers.  That subjectivity — the ideosyncratic biases, preferences, and politics of the cultural élite was the distinctive, formative basis of Canadian Culture — and CanCon.

It’s worth observing that Canada used to have more of a distinction between “high culture” and “low culture”.  High culture was primarily driven by the élite, especially at the CBC and by major news and political institutions.  Low culture was less distinctively Canadian, more market driven, and much more heavily influenced by American media.  Even at the peak of its relevance in the ’70s and ’80s, CanCon was primarily a high culture phenomenon, representing and consumed by only a minority of Canadians, and driven almost entirely by non-market preferences and priorities.  When CanCon adopted its current definition as “Canadian culture is whatever is created by Canadians”, that change was driven by a recognition that CanCon wasn’t culturally relevant to a large portion of Canadians.  But, the new definition of CanCon basically abandoned any attempt at defining relevance to the market.  It ensured funding for Canadians within that market, but it did nothing to ensure that the CanCon that was funded would be more relevant to Canadians than anything else the market produced.  Our high culture was eclipsed by our low culture, and our low culture has become almost indistinguishable from “Western culture” in any other globalized nation.  Modest as it was, the previous system managed to create culture that was more relevant then than our current one.

Let me summarize my “theory of culture”.  Culture is created through shared attention, and therefore the ways that we direct our attention dictate what becomes culturally relevant.  Canadian culture is created when Canadians pay attention together.  I hope this summary is intuitive and obvious enough that it makes sense and is uncontroversial.  The theory is my opinion — an informed one, I hope, but an opinion nonetheless.  I make no claim to its ultimate correctness, and I welcome competing theories.  But, whether it’s my theory or a different one, DOC’s talking points need to reflect an understanding of how Canadian culture works if it is going to have any hope of improving CanCon.

Having said that, a theory is not enough.  If we want a CanCon system that can create relevant Canadian culture, the theory needs to turn into policy and practice.  We need to recognize that our culture is being created by the attention economy.  If we want to influence how that culture is created, we need to regulate the market for attention, and that means properly defining that market.  In addition to the traditional players, broadcasters, distributors and whatever Canadian “star system” still exists, our attention is being captured, bought and sold by the internet giants.  We need to understand that, different as all of these businesses are, they are all competing in the same market as competitors, and the traditional Canadian media giants are being out-competed (for attention as well as money) by companies that are much bigger, which are not Canadian owned, and which are fundamentally uninterested in ensuring that the attention they direct produces a culture which is distinctively Canadian.

We need to understand what unifies this market.  It is a cultural market, not a monetary one.  Its medium of exchange is attention, not money.  Our attention is being bought and sold, either by aggregating attention and reselling it to advertisers or by offering paid content which is compelling enough to capture our attention directly.  It is a global market, not a national or regional one, and therefore the culture it produces is global, not Canadian.  And it is extremely concentrated, with very few players capturing the majority of the attention and the money that goes with it.

If we want CanCon that is relevant to Canadians, we need a system where our cultural leaders — our influencers — are selected on the basis of human, Canadian judgment, and where there are a wide range of regional and cultural tesserae represented by those leaders.  We also need a market with real national boundaries, and we need to decide, through regulation, when and how people can compete for our attention.  This means considering advertising, news feed or recommendation algorithms, culture, and other major ways that our attention is directed as part of the same market, and it should be regulated as a market.  It should be possible to take anti-trust action against entities that monopolize our attention, there should be tariffs for content that “exports” our attention, and rules to prevent people stealing or abusing our attention.

That’s a very big vision, and it’s not something that could happen overnight (maybe it shouldn’t even happen at all).  I’m not advocating that DOC should try and write those regulations.  That’s not something DOC could our should take on.  Rather, I think it’s important to understand that our attention (and therefore our culture) is being controlled in a way that is analogous to a market, and (getting back to the point) that understanding should inform the way that CanCon is defined.  Specifically, the definition needs to include the idea that CanCon is made relevant by attention from our Canadian audience, and therefore CanCon regulations need to address how that audience is formed.

In addition to the definition of CanCon, there are two other points that I would like to see DOC advocating for.  One:  recommendation algorithms need to be outlawed or regulated so that decisions about relevance come from human, Canadian judgment.  This is controversial (it’s a fairly important part of C-11), but it is absolutely essential, and probably hard to get right.  Two:  rebuild rules that restrict ownership and media concentration across different regions and media.  This is how we break up the broadcaster duopoly, and it’s also how we deal with the online advertising oligarchies of the internet giants.  Markets should be defined by metropolitan area, and violating the rules should require either divestment or paying to subsidize competitors in that market.  In my opinion, this would be far more effective at improving diversity than the current approach of trying to incentivize it on a per-production basis.  The best way to get a wider variety of content is to hear about it from a wider variety of places.
I’ve said a lot here, but I believe there is a lot more to be said on this issue.  I’ve presented a criticism and my own theory about how CanCon could be changed to make it more relevant.  I hope I will not be the only voice.  I hope my theory is a useful way to analyze our industry, and I hope that others with more knowledge and experience than me can improve and elaborate on it.  I think my policy recommendations in particular could use some development, criticism and fleshing out.  These are not fully developed policies yet, but I hope they are a good start.  And I hope that DOC is able to build off this criticism to develop a better theory of its own.  We need more than just the status quo to rebuild our industry.

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These are the talking points that DOC has released, which my thoughts above are referring to:

• Canadian content is content that is owned and controlled by Canadians.
• Some of the key creative positions need to be Canadian for it to be Canadian content, such as the writer and director. 
• Canadian stories do not need to take place in Canada: the fact that they are coming from a Canadian point of view makes it Canadian.
• When Canadians are in the driver’s seat in terms of developing Canadian content, Canadian stories are told from our own point of view. Some non-Canadian companies may decide to develop content that resonates with Canadians, but as market-driven entities they cannot be relied upon to carry out our cultural policy. 
• Canadians know what stories are important to tell. Canadian stories are often unfolding in our own communities, be these on Canadian soil or in our counties of origin. If we are not the driving force developing and producing Canadian content we risk losing content that showcases our perspectives, history and national / regional identities.
• Documentary films are key to Canadian content as they not only tell our stories from our point of view, they are a living library of Canadian perspectives.

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