Our business model sucks, literally. It is a vampiric system that limits choice, free speech and competition. Look at the free programming on 28E and tell me why we can't do that.
The way I see it, is that in the USA and Canada, after the primary broadcast networks and other local stations, cable TV came before "cable" type channels, and as cable type channels arrived (earlier ones were mostly pay with little advertising), cable providers were the inital and exclusive outlet for them, and becasue of that "cable first" situaton, the cable providers (and by extenson pay satellite providers) set the rules, and have the clout with the smaller cable channels, to tell them what to do, in that if they want to be on cable, part of the deal is they be exclusive to pay providers.
Yes they may have been distributed on satellite or microwave, but at that time, they considered those mediums closed. When home C-band gained critical mass, the major cable channels scrambled to protect the cable exclusivity, and eventually sold C-band subscriptions to home providers.
In Europe, cable TV, at least as non-broadcasts specialty channels, did not exist until the 1990s, when consumer satellite began as well. With that, as cable and home satellite had a parallel emergence, the channels themselves could decide for themseves if they could be FTA on satellite. Of course, a lot of that, at least in the UK, has to to with the TV license paying a lot of the costs stations would otherwise have to bear.