Final Submission : Intervenor 263

Document Name: 2015-134.223983.2614317.Final Submission (1k17x01!).pdf
Telecom Notice of Consultation CRTC 2015-134
Final Intervention of the
Canadian Association of the Deaf - Association des
Sourds du Canada (CAD-ASC)
Twitter: @CADASC Website:
May 25, 2016
Frank **** **** Roots
President Executive Director
Suite 606, 251 Bank **** Suite 606, 251 Bank ****
Ottawa, Ontario *** *** Ottawa, Ontario *** ***
******@***.com ******@***.com

1. Pursuant to the proceeding on “Review of Basic Telecommunications Services”, the Canadian Association of the Deaf-Association des Sourds du Canada (CAD-ASC) respectfully submits this Final Intervention.

2. CAD-ASC would like to provide our thanks to CRTC for this opportunity to have us present at the Hearing in Gatineau, Quebec on **** 18th, 2016.

Mbps Download/Upload ****

3. The CRTC launched the discussion at the hearing on Review of Basic Telecommunications Services on this topic about 5 Mbps download and 1 Mbps upload speed where the CRTC recognizes that a well-developed broadband infrastructure is essential to help Canadians participate in the digital economy.

4. As a result, the CRTC has set a target speed for broadband Internet access across Canada (Telecom Regulatory Policy CRTC 2011-291). By the end of 2015, the CRTC expects all Canadians to have access to broadband speeds of at least: 5 Mbps for downloads (data that consumers are receiving from the Internet, including files, web sites, pictures, music, and movies) and 1 Mbps for uploads (data that consumers are sending to the Internet)1

5. The Telecom Regulatory Policy CRTC 2011-291 was made during that time where VRS and other video communications were not introduced yet and to be determined as a telecommunications basic objective.

6. The Telecom Regulatory CRTC 2014-187 decision policy outlines the approval of the implementation for the VRS services in Canada for both ASL and LSQ users. The Mbps download and upload speed was not determined in their Telecom Regulatory Decision.

7. During the CRTC TNC 2015-134 hearing, many telecommunication service providers continued to maintain that the current standard on 5 Mbps for download and 1 Mbps for upload is enough for Canadians to participate in the digital economy. In the CRTC Monitoring Report, it states that by the end of 2014, ninety-six percent of Canadian households can access a download speed of 5 Mbps, which is sufficient for streaming higher quality audio and video content.2 In response to all parties involved, we stress that 5 Mbps download and 1 Mbps upload does not meet our video accessibility needs for ASL and LSQ users to enable functional equivalency for telecommunication access in the digital economy. The video content is completely different from any Sign language video communications such as VRS. Facial/bodily expressions and fingerspelling cannot be recognized through these slower speeds.

1 CRTC, Internet **** and Performance, 2 Figure 5.3, CRTC Communications Monitoring Report 2015, 3

8. Further to this, in the response dated February 29, 2016, the Canadian Administrator of Video Relay Service (CAV) explained if the IP provider is delivering 1.5 Mbps to the household, but on average other non-VRS users are consuming 1 Mbps, then the VRS user will be limited in the quality of the video communication experience. CAV considers it beyond the scope of this response, but points out that it may be a material consideration.3 9. The World Federation of the Deaf Statement on the Adoption and Adaptation of Technologies and Accessibility issued on October 20144 clearly states that Deaf people have taken advantage of the rapid advances in information and communication technologies, and use them creatively to improve their quality of life. Access to information and ease of interaction is possible by:

1. Visual communications (e.g.; YouTube videos with captions, etc);

2. Services supplied on-line in sign language;
3. Relay services: and,
4. Other emerging accessible technologies

10. Therefore, video communications including VRS must be recognized as human rights to access telecommunications, and must thereby be defined as a basic telecommunication services. The CAD-ASC points out that the Australian Communication Exchange VRS provides VRS broadband speeds up to 24 Mbps download and 8 Mbps upload 5, which provides a high video quality and ensures a full accessible to the telecommunication services. With the Australian example, CAD-ASC, therefore, sees higher speeds as a need for clear video communications for VRS and other general video communications.


11. During the public hearings in Gatineau on **** 18th, 2016, questions were raised as to how a discount or special-price package for Deaf consumers might be designed. Among these proposals was the replacement of voice-data minutes with video-data minutes, and/or higher ceilings on date-usage charges for video use for ASL and LSQ users.

12. One strategy, which was overlooked at the time of the hearing, was the current 50-percent discount offered to registered TTY users by all telcoms. This discount has been in place since the very early 1990s in recognition of the fact that it takes three to five times longer to type a TTY message than it does to voice it, and therefore it would be discriminatory to charge TTY subscribers the same per-minute costs as for voice users.

13. The CAD-ASC suggest a similar 50% discount could be offered to registered ASL and LSQ users by all telcoms and ISP’s. Deaf people who use IP Relay Services are already 3 Canadian Administrator of Video Relay Services, Responses to requests for information – 29 February 2016, **** 5

4 World Federation of the Deaf Statement on the Adoption and Adaptation of Technologies and Accessibility, October 2014,

5 Australian Communication Exchange VRS FAQ, 4

required to register with those services in order to access them, so the introduction of a standard 50% discount should not entail significant additional administrative burdens.

14. In Telecom Regulatory Decision 2014-187, the Commission noted that VRS users will need access to an Internet service and that there are a variety of Internet packages available in the marketplace that meet the minimum requirements for VRS.6 Therefore, the CAD-ASC proposes that the Commission direct all telecom providers (TSP’’s) to design and offer a more affordable package to accommodate Deaf Canadians for broadband Internet with an at least 100GB data plan to achieve a stronger video quality. This will assist them to participate in the digital economy for telecommunication services by avoiding any frequent “bill shock” due to higher data usage from their intensive use of video communications.

Telecommunications Accessibility Fund (TAF)

15. The CAD-ASC would like to point out that the Commission has created a number of funds for specific purposes, some related to accessibility such as the Broadcasting Accessibility Fund. The CAD-ASC recommends a separate fund be established as a Telecom Accessibility Fund (TAF). The TAF would be similar to the Telecom Relay Services fund that has long been a feature of the Federal Communications Commission in the USA.

16. The CAD-ASC emphasize again that all Telecommunication Services Providers including Telephone Service Providers, Wireless Service Providers, Internet Service Providers, etc.

must be required to contribute to the TAF, not merely the TSPs. The TAF would fund accessibility services to ASL and LSQ users to ensure access to any telecommunication services.

• Funding must be nation-wide to include ASL and LSQ users in both urban and rural communities;

• Funding could subsidize internet packages for ASL and LSQ low-income users to get reasonable data plans to access video communications;

• Funding can be used to develop educational videos in ASL and LSQ.

17. With the TAF funding to be available, CAD-ASC could apply to hire a Project Coordinator to provide outreach and engagement within the Deaf community across Canada via video productions, informational and announcement videos, workshops and events along with other partnerships such as CWTA and others.

Accessibility Office and Disability Advisory Council

18. The CAD-ASC understands that the CRTC has a division called Consumers Affairs and Strategic Planning, which includes the Social Policy Office (SPO), and that the latter is regarded by the Commission as its equivalent of the Disability Access Office (DAO) of the U.S. Federal Communications Commission. However, there are no ASL and LSQ users in the SPO nor elsewhere in the CRTC who have expertise in accessibility. (Hard of hearing 6 Telecom Regulatory Policy CRTC 2014-187 #84, **** 16, 5

employees are not ASL and LSQ users and cannot be considered experts in Deaf accessibility.)

19. Further to this, the CAD-ASC proposes a permanent Disability Advisory Council that would serve as a formal liaison between the CRTC, the telecom industry, and members of the disability community. The CRTC would be responsible for funding two meetings of the Council per year. Membership in the Council would be chosen from national disability consumer organizations including CAD-ASC.

20. The Accessibility Office and Disability Advisory Council can establish objectives to develop a national framework on action plans to remove barriers for persons with disabilities and Deaf people in the telecommunication sectors for the purpose of ensuring accessibility lens across all telecommunications initiatives and developments in the digital economy.

21. The CAD-ASC strongly recommends that the CRTC employ persons with disabilities and ASL and LSQ users to provide an accessibility lens to all its decisions and policies, research and regulatory framework.


22. The CAD-ASC has reviewed the Deaf Wireless Survey Analysis 7 from Deaf Canada Wireless Committee (DWCC) regarding wireless accessibility needs of ASL and LSQ users and we support these findings in the survey analysis result.

23. The CAD-ASC would like to remind the Commission to consider the accessibility needs of ASL and LSQ users which require a high Mbps download and upload as outlined in this Final Intervention, as well the elimination of throttling practices that imperil the quality of the high-speed, data-heavy video transmissions that we require for equality of access.

This will ensure that ASL and LSQ users have the same rights to access like other Canadians who use their voice for making any calls to their family, friends and anyone.


7 Deaf Wireless Survey Analysis, **** 2016,

Final Submission : Intervenor 263

Document Name: 2015-134.223983.2614318.Final Submission (1k17y01!).html

The Canadian Association of the Deaf-Association des Sourds du Canada (CAD-ASC) respectfully submits this Final Intervention for TNC 2015-134 and the Final Intervention is attached. Thank you.