Final Submission : Deaf Wireless Canada Committee (Intervenor 265)

Document Name: 2015-134.223984.2614308.Final Submission (1k17_01!).html

Please find two documents submitted for Final submission. IF there are problems with links... please advise our group and we will gladly re-submit via e-mail fixed document(s).Thank you, DWCC-CSSCRaisons pour comparaitre / Reasons for appearanceOnly if follow-up is required

Final Submission : Deaf Wireless Canada Committee (Intervenor 265)

Document Name: 2015-134.223984.2614307.Final Submission (1k17n01!).pdf

​Deaf Wireless Canada Committee Review of Basic Telecommunications CRTC TNC 2015 ­ 134

APPENDIX A:

**** of Canadian Deaf, Hard of Hearing and Deaf­Blind Organizations

May 25, 2016 Canadian Deaf, Hard of Hearing and Deaf­Blind organizations

CAD­ASC AFFILIATE LIST:

Greater Vancouver Association of the Deaf (GVAD) Calgary Association of the Deaf (CAD) Edmonton Association of the Deaf (EAD) Alberta Association of the Deaf (AAD) Saskatchewan Deaf Association (SDA) Manitoba Deaf Association (MDA) Ontario Association of the Deaf (OAD) Association ontarienne des Sourd(e)s francophones (AOSF) Société culturelle québécoise des Sourds (SCQS) Deaf and Hard of Hearing Youth Association of Nova Scotia (DYANS) Newfoundland and Labrador Association of the Deaf (NLAD) Organization Member:

Centre québécois pour la déficience auditive (CQDA) Deaf Youth Canada (DYC)

British Columbia

BC Cultural Society of the Deaf (BCCSD) BC Deaf Sports Federation (BCDSF) British Columbia Family Hearing Resource Centre (BCFHRC) BC Rainbow Alliance of the Deaf (BCRAD) BC School for the Deaf (BCSD)

British Columbia Video Relay Services Committee (BCVRS) Council of Service Providers (CSP) Deaf Children’s Society of BC (DCS) Deaf Youth Today (DYT)

Deaf, Hard of Hearing & Deaf­Blind Well­Being Program (WBP) Family Network for Deaf Children (FNDC) Greater Vancouver Association of the Deaf (GVAD) Island Deaf and Hard of Hearing Centre (IDHHC) Mid­Island Deaf Association (MIDA) Norwest Deaf Outdoors Club (4x4) Provincial Services for Deaf and Hard of Hearing (PDHHS) Western Institute for the Deaf and Hard of Hearing (WIDHH) Alberta

Alberta Association of the Deaf (AAD) Alberta – **** and Voices

Alberta Deaf Sports Association 1

Alberta Cultural Society of the Deaf (ACSD) Alberta School for the Deaf (ASD) Calgary Association of the Deaf (CAD) Connect Society

Deaf and Hear Alberta (DHA)

Edmonton Association of the Deaf (EAD) Edmonton Fellowship of Deaf­Blind (EFDB) Saskatchewan

Saskatchewan Deaf Association (SDA) Saskatchewan Deaf and Hard of Hearing SDHHS – Saskatoon Saskatchewan Deaf and Hard of Hearing SDHHS – **** Saskatchewan Deaf Sports Association Manitoba

Deaf Centre Manitoba Inc. (DCM) Deaf Support Services ­ D.E.A.F.

Manitoba Association of Visual Language Interpreters (MAVLI) Manitoba Catholic **** of the Deaf (MCCD) Manitoba Cultural Society of the Deaf (MCSD Manitoba Deaf Association (MDA) Manitoba Deaf Sports Association (MDSA) Manitoba Deaf Association (MDA) Manitoba School for the Deaf (MSD) Manitoba Video Relay Services Committee (MBVRSC) Ontario

Association ontarienne des Sourd(e)s francophones (AOSF) Belleville Association of the Deaf (BAD) Canadian Hearing Society (CHS) Canadian Cultural Society of the Deaf (CCSD) Deaf Culture Centre (DCC)

Deaf Literacy Initiative
**** Deaf Services
**** Club of the Deaf (LCD)
Deaf Halton Association (DHA)

Ontario Association of the Deaf (OAD) Ontario Cultural Society of the Deaf (OCSD) Ontario Deaf Sports Association (ODSA) Ontario Rainbow Alliance of the Deaf (ORAD) Ontario Video Relay Services Committee (OVRSC) Ottawa Deaf Sports Club (ODSC) Robarts School for the Deaf

Silent Voice
2
**** Bay Club of the Deaf

Toronto Association of the Deaf (TAD) Toronto International Deaf Film and Arts Festival (TIDFAF) Windsor Association of the Deaf (WAD) Quebec

Association de l’Ouïe de l’Outaouais Association des gais et lesbiennes Sourds (AGLS) Association des Devenus Sourds et des Malentendants du Quebec Association des personnes vivant avec une surdité de Laval (APVSL) Association des Sourds de l’Estrie Association des Sourds du Québec Association du Syndrome de **** du Québec Association Sportive des Sourds du Quebec (ASSQ) Centre de communication adaptée Centre de la communuaté sourde du Montréal métropolitain Centre des loisirs des Sourds de Montréal Inc.

Cinéall Production des Sourds

Coalition Sida des Sourds du Québec Centre québécois pour la déficience auditive (CQDA) Foundation des Sourds du Quebéc Groupe de recherché sur la LSQ et le bilinguisme sourd’ de l’Université du Québec à Montréal (UQAM)

Le Centre Alpha­Sourd Rive Sud Le Regroupement des Sourds de Chaudière­Appalaches Maison des Sourds, Montréal

Société culturelle québécoise des Sourds (SCQS) Atlantic: Nova Scotia, PEI, New Brunswick Atlantic Provinces Special Education Authority (APSEA) Deaf and Hard of Hearing Youth Association of Nova Scotia (DYANS) Deaf Literacy Nova Scotia (DLNS) Nova Scotia Cultural Society of the Deaf (NSCSD) Nova Scotia Deaf Sports Association (NSDSA) Saint John Deaf and Hard of Hearing Services, Inc. (SJDHHS) Society of Deaf & Hard of Hearing Nova Scotians (SDHHNS) ****­East Deaf and Hard of Hearing Services (SEDHHS) Newfoundland

Newfoundland and Labrador Association of the Deaf (NLAD) Newfoundland Deaf Sports Association (NDSA) Territories

Few personal contacts in Yukon (Whitehorse) 3

National organizations

Association of Visual Language Interpreters of Canada Canadian Association of Educators of the Deaf & Hard of Hearing Canadian Deaf Hockey Federation Canadian Deaf Ministries

Canadian Deaf Sports Association Canadian Cultural Society of the Deaf Canadian Ukraine Alliance of the Deaf and Hard of Hearing Deaf Youth Canada

Canadian National Institute for the **** – deaf­blind services Deaf­Blind organizations

Canadian Deafblind and Rubella Association Greater Vancouver Association of the Deaf – Deaf­Blind Planning Committee (DBPC) Edmonton Federation of the Deaf­Blind (EFDB) Association du Syndrome de **** du Québec Hard of Hearing organizations

Canadian Hard of Hearing Association:

CHHA ­ Northern Territories
CHHA ­ BC
HEAR Branch
CHHA Vancouver
CHAA BC Parents
CHHA Comox
CHAA **** Shore
CHHA Calgary
CHHA Edmonton
CHHA Lethbridge

Reference:​ ​http://www.chha.ca/chha/about­branches.php Interpreter agencies

Maritime Association of Professional Sign Language Interpreters (MAPSLI) Ontario Association of Sign Language Interpreters(OASLI) Service d’interprétationvisuelle et tactile (SIVET) Sign Language Interpreting Associates Ottawa (SLIAO) Sign Language Interpreters of the National Capital (SLINC) West coast Association of Visual Language Interpreters (WAVLI) ​ *** END OF DOCUMENT*** 4

http://www.chha.ca/chha/about-branches.phphttp://www.chha.ca/chha/about-branches.php

Final Submission : Deaf Wireless Canada Committee (Intervenor 265)

Document Name: 2015-134.223984.2614306.Final Submission (1k17m01!).pdf
Deaf Wireless Canada Committee
Review of Basic Telecommunications
CRTC TNC 2015 ­ 134
May 25, 2016
Introduction

The following constitutes our final comments to TNC 2015­134. Deaf Wireless Canada Committee (DWCC) expresses appreciation towards the CRTC for allowing us to present the Deaf community’s experience with the Wireless Service Providers (WSP’s) at the hearing for CRTC TNC 2015­134. Our committee’s final comments submission is organized by wireless concerns we have mentioned from our original intervention. The parts are as follows:

1) Advertising and Promotion
2) Digital Literacy
3) Wi­Fi and Wireless: **** and Data Requirements
4) Upload and Download Speeds
5) Text with 9­1­1
6) Responses to Telecommunications Companies and Related Organizations
7) Final Recommendations

Before we begin the document, as a preliminary clarification, we need to define some word usage. Instead of typing Deaf, Hard of hearing and Deaf­Blind, we abbreviated to DHHDB. We also use ASL and LSQ users as well as “sign language using Canadians” interchangeably.

1
Responses to the Commission’s Queries at the Hearing

In this section, we will include the questions queried by the CRTC Chairman or the Commissioners, and quote transcript line numbers and then add further comment or response to that question. All transcript references refer to this link, **** 18th CRTC TNC 2015­134 Transcript, seen at this link​: http://www.crtc.gc.ca/eng/transcripts/2016/tt0418.htm DWCC would like to clarify what we were saying in the live hearing proceeding, directly and in our own words, in response to the Chairman’s queries:

Fairness and Uniformity
Response from the Chairperson or CRTC Commissioner,

7031 THE CHAIRPERSON: ​So my first question, though, is more specifically to the DWCC. And I notice that your mandate refers to fair and uniform wireless data plans. I mean, you’ve chosen to use the word “fair” and “uniform”, those two words, and I was wondering if you could put a little bit more meat around that bone so that we understand what you mean about “fair” and “uniform”, and specifically around the word “uniform”. As you know, we tend to put emphasis on communication that is competitive and uniformity might be seen as not quite in line with a notion of a competitive market, if everything is the same.

Further Clarification from DWCC:

DWCC did not mean uniformity across the competing wireless service providers (WSPs), we do understand and see the need for competition as well, rather we meant uniformity ​within the companies. It is through our Deaf community and Committee members’ own experiences that we are not seeing uniformity or adherence to what is actually being advertised or printed. Our Committee used the word uniformity as opposed to the word disparity, of which we were seeing within​ the companies.

To attempt to further clarify as we said during the hearing with transcript line​7035​, we provide an example: There are 3 different Deaf customers of hypothetical company, **** Wireless. All three Deaf customers are located in the Vancouver area, and all have 2GB data plans. One is paying $35 for the the 2GB Greater Vancouver Association of the Deaf (GVAD) plan; another customer is paying $65.00 monthly for 2GB and has a $15 subsidy; and the third customer is paying $85.00 monthly for 2GB monthly, with a $30.00 subsidy. There is no uniformity within 2

http://www.crtc.gc.ca/eng/transcripts/2016/tt0418.htm

hypothetical company **** Wireless, and each of the three individuals get differentiating subsidy/discount for non­use of voice minutes.

The problems with this scenario is:
1) Too much disparity within each individual company;
2) Not everyone is aware of the subsidy offered;

3) There is unclear rationalization of the variation of situations where there is application of the subsidy; and finally;

4) There is too much personalization of different packages between CSR and customer taking place. Deaf community members have complained that it feels like a secretive agreement are taking place, especially when they find out their friends got a discount and they didn’t.

DWCC agrees with how wrong all of these scenarios are, therefore we are bringing this to the CRTC’s attention, with the goal to get clearly advertised and fair plans that follow exactly what is being advertised so everyone is treated fairly.

In conclusion, there is no consistency, hence, ​uniformity ​within the companies. DWCC know CRTC TNC 2013­271, the Wireless Code covers this topic, especially focused in the items numbered: 319­338. Deaf Community members maintain that greater improvements need to be made to existing efforts, because confusion and disparities yet exist.

This once again raises the concern that Canadian WSP’s advertising has to improve. If you compare Canadian WSP’s efforts to place information on the website, to American WSP’s, Canadian WSP’s actions have been very minimal. Conversely, American WSP’s have went to lengths to advertise clearly and publicly on their websites packages designed for the DHHSI or sign language using consumers. Please see Appendix C in DWCC’s ​Deaf Wireless Survey Analysis report, **** 2016, pages 77­83 for the American companies’ examples, and page 83­89 for the Canadian examples. The type of options displayed on these sites are what we need to see instead of minimal, abstract sentences on the Canadian WSP websites.

3

http://www.deafwireless.ca/wp-content/uploads/2016/05/Deaf-Wireless-Canada-Survey-Analysis-2016-REV02-APRIL-19-2016.pdfhttp://www.deafwireless.ca/wp-content/uploads/2016/05/Deaf-Wireless-Canada-Survey-Analysis-2016-REV02-APRIL-19-2016.pdfhttp://www.deafwireless.ca/wp-content/uploads/2016/05/Deaf-Wireless-Canada-Survey-Analysis-2016-REV02-APRIL-19-2016.pdfAdvertising and Promotion

7094 THE CHAIRPERSON: ​You mentioned earlier that the packages and services available to the deaf community weren’t always as clearly identified on the various websites of the service providers. You also make comments in your presentation about better communication, whether it’s through advertisement or other ways to provide information to the community. I was curious because this can’t be the only area where you need to communicate with the deaf community to share information and developments. For instance, presumably to identify the folks that participate in your survey you had to reach out to people. And by the same token, I assume that the Canadian Association of the Deaf as well, has ways of reaching out to the deaf community.

Further Clarification from DWCC:

It is our view that an entire reliance on the limited resources of the Canadian Association of the Deaf­Association des Sourds du Canada, would not be the most effective way and means for distribution. In fact, the Canadian Association of the Deaf­Association des Sourds du Canada has limited reach, the organization distributes only to its members, and to its 9 provincial affiliate members, and two organization members (source: ​http://cad.ca/about­us/membership/​), as well as its individual members. CAD­ASC does have a Facebook **** and a Twitter account, the Facebook page has 2,029 members, 1,335 followers in Twitter.

However, to merely rely on the CAD­ASC is an incredible burden with the organization’s limited resources. There are 100+ organizations in Canada that serve the DHHDB, whom can also be contacted for greater distribution reach. DWCC has put together a list of organizations in Appendix A, to show the CRTC, as well as the CWTA, of organizations that seem to have been missed in information dissemination.

Since the establishment of DWCC, we have become a new distributer of wireless­related news, media and information. This information is shared with our 700+ followers on social media platforms, and with the long list of contacts we have acquired during the gathering of contacts for distribution of our ​Deaf Wireless Survey​, which consists of now 100+ contacts of Deaf, Hard of Hearing, and Deaf­Blind (DHHDB) groups and organizations across Canada, listed in Appendix A.

CAD­ASC and the DWCC will pool their resources into a shared distribution list, to send out posts and information as necessary. When we request for greater distribution to these contacts, we will begin to habitually practise providing instructions on exactly how to distribute, wording and #hashtags, as that was successful with the distribution of the ​Deaf Wireless Survey​.

4
http://cad.ca/about-us/membership/

DWCC recognizes a few challenges with regards to distributions. Let us provide an example to illustrate, using CRTC’s videos. The DWCC commends and appreciates the CRTC for its efforts with the ASL and LSQ playlists of “​Roadmap to CRTC Processes​.” Committee members note, and are concerned, that the series of CRTC­produced videos have a very low viewer count. For example, the video on ​Complaints only had 80 views​. There needs to be improvement in the manner of distribution of such important and critical videos. DWCC sees that there needs to be further distribution for greater reach and increased viewership of these videos. Perhaps each video in the playlist, rather than the playlist as a whole, could be shared one by one to keep the interest in such ASL and LSQ videos at a momentum.

The CRTC should send an e­mail to those named in Appendix A, formally requesting for help to spread the word on the availability of these videos. DWCC recommends provisions of specific instructions for sharing in different avenues, and provide recommended #hashtags to use. Social media has greater reaches and these videos can be shared further and wider, and the awareness will be that much more increased, with a leap in viewer numbers. This approach worked for us at the DWCC with the distribution of our ​Deaf Wireless Survey. ​We can work with the CRTC to develop an extension to existing media plans, to target this population.

From experience, the most effective way to communicate with ASL and LSQ users is through videos and vlogs. When distributed efficiently, there are greater results with these informational videos, such as: greater attendance numbers at workshops, greater responses to surveys, and so forth.

Additionally, we must re­emphasize, as we did in the live proceeding, that CAD­ASC, as well as CAD­ASC’s affiliates has very limited funding, thus, with grant availability limitations, have not been able to do additional extensive work or efforts. Such examples of extensive efforts would include: purchasing expensive equipment to provide accessible videos, we do not have the facilities; obtaining a proper green screen (required because it is critical that we are inclusive of our Deaf­Blind audience); and video editing. As there is no budget for this effort, CAD­ASC and affiliates are left using volunteer resources, personal equipment, and sourcing other non­profit groups for use of their studios. This is exactly where we would appreciate specific funding such as a ​Telecommunications Accessibility Fund, whereas groups like ours and/or CAD­ASC could apply and work towards developing such informational and announcement videos. Or, after the proceeding, learning of a new coined term, “digital literacy,” that perhaps such a​digital literacy fund be created with contingency funding for production of such videos that are made specifically for ASL and LSQ users.

5
http://www.crtc.gc.ca/eng/info_sht/transcript.htm
http://youtu.be/fRlMFTI3qHo
Digital Literacy

Understanding how a system works and how to file a complaint requires an individual to process a great amount of information. In this instance, consumer education and awareness are essential for ASL and LSQ users in understanding how the telecommunications system works so that they could make informed decisions and if necessary, file complaints accordingly. (​Deaf Wireless Survey, page 19).

Here are suggestions that our Committee members came up with:
1. Videos to help ASL and LSQ users understand the complaints system

CRTC had the right idea with its production of “​Roadmap to CRTC Processes​”. There are a few more specific videos which would benefit our consumer group. We request for the CRTC to produce ASL and LSQ videos focused on the ​Wireless Code, CRTC TRP 2013­217​, especially the more relevant points that have to do with accessibility, such as section #18, points 327­338.

As well as the section about pricing items #319 to #326. Our Committee can help in the consultation of which parts should be made into ASL or LSQ, and the creation of said videos.

We will also do our part to distribute these videos via social media and our website.

Suggested title: “​Understanding Your Rights with the Wireless Code.​”
2. Videos to help ASL and LSQ users understand the complaints system

DWCC’s ​Deaf Wireless Survey results itself presents evidence of ASL and LSQ consumers facing billing issues with their WSP’s. However, there are wide­ranging gaps in linking this specific population of consumers to the informational steps in making complaints.

DWCC recognizes that many Deaf and hard of hearing consumers are not aware of what CCTS stands for, as ​Commissioner for Complaints for Telecommunications Services ​and its mandate:

“​At the requests of CRTC, CCTS administers the Wireless Code. It means that CCTS applies the code to resolve complaints it receives from Wireless customers.​” Thus, it is possible that CCTS may not have as many complaints directed to them by our demographic population of Deaf, hard of hearing and deaf­blind.

DWCC first recommends that CCTS produce a series ASL and LSQ videos that outline specific steps to access the CCTS system for finding resolution with their wireless bills. This video should integrate graphics and text, to emphasize important points or specific instructions.

For this demographic group’s accessibility, ASL and LSQ videos need to be produced along with written context in **** and **** with accompanying visual graphics. Creating generic 6

http://www.crtc.gc.ca/eng/info_sht/transcript.htm

picto­graphics, infographics and/or videographics would be useful in clarifying the flow chart of a process on filing complaints. Please refer to a chart on page 20 of our ​Deaf Wireless Survey that visually illustrates the various options and which steps need to be taken in filing complaints and reaching resolutions. (Note: one of our Committee members revised this diagram using one of the WSPs’ original flow chart visibly seen on page 20 of our​Deaf Wireless Survey).​It is with this chart, that it is clear there are various options and steps in making and resolving complaints.

To sum this up, we recommend a video production be made by the CCTS and also recommend that the CCTS create generic picto­graphics, infographics and videographics to clarify the complaints flow. However, it would be a priority to create ASL and LSQ videos with explanation of escalation paths for resolution of wireless billing issues.

Suggested title: ​“​How to Make Complaints.​”
3. Wireless Service Agreement Contract Vocabulary

Understanding what contract terms are in sign language will benefit Canadian sign language users (ASL and LSQ), but if added subtitles and voiceovers, these videos would benefit **** as as second language and the general Canadian population. This would be in accordance to items number 336(i) and especially and specifically, 337 of the Wireless code:

336. The Commission notes that, in this decision, it has required WSPs (i) to provide contracts in alternative formats for people with disabilities upon request and at no charge;

337. The Commission expects WSPs to ensure that customers with disabilities have the information they need to determine which plans and services best meet their needs.

Choose the most common vocabulary and terms in all wireless service provider contracts and define them in ASL and LSQ. To avoid duplicity and wasting resources and finances, we suggest to film them all to apply generally to all WSP’s. Then these same videos are to be shared on ​all the WSP's websites. Please feel free to consult with both CAD­ASC and DWCC for these video productions, we find that other consultations have not been all­inclusive, for example, making the videos accessible to include Deaf­Blind Canadians.

Suggested title: ​“​Your Service Agreement​”
7
4. General Wireless Terminology

DWCC should work on producing short videos on general​wireless terminology​, that will also provide specific links to both CRTC and CCTS‘s videos and any other future links related to Wireless issues. These videos would ultimately find their home on the parent organization CAD­ASC’s website.

DWCC has, in fact, begun this work, producing videos of ASL and LSQ definitions of wireless terminology, defining approximately 30 common wireless terms, as part of this proceeding, and we are just getting into the video editing phase for the ASL videos.

Due to the challenge of locating such all of the above (in items 1 to 4) important videos, the DWCC website can and will serve as a consumer education and advocacy central hub for all of the wireless­related ASL and LSQ links. DWCC plans to start with the CRTC videos on the “Roadmap,” and it is our hope that the other groups can start to produce the other videos and DWCC will gladly add it to our links and keep our Deaf community informed via social media.

One video at a time will certainly maintain people’s interest and keep momentum building.

To wrap up these points on digital literacy videos, Mr. Jim Roots mentions in transcript line 7100:

“​Your suggestion proposes that the consumer take on the responsibility to get the word out. It’s the wireless service providers to advertise and to make it known. DWCC don’t have the resources to make an ad campaign and to promote the service providers’ products and services. They have the deep pockets. They’re already advertising to other customers in the same way. They just haven’t focused their advertising to our community yet.”

Please consider how other countries have figured out strategies to reach their customers. Deaf Australia (same organization purpose as Canada’s CAD­ASC) partnered with one of the Australian WSP’s to announce and promote their deaf­friendly wireless plans, which we illustrated in our ​Deaf Wireless Survey​.

8
Digital Media Advertising

7097​And I was wondering why you think, for instance ­­ one of you has proposed that we use TV advertisement to help inform people which, as you can well imagine, is a very costly solution as opposed to the ways you might be reaching out to the deaf community otherwise?

DWCC suggested mainstream advertising as a way of improving the reach of the advertising to let others that are not in our be more aware of the options being made available to them.

DWCC proposes mainstream advertising such as TV commercials should be used to inform ​all consumers of new packages and plans, in addition to other forms of digital and print media. This recommendation has twofold benefits:

One, it educates sign language using Canadians on the products and services available to them, when this consumer group is known for loyalty to companies that appear to go the extra mile to accommodate. This means a larger consumer base for the company that steps forward and does this first.

Two, this is not a matter of reaching only sign language using Canadians, but rather a matter for the telecommunication company(ies) to show all Canadians the length they went to be inclusive and accessible. People like “feel good stories”, and a commercial with two deaf people having the ability to talk to each other through a video conferencing application on their phone provides exactly this. Regardless of someone’s need for accessibility features, seeing a corporation take that step could be the action they need to determine their own loyalty. DWCC members are willing to work with telecom providers in creating idea commercials to benefit both, as well as a general media marketing plan to compliment their ongoing efforts).

To conclude this section, a greater effort needs to be made with ASL and LSQ video productions to enhance the digital literacy of our consumer group(s). Funding needs to be made available in the form which the CRTC deems most reasonable. It would be fantastic to give DHHDB consumer groups the ability to apply for these funds, and create jobs for those that are underemployed. The CAD­ASC is such a group that would create these jobs for this underemployed population.

9
Download vs. Upload Speeds

DWCC did respond to the CRTC’s RFI with the deadline of May 5th, regarding the download and upload speeds and provided a chart and DWCC’s position. Since then, reviewing all the documents, including hearing transcripts, we are finding that several groups such as Media Access Canada group (transcript lines ​7289­7297) have views that align with ours with the provisions of equivalent, or symmetrical Mbps speeds, and therefore DWCC maintains 10/10 Mpbs as the recommended download/upload speed, for clear video communications. We want to ensure video communications are clear on BOTH ends, which differs from video streaming. If upload speed is not high enough, what would be described as lop­sided conversations occur; where one side of the video communication is clear, and the other side is blurry.

DWCC agrees with the MAC group about the larger companies’ ability to provide these specialized symmetrical speed packages opposed to the smaller companies. DWCC sees these bigger companies as capable of investing in the video communications data package offerings for ASL and LSQ users. With this, DWCC confirms the vision that such symmetrical packages provisions is possible, with policies and decisions made by the CRTC.

With sign language, there is more movement, hence more packed into each byte as it is transferred through video communications, whereas it is much less with audio travelling through the same route. It is evident that for ASL and LSQ users, fluid video communications require more Mbps and higher bandwidths for clear communications. All sign language users naturally need and require higher quality video resolution for the comfort and ease of flow in conversation without straining or pixilation, with unclear video both ways in two­way communications.​(​Source:

http://www.deafwireless.ca/wp­content/uploads/2016/05/DWCC­CSSSCResponsetoRFIQuestionforCRTC2015­134February062016_02LinkNotWorking­2.pdf​)

Wifi versus Wireless and **** Requirements

7072 ​THE CHAIRPERSON: ​Now, maybe just so I understand, many of us when we are on our wireless devices, knowing that often times going over our data caps can be quite expensive, we choose ­­ and it’s quite reasonable ­­ even with wireless devices, to use Wi­Fi, other Wi­Fi that we have in our home or Wi­Fi that’s available in restaurants or other businesses. And I was wondering if you could help me understand the behaviour in your community, whether it’s similar or not and to what extent you’re able to individually or collectively manage some of the limitations that you mentioned, both in terms of cost and technology to, for instance, use video communication services?

10

http://www.deafwireless.ca/wp-content/uploads/2016/05/DWCC-CSSSCResponsetoRFIQuestionforCRTC2015-134February062016_02LinkNotWorking-2.pdfhttp://www.deafwireless.ca/wp-content/uploads/2016/05/DWCC-CSSSCResponsetoRFIQuestionforCRTC2015-134February062016_02LinkNotWorking-2.pdfhttp://www.deafwireless.ca/wp-content/uploads/2016/05/DWCC-CSSSCResponsetoRFIQuestionforCRTC2015-134February062016_02LinkNotWorking-2.pdfFurther Clarification from DWCC:

Highlighted are several points DWCC recognize:

­ Whereas hearing people can utilize free minutes, or are given unlimited minutes, the DHHSI consumers do not have the same benefit. Many of these voice minutes and plans go unused, what is the equivalent to the unlimited talking minutes, to ensure ​functional equivalency​ for ASL and LSQ consumers?

­ Whereas data consumption is greater with video usage than voice usage, consuming more bytes with increased pixelation usage with the movement of the hands and arms for communication by ASL and LSQ users.

­ Whereas hearing people can use their phone enabled with voice anywhere anytime and still maintain quality, it is not equivalent for the Canadian sign language user group.

Considering the points above, DWCC asks, whether unlimited data minutes, or “signing minutes” will be made available to ASL and LSQ users that will be an equivalent benefit?

For ​functional equivalency related to unlimited voice minutes, options should be given to ASL and LSQ user, as as a type of “worry­free” packages for the use of video communications and data consumptions with ample data allowances.

**** to the query made by Chairman, in line 7072, about public Wi­Fi as well as “while you are out and about,” we agree with the Media Access Canada’s statement, “while there are public Wi­Fi spots, the quality of service you’re going to get there is probably even lower than what you can get off the cellular network.”

In addition, we would describe the challenge with regards to video communications as such:

For Canadian sign language users, video quality is essential, not optional. Expressions cannot be recognized through video conferencing or video calling programs on a slower connection. At such a speed, video calls usually freeze or glitch, causing the user to repeat themselves unnecessarily, an experience that speaking Canadians do not experience through voice calling, especially if utilizing a HD connection. This indicates that our recommended data amounts and speeds are necessary for sign language using Canadians to participate meaningfully in Canada’s digital economy.

ASL and LSQ users try to be careful of usage, but what is really hingeing on the actual usage is the quality of the video communications over whichever connection is being made for the communications. When public Wi­Fi areas become congested and the quality of the video communications declines greatly, the ASL and LSQ user may be forced to switch and utilize their personal wireless services instead, for improved video quality. Ample data packages need 11

to be created to allow for these kinds of scenarios so it is less challenging for video communication users, including any future video relay communications, for ASL and LSQ users.

To add to this, for DWCC’s position, let’s use the responses coming from the Canadian Administrator of Video Relay (CAV) in its response to CRTC’s request for information (RFI), on page 8, with a best estimate of how much data a typical VRS user would consume each month in MB or GB. Using the 2010­2012 Telus VRS trial’s number of 108 minutes per user per month, they estimated the data use for VRS at 120 minutes of use per month per user to be about 1.05 GB data consumption per month. However, DWCC would like to point out that the Telus VRS trial provided videophones, which were used only at home and through a wired modem connection. Fast forward to today, technology has advanced to the point that smartphone or tablet use is now most popular for video communications. As communications are not restricted to use only when the consumer is at home now, additional data is required when the consumer is not at home. In consideration of the differences between technologies’ capabilities between 2010 ­2012 to present day technology, it is vital to consider the new information we have gained in this proceeding.

In light of this new information, DWCC presents options for WSP’s to consider:

1. 2GB added to all of ASL and LSQ user’s existing data packages automatically for the provisions of accommodating the high use of video communications including mobile VRS access (new recommendation)

2. Capped 10­12 GB data allowances, with the understanding that there is 2GB overage allowance, ​without​ overage penalty (previously proposed)

3. Unlimited voice minutes to be replaced with unlimited “signing minutes” presented as unlimited data or packages without caps for ASL and LSQ users specifically for video communications (our preference). Unlimited data packages may have not previously been available, but it is time to make this possible. ​It is 2016.

Lastly, we are concerned about the decrease in quality as the use of the data increases, known as throttling, which would affect the quality of video communications. Some ASL and LSQ users have experienced package usage reach limits and all of sudden they see 3G connections rather than LTE connections. Consequently, the video communications become blurry and difficult to comprehend. WSP’s should not attempt network management or apply a throttle on this very essential component of video communications for ASL and LSQ users. One way of monitoring this is providing specified data packages and specific allowances enabled for these Canadian sign language users, and ensure that this measure of throttling does not affect video communications.

CRTC and all WSP’s need to recognize that ASL and LSQ using Canadians deserve a chance to participate in the fabric of Canadian society everyday. Providing data packages specifically for 12

video communications is essential for our functional equivalency​. Communication is a right, regardless if the individuals are hearing or Deaf or Hard of Hearing. Presently, sign language video communication is not being treated as a right because of telecoms' limitations and barriers, imposed on wireless data plans for ASL and LSQ users, with caps and throttling taking place.

Creating fair (as defined in the beginning of this document) and affordable packages will ensure that ASL and LSQ users have the same rights as other Canadians who use their voice for making voice phone calls.

Text with 9­1­1

DWCC would like to clarify what was said in the live hearing proceeding, in response to the Chairman’s query below:

7122 THE CHAIRPERSON: I’m trying to have a better understanding of your position with respect to Text 9­1­1 because there are comments that don’t align with my understanding of how Text 9­1­1 operates. There seems to be some suggestions that it’s not free, that somehow subscriber localization is not working, and that it somehow isn’t meeting the needs of the deaf community. And I just really want to understand a little bit better your preoccupation.

To start, text with 9­1­1 is set up in a way that is confusing to DHHSI people, at least the Canadian Sign language user group. It was the CRTC’s decision to set it up this way in Telecom Decision 2013­22:

14. The Commission therefore ​approves the recommendations in the Report and directs all wireless carriers and ILECs to make the changes required to support the provision of T9­1­1 service within 12 months of the date of this decision.

http://www.crtc.gc.ca/eng/archive/2013/2013­22.htm
Further information, ​http://crtc.gc.ca/eng/phone/911/can.htm

While we understand registering for Text with 9­1­1 access is a requirement, the aspect of voice minutes being needed is confusing in itself. It is required for Deaf people to initiate a voice call, the feature which they do ​not use, to call 9­1­1. As we submitted for Telecom Proceeding 2016­116 recently, we pointed out that so many Deaf people are not clear that:

1. It is REQUIRED to have voice still attached to their plan in order to access to​Text with 9­1­1 ​because;

2. They need to dial 9­1­1 first and;
13
http://www.crtc.gc.ca/eng/archive/2013/2013-22.htm
http://crtc.gc.ca/eng/phone/911/can.htm

3. They need to register. However there is confusion of where they need to go to register, and it doesn’t help with the unclear registration webpage with all the WSP icons at Textwith911.ca

Additionally, many WSP’s websites for Text with 9­1­1 registration are currently experiencing glitches in website upgrades or updates. These pages should not have been affected, as a matter of safety.

DWCC is concerned because of several incidents, regarding Text with 9­1­1, one of which we provide an example of. One of our committee members tried to text 9­1­1 in an emergency situation, not fully conscious, and could not access Text with 9­1­1 services, simply because at their WSP vendor, they had argued to remove voice minutes from their WSP service plan, and the WSP vendor removed voice minutes. This rendered ​Text with 9­1­1​ inaccessible.

Clearly, lack of knowledge is prevalent in this DHHSI group as a result of the way the CRTC determined, in Telecom Decision 2013­22, was the best way to set up the​Text with 9­1­1 system.

It is imperative changes are made to ​Text with 9­1­1​ infrastructure, to remedy these concerns.

This has given the DWCC a resolve to ensure there is priority given to those that are responsible, such as funding­rich organizations and companies, to immediately mandate efforts, such as producing announcing or digital education vlogs, to clarify why WSP vendor locations should not be allowed to remove voice plans from their wireless service agreements. One general vlog should be produced on consumer education and safety related to Text with 9­1­1. One vlog would be sufficient, and can be distributed across multiple websites including the WSP companies’ own websites.

Further comment is available on these issues at our submission to CRTC TNC 2016­116. Please see CAD­ASC and DWCC’s joint document at this ​link​.

Responses to Telecommunication Companies:

7048 THE CHAIRPERSON: ​Based on your knowledge, and I’m addressing this question to both groups, are there any Canadian service providers that are able to provide you currently ASL or LSQ interaction?

7049 I know, for instance, and we’ve heard in other proceedings that some major telecommunication companies obviously hire people from their local community and that means that there’s all kinds of multilingual capacity within their workforce. And 14

http://cad.ca/wp-content/uploads/2016/05/CADASCDWCC-Intervention-CRTC-TNC-2016-116-Textwith911.pdfsometimes those employees are called upon to help out in customer relations using that language of that individual.

7050 So I was wondering if, to your knowledge, any of the ­­ whether it’s the wireless providers or the wireline providers, are you aware of any one of them following a similar course?

DWCC’s Presentation Quote:

To further re­emphasize, we have not yet heard of vendor WSP locations with CSRs fluent in either or both ASL and LSQ for their customers, however we have a further recommendation, whereas WSP vendor locations, by way of mandated efforts by head office, to hire and find signing CSRs and then identify exactly where they are located, specific stores, specific addresses and DWCC and the CAD­ASC can assist in the promotion and awareness of specified vendor locations via the list of organizations outlined in Appendix A.

In **** 18, 2016 CRTC TNC 2015­134 Transcript, in lines 6986 ­ 6989 ​As a part of Deaf Wireless Canada Committee’s presentation, we recommended and suggested:

­ Wireless service providers should also invest in ASL and LSQ users to ensure that communications are received in those languages;

­ Employ ASL and LSQ users as customer service representatives or CSRs. Invest in extensive training for employees who are willing to learn new languages, specifically ASL and LSQ to provide customer service to those consumers;

­ Provide sign language interpretation upon request;

­ Opening direct communication with ASL & LSQ communication provided to consumers accessing the CCTS and the CRTC for complaints or queries.

Whereas in CRTC **** 18, 2016 Transcript line 7052, DWCC acknowledges the comments several WSPs have introduced about sign language interpretation provisions, further to the commentary, as a form of proposing solutions, it has occurred to DWCC that another suggestion should be also be proposed. Provisions of access to sign language communication at WSP vendor sites by way of ​Video Remote Interpreting(VRI) as means to provide prompt interpreting services on request of the WSP customers at vendor locations. Video Remote Interpreting is a video conferencing service that uses smartphones, laptops and other electronic devices to provide interpreting services off­site. VRI is a great alternative when in­person sign language interpretation services are not available.

Further explanation can be derived from the American company providing VRI services at the following link:

15
**** Communications Group:
http://www.malkacommunications.com/video­remote­interpretation/

Note: we understand that **** has a business relationship with a Canadian company providing VRI services and for the Western provinces may likely be a regional solution. As for the Eastern Canada regions, there are other VRI solutions based in the ****, such as SIgn Language Interpreting Associates of Ottawa (SLIAO): http://www.sliao.ca/

Later in the day, on **** 18, 2016, the CRTC queried TELUS on the CSR issue, and using the example between lines 8461­8480, DWCC is in agreement that it is time for not only TELUS but all WSP’s to consider the CSR dilemma and address the concerns based on our study and respondents’ review of their customer experiences at these WSP vendor locations.

Partnerships with WSPs and Related Organizations

TELUS commits to meet with advocates on behalf from the deaf community prior to the launch of VRS. In that regard, TELUS will also examine the feasibility of involving the Canadian Wireless Telecommunications Association (“CWTA”) in such initiative as this would allow for discussions between Deaf advocacy groups and the broader wireless service provider industry.

Telus Communications Company
Response to Undertaking TNC 2015­134
Information Requested by the CRTC,
Transcript Volume 6, Paragraph 8254

During the hearing, DWCC was very pleased to see that the CRTC encouraged WSPs and such groups to make contact with groups like ours. To­date, since the hearing, we are appreciative to of the back and forth communications with the CCTS, and that discussions have been initiated with Rogers, Shaw­WIND, and Bell. DWCC confirms obtaining contact information for TELUS Communication Company representatives, and are committed to starting a dialogue to address the requirements of sign language using Canadians. To respond, in all honesty, as a busy volunteer committee, we have yet to have time to initiate active communication with TELUS.

According to the TELUS Undertaking, they want to rely on CWTA for disability consultations.

DWCC has two views we want to emphasize:

1) Hard of hearing representatives who currently may be consultants for the CWTA or involved in advisory capacities, are not ASL and LSQ users and cannot be considered 16

http://www.malkacommunications.com/video-remote-interpretation/

experts on Deaf accessibility. The best contacts for these groups at this time are CAD­ASC and/or the DWCC.

2) DWCC wants to be included in direct communications with TELUS

TELUS should not rely on the CWTA, the time is now, we want to get rolling to have consultations and discussions and have packages available by Fall 2016 if possible. Actions need to be timely with the launch of VRS in Canada.

DWCC want to see that all WSP’s, including Telus, that have given us their contact information follow through and continue the dialogue with us about our issues and how they will accommodate, not keep referring to CWTA. CWTA has yet to connect with us. DWCC feel that non­signing DHHDB are on their Board or serving in their Accessibility Advisory group, we would like to ensure that someone from CAD­ASC and especially someone from the DWCC to always be represented in these groups, as we represent the Canadian sign language groups.

Additionally, DWCC would also like to see CWTA actually employing persons with disabilities or are DHHDB to help advise on projects that affect our populations.

Action Plan: ​DWCC will make itself available, and will be reaching out to the WSPs once again to initiate or continue the dialogue. DWCC would like the CRTC to mandate that WSPs be in contact with such groups as DWCC and CAD­ASC by a deadline so that such wireless measures are progressed in a timely manner. DWCC plans reach out after **** 17th, the last deadline of a related­issue proceeding which we aim to participate in (CRTC TNC 2016­192).

“Throughout the last number of months, we have heard the requests from Deaf and Hard of Hearing organizations that data­only wireless rate plans be made available that do not include unnecessary voice minutes. As we announced in a press release on February 29, in the coming months, Bell will be introducing a dedicated wireless rate plan for the approximately 357,000 Canadians that are Deaf or Hard of Hearing. As part of supporting this program, ASL/LSQ videos outlining this offer will be launched on our website. At the Bell Accessibility Services Centre, we routinely go above and beyond to ensure that our disabled customers are able to make the most of their services.” Opening Statement of Bell Canada and its Affiliates

Telecom Notice of Consultation CRTC 2015­134,
Review of Basic Telecommunications Services, **** 6
**** 19, 2016

This is an ideal start in working towards accomplishing DWCC’s goals. Bell’s Accessibility Services Centre is a great way to meet the needs of sign language users across the nation, as well as offering videos in ASL and LSQ to increase digital literacy within this customer demographic.

17

DWCC stands by available for consultation and discussion to further make Bell’s accessibility missions possible. In ​April 18, CRTC TNC 2015­134 Transcript lines 6988 to 6989​, DWCC’s recommendation were “lost in translation,” so DWCC will yet attempt to re­clarify:

We have noted through our findings and research, since 2008, originating with the Council of Canadians with Disabilities, that there have been many instances and references to such an Accessibility Office within the CRTC. It is DWCC’s recommendation that the CRTC place persons with the actual lived experience (a person with disabilities) and further to that, persons who are DHHDB with ASL or LSQ sign language and relevant experience in employ, not only as front­line, triage for queries but also at the decision­making level. Such persons would apply an accessibility lens on all processes to ensure accessibility issues are not overlooked in all CRTC’s processes. It is 8 years overdue.​The time is now.​ ​It is 2016.

DWCC’s Modified Recommendations:
Original Recommendations:

1. Clear and designated wireless packages need to be advertised to this population. These wireless packages should be focused on the data plan with voice­credits. Voice credited data plans would be a better option due to the existing Text with 9­1­1 requirement.

a. Package suggestion: 10­12GB specific packages created, with 3­5GB overage cushion allowance.

Modification: ​Based on new data, the CAV’s response, we recommend the 3­5GB overage recommendation to be adjusted 2GB to accommodate mobile video communications.

b. No throttling, eg. downgrade from LTE to 3G, causing blurry video
communications
c. Greater broadband bandwidth,

d. 10 Mbps upload & download, equal numbers for clear video communications 2. Increased promotions of wireless plans need to be distributed in print media, web, and video announcements in sign language to ASL and LSQ users, consumer organizations, and several Deaf/Hard of Hearing organizations. As well, television commercials are a useful medium, to benefit WSP’s and mainstream Canadian society.

3. Consumer educational videos, in ASL and LSQ, need to be created to explain the structure of telecommunication system (A joint committee could be created to oversee this type of initiative or project).

4. Terminology videos in ASL and LSQ for users to understand and navigate through their wireless service contracts.

18
http://www.deafwireless.ca/index.php/terminology/accessibility-lens/

5. Workshops to be hosted in different cities in each province to educate ASL/ LSQ users.

6. Create an accessibility fund, either originating from a newly created Telecommunications Accessibility Fund (TAF), or Media Access Canada’s suggested “National Disabilities Subsidy Fund (NDSF)”, pooled by the WSPs:

a. To provide those with low­income affordable smartphones and reasonable data plan packages to access video communications;

b. To be utilized as a contingency fund for projects, to develop educational videos to address the communication gap, and;

c. Creating employment opportunities and training for Deaf and Hard of Hearing employees to provide WSPs customer service directly in sign language.

7. The existing Text with 9­1­1 system needs to be overhauled to improve its effectiveness and efficiency for all consumers including ASL and LSQ users.

8. Direct Video Communication services should be provided by CCTS and CRTC to log complaints and queries.

9. Hire Deaf/Hard of Hearing people as “consumer service specialists” to accommodate Deaf and Hard of Hearing Canadians.

10. A new entity Accessibility Office to be created with people with actual lived experience employed both at the front line and in decision­making levels.

Additional Recommendations:

1. Consideration of perhaps substituting voice minutes with “sign minutes” in wireless package development

2. Examine the possibility of provisions of access to sign language communication at WSP vendor sites by way of ​Video Remote Interpreting (VRI) as means to provide prompt interpreting services on request of the WSP customers at vendor locations.

3. Greater efforts by WSPs to mandate and coordinate accessible language transactions at WSP vendor locations, by way of mandated efforts by head office, to hire and find signing CSRs and then identify exactly where they are located, specific stores, specific addresses and DWCC and the CAD­ASC can assist in the promotion and awareness of specified vendor locations.

4. Direction to specific telecommunication and wireless service providers or relevant organizations and government agencies, the responsibility of producing specific videos in ASL and LSQ:

a. CCTS to produce a series ASL and LSQ videos that outline specific steps to access the CCTS complaint system for finding resolution with their wireless bills.

b. CCTS to develop clear generic picto­graphics, infographics and videographics to clarify the complaints flow. However, it would be a priority to create ASL and 19

LSQ videos with explanation of escalation paths for resolution of wireless billing issues.

c. CRTC to produce a video primarily focused on the Wireless Code.

d. CWTA and WSPs to coordinate a digital literacy series providing ASL and LSQ terminology of common Wireless services agreement terminology.

e. DWCC and CAD­ASC to obtain funding from an accessibility fund to focus on general wireless terminology, made available by funds mandated by the CRTC.

Many of the responses we have written, are to statements by groups that have data collected on video streaming rather than video conferencing/ video calling, which is used heavily by the population of Canadians we represent. This indicates to our committee that a knowledge gap may exist in this online activity, one that has not been as heavily researched as video streaming.

With less research into video conferencing, the numbers cited by any group may not be valid, as there are less numbers to gain an average from, or to cross­reference. By failing to consider the use of video conferencing applications and software, an upload speed of 1 Mbps would seem ideal, not because of the real­life lived experience, but because wireless service providers mostly take into account the speed needed for streaming alone. The Commission should consider looking into video conferencing usage in a more in­depth manner during the next CMR, to assist both the CRTC and corporations in business decision making.

While telecommunication providers maintain a 5 Mbps/1 Mbps download/upload is enough for participation in the digital economy and make references to other countries having lower minimum speed requirements, this is a time for Canada to not do just enough, but to exceed. In a time where being connected 24/7 is a real­life situation, being able to claim we have the best connection speeds may encourage a sense of national pride.

In our **** 13 submission, to allow time to research further, and to read projected pricing recommendations coming from submissions by the end of May 25th, the DWCC will explore:

1. The topic of $15.00 subsidized suggestions based on Committee members’ experiences.

2. National Disability Subsidization Fund (NDSF) with regards to the subsidization of costs for the expensive smartphone devices that contain the video quality enhancement that is required for clear video communications.

3. Recommend data packages, with suggested pricing based on responses and estimates to our best of ability, to help this process further.

20
Final Remarks:

Sign language using Canadians requiring broadband and wireless services to access VRS coming soon, as well as other video conferencing programs. As video calling programs and applications allow ASL/LSQ users to communicate in their natural language, Deaf Wireless Canada Committee maintains the viewpoint of broadband as a basic necessary service. Communication in a signed language provides many Canadians with the functional equivalency of a hearing person’s ability to pick up the phone and verbally calling someone. If there are unlimited voice minutes available to speaking Canadians, this is not equal for our group of DHHDB, because we do not have an option to have unlimited data packages to converse with our peers in our visual language. Unlimited data packages should be given to the consumer group of which we represent and are involved in.

Deaf Wireless Canada Committee would like to remind the CRTC, CWTA, WSPs, ISPs and TSP’s that it is not a privilege to have access to signed communication venues, it is a human right. It is our right, to have the equal access and functional equivalency as our hearing counterparts enjoy. We seek fairness, equality and functional equivalence so we can live the same as our hearing Canadian society members.

*** END OF DOCUMENT***
21