Interventions Phase 2: CNIB (Intervenor 729)

Document Name: 2015-134.227253.2536904.Interventions Phase 2(1$dhk01!).html

On behalf of the CNIB and our stakeholders from across Canada, I am herein requesting to appear at the hearings scheduled for **** 11, 2016.Telecomunications services have changed dramatically over a relatively short period of time. While many of these changes have had positive changes on Canada's social fibre, the benefits have not been equitably available to those living with vision loss. Even despite the availability of robust technologies, many Canadians living with vision loss continue to experience social isolation as well as remaining marginalized.Our submission, to be submitted shortly will endeavour to highlight these challenges while identifying reasonable sollutions which will truly bring the promise of the digital world to everyone, including those living with vision loss.We would like to appear before the commission via video conferencing from the commissions Calgary and possibly Montreal offices. Raisons pour comparaitre / Reasons for appearanceIn preparing our submission, we will endeavour to document the solutions which our stakeholders feel will have the most significant impact on their leveraging telecommunications services.Should the commission choose to invite us to present, we will further highlight the solutions which we feel have the greatest likelihood of mitigating the disperities facing a growing number of Canadians living with vision loss.

Interventions Phase 2: CNIB (Intervenor 729)

Document Name: 2015-134.227253.2554105.Interventions Phase 2(1$qrd01!).pdf
CNIB
101-1355 Bank ****
Ottawa, Ontario, *** ***

Lui ****, National Manager of Advocacy for **** Bergeron Executive Director, Strategic Relations and Engagement

******@***.com – ******@***.com
Alliance for Equality of **** Canadians
PO Box 20262, RPO Town Centre
Kelowna BC *** ***
Tel: 1-*-***-***-****
Email: ******@***.com
http://www.blindcanadians.ca

Leo ****, AEBC National Director and CRTC Liaison E-Mail: ******@***.com

Filed Electronically
**** 3, 2016
Mr. John Traversy
Secretary General
Canadian Radio-television and
Telecommunications Commission
Ottawa, Ontario
mailto:******@***.com
mailto:******@***.com
mailto:******@***.com
http://www.blindcanadians.ca/
mailto:******@***.com
*** ***
**** Mr. Traversy:
Re: Notice of Consultation CRTC 2015-134 -
Review of Basic Telecommunication Services
reference: 8663-C12-201503186

1. On behalf of the CNIB and the AEBC, we would like to thank you for the opportunity to once again, bring our perspective before the commission.

2. Telecommunications services have changed dramatically over a relatively short period of time. While many of these changes have had positive changes on Canada's social fibre, the benefits have not been equitably available to those living with vision loss. Even despite the availability of robust technologies, many Canadians living with vision loss continue to experience social isolation as well as remaining marginalized. This submission hopes to highlight these challenges while identifying reasonable solutions which will truly bring the promise of the digital world to everyone, including those living with vision loss.

3. As to participation in the **** 11 hearings, we would like to request an opportunity to appear before the commission via video conferencing from the commissions Calgary and Montreal offices.

4. In preparing our submission, we will endeavour to document the solutions which our stakeholders feel will have the most significant impact on their leveraging telecommunications services. Should the commission choose to invite us to present, we will further highlight the solutions which we feel have the greatest likelihood of mitigating the disparities facing a growing number of Canadians living with vision loss.

The Commission’s role regarding access to basic telecommunications services

Introduction
The Concept of Universal Design

5. The past several years have witnessed rapid, sweeping, and comprehensive change in the ways we utilize telecommunications. Never before in our history have Canadians had access to such a wide array of telecommunications products and services. We are no longer limited by the reach of traditional copper wire telephone networks. Today, new and innovative technologies such as cellular phones, fiber optics and satellite systems have enabled us to communicate almost instantaneously with any person, at any time, and at any place in the world.

6. It is unconscionable, however, that for many persons with disabilities, these new technologies offer little of promise. Often at a disadvantage in the use of basic telephone service, people with disabilities have particular needs to which new communications services are insensitive.

7. The telecommunications system of the future will represent a mix of voice, graphic, and videotext services that may not be fully utilized by people who are deaf or hearing-impaired, blind or visually-impaired, or speech-impaired unless steps are taken now to guarantee their full and equal access.

Looking at recent history in the U.S.

8. Passage of the Americans with Disabilities Act offers some important lessons for policy makers and the telecoms. The passage of the Americans with Disabilities Act in 1990 was an important stride forward in this effort. However, with regard to telecommunications access by persons with disabilities, many fundamental issues remain to be addressed in the U.S..

9. Looking at the research from the U.S. we have learned that The First **** Ribbon Panel Report, "Laying the Foundation," examined in great detail the demographics of people with disabilities, and how various disabilities affect people's opportunities to take advantage of new and existing telecommunications facilities and services.1 The report found that telecommunications innovations held great promise to facilitate people • 1 From the Foreword in Telecommunications and Persons with Disabilities: Laying the Foundation - A Report of the First Year of The **** Ribbon Panel on National Telecommunications Policy.

World Institute on Disability. 1991. p. iii.

http://trace.wisc.edu/docs/framework/framewrk.htm#foreward http://trace.wisc.edu/docs/framework/framewrk.htm#forewardwith disabilities' involvement in many aspects of everyday life that are now not available to them, or only available at great cost. The report concluded that the key to this promise lies in designing telecommunications services and equipment to be accessible to a wide range of users' capabilities, which is known as "universal design." The **** Ribbon Panel spent the significant part of its research time exploring and refining this concept of "universal design." The researchers learned a lot about the design process that engineers and manufacturers of telecommunications equipment use, and they looked at recent developments in architectural design to find lessons to guide them in suggesting modifications to that process; we in our discussion should review these research findings as we move forward….

10. U.S researchers also looked at telecommunications policy-making and standards-setting, because they saw the important impact they will have on whether or not new technologies will incorporate universal design principles. They concluded that the goal of Universal Service, long the basis for public policy-making in telecommunications, must incorporate the concept of universal design if we are ever going to make telecommunications truly accessible to everyone.

11. Finally, as we conclude our introductory remarks to our submission, we state that the concept of universal design is based upon the realization that we all differ in our abilities to move, see, hear, and think:

universal design will enable the greatest number of people to actively participate in society through telecommunications.

Which services should be considered by the Commission as basic telecommunications services necessary for Canadians to be able to meaningfully participate in the digital economy? Explain why.

11. Access to Telecommunications beyond voice over copper is Essential in order that any degree of participation in Canada’s social/digital landscape is to be achieved.

12. It is through communication that we develop relationships with others, transact our business, and pursue our goals. Over the years, the telephone has increasingly become a predominant mode of communication, which is why our Canadian telecommunications policies are built upon the concept of "universal service." These policies direct that every Canadian should have access to telephone service at reasonable prices, regardless of where they live and irrespective of ability.

13. Today, however, telecommunications is more than the traditional residential telephone service. It goes beyond the copper wires and networks that connect one telephone to another. Modern telecommunications also travels over fiber optics or cellular and radio transmission systems. Communication over robust complex networks connecting disparate devices are everywhere.

14. Today telecommunications is construed to mean electronically-based communication using land-line networks, radio transmissions, and satellite relays. All telecommunications systems require an originating device, one or more receivers, and a transmission medium: radio waves, fiber optics, copper wire, coaxial cable, satellites, wired or infra-red local area networks, or combinations of these. The term "telecommunications" has become synonymous with any method used to deliver and communicate information electronically.

15. Today, what we used to see as distinct technologies - telephones, television, radio, and cable - are converging. The key component now is information, which can be represented in digital form.

16. Regardless of the medium, telecommunications products and services serve as the conduit through which information is acquired, stored, manipulated, managed, moved, controlled, displayed, switched, exchanged, transmitted or received. Telecommunications has become the passageway to knowledge acquisition, from using a bank's audio text services to get your account balance, to using a database for research. It is also the means for communicating ideas to others and to participating in the democratic process. Without access to modern telecommunications technologies and services, one cannot participate fully in all aspects of modern life. Policy-makers are beginning to recognize this, and it is our challenge to work with them to update definitions of universal service to include more than "conventional telephone service."

17. For Canadians with vision loss, the expansion of telecommunication services has removed many of the barriers previously deemed irremovable. With the digitization of most of today’s information, access to employment websites, medical information, and social engagement vision loss need not necessarily mean social isolation. As such, access to a robust internet with acceptable reliability is essential if this marginalized population has any hope of narrowing the income gap which exists between those with and those without disabilities.

Telecommunications Access Opportunities

18. For individuals with limitations in hearing, seeing, moving, speaking, or cognition, the explosion of telecommunications offers opportunities as never before:

 Interactive cable systems for making entertainment choices or participating in "electronic" town hall meetings;

• Kiosks with interactive video terminals, placed in strategic public locations to convey necessary information about, and access to, local government services;

• Remote classrooms and in-home learning using "real-time video" for education and training by competent, stimulating teachers;

• TV receivers with built-in decoder circuitry to provide closed captioning of aurally-delivered program material; or

• Television receivers and set top boxes with built-in secondary audio program circuitry, to provide "described video" spoken interpretation of visually presented TV program material.

19. New technology has the capability of "speaking" for people with speech disabilities and "hearing" for people who are deaf. It can bring information and education into homes and workplaces for people who have mobility limitations. It can provide added cues and reminders for people with memory or cognitive loss. Overall, it can help support a web of communication that makes it easier for people with disabilities to stay integrated in society.

20. This speaks to the need to have fully integrated digital services delivered in a reliable robust manner which will facilitate improved access for Canadians with vision loss.

Barriers to Access for People with Disabilities 21. For people with disabilities, the explosion of telecommunications offers both a grand opportunity and the risk of establishing new barriers. Even though accessible technologies exist, they are often not integrated into most marketed equipment and services. As a result, telecommunications can become a barrier that "locks out" people with disabilities, rather than enabling them to participate more fully in society. People with disabilities still lack easy access to even the most basic telecommunications services:

• Telephone communication between deaf, hard of hearing, speech impaired individuals and the hearing/speaking public.

despite the increasing development of telecommunications relay services, the rate by which information is exchanged can be slow and uses a third party to facilitate calls thereby impeding either effective communications;

• Access to elementary visual information displayed on terminals of every sort - telephone status LEDs, caller-ID information displays, and directions on public pay phones - is inaccessible to people with visual limitations;

• Telephone keypads, keyboards and controls/switches cannot be used by individuals with limitations in reach or articulation and prevent full access to voice and data communications;

• Complicated choice menus, whether visual or aural, limit the usefulness of audio text, videotext or computer system software for individuals with limitations in cognition or memory.

22. Barriers are not only technical; they are also economic. With an unemployment rate that exceeds 60%, people with disabilities are one of the lowest-income groups in the country, yet the cost of equipment and services that people with disabilities must bear is often much higher than for the general population. For example, a residential telephone for an individual without a disability can be purchased for under $50 including advanced communications features. An individual who cannot speak or is deaf must spend $200 or more for a TTY, without advanced features. On the extreme end of the scale, a deaf-blind individual needs a unique device, TeleBraille 2, costing several thousand dollars, just for very basic telephone communication.

In short, whether it's the equipment needed to communicate or the enhanced service required to access information in an alternative manner, telecommunications for individuals with disabilities is costly.

Identify, with supporting rationale, the terms, conditions, and service characteristics under which basic

telecommunications services should be provided. Should any obligations be placed on the provider(s) of these services? If so, what obligations and on which service provider(s)?

23. "Universal Service" is a public policy mandate that all households should have access to basic telephone service. For decades, regulators have MANDATED local residential telephone rates low in order to encourage high levels of penetration of telephone service. Because telephone service is so intrinsic to our everyday lives, most policy-makers see Universal Service as a fundamental principle of telecommunications policy.

As new telecommunications equipment and services have evolved, especially with the explosion in computers and digitization, most policy-makers have become concerned that our definition of basic telephone service may need revision. Now, people are beginning to say that "Universal Service" should refer not just to universal basic telephone service, but to universal telecommunications service, which includes access to electronic networks, broadband telecommunications facilities, advanced information services, etc.

Therefore, regulators and industry should move to standards of service that apply to all telecoms….

What should be the prices for basic telecommunications services and how should these prices be determined?

Provide rationale to support your answer.

24. We are ill equipped to provide any recommendations to this question as our respective areas of knowledge does not include the economics of telecommunication services. However, given the disproportional representation of Canadians with vision loss and or other disabilities amongst Canada’s lowest income cohort, care should be exercised to insure that affordability of basic telecommunications does not add yet another barrier to this population.

4. Can market forces and government funding be relied on to ensure that all Canadians have access to basic telecommunications services? What are the roles of the private sector and the various levels of government (federal, provincial, territorial, and municipal) in ensuring that investment in telecommunications infrastructure results in the availability of modern telecommunications services to all Canadians?

25. As with any infrastructure which benefits all citizens, we are of the opinion that governments need to adopt a similar strategy when speaking about basic telecommunication services. Although the economics of densely populated cities may create an efficient marketplace, it is essential that rural communities not be forgotten when investments in data networks are being planned. Basic telecommunications, including voice and data, are as essential to the full participation of all Canadians as is the networks of roads and highways which connect us to one another.

26. For instance, after almost one hundred years of delivering recorded and braille books to Canadians who are blind via the mail, CNIB and Canada’s public libraries have begun to adopt “direct to player” delivery of alternate format materials. This service eliminates the need for the physical distribution of alternate format recorded materials by simply having content downloaded directly to a patrons device.

However, without access to a reliable delivery infrastructure – the internet – patrons will continue to experience timely delays in accessing parallel services to those available to their neighbours through their public libraries. Still in its infancy, we believe that within the very near future, alternate format reading materials will only be provided via “direct to player” downloads. If Canada’s public infrastructure, including the backbone for basic telecommunication services cannot facilitate this then those Canadians living with vision loss without reliable affordable access will be further marginalized.

5. What should be the Commission’s role in ensuring the availability of basic telecommunications services to all Canadians? What action, if any, should the Commission take where Canadians do not have access to

telecommunications services that are considered to be basic services?

27. As mentioned above, governments at all levels need to accept a degree of responsibility to insure that the infrastructure necessary to support basic telecommunication services is available. As to the role of the commission, we believe that the commissions mandate would be best achieved as an intermediary between industry and the funding bodies which maintain public infrastructure. The commission is uniquely positioned to provide an impartial commentary on infrastructure as where industry may not necessarily be equally motivated. This form of intervention could be to support public investment in rural Canada, insuring that all citizens benefit equally from the digital economy.

6. In Telecom Regulatory Policy 2011-291, the Commission stated that it would closely monitor developments in the industry regarding the achievement of its broadband Internet target speeds to determine whether regulatory intervention may be needed. What action, if any, should the Commission take in cases where its target speeds will not be achieved by the end of 2015?

28. Once again, we would like to refer back to the analogy of public roads and other infrastructure. If broadband Internet target speeds are not available for the vast majority of Canada’s communities, then we believe that the commission, industry and governments need to develop a strategy to meet these targets. Although industry stands to be a key beneficiary, rural communities also stand to benefit as their citizens will have increased access to Canada’s information highway.

Thus, we would recommend that the commission assume a leadership role in bringing together key stakeholders with the goal of implementing a strategy which will meet the speed targets set out by the commission.

29. If successful, all citizens regardless of where they live or the means by which they access the internet will be better equipped to leverage the possibilities offered through a robust and reliable digital infrastructure.

Regulatory measures for basic telecommunications services 8. What changes, if any, should be made to the obligation to serve and the basic service objective?

30. We believe that the commission has already set forth policies which address this matter with respect to how Canadians with vision loss receive basic telecommunication services. Access to affordable handsets, both wired and mobile, accessible customer portals, knowledgeable customer service representatives and a 30 day grace period allowing Canadians with disabilities to insure that the products and services they purchase meet their needs. What is required though is mechanisms by which these requirements, if not met, can be mandated. We suspect that the commissions deliberations will likely result in an expansion of the definition of “basic telecommunication services” and as such, we are hopeful that the policies addressing accessibility issues continue to remain at the fore front when licence renewals are brought forward.

9. Should broadband Internet service be defined as a basic telecommunications service? What other services, if any, should be defined as basic telecommunications services?

31. As was stated earlier in our submission, It is our position that Access to Telecommunication services, including broadband, is Essential for the participation in the digital world. Canada’s telecommunications landscape has long recognized the need for Canadians to have access to basic telephone services at a reasonable price. Given that we have moved well beyond the copper line voice networks which have connected Canadians for several generations, it follows that basic broadband now becomes the definition of “Basic Telecommunications Services”.

32. Today, what we used to see as distinct technologies - telephones, television, radio, and cable - are converging. The key component now is information, which can be represented in digital form.

Policy-makers are beginning to recognize this, and it is our challenge to work with them to update definitions of universal service/”basic telecommunication services” to include more than just the telephone.

Conclusion

33. We have endeavoured here in to provide our prospective on what we believe “Basic Telecommunication Services” should consist of in the future. Canadians with vision loss stand to be further marginalized if their access to the opportunities leveraged by emerging products/services cannot be realized.

34. We appreciate that the commission’s role cannot bring about a truly level playing field free of accessibility barriers. This responsibility lies clearly with society as a whole with all stakeholders engaged in meaningful dialogue with the goal of identifying solutions.

35. Yet, in 2016, the manner in which we exchange information has fundamentally shifted. Thus, so should the definition of “Basic Telecommunication Services” be likewise expanded.

36. We appreciate the commission extending CNIB and AEBC an extension and hope that our comments continue to prove helpful and informative.

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