Intervention: Canadian Hearing Society (Intervenor 191)

Document Name: 2015-134.223714.2388138.Intervention(1f6p601!).doc
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The Canadian Hearing Society Response to CRTC Telecom Notice of Public Hearing CRTC 2015-134 Reference: 663-C12-201503186
1. Request to Make an Oral Presentation:

The Canadian Hearing Society (CHS) respectfully requests four CHS representatives (Gary ****, CHS Special Advisor to the President, Public Affairs; **** Wilson, Director, JoAnn ****, Director, CHS Communication Devices Program, CHS Ontario Interpreting Services (OIS) and Communication Access Realtime Translation (CART) Services; Jim ****, Director, CHS Information Technology) be invited to make a presentation at the public consultation in Gatineau. We feel that a public presentation to the Commission of our key messages and recommendations is critical in allowing participants to understand fully the implications, benefits and challenges faced by deaf, deafened and hard of hearing Canadians. (Adequate, qualified ASL/English sign language interpretation would be an accessibility requirement for our participation in the hearing.) 2. In addition to requesting a presentation at the public consultation, CHS submits the following comments, resources and recommendations.

3. Resources:

· U.S. Government Accountability Office, Report to the Honorable **** Sessions, U.S. Senate, Telecommunications Relay Services: FCC Should Strengthen Its Management of Program to Assistant Persons with Hearing or Speech Disabilities, **** 2015 at see page 7, Figure 1: Description of the Six Forms of Telecommunication Relay Services (TRS) (as of January 1, 2015) including Text Telephone (TTY), Video Relay Services(VRS), Speech-to-Speech (STS) Relay Services, Internet Protocol (IP) Relay Services, Captioned Telephone Services (CTS) and Internet Protocol Captioned Telephone Service (IP CTS).

· The Canadian Hearing Society’s Video Relay Services, including Prevalence of Hearing Loss, and a list of significant legal decisions available at · Canadian Association of the Deaf Position Paper on telecommunications at

· National Association of the Deaf Position Paper on Technology at

· Canadian Hard of Hearing Association Submission in response to CRTC that request that cable networks are required to provide captioning for all local programming (March 2010) · Association of Hearing Loss of America’s Public Policy and Advocacy Agenda at

· World Federation of the Deaf Statement on the Adoption and Adaptation of Technologies and Accessibility at · International Federation of Hard of Hearing’s Accessibility Guidelines Paper at

· Canadian Human Rights Commission’s Report entitled A Review of Government of Canada Telephonic Communication with People Who Are Deaf, Deafened, Hard of Hearing, or Have a Speech Impediment available at· TDI, an organization that promotes equal access to telecommunications, media, and information technology for deaf and hard of hearing individuals, available at, Recommendations

Video Relay Services

4. We are pleased with CRTC’s commitment to improve the quality of basic telecommunication services by directing TSP(s) to implement the establishment of governance of Canadian Association of Video Relay Services and Video Relay Services (CAVRS) will be implemented and delivered across Canada under the direction of CAVRS in order to meet the CTRC objectives CHS strongly supports the implementation of a CAVRS as directed by CRTC consisting of key

stakeholders, including VRS customers from across Canada, which will have strong oversight on all facets
of VRS operations. The CAVRS governance will work in collaboration with the CRTC and provide
consultation to design a national bilingual VRS which meets the needs of consumers and is cost effective.
This CAVRS governance will ensure that there is high quality service, continuous improvement in services,
education and outreach, and maintain the functional equivalency of telecommunications access to the level
that hearing customers take for granted.
5. Concern: Significant Delays

VRS has been operating competitively in the United States since 2000. American VRS vendors have proven expertise and are ready to enter the Canadian market. The infrastructure and “know how” to deliver VRS has been improved over the years and is well positioned to work with the telecommunications providers in Canada. In our view what is basically slowing down the process is how this service will be paid for in Canada. The potential business model would look much differently than how VRS operates in the US; however, this unknown creates challenges to the development of solid business plans leading to implementation.

Recommendation: In an accountable and transparent way, the CRTC creates a funding framework from which the telecommunications companies and the VRS vendors can create concrete business development plans through CAVRS’s RFP process.

6. Concern: **** Implications and Mitigation Strategies

Learning from experiences in the roll-out of VRS in other jurisdictions, we have a grave concern for the real and significant impact the hiring of interpreters by the VRS providers will have on our current community interpreting resources. There is potential that it will be easier to get an interpreter to order a pizza through a VRS provider than to secure one for cancer treatment. The current condition of the community interpreting field nationally is in crisis; there is a significant skills shortage of skilled and qualified interpreters in all jurisdictions; fewer post secondary institutions offer accredited training; there is a lack of practical national standards in the country; communication access policy frameworks either do not exist in the public sector or are inadequate. Enter VRS and the whole situation is significantly further challenged.

Recommendation: It is absolutely essential for the CRTC to mandate the full and complete engagement all stakeholders – deaf, deafened and hard of hearing community members, representatives of the interpreting community, existing community interpreting service providers (like The Canadian Hearing Society) – in the development and delivery of VRS in Canada to assure that resource capacity will not be entirely draining from community service needs.

Teletypewriters (TTYs), Message Relay Services (MRS and Internet Protoco(lP) Relay Services
7. Concern: There is lack of commitment to maintain quality standards of services in a technologically ever-changing environment.

Recommendation: CRTC set regulations requiring telecommunication carriers to maintain compatible and accessible levels of TTY, MRS and IP-Relay services and establish CRTC Accessibilty Advisory Committee to monitor quality control, usage, and innovations.

8. Concern: There is lack of compatibility of internet phone (VOIP) and (i.e.TTY, 711, IP-Relay) services.

Recommendation: CRTC set regulations to ensure that internet phone service providers provide the equitable, compatible, accessible phone service to consumers regardless of the product or services used.

9. Concern: Culturally Deaf, oral deaf, deafened and hard of hearing TTY and VCO users miss calls from people who do not specifically call a TTY. Opportunities are lost and access eludes them.

Recommendation: When callers reach a TTY or VCO number, the call is automatically transferred to a relay service (both MRS and IP-Relay) who will relay the call using a TTY. CRTC service regulations need to be established to address this service.

10. Concern: Payphone TTYs are not accessible in public places.
Recommendation: CRTC set regulations requiring the availability of payphone TTYs and/ or videophones in all public places.
IP-Relay Services
11. Concern: IP-Relay is only offered to residential landline account.

Recommendation: CRTC to require TSPs to develop either a native application in mobile devices with iOS, Android and blackberry operating systems or to have a mobile friendly html site that is easy to navigate and use the service.

Captioned Telephone Services

12. Concern: Captioned telephone services are not available in Canada, such as CapTel and CaptionCall Services in the United States. These services are designed to help individuals struggling with hearing loss use the phone. This service works with voice recognition software and a captioning service and assists the caller with captions and voice communication.

Recommendation: CRTC set regulations to provide captioned telephone services in Canada, similar to that of CapTel. See details in the description of captioned telephone services at and Captioning on the Internet and Webcast

13. Concern: There is a lack of CRTC regulation requiring mobile wireless, broadband internet service and
TSP providers to be accountable for ensuring quality captioning.
Recommendation: CRTC set regulations requiring mobile wireless, broadband internet and TSP service providers to ensure quality captioning.

14. Concern: Webcast, internet and TSP service providers commercial advertising is often not captioned making it inaccessible to webcast viewers who are deaf or have hearing loss.

Recommendation: CRTC set regulations requiring webcast, internet service, TSP providers ensure webcast and internet commercial advertising is captioning.

15. Concern: There is a lack of captioning for emergency webcast internet service and TSP providers

Recommendation: CRTC set regulations to require to ensure that all emergency webcast, internet service and TSP providers are captioned and accessible.

16. Concern: There is a lack of captioning in Web casts or videos of internet providers.
Recommendation: CRTC set regulations to require internet providers provide captioned web casts and
video clippings over the internet.
17. Concern: There is a lack of ASL and LSQ content in Webcast or videos of internet providers

Recommendation: CRTC set regulations to require internet providers provide ASL and LSQ video clippings over the internet. For example, the websites of CRTC announcement on VRS, the Ontario Human Rights Commission ( ), Ontario Ministry of Health and ****-Term Care, ( ) and Elections Canada ( )18. Concern: The assumption of using “YouTube” closed captioning function provides quality captioning. The functionality is very low quality and the output is often wrong and information is missing.

Recommendation: That all captioning on the internet and webcasts needs to manually coded until the quality of automatic captioning comes up to same level of quality as manually coded captions.

ASL and LSQ Content
19. Concern: There is a lack of ASL and LSQ content in Web casts or videos of internet providers.

Recommendation: CRTC set regulations to require internet providers provide ASL and LSQ video clippings over the internet. For example, the websites of CRTC announcement on VRS, the Ontario Human Rights Commission, Ontario Ministry of Health and ****-Term Care, and Elections Canada.

Customer Service and Support

20. Concern: Technology is quickly replacing human customer service and support with the goal to improve the access, accuracy, and speed in which people can be served. As innovative technologies are developed, universal design elements are not incorporated, creating, in fact, barriers to accessible, accurate and speedy customer service and support and rendering them completely inaccessible. Trying to retrofit these accessible elements is often not successful. Access must be considered and built in from the start.

Recommendation: CRTC establish a Disability Advisory Committee to review and examine all applications/proposals for technology, service or production to ensure universal design and accessibility is incorporated; to ensure that the committee comprise highly qualified people with disabilities and experts with extensive knowledge of accessibility aspects where they can review and consider applications and make binding recommendations for compliance with accessibility requirements.

21. Concern: Many voice (spoken language)-based services that require callers to identify themselves, and provide information for security purposes, do not accept relay (video or TYY) service operators to relay the information from a deaf customer or customer with hearing loss, thus severing access to the service.

Recommendation: Amend CRTC regulations to approve relay (video and TTY) service providers as the legitimate voice representatives for deaf customers or people with hearing loss who rely on such means to access services.

Emergency 911, E911, T911 and Public Announcement Services

22. Concern: Emergency 911 call centres often are not accessible to TTY and Voice Carry Over (VCO) callers. Many centres have removed their TTYs, not maintained them until they are in a state of not working, or have operators who are not trained to use TTY or VCO appropriately and effectively.

Recommendation: CRTC set regulations requiring ALL emergency 911 call centres to be accessible to culturally
Deaf, deaf, deafened and hard of hearing callers through TTY, VCO or phone texting and automatically display
information from those contacting emergency services.
23. Concern: Emergency communication services are not accessible by current communication accessibility technology.
Recommendation: CRTC set regulations requiring Emergency 911 call centres be technologically accessible and
compatible with VRS and IP relay.

24. Concern: Basic technological platform is one that relays on voice-to-voice communication; those with communication difficulties are still unable to access our current day 911, E911, T911 and NG911 system. The need for an upgraded technological architecture and process is vital for those Deaf people and individuals with hearing loss.

Recommendation: CRTC set regulations requiring E911, T911, NG911and wireless service providers to set basic standards in place to provide equality to all users. On December 6, 2012, Federal Communications Commission(FCC) announced that Gallaudet University’s Technology Access Program (TAP) was recently recognized by the FCC for its work in developing text-to-911 capabilities which will be available nationwide by May 15, 2014, by the USA’s four largest wireless carriers: AT7T, Verizon, Sprint, and T-Mobile. See details at 25. Concern: There is lack of visually accessible emergency information when on the road or at home of announcements that are auditory in nature – radio, PA, blackberry pagers, cellphones, I-Phone, I-PAD, and latest communication technologies Recommendation: CRTC set regulations requiring the emergency communication industries to provide text based information to cell phone, text services and other such devices and service providers in order to ensure culturally Deaf, oral deaf people, deafened and hard of hearing individuals have access to up-to-date emergency information in the cases, for example, of natural disasters, weather warnings, amber alerts, traffic accidents, etc.

Broadband and Dataplan Affordability

26. Concern: The data plans in both residential and on mobile devices are significantly more expensive for Deaf people and hard of hearing people who cannot and understand voice telephone. Forcing to have voice plan under their mobile device and needing more data for video calls and so on is an additional cost.

Recommendation: Cost for mobile and residential internet data plans should be the same cost as what most Canadians pay; however, the functional equivalence would be to remove the voice plan and the minutes need to be translated to data. Often mobile providers provide unlimited local minutes and reduce long distance charges. This needs to be reflected in a dat plan that would provide unlimited local data, etc.

Portrayal and Employment of Persons with Disabilities
28. Concern: There is a lack of employment equity initiatives specifically with regards to persons with
disabilities, in telecommunication industries and in CRTC’s personnel hiring, retention and promoting
employees with disabilities practices (from front line staff to senior management).

Recommendation: CRTC set regulations requiring telecommunication industries and CRTC personnel to establish employment equity measures so as to comply with Federal Employment Equity legislation, and the Canadian Human Rights Act (i.e., duty to accommodate in workplace).

29. Concern: There is a lack of internal access and accommodation and anti-ableism policies in the CRTC.

· CRTC set regulations requiring that it establish clear internal policies and procedures for providing access and accommodation for culturally Deaf, deafened and hard of hearing participants in the CRTC system, employees, consultants, etc., and provide awareness training to confront and eradicate ableist/and audist attitudes and behaviours in the CRTC system.

· CRTC provide regular, mandatory awareness training about communication needs and how to meet the communication needs of culturally Deaf, oral deaf, deafened and hard of hearing individuals for all levels of CRTC personnel.

· CRTC publish its policy on Accessibility and Accommodation in accessible format such as in sign language, and captioned in video or DVD format.
Establishment of CRTC Disability Rights Office (see details at similar concept of FCC Disability Rights Office ( )
30. Concern: There is lack of CRTC public education and enforcement mechanism in addressing disability-
related matters, including access to telecommunications services and equipment; hearing aid compatibility; access to
advanced communications services and equipment; access to Internet browsers built into mobile phones;
telecommunications relay services; the National Deaf-Blind Equipment Distribution Program; accessible video
programming and video programming apparatus (access to televised emergency information, closed captioning on
television and television programs on the Internet, video description, and accessible user interfaces, text menus, and
program guides). Currently each of these technologies (i.e. IP-Relay, captioned telephones, VRS, TTY, etc) are
addressed one at a time by CHS and other stakeholders, but no one is really looking at and overseeing the big picture
and ensuring that each of these changes is in harmonious with all the others.
Recommendation: CRTC establish its Disability Rights Office (DRO) which is familiar function of

FCC Disability Rights Office. DRO provides expert advice and assistance to other Commission Bureaus and Offices, consumers, industry, and others on issues relevant to persons with disabilities. DRO initiates rulemaking, where appropriate. DRO also reviews relevant agenda items and other documents and coordinates with Bureaus and Offices to develop recommendations and propose policies to ensure that communications are accessible to persons with disabilities, in conformance with existing disability laws and policies, and to ensure that they support the Commission’s goal of increasing accessibility of communications services and technologies for persons with disabilities. DRO will oversee all these changes and report to CRTC on a regular basis about their progress.

Establishment of Telecom Accessibility Fund
31. Concern: There is non-existing Telecom Accessibility Fund which is similar to Broadcasting Accessibility Fund as directed by CRTC

Recommendation: CRTC directs TSPs to establish Telecom Accessibility Fund which is similar to the Broadcasting Accessibility Fund Inc, (the fund) that is an independent and impartial funding body supporting innovative projects that provide solutions to promote the accessibility of all telecom content in Canada. The Fund will support projects that provide practical solutions to increase accessibility to telecom content and that, whenever possible, make use of inclusive design principles to promote accessibility at the earliest stages and in the most cost-effective manner for new technologies and applications in Canada.

***End of Document***

Intervention: Canadian Hearing Society (Intervenor 191)

Document Name: 2015-134.223714.2388139.Intervention(1f6p701!).html

**** Secretary GeneralPlease find CHS submission in response to CRTC Telecom Notice of Public Hearing CRTC 2015-134 and Reference 663-C12-201503186.Thank you for the opportunity to review and provide comments.Gary MalkowskiSpecial Advisor to President, Public AffairsCanadian Hearing SocietyRaisons pour comparaitre / Reasons for appearanceWe would like to attend to discuss the trends and benefits of captioned telephone services for those individuals with hearing loss who really need this service. Also, we would address to discuss captioning on the internet and webcast and its benefits. Possibly we would like to arrange to set up captioned telephone demonstration at the public hearing to show the benefits of the use of captioned telephone services that are not available in Canada. Also, we will show captioning on the webcast via the internet and demonstrate poor quality of auto captioning used on Youtube at the public hearing (i.e. provide examples of good and poor quality of auto-captioning versions)