Intervention: Deaf Wireless Canada Committee (Intervenor 265)

Document Name: 2015-134.223984.2394488.Intervention(1fblk01!).pdf

c/o Canadian Association of the Deaf-Association des Sourds du Canada (CAD-ASC) 251 Bank ****, Suite 606, Ottawa, ON *** ***

www.deafwireless.ca (under construction)
E-Mail: ******@***.com Twitter: @DeafWirelessCAN
July 14, 2015
John Traversy
Secretary General
CRTC
Ottawa, ON *** ***

Re: DWCC Response to CRTC Telecom Notice of Consultation CRTC 2015-134-1 File: 8663-C12-201503186

**** Mr. Traversy,

The Deaf Wireless Canada Committee (DWCC) respectfully requests four representatives from our Committee to be invited to appear and present our case at the public consultation for basic telecommunications services. The four potential presenters would be: **** Anderson-Kellett (Chair), Rytch Newmiller (Vice-Chair), and our technical advisors, **** Beatty and **** Cannon (subjected to changes). We will need American Sign Language (ASL) and Langue des Signes Québécoise (LSQ) interpreters and also recommend live captioning during our participation at the public hearing.

Our Committee believes that the basic telecommunication services – mainly wireless communications – for Deaf, Hard of Hearing and Deaf-Blind Canadians have concerns that need to be addressed in a systematic order. New technologies for accessibility are either currently in use or brand new. An example of the current technology is video messaging as opposed to text messaging.

Examples of brand new technology are Video Remote Interpreting (VRI) and Video Relay Services (VRS). These types of communications would bring up more demand on data usage. In anticipation of upcoming implementation, we would like to have the opportunity to present our case. Please note throughout in the documents that we will refer Deaf, Hard of Hearing, and Deaf-**** Canadians to ASL & LSQ users for clarity reasons.

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http://www.deafwireless.ca/
mailto:******@***.com

Our main points are outlined here with further details in upcoming paragraphs:

1) Clarify what functional equivalency means for full accessibility in a rapidly evolving digital communications landscape. Video communications is the functional equivalency for ASL & LSQ users.

2) Explain how much video quality specifications are required for a higher broadband standard, which may become more cost intensive.

3) Explain how extensive and higher costs of data utilization vary with ASL & LSQ users in comparison with the mainstreamed population demographic.

4) Identify issues with wireless service contracts; current options may be confusing or a barrier for many whose first language is not **** yet rather in sign languages.

Our committee has several key points and recommendations to be shared with the CRTC. We believe our Information would help participants understand the benefits, challenges and implications as well as impacts faced by ASL & LSQ users and their family members.

ASL & LSQ users believe that wireless and Internet telecommunications services do fulfill many social, economic and cultural needs in today’s digital economy.

Yet, we need to emphasize that our main focus is having full video communications accessibility, which would allow ASL & LSQ users to participate in the fabric of Canadian society in a functional-equivalent manner.

For ASL & LSQ users, wireless communication is increasingly becoming our basic telecommunications service. Increasing number of ASL & LSQ users do not have, are removing, or planning to remove landline phone(s) from their household mainly because of technology incompatibility of TTY devices to digital phones. TTY machines are becoming increasingly obsolete. Because of mitigating changes, we are in support of a review for basic telecommunications services and current practices.

Background

The Deaf Wireless Canada Committee (DWCC) is formed because a number of grassroots members of the Deaf Community were all sharing similar concerns about the present wireless data plans particularly over social media that at some point, a few people believed it was time to form a committee to examine the issues and to formulate recommendations. The key objective of the committee is to bring forward the issues and recommendations to the attention of the CRTC, CCTS, and CWTA. At this time of submission, twenty-one members have joined the committee, which is also comprised of subcommittees. Executive Team, CRTC Submission Writing Team, Survey Team, Public Relations Team, Finance Team, and Distribution Team are the subcommittees.

The Canadian Association of the Deaf (CAD-ASC) recently approved the DWCC on **** 24, 2015 as a standing ad-hoc committee. One of the DWCC members, **** Anderson-Kellett, is the Director on the CAD-ASC Board. The CAD-ASC staff will provide administrative support and consultation to the committee. The DWCC under CAD-ASC is a non-profit group.

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Issues
The DWCC has identified the following issues:

• ASL & LSQ Users are being forced to pay for voice minutes that they do not use.

• ASL & LSQ Users, who are adamant to remove voice plan, spend at least 1.5 hours dealing with a hierarchy of management until the most senior manager approve such requests.

• Some ASL & LSQ Users may have experienced frequent “bill shock” due to higher data usage from intensive use of video communications.

• Current data plans may not adequately meet ASL & LSQ users’ needs once VRI, VRS, and more video messaging apps become available.

• The lack of fair data plans that wireless companies (or Telecommunications Service Providers – TSPs) provide for ASL & LSQ users. High quality video communication is one of the items they need in their data plans.

• Disparity of data plan costs is unfair among the ASL & LSQ users. For example, one person paid $43 for 6 GB data usage and unlimited texts when the other person pays $63 for 2 GB data usage and 2500 texts.

• The lack of advertising of data plans for ASL & LSQ Users.

Data consumption

We would like to present following examples of data consumption by visual mediums:

• Instead of texting, video “texting” or messaging is on the rise, with the availability of such video messaging apps as Glide.

• Increased usage of FaceTime and Skype apps using mobile devices that increased data consumption is becoming evident for these ASL & LSQ users compared to their hearing counterparts.

• New technologies for accessibility are being implemented, such as VRI and VRS, which will bring upon more demand on increased data usage.

• Higher broadband is required for better video quality that is more costly.

• People are incognizant that Deaf, Hard of Hearing, and Deaf-Blind people do not receive information in the same way as hearing people do. The ASL & LSQ users learn of updates and news in the language that they use from others reporting in sign language; thus, there is more usage of video connections via web-video services like YouTube.

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Accessibility issues

We have noted accessibility issues related to wireless telecommunications other than data usage and data plan packages. ASL & LSQ users may want to continue specific type of services including IP-Relay services. We need to be aware of how the information is shared through the CRTC and other websites. As well, an Accessibility Office proposal needs to be considered.

• IP-Relay Services, an alternative to the TRS or MRS (TTD/TTY Relay Services), need remain available on smartphones or mobile devices. The IP-Relay Services need to be improved in terms of services and code of ethics by relay operators.

• There was a consultation notice for the future use of IP-Relay and TRS/MRS that there was lack of ASL and LSQ to explain the consultation process to allow for ASL and LSQ users submit their responses in writing or a video in their language. CRTC processes that involve deaf and hard of hearing telecommunications or broadcasting consumers need to be made more accessible.

• The committee believes that more analysis and review is needed to explore the possibility that the current Social Access office becomes transitioned into an Accessibility Office with the CRTC. Our proposal is that for a long term or permanent plan, an Accessibility Office needs to address several key issues and operate similarly to the FCC’s Disability Rights Office, (https://www.fcc.gov/encyclopedia/disability-rights-office). The Accessibility Office would deal with broad range accessibility issues, to apply accessibility philosophies to CRTC processes, and ensure inclusivity of ASL & LSQ users in the process addressing critical issues.

Our committee acknowledges that the Canadian Hearing Society (CHS) had submitted to this Notice of Consultation, and we are in agreement of their items numbered 11 to 20, 22, and 24 to 31.

The primary concern of the committee is currently focused on data packaging, fair pricing, video quality, and accessibility for ASL & LSQ users.

Next Step: Plans to formulate recommendations

We, as committee members, have based information through our first-hand experience and our conversations with other ASL & LSQ users. Through the formal committee discussions, we were able to identify key issues and important information pertaining data consumption. Before we provide formal recommendations, we have plans to collect further information to present a clearer picture of what is happening among the ASL & LSQ users.

Our first planned project is a survey conducted to collect evidence on the demographic information of ASL & LSQ users, their current data plans, their processes in obtaining data plan and agreed prices, their primary means of communications, and the future of their communications. Disparity of data plan costs and current practices by each provider would be also reviewed. The outcome of the survey will be shared with the CRTC, CCTS and CWTA. In addition to the survey outcome, we will examine the affordability of the plans to match the broadband quality needed for video communications over data connections. An example of questions asked would be: How much are you paying for your monthly data usage? Do you have a contract or are you paying month to month?

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https://www.fcc.gov/encyclopedia/disability-rights-officeThe survey will be conducted in the four languages of our consumer group: ****, ****, American Sign Language (ASL) and Langue des Signes Québécoise (LSQ). It will be distributed across the country reaching a wide variety of Deaf communities.

In addition to the survey, our committee’s website currently is in the planning and design stages.

The website will have a forum page where people can express their experiences with their wireless plans so we can collect stories and share them at the hearing.

The timeline for the survey is that we will aim to have the survey results completed by October 9th.

We plan to present a preview of the survey questions and the preliminary results of the questions.

We have firm preference to present the full analysis of the survey and recommendations in person at the hearing in **** 2016. We will also demonstrate a numerical analysis of video communications as data usage for a comparison to the voice minutes for hearing consumers.

At this point, we believe that the two current issues and recommendations are very important that need to be included in this submission:

1) Data consumption and the comparisons of data usage is one of the two issues.

One of the scenarios is: Hearing customers are given voice minutes as part of the wireless data plan packages, often with free minutes after 6:00 pm (18h00), and thousands of ASL & LSQ users cannot make use of these minutes.

Data plans are made available for all consumers; however, ASL & LSQ users have a communication barrier: the limited use of video communication to avoid additional charges if over the set data usage.

Whereas for hearing people, it is a bonus or a luxury to have, to watch movies, or play games while in reality, for ASL & LSQ users needs video messaging for our everyday communications for functional equivalency. The ASL & LSQ users are utilizing the latest app, Glide, for a back and forth communication using sign language. Their data usages continue to increase due to the additional cost of extra data usage, for example an extra $10 for each GB. Additionally, there is confusion on how many bytes is used in data consumption, for example 500 MB versus 6 GB.

Recommendation:

Provisions of fair and accessible wireless packages for all ASL & LSQ users with voice minutes credited and fair data packages for Canadian consumers. As well, more awareness needs to be provided to compare the data consumption.

2) Private and customized agreements among ASL & LSQ users are the other issue.

Based on intertwined conversations among ASL & LSQ peers as friends, family, and/or work colleagues, the committee members learned that the private and customized data packages are created for a limited number of ASL & LSQ users. The rest of ASL & LSQ consumers received standardized data packages. No one is aware of a standard accessibility package for those who require no voice but increased data usage. Senior management of the companies approves these credits or discounts. This is frustrating because the information 5

is not consistent wherever ASL & LSQ users go. Additionally, there seems to be a wide disparity of packages offered for these consumers under even the same companies.

Recommendation:

Standardized and fair ADVERTISED accessibility packages for those that need customized data plans for their access needs. For an excellent example, please see Australian company Jeenee’s advertisement of their package available to Deaf Australians:

https://vimeo.com/126859427

This is precisely why we need to undertake a Canada-wide survey to further research the current wireless communication issues and possible issues we may face in the future once VRI, VRS, and other video technologies become available. We plan to present the full results of this survey at the hearing.

Please see an expanded version of the points covered in this letter over the next few pages.

We would like to end with a note of appreciation to the Canadian Association of the Deaf (CAD-ASC) for the opportunity present our information from the grassroots’ views, so we can remain focused on our specific concerns with video communication, quality and data in connection with wireless means and some wireline applications.

Additionally, we would like to give thanks to Mr. Travesty and the CRTC for taking time to read and address our concerns. We look forward to participating in the coming hearing in **** 2016, with our detailed presentation of the results of our survey.

We do look ahead with the anticipation that we can collaborate with the CRTC and relevant working groups in creating a more lasting and positive change with the wireless service providers (WSP’s) and provide resolutions on behalf of the Deaf, Hard of Hearing and Deaf-Blind Community.

Full accessibility by participation in the social and economic fabric of Canadian society benefits all.

The time for resolution is now before other accessibility services and evolving technologies arrive.

Thank you,
Sincerely,
**** Anderson-Kellett, Chair
Deaf Wireless Canada Committee
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https://vimeo.com/126859427
Table of Contents
Part I: Survey

1.1. Methodology ....................................................................................................... 8 1.2. Timeline ................................................................................................................ 8 1.3 Sample of Survey Questions ......................................................................... 9 Part II. Data Plans

2.1 Visual Communication Means .................................................................... 9 2.2 Wireless Service Provider data package issues ................................... 10 2.3 Broadband upload and download impacts on video quality .......... 11 2.4 Clarifications of Service Plans in an Accessible Means ..................... 11 2.5 Advertising Wireless Service Provider plans........................................ 12 2.6 Accommodations for People with Disabilities ..................................... 12 Part III. Text 911 issues

3.1 Unclear process for registration ................................................................ 12 3.2 Education ............................................................................................................. 13 3.3 Regional disparities ......................................................................................... 13 3.4 Technical Issues with Text with 911 Accessibility ............................. 13 Part IV. Accessibility issues with the CRTC’s processes

4.1 Consultation processes .................................................................................. 14 4.2 Option to submit comments in sign language ...................................... 15 4.3 Accessibility Office ........................................................................................... 15 4.4 Lack of awareness of the CCTS ................................................................... 16 Appendix A: Links & Resources ............................................................................................. 17 7

Part I: Survey
1.1 Methodology

The Deaf Wireless Committee of Canada (DWCC) under the CAD-ASC, is a grassroots, volunteer-based committee that consists of Deaf people with the common motivation to get the wireless accessibility issues clarified and resolved and to educate people about the value of clear video communications using wireless (and wireline) telecommunications. We plan to undertake an online survey to gather the wireless consumer experience.

Gathering the consumer experience will be done via two formats:

1) Utilizing the Survey Monkey tools, with questions & answer options available in four languages, ****, ****, American Sign Language (ASL) and Langue des Signes Québécoise (LSQ).

2) Collection of Consumer experiences with the WSP’s from a Forum page on our website.

The 21-member Committee will distribute the survey. Our Distribution Team is a sub-committee comprised of members located across Canada from Halifax to Vancouver. ****-Canada channels will include e-Newsletters, websites, and social media pages. The goal is to get a range of 500 – 1,500 respondents to gain a picture of the current issues of wireless telecommunications for these consumers. We aim to provide recommended accessible data plan options based on our results.

1.2 Timeline

July 14, 2015 – Submit the committee’s papers for the CRTC 2015-134 hearing July 18 – **** 19

1) Develop **** version & design graphic illustrations to aid in the survey questions 2) ASL & LSQ vlogs advertising the survey for community preparation: CAD-ASC **** 20 – E-mail **** questions & material to **** translation volunteer **** 22 – ASL talent filming of survey questions

**** 22 – 29 – **** translations of Survey by a volunteer **** 30 – Send **** version to LSQ talent & see if anyone in Quebec can edit LSQ video to match the ASL version

**** 30 – **** 10: ASL & LSQ video editing - merging everything into Survey Monkey set-up/design

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**** 1st – Website launched with About Us, Forum pages to collect consumer-direct experiences

**** 15 – 30 - ASL & LSQ Survey distribution by everyone in the committee and CAD-ASC Board members

October 1 – Survey Analysis with creation of visual charts, graphs and, if possible, infographs.

October 8th – Preview write-up of Survey results & forum comments so far sent to CRTC (CCTS & CWTA too) – sent on the day before deadline.

**** 11th 2016 Survey results in full and a sample of forum comments to be shared at public hearing in detail and with graphic illustrations demonstrating our points.

1.3 Examples of Survey Questions:
1.3.1 What kind of smartphone do you have?
1.3.2 Which WSP provider do you subscribe to?
1.3.3 What kind of wireless plan do you have?
1.3.4 Do you have voice included in your plan?
1.3.5 Have you registered with Text with 911? (Y/N)

Survey respondents will be anonymous, with only the collection of generic profiles, such as location of residence, age, and gender to demonstrate demographics of ASL & LSQ users. We also develop a plan to allow for anonymous responders included in the process of participation in the forum discussions, to protect any issues with the consumers and the WSP’s.

Part II: Data Plans
2.1 Visual Communication Means
2.1.1 Issue:

• Instead of texting, video “texting” or messaging is on the rise, with the availability of such video messaging apps as Glide.

• Increased usage of FaceTime and Skype apps using mobile devices that increased data consumption is becoming evident for these ASL & LSQ users compared to their hearing counterparts.

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• New technologies for accessibility are being implemented, such as VRI and VRS, which will bring upon more demand on increased data usage.

• Higher broadband is required for better video quality that is more costly.

• People are incognizant that Deaf, Hard of Hearing, and Deaf-Blind people do not receive information in the same way as hearing people do. The ASL & LSQ users learn of updates and news in the language that they use from others reporting in sign language;

thus, there is more usage of video connections via web-video services like YouTube.

2.1.2 Recommendation: Recognize that video communications is required for functional equivalency by ASL & LSQ consumers and that fair data packages need to be created.

2.2 Wireless Service Provider Data Packages

2.2.1 Issue: The committee has acknowledged that the CRTC Telecom Regulatory Policy decision 2013-271, sections #311 to #326 in regards to data plans and how it can be better addressed with the WSPs and that it was all to be put into effect at the end of December 2013. The concerns covered advertised prices, more simplified language in writing, promoting the rights of the customers to understand their bills and what’s covered and what is not.

Many ASL & LSQ users still struggle with a full understanding of their data plans, with getting their voice portion of the plans removed, or credited, and not understanding the disparity between actual bills and data usage being variable among customers. There is no consistent agreement on what’s fair pricing with the data usage in terms of GB that would be consistent and prevalent with a higher usage of video communications. Also they still don’t understand that advertised prices can be misleading in particular understanding in how GB data packages could become inadequate for their increased use of video communications.

With the upcoming new evolving video technologies, the data usage can potentially increase dramatically above 10 GB per month, which could prove costly and unaffordable for ASL & LSQ users who strongly prefer video communications to text based communications on their smartphones.

2.2.2 Recommendation: With a coordinated agreement among WSPs, a fair and uniform Deaf/disability data plans with stable price packages to match data usage is proposed as a resolution.

A newer and more simplified plain **** version of the advertised and billing contracts can be proposed for the Deaf/disability and the immigrant population to be well designed by all WSPs and reviewed by CRTC and other customer organizations for final approval before distribution.

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ASL & LSQ users would appreciate an ASL & LSQ video version of wireless customers rights, understanding their contracts and the language used in their bills to avoid further confusion and billing shock.

2.3 Broadband uploads and download Video quality impacts 2.3.1a Issue: The average upload speeds for ASL & LSQ users are inadequate for current needs. CRTC’s current basic broadband services speed targets (5 Mbps download/1 Mbps upload) are inadequate for enabling Deaf Canadians to participate meaningfully in the digital economy.

2.3.1b Issue: Many of Wireless’s Deaf customers have 4G LTE service, which typically provides mobile Internet speeds of more than 30 megabits per second. We are aware that wireless & wireline providers have specifically identified this practice as a legitimate and reasonable way to manage network resources (throttle) for the benefit of all customers. It has been known for years that all of the major carriers apply this.

Wireless & Wireline providers could cause detrimental effects on our video calls by using managed network resources (throttle). 700kbps **** is required to use FaceTime, Glide, VRS apps and 3.5Mbps **** is required for streaming 720p HD Video calls. When the wireless providers use the throttle, their Internet speeds switch to 512kbps to slow down video call data. The end result is that it becomes near impossible to utilize video calls with blurry input or output.

We must safeguard our video calls from this throttle.

2.3.2a Recommendation: For clear video communications, improved and increased upload speeds need to be available offered by wireline and wireless service companies. 25 Mbps download/ 5 Mbps upload speed or better is recommended for visual clarity of the signer so that jerky movements do not occur. We would recommend that CRTC establishes a guideline whereas upload speeds need to be closer in symmetry with the ability to support video calls on both sides. A ping of 90ms or lower is recommended.

2.3.2b Recommendation: We recommend CRTC to establish mandated designations such as: all the wireless/wireline providers cannot throttle ASL and LSQ consumers’ video calls due to life, health, safety or property (911 calls). Video calls must be treated in the same manner as with voice calls.

2.4 Clarification of Service Plans in an Accessible Means 2.4.1 Issue: The current wireless packages are not in plain and simple language including legal jargon. According to the Wireless Code, contracts are supposed to be provided in plain and clear language.

2.4.2 Recommendation: Service plans and contract details to be provided in plain and simple languages: **** or **** and also in the option of ASL or LSQ.

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2.5 Advertising Wireless Service Plans:

2.5.1 Issue: Wireless companies are arranging individualized data package plans with ASL & LSQ users. There is a wide disparity of pricing and packages provided even among ASL & LSQ of the same company. This is not good business practice.

2.5.2 Recommendation: It should be mandated, to have extensive advertising on provisions of packaging for our ASL & LSQ users.

2.6 Accommodations for People with Disabilities

2.6.1 Issue: The CRTC Telecom Regulatory policy 2013-271 sections #327-338 states that the accommodations for people with disabilities shall be honoured by WSPs. In reality, nothing much is happening. As it is, ASL & LSQ users do not see the reports by WSPs submitted to CRTC yet by **** 3, 2014, specifically on what wireless plans they offer for people with disabilities, how they promote these plans, and what accessibility specific customers available.

2.6.2 Recommendation: The committee respectfully requests CRTC to reinforce this policy of accommodations as to remind all WSPs and with a new deadline. Also if the new Accessibility office can be created, this issue can be further enforced and there can then be on-going consultations with all WSPs consistently for more future modifications.

Part III: Text with 911
3.1 Unclear Registration Process for Text with 911

3.1.1 Issue: While there is a website specifically made as a one-stop process, the website is not user friendly in terms simplified language. If you look at this page (http://textwith911.ca/wireless-service-providers/), it looks cluttered. And when you click on the logos, you do not get a simple straightforward link to the Registration page. Let us use the Rogers logo link as an example, when you click on this logo it takes you to general Accessibility **** (http://www.rogers.com/web/content/accessibility-services-wireless), and you have to scroll up the page a number of times before you get to the Registration link.

This process is too cumbersome. The steps need to be made simpler to access the registration process for all.

3.1.2 Recommendation: The Committee suggests that CRTC ensures that the process be made less cumbersome, and much simpler of a registration process. The CRTC should encourage the CWTA to create a policy or guideline that all WSP’s must make the Registration process simpler, with a two-click rule to reach the Registration link.

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http://textwith911.ca/wireless-service-providers/

http://www.rogers.com/web/content/accessibility-services-wireless3.2 Education about Text with 911 across Canada

3.2.1 Issue: FAQ’s and such information on the website are not accessible for those with sign language as a primary form of communication. The website is only partially available in video format, and with very small video embeds.

3.2.2 Recommendation: Our committee commends the effort that E-Comm and the Western Institute of the Deaf and Hard of Hearing (WIDHH), took to create a video to increase awareness (see link: http://www.ecomm911.ca/calling-911/T911system.php) however a wider distribution reach would be more effective. Unfortunately, not everyone is aware of the videos and vlogs available. The Committee recommends a more effective means by providing community education workshops by Deaf community organizations and service providers. Workshops at major locations are more hands-on and accessible in their own language and interactive for discussions and Q&A. Funding needs to be made available for such a program. The CRTC should assist to make this possible.

3.3 Regional disparities still exist for Text with 911 across the country 3.3.1 Issue: Text with 911 is still not fully functional across our Canadian provinces according to this link: http://textwith911.ca/service-availability/ Rural communities do not have this access. It is yet to be fully accessible to all those with text access. This is a serious issue.

3.3.2 Recommendation: CRTC needs to follow up with CWTA’s Text with 911 programme and work with them to provide a progress report and encourage for more advancement in the service regions. A Map visually detailing cross-country coverage on Text with 911 is recommended so that the Deaf, Hard of Hearing, and Deaf–Blind Canadians could see which area is adequately covered. Annual updated progress reports are recommended.

3.4 Technical conflicts regarding Text with 911 accessibilities 3.4.1a Issues: ASL & LSQ Users are forced to pay for a service that they do not benefit from (voice 911, without voice plan). With recent implementation, they have to pay for it in order to access Text with 911. The process need to be reviewed.

3.4.1.b Issues: Why is it that the consensus concept for Text with 911 in Canada and the US are comparatively different? There is a disparity in the response times for the calls between the two countries. Apparently in the US it only takes four seconds while we are seeing in Canada, on the advertisements that it takes two minutes, this in itself is a serious safety and an accessibility concern, especially when it comes to life-threatening situations.

We wonder why we have to wait a whole two minutes here in Canada to wait for a connection with a dispatcher.

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http://www.ecomm911.ca/calling-911/T911system.php
http://textwith911.ca/service-availability/

3.4.1.c Issues: Deaf visitors to the country, including Americans who are dual citizens to Canada, cannot access Text with 911. How can Americans that hold dual citizenship benefit from Text with 911 in Canada? There is a barrier for this group.

3.4.2a Recommendation: If for some reason it is technically not possible to separate the voice technology with texting, the Committee suggests that the CRTC encourages the Wireless Service Providers to allow voice enabled for the provisions of access to 911 but provide service credits for the unused voice minutes.

3.4.2b Recommendation: Upgrades to the Text with 911 systems to improve the response times. Texting for these purposes should automatically include GPS.

3.4.2c Recommendation: CRTC needs to re-examine the 911 platform that will better accommodate our evolving technologies. There should be apps developed for just this purpose here in Canada, as they have in the US, see these download links:

http://www.ten43.com/apps/Advanced911-iphone.html,

https://itunes.apple.com/us/app/advanced-911-text-911/id455783722?mt=8 https://itunes.apple.com/us/app/911-help-sms-911helpsms-ice/id798026644?mt=8 https://www.911helpsms.com/

These apps couple GPS with text technologies and thus better the response time for emergencies.

This is a simplified and safer system.
Part IV: Accessibility
4.1 CRTC Consultation Processes

4.1.1 Issue: CRTC Consultation processes are often inaccessible. For example, the recent consultation process for Message Relay Services that ended July 7, 2015. Regardless of quite a few attempts made by Deaf community members to post, share and re-tweet about the process, the Deaf community in general found the consultation process unclear. In all honesty, there would have been much greater participation in the consultation had there been more inclusivity applied to the process.

NOTE: With VRS not yet on the horizon, Message Relay Services are currently the only option for relay services for this consumer pool, which means thousands of consumers were missed out in this consultation process because of the ambiguity of the process in a language that is not their strength. This consumer pool struggles with written language as their second language.

4.1.2 Recommendation: All CRTC processes that involve deaf and hard of hearing telecommunications or broadcasting consumer issues need to be made more accessible.

For example, if the CRTC plans to open a process that INCLUDES all of the broad range of deaf, Deaf, hard of hearing, Hard of hearing, deaf-blind, or Deaf-Blind consumers in a consultation process, ASL and LSQ instructional videos should be made available explaining 14

http://www.ten43.com/apps/Advanced911-iphone.html

https://itunes.apple.com/us/app/advanced-911-text-911/id455783722?mt=8https://itunes.apple.com/us/app/911-help-sms-911helpsms-ice/id798026644?mt=8https://www.911helpsms.com/

the steps to register, creating a user name, login steps, etc. Also, the questions should have been explained in ASL and LSQ for greater clarity.

4.2 Submission Options in Sign Language

4.2.1 Issue: CRTC Consultation processes that clearly involve deaf and hard of hearing telecommunications (Relay Services issues) or broadcasting (captioning issues) consumer issues need to be open with options for public submissions. The only options to submit a comment, feedback or experience were in either **** or ****.

4.2.1 Recommendation: CRTC provide video submission options for Deaf, hard of hearing, and Deaf-Blind consumers. The CRTC can hire ASL or LSQ sign language interpreters to translate these sign language messages into the written word.

4.3 CRTC Accessibility Office and Disability Advisory Committee 4.3.1 Issue: The CRTC handles a range of feedback and comments by consumers with disabilities, in connection with all their programs, services, and notice of consultations, but does not have one formal one-stop place to address these issues. Quite a variety of consumer groups made this recommendation over the past few years, especially with the 2013-155, 2014-187, 2014-188 interventions from varied individuals and consumer groups such as the BCVRS, OAD, CHS, CAD-ASC, and Media Access Canada.

4.3.2 Recommendation: CRTC needs to take into account all of the various consumer groups’ recommendations for the establishment of a new department that primarily addresses all accessibility issues related to the CRTC. This office can be responsible to act as a liaison with between CRTC and all consumer groups connected to people who have disabilities. Our committee proposes to start with one main staff person and an assistant, within a new office mechanism similar to FCC’s Disability Rights Office:

https://www.fcc.gov/encyclopedia/disability-rights-office Greater inclusivity would collectively be achieved by an establishment of a Disability Access Committee similar to the FCC’s: https://www.fcc.gov/disability-advisory-committee One of the tasks of this Accessibility Office would be to establish a direct communication venue for Deaf, Hard of hearing consumers to access in their own language to deal with consumer and social issues. A good example of this would be:

https://www.fcc.gov/document/fcc-adds-american-sign-language-consumer-support-line-videophone

4.4 Lack of awareness of the CCTS

4.4.1 Issue: Many Deaf, Hard of Hearing and Deaf-Blind Canadians are not aware and do not understand that there is actually a complaint body for wireless services provider issues.

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https://www.fcc.gov/encyclopedia/disability-rights-officehttps://www.fcc.gov/disability-advisory-committee

https://www.fcc.gov/document/fcc-adds-american-sign-language-consumer-support-line-videophonehttps://www.fcc.gov/document/fcc-adds-american-sign-language-consumer-support-line-videophoneThere have not been any videos produced in ASL or LSQ announcing this service for these consumers in a language that they can understand fluently. They do not know the steps for conflict resolution on these issues or that such an organization exists.

4.4.2 Recommendation: CRTC should take steps to advise and work with the CCTS to ensure that there is accessible information in sign language in both Canadian sign languages. Videos should be made that outline the steps for resolution of wireless service provider issues such as billing and how to access the CCTS.

CCTS should also provide a video consumer support service, such as an ASL/LSQ Consumer Support Line, specifically designed to enable consumers who are deaf and hard of hearing to engage in a direct video call with a consumer specialist at the CCTS. The service will allow Deaf and Hard of Hearing consumers to communicate in their primary language, American Sign Language and la Langue des Signes Québécoise (LSQ) to get resolutions for their issues.

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APPENDIX A - Reference links

Other examples of publicly advertised packages for Deaf, Hard of Hearing and Deaf-****:

Australian company Jeenee’s advertisement for Deaf Australians:

https://vimeo.com/126859427

E-Comm 911 and Western Institute of the Deaf and Hard of Hearing (WIDHH) co-production on Text with 911:

http://www.ecomm911.ca/calling-911/T911system.php
Text with 911 links:
http://textwith911.ca/service-availability/
FCC Disability Rights Office

https://www.fcc.gov/encyclopedia/disability-rights-office Disability Advisory Committee

https://www.fcc.gov/disability-advisory-committee
FCC’s ASL – Accessible Consumer Line

https://www.fcc.gov/document/fcc-adds-american-sign-language-consumer-support-line-videophone

Text with 911 apps available in the US:
http://www.ten43.com/apps/Advanced911-iphone.html,

https://itunes.apple.com/us/app/advanced-911-text-911/id455783722?mt=8 https://itunes.apple.com/us/app/911-help-sms-911helpsms-ice/id798026644?mt=8 https://www.911helpsms.com/

***END OF DOCUMENT***
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https://vimeo.com/126859427
http://www.ecomm911.ca/calling-911/T911system.php
http://textwith911.ca/service-availability/

https://www.fcc.gov/encyclopedia/disability-rights-officehttps://www.fcc.gov/disability-advisory-committee

https://www.fcc.gov/document/fcc-adds-american-sign-language-consumer-support-line-videophonehttps://www.fcc.gov/document/fcc-adds-american-sign-language-consumer-support-line-videophonehttp://www.ten43.com/apps/Advanced911-iphone.html

https://itunes.apple.com/us/app/advanced-911-text-911/id455783722?mt=8https://itunes.apple.com/us/app/911-help-sms-911helpsms-ice/id798026644?mt=8https://www.911helpsms.com/

Table of Contents

Intervention: Deaf Wireless Canada Committee (Intervenor 265)

Document Name: 2015-134.223984.2394489.Intervention(1fbll01!).html

See attachment. Raisons pour comparaitre / Reasons for appearanceWith emerging video accessibility and technologies on the horizon, we are facing several challenges with wireless communication, especially with the video communication in terms of data usage. The consumer group is comprised of ASL & LSQ users or the Deaf, Hard of Hearing, and Deaf-Blind Canadians. We are seeking resolutions before the new changes happen:? wireless services are our basic telecommunication needs and with this, video upload and download speed concerns need to be addressed for clarity of video communications for these consumers, especially with high demand of video messaging? wireless data packages are not standardized for this group which has no use for voice minutes and heavily uses data for video communications, thus issues need to be addressed? concerns related to the technical impacts of video quality for broadband or wireless video communications? Text with 911 program concernsOur initial submission is a start, as we will have more information to share with the CRTC in early October 2015. We have yet begun to survey respondents to accurately demonstrate the issues, thus the **** 11, 2016 hearing presents the opportunity for us to submit the full survey results in graphic and visual means and to answer queries related to the data presented in person.