Final Replies : Deaf Wireless Canada Committee (Intervenor 265)

Document Name: 2015-134.223984.2630348.Final Replies (1kdl801!).pdf
​Deaf Wireless Canada Committee
Review of Basic Telecommunications
CRTC TNC 2015 ­ 134
FINAL REPLY COMMENTS
**** 13, 2016
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Introduction

Proceeding 2015­134 explored basic telecommunications services with the debate of “wants” vs. “needs,” and DWCC hopes to have shown all the parties and the Commission that video communication is a ​need​ for us and the Canadians we represent.

1. It is a matter of functional equivalency, hearing people can pick up a phone to call family members, friends or government service providers over wireless, wireline or wired internet connections, yet Canadians using sign language do not have this same liberty. We won’t be stifled by data caps and limits for video calling. We’re asking for the same benefits that hearing Canadians enjoy: unlimited talk time. ASL and LSQ users need the equivalent, unlimited video communication time.

2. Is it fair that ASL and LSQ users have to rely on limited wifi locations, for simple but critical video communications? Video calling is essential, a need for everyday life communication, and should not be restricted by wifi availability. This is what DWCC aims to shine a light on, to argue the case of functional equivalency. For functional equivalency, this consumer base requires 10­12+ GB of data, if not unlimited. A $15­30 credit is insufficient in replacing the ability to communicate readily.

3. DWCC requests download and upload speeds that allow for clear non­pixelated video communications on both ends. Additionally, we seek symmetrical download and upload speeds of 10 Mbps. DWCC finds that the speeds proposed by various parties, are based on numbers and data that is outdated, and it is time for CRTC to seek and set the standard for modernized download and upload speed designations.

4. DWCC supports the parties stating that benchmarks and goals need to be established for future and upcoming years. Referencing Xplornet, in summary: Xplornet states that there should be aspirational benchmarks set for future years, to accommodate the evolution of the incorporation of video­type of services requiring higher speeds and larger amounts of bandwidth. DWCC agrees with this point to keep up with evolving technologies.

5. DWCC aligns itself with other groups regarding a National Disability Subsidy Fund for specific purposes. ​ASL and LSQ users need smartphones capable of clear video communications, however these devices becomes unaffordable. Many Deaf are still using their iPhone 4s’s because they cannot afford to upgrade and buy newer devices.

6. ASL and LSQ users need the best smartphones to carry clear video communications, however it becomes unaffordable. This is where DWCC agrees a national disability subsidy fund (NDSF) proposed by the Media Access Canada Group, will be a great benefit to our consumer group of ASL and LSQ users that utilize video communications 2 of 10

so that they can obtain the proper devices for accessibility purposes without the financial burden of extra costs monthly.

7. DWCC strongly believes some kind of funding mechanism needs to be put in place for the enhancement of digital literacy for the ASL and LSQ consumer group, to create ASL and LSQ videos across a broad range of topics. Most importantly, plain language service agreement and common contract terminology needs to be translated into ASL and LSQ, in the alternative formats as set out in the Wireless Code, CRTC TNC 2013­271. For these video projects to take place, some kind of fund needs to be created to provide various non­profit groups the opportunity to apply for ongoing project funding to meet these accessibility needs.

8. There needs to be clarity regarding various parties’ mention of the no­voice usage $15.00 discount/subsidy. DWCC asks why has this changed and where does the $15.00 come from? DWCC would like further investigation into where the number of $15.00 is coming from. We agree with the CRTC that more explanation, of this price’s origin is required.

There should be an across the board consistent cost that is fair and uniform, and applicable among individual wireless service providers?

9. **** Malkowski of the Canadian Hearing Society (CHS) sums it up in his response to the CRTC during the live interrogatory **** 19th below:

8737 COMMISSIONER MENZIES: ​Okay. Let me ask it this way.

TELUS referred to an $15 adjustment that they make for qualifying individuals regarding accessibility issues.

8738 ​Do you think that's appropriate?

[Gary ****] ​8740 I have seen many clients who come and use our CHS services, interpreting mental health services, employment services, and they are all very frustrated with the high usage ­­ the high cost and ​$15 is really not comparable. It's going to cost a lot more. I think data usage will be a lot more than $15 would compensate.

10. As a result of cost variations, and responses during this Basic Telecommunications Services proceeding, DWCC sees the need to carry on with the analysis of package contents and costs during the newly released CRTC TNC 2016­192 proceeding on cost differentials. We will seek participation in that respect, and this will allow additional time to compare existing package costs with the goal of coming up with a recommended pricing matrix.

11. DWCC observes that wireless service providers are advertising prices but not upholding them, in that there is much disparity between advertised and actual pricing. We look 3 of 10

forward to providing our community’s experience in the TNC 2016­192 proceeding.

12. What DWCC is observing is many members are going into the vendor locations with uncertainty. There is no simplicity to the wireless service provider customer. Specialized packages need to be coded or given a name to simplify this process for ASL and LSQ users to state which packages they are looking for.

13. These packages also need to be consistent, clearly advertised and properly located on websites and mainstream venues, for ease of location and reference. This is a big frustration for all ASL and LSQ customers, being given the wrong packages with unused features, paying for something they are not using, ie. voice minutes or plans.

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Bell Canada and its Affiliates

14. Overall, the intervention by Bell Canada and its Affiliates refers to download speeds repeatedly, but falls short with recognizing that upload speed plays a vital part in sign language using Canadians participating in the digital economy. This population partakes in the digital economy via video communication, such as VRS and video conferencing applications/programs. Below, we have highlighted several statements that required a response.

“The vast majority of other applications can be performed with a connection of 5 Mbps, including real­time gaming, videoconferencing and high definition (HD) video streaming. The results clearly demonstrate that all but the most intense online activities, such as the streaming of video in quantities greater than HD, can be achieved through a 5 Mbps connection. DWCC submit that although of interest from an entertainment perspective, such applications and services are not necessary​ to meaningfully participate in the digital economy.”

Bell Canada and its Affiliates,
Telecom Notice of Consultation CRTC 2015­134,
Review of Basic Telecommunications Services, **** 8
July 14, 2015

15. As stated by Bell in their original intervention, streaming video (not video conferencing) in quantities greater than HD requires more than a 5 Mbps connection. For sign language using Canadians video quality/speed is crucial, not optional. If streaming video requires more than 5 Mbps, video calling requires the same. Expressions cannot be recognized through video conferencing programs on a slower connection. Video conferencing calls freeze or glitch, causing the user to repeat themselves unnecessarily; an experience that speaking Canadians do not experience through voice calling.

“With regard to VRS, since we expect VRS to be developed to work on both mobile (which have significant capacity constraints) as well as wireline connections, we expect VRS to be designed to work with 5 Mbps or less.

We are certain that parties can come up with various hypothetical scenarios which would require higher bandwidth connections. However, the facts clearly demonstrate that a 5 Mbps connection is adequate as a basic service to meet the minimum requirements of Canadians. In any case, we note that we have proposed that any Commission­established funding mechanism should fund projects of at least 10/1 in areas that are not currently served by 5/1 which would provide households even more flexibility and also ensures that 5 of 10

deployment requirements are not met using legacy technologies that cannot be scaled at even higher speeds in the future.”

Further Intervention of Bell Canada and its Affiliates
Telecom Notice of Consultation CRTC 2015­134,
Review of Basic Telecommunications Services, Pages 31­32
February 1, 2016

“We note in this respect that upload speeds typically do not increase in lockstep with download speeds. In other words, an increase of the 5/1 target to 10 Mbps download should not, in our view, result in an increase to the upload speed. This is due not only to technological limitations (increases in upload speeds can significantly increase the cost of deployment) but also due to usage patterns.

Upload speed requirements for residential application uses are typically much lower than with respect to download. For example, recommended specs for a Skype group session are 4 Mbps / 512 Kbps. And as indicated in our initial Intervention, Microsoft recommends as a minimum requirement for online gaming 3 Mbps download and 0.5 Mbps upload. For this reason, our recommendation is for the upload speed in the target to remain at 1 Mbps at this time. To do otherwise would simply increase the cost (or delay) the deployment of broadband to underserved communities for relatively little gain from a user experience perspective.”

Further Intervention of Bell Canada and its Affiliates
Telecom Notice of Consultation CRTC 2015­134,
Review of Basic Telecommunications Services, **** 32
February 1, 2016

16. A 0.5 Mbps upload speed required for gaming does not compare to video conferencing for sign language communication. Video games should require less of an upload speed because it’s quicker and faster for processors to identify where a character is in a game, and relay the movements to co­players through the code it is developed in.

17. Video conferencing requires a higher upload speed for sign language conversations to be held at a natural pace, without losing video quality. This is especially true when human conversation is not restricted in the way video games are. Moreover, in­game conversations occur over headsets and typed messages which is not as taxing on upload speed as clear video communications.

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Bell Canada and its Affiliates
As requested by Telecom Notice of Consultation CRTC 2015­134,
Transcript Ref: Vol.7, Line 9656
May 5, 2016

18. As shown above, Cable 10 in Quebec offers 10 Mbps for the upload speed, significantly high compared to others. With limited technical knowledge, we are uncertain why the download speed is so low. If this was not an error in typing, this chart indicates that the upload speed DWCC seek is possible. If this is correct in showing Cable 10 already provides 10 Mbps, this shows others can work towards achieving the same.

TELUS Communications Company

As TELUS stated in its Second Intervention​1​, on October 16, 2015 TELUS implemented a pricing discount tailored to its postpaid wireless customers who are deaf or hard of hearing.

TELUS’ basic wireless plan​2 ​is tariffed at $75 per month. It includes two components, a voice plan at $40 and a data plan at $35.

The voice component of $40 includes 300 local minutes, unlimited nationwide text, unlimited nationwide picture and video messaging, access to 9­1­1, access to message relay services, voicemail, call display and call waiting.

Deaf or hard of hearing customers could potentially benefit from most of the features included in the $40 voice component other than the 300 local minutes.

TELUS considered that a discount of $15 per month was a reasonable estimate of the value of the 300 local minutes included in the voice component.

Telus Communications Company
Response to Undertaking TNC 2015­134

Information Requested by the CRTC, Transcript Volume 6, Paragraph 8458 7 of 10

19. The voice component costing $40 consists of eight different features. Of these features, only four are accessible to Deaf and hard of hearing customers. These features are:

1. Unlimited nationwide text
2. Unlimited nationwide picture and video messaging
3. Access to 9­1­1
4. Access to message relay services

20. The second feature providing unlimited video messaging sounds beneficial on paper, but requires the use of data to send said messages, limiting the effectiveness of video messaging for ASL/LSQ users. This feature also does not allow real­time conversations to provide functional equivalency for sign language users.

21. The third feature is accessible to ASL/LSQ users only depending on the availability of Text with 9­1­1 services in the province of which the user resides (the allotted 300 minutes of talk time are not being used except for once or maybe never, in an emergency situation).

22. This plan is also not consistent Canada­wide, It depends on who a customer talks to at Telus, and where. DWCC recommends for the discount of the voice component to be half of the usual cost, to allocate for using half of the features included. Which means a discount or subsidy of $20/month.

23. Committee members have the same questions as the CRTC regarding the $15 discount or subsidy. With some of the WSP’s, some DWCC members had a $30.00 for one spouse or $31.00 credit for the other spouse (spousal family share plan) but now it is $15.00 each.

We are unaware of where the number comes from, or why it has been changed, even though members stayed with the same company and plan.

24. Moreover, with Video Relay Services (VRS) becoming available in the near future, sign language using consumers need talking “minutes” as well. For full functional equivalency, if a $75 wireless plan provides 300 local minutes and 2.5 GB of data, sign language users require enough data for to use VRS and other video chat applications for 300 minutes. Enough data should be allocated after these 300 video minutes to provide sign language using Canadians with 2.5 GB of recreational use data, as other speaking Canadians.

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Final Remarks

25. 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 pixelation, with unclear video both ways in two­way communications. ( ​Source:

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

26. DWCC members are not technical experts, however we know that we we need to re­emphasize what can be best described by a previous consultation with the Technology Access Program at Gallaudet University, by way of Mr. **** Vogler: ​A better perspective may be a comparison to SD and HD voice in the hearing world. SD voice is "enough" to have a phone conversation, but HD voice makes things sound so much better (and incidentally also improves speech understanding for hard of hearing people who listen on the phone). The hearing world is enthusiastically embracing HD voice for this reason, and carriers are providing it, even though it uses more bandwidth than SD voice. Let’s make an analogy with respect to video for this purpose. 512 kBit/s is good enough to enable communication at quality levels comparable to SD voice, but it definitely is not comparable to a ​functionally equivalent experience that hearing folks ​have with HD voice. For that you need higher bandwidths.

27. In addition to the points we raised in our final submission, submitted on May 25, 2016; it’s important that we acknowledge none of the WSP’s have shared they would provide clearly communicated packages for sign language users (except for Bell, which intended to provide these packages before the 2015­134 hearing began). There is a significant disparity in price ranges ​within each company, which should not exist, because hearing people paying for voice minutes have standardized, somewhat more stable plans.

28. Sign language using Canadians with the same WSP receive various voice credits or (dangerously) have their voice minutes removed, disallowing them to text 9­1­1 in case of emergency. These credits, discounts or subsidies are not consistent within each individual company, which makes it difficult to enhance digital literacy. We cannot explain something to the community we represent, if they may or may not receive this. DWCC needs to know standardized packages exist, and are given a code or a name, so we can work together with the CRTC and WSP’s to spread awareness of these plans and advance digital literacy.

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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.pdf29. The DWCC has been consistent in requesting reasonable, fair, advertised, and accessible wireless services. These services will provide functional equivalent wireless services for ASL and LSQ using Canadians. We would like for ASL and LSQ using Canadians to utilize wireless services without hesitation, just as other Canadians can pick up the phone and call.

30. DWCC looks forward to collaborating with CRTC, CWTA, CCTS, and WSPs to ensure that this is possible, and to share updates and information with our ASL and LSQ community members, in partnership with the Canadian Association of the Deaf (CAD­ASC).

Submitted by:

**** Marsh, DWCC Writing team member, with final approval of Chairperson **** ****­Kellett, Chair of Deaf Wireless Canada Committee

**** 13, 2016
*** END OF DOCUMENT***
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Final Replies : Deaf Wireless Canada Committee (Intervenor 265)

Document Name: 2015-134.223984.2630349.Final Replies (1kdl901!).html

Please find the Final Reply Comments. We decided to leave the complex recommended pricing matrix for participation in a separate CRTC proceeding regarding differential pricing ( CRTC TNC 2016-192) This summarizes the DWCC's position and review of any remaining unanswered responses. Raisons pour comparaitre / Reasons for appearanceOnly if they need to call us for more further detailed review of our positions as we have previously already appeared at the hearing **** 2016.